PRIVACY POLICY
Date of publication: 24 April 2023

This document (" Privacy Policy", "Policy") defines the policy of commercial activity of an individual entrepreneur TimurKhabibullin ("IE Khabibullin", "Platform" or "EnTeo.Site"), duly registered under the laws of Georgia with registered address at 23 Yusuf Pagavastr, 6000 Batumi, Georgia registration number 345695143, for the provision of training services ("Services") on the website https://enteosite.online/ ("Website") in relation to the processing of Personal Data and contains a system of basic principles applied to the processing of Personal Data in the activities of IE Khabibullin, as well as information about the implemented requirements and measures of Personal Data protection.

The Policy is aimed at ensuring the protection of human rights and freedoms when processing their Personal Data, including the protection of the rights to privacy, personal and family secrets, in particular, in order to protect against unauthorized access and unlawful dissemination of Personal Data processed on the Platform.

The Platform is committed to protecting Your Personal Data and take the security of Your personal information very seriously. There are strict security measures have been taken to protect your Personal Data in the activities of IE Khabibullin as well as procedures that are regularly tested and reviewed. If You have any concerns about the way in which the Platform processes or protects Your Personal Data or would like to contact with the Platform about any aspect of this Policy, please get in touch through the contact details which are defined in Section 15 of the Policy.

This Policy applies to the information which is collected by the Platform when You interact with it, including but not limited to information provided when You access the Website and however else You may interact with the Platform. The Personal Data processing is carried out by the Platform on a legal and fair basis.

Your use of the Platform is subject to this Privacy Policy. This Policy shall be read in conjunction with any notices or terms located within the Website. The Platform reserves the right to amend this Policy at any time and for any reason. Any changes to the Policy will be communicated to You by updating the "Date of Publication" at the top of this page. Any changes or modifications will take effect immediately upon the updated Policy posting on the Website.

It is recommended that You review the Policy on a frequent basis to ensure You are informed of any changes. If You continue using of the Website after the updated Policy is posted, You are deemed to have been made aware of, bound by, and accepting the new Policy's modifications.

«y visiting the Website and/or using the Services, You agree that You are familiar with this Policy and agree to its terms. Please take time to read the Policy carefully.

IF YOU DO NOT AGREE WITH THIS POLICY, PLEASE DO NOT USE PLATFORM AND SERVICES OT IT.

1.DEFINITIONS"Automatic Information" means automatically collected additional information about You, including Your IP address, cookie information, browser type, operating system, access times, and the websites You visited immediately before and after accessing the Website.

"Consent"
means any freely given, specific, informed and unambiguous indication of Subject of Personal Data's wish to Policy accession and Personal Data processing without any reservations and restrictions.

"Financial Data" refers to the following fаinancial information: credit card numbers, brands of payment systems, holders' names, expiry dates etc., that is collected when You transfer a cost of payment. The Platform stores just a small portion of the financial information it collects, if any at all.

"Personal Data" or "Identification Information" means information about You that is personally identifiable and may include name, address, date of birth, nationality, ID number, issue and expiry date of your identity document, marital status, phone number, email address, or other information that is not otherwise publicly available and that is protected from disclosure under applicable laws.

"Service Providers"means the Platform's processors who process and use Your Personal Data on behalf of, for purposes and on instructions of the Platform.

"Subject of Personal Data" refers to users of the Website.

The term " You" or "Your" refers to the user of the Website.

2. COLLECTION OF YOUR PERSONAL DATA

While Your operating on the Website and delivering the Services, the Platform collects and processes the Personal Data, which subsequently may be used for typical business and commercial purposes (including compliance with legal obligations and use for auditing, security, and anti-fraud purposes).

The Platform collects Personal Data from the following sources:

- from an electronic application of a person wishing to accept a Public offer;
- from cookies and tracking technologies on Your devices, if You have given Your Consent to their use;
- during Your transactions performing;
- during your visit to the Website;
- during communication with the Platform (by email, mail, mobile phone, etc.);
- during the provision of Services to You.

