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Kept Privacy Statement

The Policy was last updated on November 8, 2022

Kept1 is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, Kept is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”, "personally identifiable information") that has been received directly from you or through third parties authorized by you in electronic form or on physical media and processed by Kept with or without the use of automation tools.

Generally, our intent is to collect only the personal information that is provided voluntarily by you so that we can offer information about Kept (including events and job vacancies) and/or services to you or persons having civil law relations with you or for making decisions on cooperation or entering into contracts. Please review this Kept Privacy Statement (hereinafter "Kept Statement") to learn more about how we collect, use, share and protect the personal information that we have obtained.

This Kept Statement applies to the information processed via electronic resources of Kept, including the web site as well as other web sites and resources of Kept or its third-party contractors that contain the link to this Kept Statement.

When receiving personal data electronically, Kept Russia may in some cases process this data in conjunction with Kept Belarus, being governed to the extent necessary by the provisions of this Statement, taking into account the specifics stipulated by applicable policies and legislation, as we inform you below.

1. Collection and use of personal information
1.1 What information we collect
1.1.1. Information about employees and candidates
1.1.2. Information required for marketing activities
1.2 The legal grounds we have to use your personal information
1.3 Personal data processing and protection policy
1.4 Cookies
1.5 Children
2. Sharing and transfer of personally identifiable information
3. Choices
4. Your rights
5. Data security and integrity
6. Links to other sites
7. Changes to this Kept statement
8. Policy questions and enforcement

1. Collection and use of personal information

1.1 What information we collect

We obtain personal information about you if you choose to provide it directly or through third parties authorized by you. In some cases, you may have previously provided your personal information to Kept (if, for example, you are a former employee or you already have business relations with Kept). If you choose to register or login to a Kept web site using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with Kept, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect may depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

When you register or submit personal information to Kept we will use this information in the manner outlined in this Kept Statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a Kept web site and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other Kept sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with Kept, we will use the information that you provide to match you with available Kept job opportunities.

In some cases where you have registered for certain services we will store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

1.1.1 Information about employees and candidates

We process personal information of our employees, former employees and candidates for vacant positions. The specific types of information and purposes of its processing depend on your relations with Kept and are described in respective forms of consent for processing of personal information. If you belong to one of the mentioned categories, information about you may be included when applicable into Kept Russia talent pool on the condition that your consent has been obtained. In this case your information shall be processed according to Regulations on talent pool of Kept in Russia.

1.1.2. Information required for marketing activities

For promoting our services we develop various marketing activities: organize events (including webinars), publish content on topics of interest, send newsletters about our services, events and publications to the (potential) clients and persons related to them as well to the visitors to our events. We aim at making the information you receive up–to–date and corresponding to your interests. In order to achieve this we may require your personal information (full name, email address, place of work, job position, other contact information).

When you provide your personal information to Kept or when you act as a contact person for communication with Kept, e.g. during rendering the services under a contract, we may include information about you in our (potential) client relationship management system (hereinafter “CRM”) for confirming our business relations as well as for sending you invitations to complete a survey about the quality of the services we have rendered. The access to the information contained in CRM is limited to our authorized employees who need this information for maintaining business communication with Kept clients (including potential clients).

For collecting your personal information we may use the services administrated by the third parties (e.g. online registration platforms or websites for holding webinars). The relevant suppliers process personal information in accordance with their own policies and we are not responsible for the confidentiality or the information you provide to such platforms. To get more detailed information we recommend that you study the policies of the abovementioned service providers before submitting the data collection forms.

1.2 The legal grounds we have to use your personal information

Kept generally collects only the personal information necessary to fulfill your request or to perform our contractual obligations. Where additional, optional information is sought, you will be notified of this at the point of collection.

To comply with the applicable legislation allowing us to process personal information so long as we have ground under the law to do so, when we process your personal information, we will rely on one of the following processing conditions:

Special categories of personal data are defined according to the legislation and processed by Kept only in accordance with applicable laws.

1.3 Personal data processing and protection policy

Kept Russia Personal data processing and protection policy has been adopted in accordance with Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”, which constitutes an internal fundamental regulatory document of Kept and determines the main areas of activity of each firm mentioned above in relation to the processing and protection of personal data.

