PERSONAL DATA PROCESSING POLICY (Privacy Policy) WITH CONSENT FOR PERSONAL DATA PROCESSING

City of Baku

This personal data processing policy is developed in accordance with the requirements of the Law of the Republic of Azerbaijan dated 11.05.2010, No. 998-IIIQ "On Personal Data" and defines the measures to ensure the security and processing of personal data by LLC "APPLY ITALY", registered as a legal entity on August 26, 2021, TIN 2006915751.

1. GENERAL PROVISIONS

1.1. In accordance with Article 2.1.10 of the Law of the Republic of Azerbaijan No. 998-IIIQ dated May 11, 2010, "On Personal Data", the personal data operator (hereinafter referred to as the Operator) is the owner of personal data, collecting, processing, and protecting personal data or a state authority or local self-government body, a legal or natural person, entrusted with these functions to a certain extent and under certain conditions.

1.2. For the purposes of this Privacy Policy, "APPLY ITALY" is the designated Operator (hereinafter referred to as the Operator) in the field of communications, information technology, and mass communications, without state regulation and state control.

1.3. The Privacy Policy defines the procedure for processing and protecting personal information about individuals (hereinafter referred to as "Users"), which may be received by the Operator when using the services provided through the services, programs, and website located at https://applyitaly.it/ (hereinafter referred to as the "Website").

1.4. The use of the services of the Website signifies the unconditional consent of the User with.this Privacy Policy and the conditions for processing their personal information stated therein; if the User disagrees with these conditions, they should refrain from using the services.

1.5. The text of the Policy is available to Users on the Internet at: https://applyitaly.it/privacy

2. PERSONAL INFORMATION

2.1. Within the framework of this Policy, User personal information means:

2.1.1. Personal information that the User provides about themselves when using the website and the educational platform, including the User's personal data. Information mandatory for ordering the services of the Contractor is marked in a special way. Other information is provided by the User at their discretion.

2.1.2. Data automatically transmitted to the Website services during their use through the software installed on the User's device, including IP address, cookie data, User browser information (or other software used to access the services), technical specifications of the equipment and software used by the User, date and time of access to the services, addresses of requested pages, and other similar information.

2.1.3. This Privacy Policy applies only to the Website https://applyitaly.it/ and to all subdomains created on its basis. The website owner does not control and is not responsible for third-party websites to which the User can follow the links available on the Website and all subdomains created on its basis.

3. CONSENT TO THE PROCESSING OF PERSONAL DATA

3.1. The User agrees with the terms of the Policy and gives the Website Owner specific and conscious consent to the processing of their personal data by the Website Owner as the Operator under the Privacy Policy and the Law of the Republic of Azerbaijan No. 998-IIIQ dated May 11, 2010, "On Personal Data."

3.1.1. When ordering services, for personal data that the User provides to the Website Owner when filling out the service order form located on the Internet at: https://applyitaly.it/, the User is considered to have given consent to the processing of their personal data entered in the fields of the feedback form at the moment of ticking the checkbox in the field. For paid materials: 'By clicking the "Pay" button, I give my consent to the processing of my personal data and accept the terms of the User Agreement and the Public Offer,' or for free materials 'By clicking the "Get" button, I give my consent to the processing of my personal data and accept the terms of the User Agreement and the Public Offer,' or for the feedback form 'By clicking the "Submit" button, I give my consent to the processing of my personal data and accept the terms of the User Agreement and the Public Offer.

4. SUBJECT OF THE PRIVACY POLICY

4.1. This Policy (in accordance with Article 10.4 of the Law of the Republic of Azerbaijan No. 998-IIIQ dated 11.05.2010 "On Personal Data") ensures the non-disclosure and confidentiality of personal data provided by the User at the request of the Website.

4.2. Personal data permitted for processing under this Privacy Policy is provided by the User by filling out the feedback form and ordering services on the Website, as well as in the process of receiving services from the Website Owner or as a result of posting their review of the services on the Website and includes (may include partially or in full) the following information:

- User's name;

- Phone number;

- Email address (e-mail).

