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Privacy Policy (inoperative from July 29, 2014)

This Privacy Policy (hereinafter referred to as “the Privacy Policy”, "the Policy”) sets out the procedure for processing and protection of personal data of the Users which 2GIS LIMITED, a legal entity registered under the laws of the Republic of Cyprus, having its registered address at: 12 Esperidon Street, 4 floor, 1087 Nicosia, Cyprus (hereinafter referred to as "the Administration”), may obtain during its provision of any of the Administration Services (hereinafter referred to as “2GIS Services”).

Definitions

Law shall mean Data Protection Act of Cyprus, Cap. 138 (I)/2001, EU Directive 2002/58 on Privacy and Electronic Communications, including any amendments, revisions, re-enactments or consolidations thereof together with any other applicable legislation.

2GIS Services shall mean materials and services to which the User is granted access via the Website and the Platform, provided under the 2GIS Services Use Agreement. Any matters relating to use of 2GIS Services not covered by this Policy shall be governed by the 2GIS Services Use Agreement, located at: http://law.2gis.ae/rules.

Flamp Service shall mean the service owned by the Administration and designed to allow the Users to express their opinions and share their reviews about works, products and services provided by legal entities and sole proprietors included in the Business Listing.

Platform means soft hardware integrated with the Administration Website.

Administration Website / Website means websites located in the domains at 2gis.ae.

Personal Data shall mean any information, as defined below, relating to the User that can identify the User–

(a) from such data, or

(b) from such data and other information which is in the possession of, or is likely to come into the possession of, the Administration,

and includes any expression of opinion about the User and any indication of the intentions of the Administration or any other person in respect of the User.

Processing of Personal Data ('processing') shall mean any operation or set of operations, which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

Sensitive Data means data concerning racial or ethnic origin, political convictions, religious or philosophical beliefs, participation in a body, association and trade union, health, sex life and sexual orientation as well as data relevant to health, injury, death or criminal prosecutions or convictions.

1. General Provisions

1.1. By using 2GIS Services, you agree that:

а) You have read the terms of this Privacy Policy prior to beginning of use of 2GIS Services.

b) Use of 2GIS Services in any form means that you accept all terms of this Privacy Policy, without any exceptions or restrictions on your part.

c) If you do not agree with the terms of this Privacy Policy, you should immediately cease any use of 2GIS Services.

d) The Privacy Policy (or any of its parts) may be amended by the Administration without special notice and without payment of any compensation with this regard. A new version of the Privacy Policy shall enter into force upon posting thereof on the Administration Website located at 2gis.ae.

1.2. By accepting the terms of this Privacy Policy, the User agrees to processing of the User information by the Administration for the purposes set forth herein, and to the disclosure of User information to third parties in accordance with this Policy.

1.3. As a general rule, the Administration does not check the reliability of personal data provided by Users. However, in cases directly defined in individual agreements on 2GIS services use, the User shall be obliged to provide evidence of reliability of the provided personal data.

2. Scope of Users’ Information Obtained and Processed by Administration

2.1. This Policy shall cover the following types of personal data:

2.1.1. Personal Data provided by the Users about themselves on their own during registration, including personal data of the User provided to the Administration through websites or services of third parties, or personal data submitted by the Users during use of 2GIS Services. Personal Data thus obtained may include, in particular, name, surname, image, phone number and/or e-mail address of the User. Mandatory information submitted for provision of 2GIS Services or their individual features is particularly marked. Additional information shall be provided by the User at his/her discretion.

2.1.2. Data automatically submitted to 2GIS Services during their use via software installed at the User device, including IP address, MAC address, cookies, information about browser, operating system, access time, search queries, data on location and movement of the User device.

2.1.3. Data additionally submitted by the Users following the Administration’s requests related to the Administration’s fulfilment of its obligations to the Users with regard to use of 2GIS Services.

2.1.4. Photos placed by users of services provided by Foursquare Labs, Inc. on the Internet website https://foursquare.com and brought to the Users’ attention jointly with 2GIS Software Products using API service by Foursquare Labs, Inc.

2.1.5. Other User information collection and/or processing of which is stipulated by individual 2GIS Services Use Agreements and/or rules of individual 2GIS Services provision.

