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Privacy and Data Protection Appendix

This Privacy and Data Protection Appendix (“Appendix”) amends (for valid consideration which is hereby acknowledged as duly received) the agreement entered into between the Partner (“Partner”, “You”, “Your” etc.) and the relevant ООО "Э-КОМ ЛИГАЛ", duly registered and acting under the laws of Russian Federation (ООО "Э-КОМ ЛИГАЛ") for the selling and/or purchasing of advertising inventory and serving of advertisements to Data Subjects ("Agreement"). This Appendix shall be incorporated into and form part of the Agreement and be deemed to have become effective as of the date both Partner and ООО "Э-КОМ ЛИГАЛ" have executed this Appendix. In case of any conflict between a provision of the Appendix and the Agreement, as it relates to Personal Data, the provision of the Appendix shall prevail. Capitalized terms used herein and not defined herein will have the meaning set forth in the Agreement and/or the Data Protection Laws. ООО "Э-КОМ ЛИГАЛ"’s provision of the Service to Partner entails the transmission and processing of data retrieved, sent and received by and from its partners (including Partner) and their Data Subjects, clients and other third parties. Such data may constitute Personal Data (as defined below). Therefore, the parties agree to comply with the following provisions.

1. Definitions.

1.1. “Data Protection Laws” means any applicable data protection or privacy laws or regulations as may be amended or superseded from time to time, including but not limited to: the EU General Data Protection Regulation (“GDPR”) as implemented by countries within the EEA and in the USA; and/or other laws or regulations that are similar, equivalent to, successors to, or that are intended to or implement the laws or regulations applicable to Partner in relation to the transmission and processing of Personal Data under or in relation to the Agreement.

1.2. “Controller”, “Data Subject”, “Personal Data”, “Processor” “Processes/Processing” shall each have the meanings given in the applicable Data Protection Laws.

1.3. “ООО "Э-КОМ ЛИГАЛ" Privacy Policy” means the privacy policy available at ООО "Э-КОМ ЛИГАЛ"’s official website: or at any other or additional location, as may be updated from time to time.

1.4. “Service” means ООО "Э-КОМ ЛИГАЛ" and/or its Affiliates’ proprietary technology and/or services for enabling and optimizing publishers and advertisers' ability to sale and purchase advertising inventory on certain mobile applications and mobile/desktop websites, including via programmatic auction (if applicable) and any kind of mailings, including all sorts of messaging.

1.5. “Data Subjects” means a human end-Data Subject accessing a mobile/web application/website or receiving any kind of mailings and all sorts of messaging.

2. Partner and ООО "Э-КОМ ЛИГАЛ" each agree and acknowledge that where a party Processes Personal Data under or in connection with the Agreement it alone determines the purposes and means of such Processing as a data controller (as defined under applicable Data Protection Laws).

3. Each party confirms that it has complied, and will continue to comply with its obligations relating to Personal Data that apply to it under applicable Data Protection Laws.

4. Partner warrants that it has provided adequate notices to and obtained valid consents from Data Subjects (or his partners warranted him that they had done it), in each case, to the extent necessary for ООО "Э-КОМ ЛИГАЛ" to Process their Personal Data or other information in connection with the Agreement, including, without limitation for direct marketing activities and international transfers of Personal Data outside of the EEA. Partner will on request provide records of all relevant consents obtained (or make his partners who warranted to provide) to ООО "Э-КОМ ЛИГАЛ". Partners shall notify ООО "Э-КОМ ЛИГАЛ" in writing within 24 hours of Partner receiving Data Subject’s objection to or withdrawal of Data Subject’s consent to Process their Personal Data or other information including, without limitation for direct marketing activities and international transfers of Personal Data outside of the EEA. Partner will not by act or omission, cause ООО "Э-КОМ ЛИГАЛ" to violate the ООО "Э-КОМ ЛИГАЛ"’s Privacy Policy, any Data Protection Laws, notices provided to, or consents obtained from, Data Subjects as result of Processing Personal Data in connection with or ООО "Э-КОМ ЛИГАЛ" otherwise performing the Service under the Agreement.

5. ООО "Э-КОМ ЛИГАЛ" will Process Personal Data in accordance with the ООО "Э-КОМ ЛИГАЛ"’s Privacy Policy.

6. Each party will limit access to Personal Data to those personnel who require such access only as necessary to fulfil such party’s obligation under the Agreement.