4.3. The Website Owner protects the data automatically transmitted during the viewing of advertising blocks and when visiting pages with an installed statistical system script ("pixel"):

- IP address;

- Information from cookies;

- Access time;

- Information about the device used by the User to access the website;

- Address of the page where the advertising block is located.

4.3.1. The Operator informs the User that disabling cookies may result in the inability to access parts of the website that require authorization.

4.3.2. The website owner collects statistics on the IP addresses of its visitors. This information is used to identify and solve technical problems.

4.3.3. Any other personal information not specified above (used browsers and operating systems, etc.) is subject to secure storage and non-disclosure, except as provided for in section 6 of this Policy.

5. PURPOSES OF PROCESSING USERS' PERSONAL INFORMATION

5.1. The Operator (in accordance with Article 10.4 of the Law of the Republic of Azerbaijan No. 998-IIIQ dated 11.05.2010 "On Personal Data") is the sole service provider, collecting and storing only the personal information necessary to provide services or fulfill agreements and contracts with the User.

5.2. The Operator processes the User's personal information for the following purposes:

- 5.2.1. Identifying the User for providing services under the contract concluded with the User.

- 5.2.2. Providing the User with access to the educational platform.

- 5.2.3. Establishing feedback with the User, including sending notifications, requests related to the use of the Website, providing services, processing requests and applications from the User.

- 5.2.4. Determining the User's location to ensure security, prevent fraud.

- 5.2.5. Confirming the accuracy and completeness of personal data provided by the User.

- 5.2.6. Notifying the User of the Website about changes, additions to the services provided under the contract with the User, including promotions, events, and special offers.

- 5.2.7. Providing effective client and technical support to the User in case of problems related to the use of the Website or in the process of receiving services from the Website Owner.

6. CONDITIONS FOR PROCESSING USERS' PERSONAL DATA AND ITS TRANSFER TO THIRD PARTIES

6.1. The processing of the User's personal data is carried out by the Operator using databases located in the country of the User's citizenship.

6.2. The confidentiality of the User's personal information is maintained, except in cases of voluntary provision of information by the User for general access to an unlimited number of people. When using certain services, the User agrees that a certain part of their personal information becomes publicly available.

6.3. The Operator (in accordance with Article 10.4 of the Law of the Republic of Azerbaijan No. 998-IIIQ dated 11.05.2010 "On Personal Data") is the sole service provider, collecting and storing personal data necessary for fulfilling agreements and contracts with the User.

- 6.3.1. The User has consented to such actions.

- 6.3.2. The transfer is necessary for the use by the User of a certain service or for the execution of a certain agreement or contract with the User.

- 6.3.3. The transfer is provided for in accordance with Article 13 of the Law of the Republic of Azerbaijan No. 998-IIIQ dated 11.05.2010 "On Personal Data", as well as other applicable legislation within the framework of the established procedure.

- 6.3.4. In the event of the sale of the Website, the purchaser assumes all obligations to comply with the terms of this Policy regarding the personal information received.

6.4. The processing of the User's personal data is carried out during the period of providing services by the Contractor, and for another period necessary to achieve the purposes of processing personal data, by any legal means, including in information systems of personal data with the use of automation tools or without the use of such tools. The processing of personal data of users is carried out in accordance with the Law of the Republic of Azerbaijan No. 998-IIIQ dated 11.05.2010 "On Personal Data". Processed personal information is destroyed or anonymized when the processing goals are achieved or if there is no longer a need to achieve these goals.

6.5. In the event of loss or disclosure of personal data, the Operator informs the User about the loss or disclosure of personal data.

6.6. The Operator, in accordance with the Law of the Republic of Azerbaijan No . 998-IIIQ dated 11.05.2010 "On Personal Data", takes the necessary organizational and technical measures to protect the User's personal information from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other unlawful actions of third parties.

6.7. The Operator, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

7. OBLIGATIONS OF THE PARTIES

7.1. The User must:

- 7.1.1. Provide information about personal data necessary for using the Website, providing services, or the educational platform.

- 7.1.2. Update, supplement the provided information about personal data in case of changes.

7.2. The Operator must:

- 7.2.1. Use the received information solely for the purposes specified in this Privacy Policy.

