SESSA PRIVACY POLICY
This Confidentiality Policy is applied to all information that SessaCapital’s website may receive about the User while using the said company’s website.
1. TERMS AND DEFINITIONS
1.1 The following terms are used in this Confidentiality Policy as follows:
1.1.1. “Website Administration” means authorized employees of the Website
Administration acting on behalf of Sessa
Capital, who arrange and/or carry out the processing of personal data, the
definition of the purposes of this
processing, the selection of data to be processed, actions (manipulations) with the
above data.
1.1.2. "Personal data" mean any information relating to a person, directly or
indirectly determining
1.1.3. “Personal data processing” mean any actions (manipulations) or their
combination with personal data carried
out with or without automated devices, including, collecting, recording, organizing,
accumulating, storing, updating
(modifying), selecting, using, transferring (distribution, provision, access),
depersonalization, blocking,
deletion, destruction.
1.1.4. “Confidentiality of personal data” means a mandatory requirement to prevent
the dissemination of personal
data of their subject without his consent, relating to the operator or another
person having access to the said
data.
1.1.5. “User” means a person who has access to the Company’s Website via the
Internet.
1.1.6. Cookie means small pieces of data sent by a web server and stored on a
user's computer and sent by a web
client or a user's web browser to a web server every time an HTTP request is made
while trying to open the page of
the corresponding website.
1.1.7. “IP address” means a unique network address of a node in a computer network
built using the IP protocol.
2. GENERAL PROVISIONS
2.1. The User's application of the company's website means his/her consent and
acceptance of this Policy and all conditions for processing personal data of the
user.
2.2. In case of disagreement with the provisions of this Policy, the User shall be
obliged to stop using the Company's Website.
2.3. This Policy shall be applied only to the Sessa Capital website. The Company's
Website shall not control and shall not be liable for third-party websites that the
User can access by clicking on the links available on the company's website.
2.4. The Website Administration shall not verify the authenticity of personal data
provided by the User on the Company's Website.
3. SUBJECT MATTER OF THIS POLICY
3.1. This Policy establishes the responsibilities of the Company's Website
Administration for non-disclosure and establishment of a security regime in relation
to the confidentiality of personal data that the user provides to the Administration
of the website during registration.
3.2. Personal data permitted to be processed in accordance with this Policy shall
be provided by the User by completing the registration form on the Sessa Capital
website in the registration section and include the following information about the
User:
3.2.1. Surname and first name;
3.2.2. Contact number;
3.2.3. E-mail address;
3.2.4. Accounts in social networks;
3.3. The Company's Website protects the following data, which is transmitted
automatically during scanning and when visiting pages with an established
statistical script:
IP address;
information from cookie files;
information about the browser;
access time;
page address;
User activity on the page;
page redirect to the current (the address of the previous page).
3.3.1. Turning off cookies may make it impossible to access parts of the Company’s
Website where authorization is required.
3.3.2. The Company's website collects statistics on the IP address of all visitors.
This information helps to find and solve technical problems and control the legality
of financial transactions.
3.4. Any other personal information not mentioned above (history of operations,
browsers used, operating system, etc.) is subject to safekeeping and
non-proliferation, due to the thinning of the cases described in paragraph 5.2 of
this Policy.
4. PURPOSE OF COLLECTING PERSONAL INFORMATION OF USERS
4.1. The Company's Website Administration may use the User’s personal data for the
following purposes:
4.1.1. To identify the User registered on the Company's Website for the purpose of
securing remote financial transactions with Sessa Capital.
4.1.2. Providing the User with access to the personalized resources of the
Company’s Website.
4.1.3. Associating the User’s feedback, including sending out notifications,
newsletters, inquiries regarding the use of the Company's Website, the provision of
services, the processing of inquiries and the statements of the User.
4.1.4. Determine the location of the User for security purposes and to prevent
fraud.
4.1.5. Confirmation of the authenticity and completeness of personal data provided
by the User.
4.1.6. Create an account for financial transactions, if the User agrees to create
an account.
4.1.7. Sending notifications to the Company Website about news and actions.
4.1.8. Processing the financial information of the User.
4.1.9. Providing effective customer and technical support to the User in case of
problems with the use of the Company's Website.
4.1.10. Providing the User via e-mail special offers, information on financial
transactions, newsletters, and other information on behalf of the Company Site.
4.1.11. Implementation of promotional activities with the consent of the User.
5. METHODS AND REGULATIONS ON THE USER’S PERSONAL DATA PROCESSING
5.1. The User’s personal data are processed out of time, in any legal way,
including the use of personal data
systems with or without automated work tools.
5.2. The User agrees with the Administration’s right to transfer personal data to
third parties, in particular,
electronic postal services for the subsequent delivery of correspondence, solely for
the purpose of fulfilling the
Company's obligations to the User.
5.3. In case of loss or disclosure of personal data, the Website Administration
shall notify the User thereof.
5.4. The Website Administration shall take all required organizational and
technical measures to protect the User’s
personal information from unauthorized or accidental access, destruction,
modification, blocking, copying,
distribution or other, including illegal actions by third parties.
5.5. The Website Administration together with the User shall take all required
measures to prevent loss of funds or
other negative consequences of the loss or disclosure of the User’s personal data.
6. PARTIES’S OBLIGATIONS
6.1. The User shall be obliged:
6.1.1. To provide information about personal data required to use the Company’s
Website.
6.1.2. To update, supplement the information provided about personal data in case
of any amendments thereto.
6.2. The Website Administration shall be obliged:
6.2.1. To use the information obtained solely for the purposes specified in
paragraph 4 of this Policy.
6.2.2. To take measures to keep confidential information confidential, not to
disclose it without the prior written consent of the User, save for the exceptions
mentioned in paragraph 5.2 of this Policy.
6.2.3. To take precautionary measures in relation to the confidentiality of the
personal data of the User in accordance with the usual practices applicable to the
protection of such information in similar existing organizations.
6.2.4. Block personal data relating to a specific User since the moment of creating
a request from the User or his legal representative, or an authorized person of this
User, in order to protect the rights of the subject of personal data for the period
of verification in case of finding personal data, whose authenticity is in doubt, or
unlawful acts.
7. PARTIES’ LIABILITY
7.1. In case of failure to fulfill the obligations, the Website Administration
shall be liable for losses incurred
by the User in connection with the unlawful use of his personal data.
7.2. In case of loss or disclosure of confidential information, the Website
Administration shall not be liable if
the information mentioned is:
7.2.1. It became publicly available prior to its loss or disclosure.
7.2.2. It was received from third parties prior to its receipt by the
Administration Website.
7.2.3. It was disclosed with the consent of the User.
8. DISPUTE SETTLEMENT PROCEDURE
8.1. Prior to filing an application with the court with a claim regarding a dispute
arising out of the relationship
between the User and the Website Administration, the parties shall be obliged to
file pre-trial claims.
8.2. The claimee shall be obliged to notify the applicant in writing of the results
of its consideration on the
merits thereof within 30 calendar days upon the receipt thereof.
8.3. If it is impossible to reach an agreement, the dispute may be submitted to the
court for further settlement.
9. MISCELLANEOUS
9.1. The Website Administration shall be entitled to amend this Policy without the
User’s prior consent.
9.2. A new version of this Policy shall become effective after any new information within it is properly relayed to the investors/users.
9.3. Any suggestions or questions regarding this Policy should be addressed to the
technical support service of the Company’s Website.
9.4. This Confidentiality Policy is published on the page