3. THE CATEGORIES OF INFORMATION IS BEING COLLECTED
The Platform collects, uses, processes and protects the following categories of Personal Data as described more specifically below. EnTeo.Site does not collect Personal Data to which the Subjects of Personal Data have not given their Consent.

3.1. Information You provide Most of the information that the Platform collects about You is required to meet legal and regulatory obligations of EnTeo.Site, such as the anti-money laundering/ combating the financing of terrorism, however, the Platform requests Your Consent to the processing of Your Personal Data. When You fill out and send an electronic application to the Platform, pay for Services, communicate with the Platform and accept the Services provided to You, the Platform may collect and store the following Personal Data provided by You.

Collection stage
1. Filling out and sending an electronic application
Identification Information collected
● Name;
● Surname;
● E-mail address;
● Mobile phone number.

Collection stage2. Transactions performing
Identification Information collected
● Financial Data

Collection stage
3. Communication with the Platform
Identification Information collected
● Service Customer's number

3.2. Other information Platform collects
The Platform also may collect other information about users, their devices, or their use of the Website in ways that are described to them at the point of collection or otherwise with their Consent.

3.3. Information the Platform automatically collects from Your use of the Website
The Platform automatically collects information about Your use of the Platform. EnTeo.Site may use the Automatic Information with the aim of drawing inferences about Your preferences. The Automatic Information helps the Platform to provide You with personalized content and offers and helps the Platform to develop and provide better Services.

3.4. Automatic collection of information from Cookies and other technology The Platform and Service Providers may use Cookies, Web beacons and other tracking technologies on the Platform in order to personalize Your experience and improve the Website.

3.4.1. Cookies

"Cookie" is small part of information sent by a web-server to a web-browser, which enables the server to collect information from the browser. When You visit the Website again, the Cookie allows the Platform to: (i) recognize Your computer/device; (ii) store Your preferences and settings; (iii) understand the web-pages of the Platform You have visited; (iv) enhance Your User experience by delivering and measuring the effectiveness of content and advertising tailored to Your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.

Cookies are used by the Platform in order to ensure the technical functionality of the Website. When Сookies are used to remember Your choice or for statistical purposes, the legal basis for this is Your Сonsent. You can always revoke Your Consent by changing the Cookie settings.

Cookies may be placed by third-party analytical tools, as described in the section "Using third-party services", and, therefore, may be available to relevant third parties in accordance with this Policy.

Most browsers allow You to turn off Cookies. If You want to know how to do this, please look at the help menu on Your browser. However, some Website features or Services may not function properly without Cookies.

3.4.2. Web beacons

Small graphic images or other web programming code called "Web beacons" may be included in the Platform's web-pages code and e-mail messages. Web beacons may be invisible to You, but any electronic image or other web-programming code inserted into a web-page or e-mail can act as a Web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Platform, to monitor how Users navigate the Platform, to make Cookies more effective, and to analyze how the Platform's emails, and links were opened, viewed, and used.

4. USAGE OF YOUR PERSONAL DATA
The Platform and Service Providers use the information described above to accomplish the following business and operational purposes:

- Process an electronic application of a person wishing to join the Public Offer;
- Provide, maintain and improve Platform Services;
- Protect of Website users;

HOWEVER, THE PLATFORM IS NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL DATA THAT YOU DISCLOSE ON THE WEBSITE TO ANY THIRD PARTY. BY MAKING ANY INFORMATION AVAILABLE THOUGH THE WEBSITE YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND HAVE AGREED TO SUCH RISKS.

- Comply with laws, regulations, and other legal process and procedures;
- Respond to and complete Your requests (including providing notifications and answers related to questions You submit);
- Process payments;
- Conduct internal business operations in support of the Platform's functionality, such as auditing, security, resolving crashes, preventing fraud, invoicing and accounting, sales and marketing, analytics, and research and development;
- Customize content, preferences, and advertising on the Platform;
- Establish, exercise, or defend Platform legal rights;
- Take steps that the Platform reasonably believes to be necessary to protect the safety, security, and rights of EnTeo.Site, its employees, Service Providers, and others.