- 7.2.2. Ensure the storage of confidential information in secret, not to disclose it without the prior written permission of the User, as well as not to sell, exchange, publish or disclose the transmitted personal data of the User in other possible ways, except as provided for in this Privacy Policy.

- 7.2.3. Take precautions to protect the confidentiality of the User's personal data in the manner usually used to protect such information.

- 7.2.4. Block personal data related to the relevant User from the moment of the User's request or request of their legal representative or authorized body for the protection of the rights of personal data subjects for the period of verification in case of detection of inaccurate personal data or unlawful actions.

7.3. The User has the right to:

- 7.3.1. Provide the Operator with personal data for processing at their discretion under the conditions specified in the Policy.

- 7.3.2. Demand from the Operator to clarify their personal data, block, or destroy them if such data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing. The request is sent to the Operator's email: [email protected]

- 7.3.3. Submit an application to the Operator to withdraw their consent to the processing of personal data in the manner provided for in clause 7.3.2 of the Privacy Policy.

- 7.3.4. Receive information from the Operator regarding the processing of their personal data based on a request in the manner provided for in clause 7.3.2 of the Privacy Policy.

- 7.3.5. Opt out of receiving promotional mailings from the Contractor, other messages from the Contractor by following the instructions in these messages. In case of refusal, the Contractor has the right to send non-promotional messages to the User, such as notifications about changes in the order of services or account information of the User.

8. RESPONSIBILITIES OF THE PARTIES

8.1. The Operator, who has not fulfilled their obligations, is liable for the losses incurred by the User in connection with the unlawful use of personal data, in accordance with Article 19 of the Law of the Republic of Azerbaijan "On Personal Data" dated 11.05.2010 No. 998-IIIQ and other legislation of the Republic of Azerbaijan.

8.2. In the event of loss or disclosure of confidential information, the Operator is not responsible if this confidential information:

- 8.2.1. Became public before its loss or disclosure.

- 8.2.2. Was received from a third party before it was received by the Operator.

- 8.2.3. Was disclosed with the consent of the User.

9. DISPUTE RESOLUTION

9.1. All possible disputes and disagreements arising from relations regulated by the Privacy Policy are resolved in the manner prescribed by the legislation of the Republic of Azerbaijan. The recognition of invalidity or lack of legal force of individual provisions of the Privacy Policy does not entail the invalidity of other provisions or the Policy as a whole.

9.2. In the event of any disagreements or disputes between the User and the Website Owner, before going to court, the parties must comply with the requirements of the Law of the Republic of Azerbaijan "On Mediation" dated 29.03.2019 No. 1555-VQ.

9.3. The claim is sent to the User to the email address provided during registration on the Website, and to the Website Owner to the email: [email protected]

9.4. The party to whom the claim is sent must, within 10 (ten) business days from the date of its dispatch, notify the applicant in writing of the results of the consideration of the claim.

9.5. The User and the Website Owner take all possible measures to resolve the dispute in a pre-trial order. If it is impossible to resolve the dispute, either Party has the right to apply to the court at the location of the Website Owner to protect their rights.

10. ADDITIONAL CONDITIONS

10.1. The Website Owner has the right to make changes to this Privacy Policy without the consent or prior notification of the User.

10.2. The new Privacy Policy comes into force from the date of its publication on the Website unless otherwise provided by the new edition of the Privacy Policy.

10.3. The current Privacy Policy is posted on the page at: https://applyitaly.it/privacy

11. INFORMATION AND DETAILS OF THE PERSONAL DATA OPERATOR

Full name: APPLY İTALY

Registration details: Registered as a legal entity on 26.08.2021

Email:[email protected]

Phone: +39 3494212410

TIN: 2006915751

Bank details:

Beneficiary name: APPLY ITALY

Beneficiary account number: AZ74PAHA40160EURHC0100408635

Beneficiary's Bank: "PASHA Bank" OJSC

Beneficiary bank details: 13 Yusif Mammadaliyev str, Baku, Azerbaijan SWIFT: PAHAAZ22

TIN: 2006915751

Correspondent details:

Bank: Raiffeisen Bank International AG

Address: Am Stadtpark 9, 1030 Vienna

SWIFT BIC: RZBAATWW

Correspondence account number: 001-55.081.095