Kept in Belarus is governed by the Personal Data Processing Policy developed in accordance with the Law of the Republic of Belarus No. 99- 07.05.2021 "On the Protection of Personal Data," which is the fundamental internal regulatory document of Kept Belarus, which determines the key areas of activity of each of the legal entities indicated therein in the area of personal data processing and protection.

1.4 Cookies

Our websites may use cookies. Where cookies are used, a statement will be sent to your browser explaining the use of cookies. To learn more, please refer to our Cookies Notice.

1.5 Children

Kept understands the importance of protecting children's privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

2. Sharing and transfer of personal information

2.1 Transfer within the network of Kept firms

We share information about you with other member firms of the Kept network to provide services to us and you, for example hosting and supporting IT applications, Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run Kept’s business.

2.2 Transfers to third parties

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, to perform contractual obligations and/or as required or permitted by law or professional standards. For more information on such third parties, please see this link.

In addition, Kept will transfer certain personal information across geographical borders to outside companies working with us or on our behalf for the purposes described in this Kept Statement. In these cases, your personal information will continue to be protected in accordance with the terms of our contracts with these third parties.

Kept will not transfer the personal information you provide to any third parties for their own direct marketing use.

3. Choices

Kept will ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in "Cookies" above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

4. Your rights

If Kept processes personal information about you, you have the following rights:

- Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If the applicable legislation requires us to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.

- Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more.

Automated decision-making: you have the right not to be subject to automated decision-making unless you provided your written consent or unless so required by applicable laws.

Rights to withdraw your consent and/or send a complaint to supervisory authority: see Section 8 “Policy questions and enforcement” for more details.

- Other Rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.

You can make a request or exercise these rights by contacting Kept at dataprivacy@kept.ru (for contact Kept Belarus please use dataprivacybelarus@kept.by), outlining the purpose for which your contacts have been provided to us, and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

5. Data security and integrity

Kept has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite Kept's best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual's requests and/or perform contractual obligations, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until the person that has provided the personal information asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to requirements of i)-iii) above, personal information will not be retained longer than required according to the applicable legislation.

6. Links to other sites

Please be aware that Kept web sites will typically contain links to other sites, including sites maintained by other Kept member firms that are not governed by this Kept Statement but by other privacy statements that will often differ somewhat. We encourage users to review the privacy policy of each Web site visited before disclosing any personal information.

By registering on any Kept web site and then navigating to another Kept web site while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the Kept web site you are visiting.

7. Changes to this Kept Statement

Kept may modify this Kept Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the "updated" date at the top of this page. We encourage you to periodically review this Kept Statement to be informed about how Kept is protecting your information.

8. Policy questions and enforcement

Kept is committed to protecting the online privacy of your personal information.

If you have questions or comments about our administration of your personal information, please contact our Data Privacy Liaison at dataprivacy@kept.ru (for contact Kept Belarus please use dataprivacybelarus@kept.by). You may also use this address to communicate any concerns you may have regarding compliance with our Kept Statement. We will acknowledge your email within 14 days and seek to resolve your concern within one month of receipt, unless another period is stipulated by applicable legislation. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised, but within the period stipulated by applicable legislation.

In any event, you always have the right to lodge a complaint with the regulator in charge of protecting personal information in your jurisdiction.

1 “Kept”, “we”, “us” and “our” refers to Kept Russia and Kept Belarus.

Kept Russia refers to Kept JSC, Kept Tax and Advisory LLC, Kept Digital Products LLC, Kept Verification LLC, companies, registered under the laws of Russian Federation, each of which is a separate legal entity and should be considered separately as part of the interpretation of this Statement.

Kept Belarus refers to Kept LLC (Republic of Belarus, 220012, Minsk, 49 Platonova street, premises 26-7), Kept Advisory LLC (Republic of Belarus, 220012, Minsk, 49 Platonova street, premises 26-4), Kept Technologies LLC (Republic of Belarus, 220012, Minsk 49 Platonova street, premises 26-28), companies, registered under the laws of Republic of Belarus, each of which is a separate legal entity and should be considered separately as part of the interpretation of this Statement.