7. Each party will maintain appropriate administrative, physical, organizational and technical safeguards aimed at maintaining an appropriate level of security.

8. Each Party will provide other Party with all necessary assistance in connection with communications from, or requests made by Data Subjects in relation to their rights under Data Protection Laws, and supervisory authorities, in each case as they relate to Data Subject Personal Data.

9. Each Party to the best extent possible will provide the other Party assistance in complying with the Data Protection Laws.

10. Contract Clauses for Controller to Processor (Processor to Sub-Processor) relationships:

10.1. Obligations: Between Partner and ООО "Э-КОМ ЛИГАЛ", Partner are sharing Personal Data in relation to the Agreement. Therefore, Partner, as the Controller (or Processor) will have the responsibility to obtain appropriate consents (warranties regarding obtaining such consents from Controller if you act as Processor) for Processing of Personal Data by ООО "Э-КОМ ЛИГАЛ" as Processor (SubProcessor) in the capacity of a Processor (Sub-Processor) as highlighted in this Appendix. You will comply with the requirements of the Data Protection Laws as a Controller (or Processor) and will be responsible for notifying ООО "Э-КОМ ЛИГАЛ" of any Data Subject request towards deletion, rectification, opt-out election or any other execution of rights by Data Subject, which influence execution of Agreement between the Parties.

10.1.1. Paragraphs:

10.1.2 – 10.1.5 shall apply if and to the extent that the Processor processes any Personal Data on the Controller’s behalf when performing its obligations under the Agreement.

10.1.2. Each party acknowledges that: Processor shall only Process Personal Data for the following permitted purpose in relation to advertising campaigns:

(1) For fraud detection purposes including creating fraud reports to be shared with advertisers;

(2) For reporting purposes including reports to be shared with advertisers or for reporting to Controller;

(3) For determining performance of campaigns distributed through Publisher’s inventory or network and billing purposes. the processing shall continue for the duration of Agreement and this Appendix as part thereof; the processing concerns: clicks, actions and impressions data, IP Address, device identifiers, http headers, publisher details (such as site ID, partner ID, advertiser and publisher name), campaign details (such as campaign ID, creative ID) and such other data sets.

10.1.3. The Processor shall: process the Personal Data only to the extent necessary for the purposes of the Agreement and otherwise in accordance with the documented instructions of the Controller; not process the Personal Data in any country outside the European Economic Area other than in accordance with the terms of the Model Contract Clauses. If the Processor is required by applicable laws to transfer the Personal Data outside of the European Economic Area, the Processor shall execute appropriate documentation as required under Data Protection Laws (unless the Processor is barred from making such notification under the relevant applicable law). Partner acknowledges that ООО "Э-КОМ ЛИГАЛ" may need to transfer Personal Data outside of EEA in the context of Processing; ensure that all persons authorised by it to process the Personal Data are committed to confidentiality or are under a statutory obligation of confidentiality under applicable law; have at all times during the term of the Agreement appropriate technical and organisational measures to ensure a level of security appropriate to the risk to protect any Personal Data, with particular regard to its accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access; where the Processor does engage another Processor, substantially similar obligations to those set out in paragraphs in this Appendix shall be imposed by the Processor on the other Processor in a written contract; cease processing the Personal Data immediately upon the termination or expiry of Agreement and this Appendix or, if sooner, on cessation of the contractual activity to which it relates and, at the Controller’s election, delete or return all Personal Data to the Controller, and delete all existing copies unless applicable law requires their retention; Processor shall not retain Personal Data for longer than necessary to meet the permitted purposes hereunder or use the same for any purposes other than such permitted purposes. If requested by Controller, Processor shall without delay, rectify the Personal Data, to ensure it remains accurate, complete and current or delete the same upon notification by Controller to honour any Data Subject’s request. Controller agrees to notify Processor of such requests immediately. make available to the Controller all information reasonably necessary to demonstrate compliance with the obligations set out in this Appendix, and reasonably assist in audits, including inspections, conducted by the Controller or its representative to determine Processor’s compliance with its obligations hereunder. Processor shall have audit rights to determine Controller’s compliance with Data Protection Laws and Controller shall make available to the Processor all information reasonably necessary to demonstrate such compliance. Any audit will be conducted upon provision of reasonable notice and during regular working hours; at the earliest opportunity, and in any event within 48 hours after having become aware, notify the Controller of any unauthorised or unlawful processing of any Personal Data to which this clause applies and of any loss or destruction or other damage and shall take such steps consistent with good industry practice to mitigate the detrimental effects of any such incident on the Data Subjects and co-operate with the Controller in dealing with such incident and its consequences; and

10.1.4. Where the Processor intends to or replace other Sub-Processors, it shall first inform the Controller of the intended change, and shall implement appropriate data processing terms with such new Processors.

