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These principles have been developed in accordance with clause 2 of article 18.1 of the Federal Personal Data Act and personal data protection regulations, and govern the terms of collection, processing, storing and protection of personal data by LLC IPT Consult, an authorized agent of which is IPT Consult LLC, a US resident company (the “Terms”).

LLC IPT Consult (hereinafter referred to as the “Company”) collects personal information of the Customer if the Customer uses or wishes to use the services.

The Terms are effective since 2016 (date of website start) but also apply to processing of customer data before that date.

  1. General Policy Provisions

These Terms can be accessed by the Customers at www.wallstreet-partner.com/privacy-policy

The Company may unilaterally modify the Terms at any time by notifying a Customer of any website changes. Modifications will become effective upon their publication on the website, unless another term is defined.

  1. Definitions

LLC IPT Consult is a private company limited by shares that provides the services in the field of business consulting.

Customer shall mean an individual or legal entity that used, uses or intends to use the services offered by LLC IPT Consult.

Personal Data shall mean any Customer-related information.

Customer Data shall mean any Customer information disclosed to LLC IPT Consult in connection with use by the Customer of advisory services of LLC IPT Consult.

Customer Data Controller shall mean LLC IPT Consult.

  1. General principles of data processing and types of processed data

3.1. LLC IPT Consult may engage the employees to process the data of the Customer who used, uses or intends to use the services offered by LLC IPT Consult. When disclosing Customer Data to the employees, LLC IPT Consult warrants that the employees process the Customer Data in accordance with the Controller’s instructions, comply with confidentiality requirements and employ appropriate security measures.

3.2. In processing Customer Data LLC IPT Consult proceeds from the applicable laws and makes necessary engineering and organizational arrangements to ensure the security of the Customer’s data in order to prevent illegal processing, access and disclosure of information to the third parties.

3.3. LLC IPT Consult collects and processes only the following information connected with services provided and relationships with the Customer:

3.3.1. Customer Data: information of the identification document of the Customer (e.g. passport or another ID), name, personal identification code, date of birth and other personal data of the Customer. Submission of required data for purchase of services is mandatory as provision of services without data is impracticable;

3.3.2. Customer’s contact information: address, telephone number, e-mail address;

3.3.3. Communication data: conversations regarding service provision, both by telephone or online, and over other communication channels, and communication between LLC IPT Consult and the Customer by electronic or regular mail.

3.3.4. Financial data: individual bank account number and financial institution data (company name, address, telephone number, e-mail and other data).

3.3.5. Service-related data: e.g. information, requests and complaints regarding purchases of services, fees and consultations.

  1. Customer Data Processing Purposes

LLC IPT Consult processes customer data in order to:

4.1. Provide high-quality advisory services to the Customer and manage customer relations.

LLC IPT Consult processes Customer Data for the purpose of entering into and fulfilling the contract with the Customer.

4.2. Protect the legitimate interests of the Customer and research the service quality.

4.3. Provide additional services to the Customer, analyze the market and compile statistical data, including making offers under the Customer’s consent or at the LLC IPT Consult’s discretion to provide the best service to the Customer.

4.4. Prove and protect the claims whether in contract or tort or legitimate interests of LLC IPT Consult, e.g. for the purpose of preparing legal claims, inquiries, etc.

4.5. Obtain payments through payment service providers.

  1. Customer Data Recipients

5.1. Customer data may be delivered and processed jointly with lawful authorities of USA and European Union (e.g. notaries public, marshals, bailiffs, judges and other officials) or of another state for the purpose of meeting the objectives of the Customer’s orders.

5.2. Auditors, legal and financial advisers or other persons authorized by LLC IPT Consult.

  1. Data Storage Duration

6.1. Customer data will not be processed for longer than necessary. Service periods may be based on the agreements with Customers, on legitimate interests of LLC IPT Consult or applicable law (e.g. accounting laws, conduct of business rules or other legal provisions).

  1. Individual’s Rights

The Customer (individual) of LLC IPT Consult has the following rights in respect of personal data processing:

7.1. Apply for correction of inaccurate personal information if it is inadequate, inaccurate or incomplete;

7.2. Request the information about whether LLC IPT Consult processes personal data of the Customer, and gain access to such data.

7.3. Revoke the consent to personal data processing;

7.4. Restrict personal data processing in accordance with applicable law, particularly when the Customer has filed an application for correction or deletion of their personal data.

7.5. Request deletion of their data, e.g. if the data is processed under a consent and the Customer revokes their consent. Data deletion can not be requested if personal information requested to be deleted is also used on other grounds, such as contract or legal obligation.

7.6. Obtain their personal data that the Customer has provided and that is processed under their consent, in writing or in electronic form, or, if technically practicable, supply the information to another provider (data transfer right).

7.7. Give objections against personal data processing.

7.8. File personal data processing complaints with the Data Protection Inspectorate if the Customer believes that their personal data is processed unreasonably or in violation of applicable laws and regulations.

  1. Contact Information

8.1. The Customer may contact LLC IPT Consult on any matters related to processing of their personal data at contacts listed at www.wallstreet-partner.com.