3. Purposes of Collection and Processing of User Information

3.1. The Administration shall collect and process only such information about the Users (including their personal data) as required to fulfil the Administration obligations to provide 2GIS Services.

3.2. The Administration may use personal data of the Users for the following purposes:

3.2.1. Identification of a party of agreements between the User and the Administration.

3.2.2. Provision of 2GIS Services to Users, further improvement of 2GIS Services, and the development of new Services.

3.2.3. Responding to the Users’ requests to the support service, informing the Users about capabilities of 2GIS Services and sending requests concerning the use of 2GIS Services.

3.2.4. Fulfilment of marketing tasks, conducting statistical or other research based on anonymised data.

3.3. The User hereby agrees to the disclosure of his/her personal data to affiliates and partners of the Administration, and to Foursquare Labs, Inc. for the purposes set forth in Paragraph 3.2 hereof.

3.4. When it is required to use the User’s personal data for a purpose not set forth herein, the Administration shall ask for the User’s consent.

4. User Information Processing

4.1. Personal Data about the Users shall be stored according to the applicable legislation.

4.2. Personal Data about the Users shall not be provided to any third parties except for the following cases:

4.2.1. Only if the User has unambiguously given his/her consent.

4.2.2. The provision is required to ensure functioning of 2GIS Services and/or individual features of 2GIS Services, and the implementation of partner or other 2GIS Services programmes.

4.2.3. Disclosure is prescribed by the applicable legislation.

4.2.4. Disclosure is conducted to protect rights and legal interests of the Administration and/or third parties in the events when the User violates terms of user agreements concerning individual 2GIS Services or processing is necessary in order to protect the vital interests of the User.

4.2.5. If the Administration takes part in a merger, acquisition or any other form of sale of all of its assets or a part thereof. In such event, all obligations concerning observance of this Policy shall be transferred to the purchaser of the Administration’s assets.

4.2.6. If disclosure is in the public interest and such public interest outweighs the right to privacy.

4.3. When using Flamp Service, the User agrees that certain information he/she submits to Flamp Service may be accessible to other Users both immediately on the websites located in the domain which hosts Flamp Service and its subdomains and via translation services using various technical means with a reference to the original source (e-mails, RSS feed etc.). In particular, information about the name and surname of the User stated in his/her Dashboard, as well as User-provided links to his/her personal pages in social media, are accessible to all the other Users of Flamp Service.

4.4. The collection and processing of sensitive data is prohibited, unless it is directly stated by the applicable legislation.

5. Rights of Users

5.1. The Users shall have the right to:

5.1.1. Independently change or update their information in their Dashboards on the Administration Website or require the Administration to rectify such information.

5.1.2. Block their information provided in their Dashboards on the Administration Website or require the Administration to block this information. However deleting the profile may render some 2GIS Services unusable.

5.1.3. Delete or require the Administration  to delete the User’s personal data if the data are incomplete or irrelevant, if the recording, disclosure or storage of the data is prohibited, or if the data have been stored for longer than necessary.

5.1.4. Request and obtain from the Administration information concerning the processing of their personal data, and object, at any time, on compelling legitimate grounds relating to the particular situation, to the processing of data relating to User.

6. User Information Protection Measures

6.1. The Administration shall make all necessary and sufficient organisational and technical measures to protect the User personal data from unauthorized or accidental access, deletion, change, blocking, and distribution of personal data and from other unlawful actions. Such measures shall involve, in particular, internal checks of the processes of collection, storage and processing of data and safety measures, including encrypting measures to ensure data physical safety to prevent unauthorized access to the systems containing personal data.

6.2. While processing the User’s personal data, the Administration shall comply with applicable Law.

7. Final Provisions

7.1. This Policy, relations between the User and the Administration arising in relation to applying of this Policy, and issues out of the scope of this Policy shall be governed by Law and the applicable legislation of the Republic of Cyprus.

7.2. The Users shall have the right to contact the Administration with requests, propositions or questions concerning this Policy through 2GIS User Support Service (http://info.2gis.ae/dubai/feedback), or at the address: info@2gis.ae.

7.3. The current version of this Privacy Policy is available on the Administration Website at http://law.2gis.ae/privacy.

Policy Last Updated: December 01, 2013