10.1.5. The Processor acknowledges that the Controller is under certain record keeping obligations under the Data Protection Laws, and agrees to provide the Controller with all reasonable assistance and information required by the Controller to satisfy such record keeping obligations.


The Model Contract Clauses require setting out more detail about what data is being transferred and why, as well as how the Processor must keep that data secure.

10.2.1. Description of ООО "Э-КОМ ЛИГАЛ"’s data Processing for Partner Partner is the Data Controller and the contact details are set out in this Appendix. ООО "Э-КОМ ЛИГАЛ" is the Data Processor and our contact details are also set out in this Appendix. The types of data being transferred are Personal Data, which does not include special categories of data. ООО "Э-КОМ ЛИГАЛ" will be carrying out the tasks in relation to that data as set out in this Appendix.

10.2.2. Description of Processor’s security measures Restriction of access to data centres, systems and server rooms as necessary to ensure protection of Personal Data. Monitoring of unauthorised access. Written procedures for employees, contractors and visitors covering confidentiality and security of information. Restricting access to systems depending on the sensitivity/criticality of such systems. Use of password protection where such functionality is available. Maintaining records of the access granted to which individuals. Ensuring prompt deployment of updates, bug-fixes and security patches for all systems. Providing Anonymization (encryption, Pseudonymization) measures where applicable and required by Data Protection Laws.

10.2.3. Liability and Payment of Compensation Without prejudice to the provisions of the Agreement, ООО "Э-КОМ ЛИГАЛ" shall defend, indemnify and hold Partner harmless and keep Partner indemnified, on demand from and against any and all damages incurred by Partner as a result of ООО "Э-КОМ ЛИГАЛ"’s and/or its employees or representatives unauthorised and/or unlawful Processing, or accidental loss, disclosure, destruction or damage to any Partner Data obtained from (or held by ООО "Э-КОМ ЛИГАЛ" or its personnel on behalf of) Partner, save where such loss, disclosure, destruction or damage was carried out or incurred at the Partner’s request. ООО "Э-КОМ ЛИГАЛ" shall be liable for and shall indemnify Partner and its employees and agents from and against all damages (including non-material damage) which Partner may suffer consequent upon breach of applicable Data Protection Laws, recklessness or wilful default of ООО "Э-КОМ ЛИГАЛ", its employees or agents. In no event shall ООО "Э-КОМ ЛИГАЛ"’s total liability to Company under this Appendix exceed $100.00. Notwithstanding the provisions of the Agreement, Partner shall defend, indemnify and hold ООО "Э-КОМ ЛИГАЛ" harmless and keep ООО "Э-КОМ ЛИГАЛ" indemnified, on demand from and against any and all actual or alleged claims and damages incurred by ООО "Э-КОМ ЛИГАЛ" as a result of Partner’s and/or its employees or representatives (including without limitation any affiliates) unauthorised and/or unlawful data transfer or processing, or accidental loss, disclosure, destruction or damage to any ООО "Э-КОМ ЛИГАЛ" Data obtained from (or held by Partner or its personnel on behalf of) ООО "Э-КОМ ЛИГАЛ", save where such loss, disclosure, destruction or damage was carried out or incurred at ООО "Э-КОМ ЛИГАЛ"`s request.

Partner shall be liable for and shall indemnify ООО "Э-КОМ ЛИГАЛ" and its employees and agents from and against all damages (including non-material damage) which ООО "Э-КОМ ЛИГАЛ" may suffer consequent upon any breach of Applicable Data Protection Law, recklessness or wilful default of Partner, its employees or agents.

11. This Appendix, (including all Clauses) and any dispute or claim (including non-contractual disputes or claims) arising out of or in connection with it or its subject matter or formation (a “Claim”) shall be governed by and interpreted in accordance with the law of California, USA (unless required otherwise by Data Protection Laws).

The parties irrevocably agree that the courts of California, USA have exclusive jurisdiction to settle any Claim, unless required otherwise by Data Protection Laws.

12. In case of conflict between the provisions regarding handling of Personal Data provided in this Appendix and pointed in the Agreement, the Appendix will prevail.