Please note that Platform may combine the information which is collected through the Website with information that is collected automatically and use such combined information in accordance with this Privacy Policy.

You can always refuse to process Your Personal Data for marketing purposes, as well as refuse to receive messages for marketing purposes from the Platform by clicking the "Unsubscribe" button at the end of an email containing such a message, or by sending an email to address defined in Section 15 of the Policy.
5. DISCLOSURE OF YOUR PERSONAL DATA
The Platform may release Personal Data have gathered about You in certain circumstances. The following methods in which Your information may be shared.

5.1. Service Providers
The Platform uses Service Providers to carry out business activities and provide Services, in particular, to store data, provide content management tools and payment tools, develop a Website and software, provide marketing services, provide technical support and advice to Сustomers in connection with their use of software.
5.2. Advertising Partners
The Platform may share Your Personal Data and commercial information with advertising partners that use various technologies to send (or serve) relevant ads to You as You browse the Internet. The Platform may share Your Personal Data or Your non-personally identifying information with ad networks for online behavioral advertising purposes.
5.3.Within the Platform
The Platform may share any of Your Personal Data with Platform employees, subsidiaries, joint venture partners, and other entities under common control subject to this Privacy Policy.
5.4. By Law or to Protect Rights
If this Personal Data is requested by any judicial, non-judicial state or supranational authority required by any applicable laws, regulation, edict, local acts or it is necessary for national security, law enforcement, or other issues of public importance that disclosure of Personal Data is necessary. In case this Personal Data are used to detect, prevent, or otherwise addressees fraudulent, unlawful, dishonest or improper activity.
5.5. Third Parties Not Listed
Your Personal Data may be disclosed to marketers and investors for the purpose of conducting general business analysis. Additionally, the Platform may share Your Personal Data with such third parties for marketing purposes, as permitted by law.

Hereby You give EnTeo.Site Consent on Your Personal Data disclosure to third parties and use in cases provided in this Police. However, in order to disclose Your Personal Data to any third parties, in cases not indicated in the Policy, the Platform will ask for Your prior Consent.

The Platform does not disclose or distribute Personal Data to third parties without the Consent of the Personal Data Subject, except in the following cases:
- the information is posted by the Subject of Personal Data in the public access independently;
- the transfer of Data is expressly authorized by the Subject of Personal Data;
- at the request of state bodies in the cases and in the manner prescribed by applicable law;
- in other cases in accordance with applicable law.

7. USAGE OF THIRD-PARTY SERVICES
The Platform may use third-party services and tools to obtain analytical information. Such third-party services allow the Platform to record and analyze the use of the Website by users. The Platform uses this Data in order to study and understand the needs and preferences of both existing Customers and potential Customers, to continuously improve the Services provided, improve the quality of Services and simplify access to information posted by the Platform.

«elow You can find a list of third-party services currently used by the Platform.

Third-party services / Company

1. Google Analytics / Google LLC
Link to documents on the processing of Personal Data by a company providing third-party services
https://policies.google.com/privacy?hl=en
2. Google Tag Manager / Google LLC
Link to documents on the processing of Personal Data by a company providing third-party services
https://marketingplatform.google.com/about/analyti...
3. Yandex.Metrica / YANDEX, LLC
Link to documents on the processing of Personal Data by a company providing third-party services
https://yandex.ru/legal/metrica_eea_termsofuse/

The company providing the relevant third-party service may have access to statistical and other depersonalized data collected through such a service.

8. STORAGE OF PERSONAL DATA
EnTeo.Site complies with the General Data Protection Regulation (the – " GDPR") and other applicable data protection laws each jurisdiction. The information is collected from You may be transferred to companies within the same corporate group, and stored at European Union ("EU") / European Economic Area ("EEA"), subject always to: a) compliance with the applicable data protection laws of the EU; b) storage of Your Personal Data is necessary to providing the Platform Services to You, including the core functionality of the Website and improving the Platform; c) the relevant Data Processing Agreements in place between the Platform and the relevant company; d) Your Consent for doing so.

The Service Provider that are used to store Your Personal Data are owned and hosted by Selectel using the services whose description is available by the link https://selectel.ru/about/details/.

The Platform limits access to Personal Data about You to employees who need to come into contact with that information to provide Services to You or in order to fulfill their official duties. These employees are bound by confidentiality obligations and may be subject to liability, if they fail to meet these obligations. You agree and acknowledge that Personal Data about You may also be processed by staff operating outside the EU/ EEA who works for IE Khabibullin or one of Service Providers. Such staff may be engaged using Your information for the purposes listed above. By submitting Your information, You agree to this use. The Platform will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Privacy Policy.

9. THIRD-PARTY WEBSITES
The Website may contain links to third-party websites and apps that You may find useful, such as advertisements and third-party websites. Once You leave the Website via these links, any information You provide to these third parties is not covered by this Policy, and the Platform cannot guarantee the security or privacy of Your Personal Data. Before You access or provide Personal Data to any third-party website, You should acquaint Yourself with the third party's privacy policies and practices (where applicable), and take all necessary actions to safeguard the privacy of Your Personal Data. The Platform is not responsible for the content, privacy, or security practices or policies of third parties, including any other websites, services, or applications that may be linked to or accessible through the Website.

10. THIRD-PARTY WALLETS

Your dealings with any third-party wallet provider are subject to the third party's appropriate terms of service and privacy policy. It is not covered by this Policy and the Platform cannot guarantee the security or privacy of Your Personal Data and funds.

11. DATA RETAINING
The Platform may preserve Your Personal Data for as long as You use the Service of the Platform, or as long as necessary to accomplish the purposes set forth in this Policy. The Platform may retain Your Personal Data after You stop using the Service if the Platform believes that such retention is reasonably necessary to comply with its legal obligations, resolve disputes, prevent fraud and abuse, enforce the Platform's terms of use and other Platform's agreements, and/or protect its legitimate interests. The Platform shall erase Your Personal Data if it is no longer necessary for these purposes.

12. SECURITY OF YOUR INFORMATION
The Platform's administrative, technical, and physical security measures safeguard Your Personal Data. While the Platform has taken reasonable steps to secure the Personal Data You provide to it, please keep in mind that however no security system is flawless or impenetrable, and no means of data transfer can be guaranteed to be free of interception or other type of misuse. Any information disclosed online is subject to interception and exploitation by unwanted parties. As a result, the Platform cannot guarantee the complete confidentiality of any Personal Data You provide.

13. YOUR RIGHTS

Rights
Right 1 The right of access
You have the right to be provided with clear, transparent and easily understandable information about how, for what purpose and under which legal grounds the Platform uses Your Personal Data and Your rights.
Right 2 The right to be informed A
right to access Personal Data held by the Platform about You. Whether provision of Personal Data is mandatory or voluntary; if mandatory – the legal consequences of refusal to submit them.
Right 3 The right to rectification
A right to require the Platform to rectify any inaccurate Personal Data held by it about You.
Right 4 The right to erasure
A right to require the Platform to erase Personal Data held by it about You. This right will only apply where (for example): the Platform no longer need to use the Personal Data to achieve the purpose the Platform collected it for; or where You withdraw Your Consent if the Platform is using Your Personal Data based on Your Consent; or where You object to the way the Platform processes Your Personal Data. This right is not absolute and will not apply when legitimate and overriding reasons apply.
Right 5 The right to withdraw Consent
A right to withdraw Your Consent, where the Platform is relying on it to use Your Personal Data on marketing and other similar purposes (for example, to provide You with marketing information about the Platform's Services or products).
Right 6 Right to receive information on disclosure
A right to receive information on to whom Your Personal Data were disclosed, and the grounds and purpose of the disclosure.

14. POLICY FOR MINORS
The Platform does not collect or market to minors under the age of 18 on purpose. If You become aware that the Platform has acquired Personal Data from persons under the age of 18, please contact the Platform using the contact information given below.

15. CONTACT DETAILS If You have questions or comments about this Policy, please contact the Platform at:

IE Timur Habibullin
Address: 23 Yusuf Pagava str, 6000 Batumi, Georgia
Email: tfhservis@gmail.com
Made on
Tilda