1. General Provisions

1.1. This Privacy Policy (the "Policy") applies to the platform, including any related websites and interfaces (collectively, the "Platform"), provided by the "MARKET-UP" company (the "Company"). The Policy is an additional, integral document to the User Agreement and describes how the Company collects, uses, discloses, and stores personal data that it receives from users of the site and in connection with the use of personal account services on the Platform.

1.2. For the purposes of this Policy, "personal data" means information relating to a user by which the user can be directly or indirectly identified.

1.3. By registering on the Platform and using it, the user agrees that their personal data will be processed in accordance with this Policy and the Platform's Terms of Use. Capitalized terms used herein have the same meaning as in the User Agreement.

1.4. The Company collects and processes the user's personal data both directly from the user — during registration and when the user provides such information — and automatically, when the user uses the Platform.

1.5. The purpose of this Policy is to provide users with information about the purposes of collecting and processing personal data, the legal grounds, the scope of processing, the security measures, and the retention periods for such data.

2. Information the Company Collects Directly from the User

Account and Profile Information

— the email address, username, and any other personal data that the user provides to the Company when communicating with it; such data is used solely to communicate with the user;

— the name and address that the user provides upon registration.

Payment and Transaction Information

The Company collects information related to the payment of subscriptions and the operation of the personal electronic wallet (account) on the Platform, including the history of subscription purchases and sales, as well as balance information and transactions carried out within the Platform. This information is used to process payments between users, maintain a transaction history, and prevent fraud.

Other Necessary Information

The Company may need to collect additional information in order to comply with legal requirements — for example, to check whether the user is on any restricted-persons list.

Communications with the Company

The Company collects information that the user provides when contacting support, including correspondence by email and through contact forms on the Platform. This information is used to respond to the user's inquiries, provide support, facilitate transactions, and improve the Platform.

2.1. If a user acts as an authorized person on behalf of another user and provides that user's personal data, they are responsible for ensuring that they have all necessary permissions and consents to provide such data to the Company, and for ensuring that the Company's use of such data does not violate applicable legislation.

3. Information the Company Collects Automatically

3.1. When the user uses the Platform, the Company's servers automatically record information using cookies and other tracking technologies, including data that the user's browser sends every time they visit the Platform: IP address, the address of the web page from which the user arrived at the Platform, browser type and settings, the date and time of the request, language preferences, and cookie data.

3.2. The Company may also collect information about the device the user uses to access the Platform: device type, operating system used, device settings, unique device identifiers, and crash data.

3.3. The Company may combine this information with other collected data, including, where applicable, the user's name, email address, and other personal data.

A detailed description of the categories of cookies, the purposes of their use, and the procedure for obtaining consent is provided in a separate document — the Cookie Policy, which forms an integral part of this Policy.

4. Legal Grounds and Purposes of Data Processing

The Company processes the user's personal data on one or more of the following legal grounds: performance of the contract with the user (the User Agreement), the Company's legitimate interest, the user's consent, and compliance with legal requirements. The purposes of processing and their corresponding grounds are set out below.

— Providing access to the Platform, facilitating communications and transactions, responding to user inquiries, and other customer-service purposes — on the basis of contract performance.

— Adapting content and personalizing the user experience — on the basis of the Company's legitimate interest or the user's consent, where applicable.

— Analyzing how users use the Platform (in aggregated or individual form) in order to improve the Platform, as well as for other research and analytical purposes — on the basis of the Company's legitimate interest.

— Marketing and advertising purposes, including sending news, special offers, information about promotions, giveaways, and contests, as well as configuring advertising for the Platform on third-party sites — on the basis of the user's consent. The user may withdraw such consent at any time by unsubscribing from mailings or contacting support, without affecting their ability to use the core functions of the Platform.

5. Disclosure of User Information

The Company may disclose the user's data, including personal data:

— to affiliates or subsidiaries — solely for the purpose of providing the Platform; in that case, the use and disclosure of personal data by such affiliates and subsidiaries is carried out in accordance with this Policy;

— to third-party service providers, contractors, or agents performing functions on behalf of the Company, provided that such third parties have agreed to use the data solely to provide the relevant services;

— in the event of negotiations for the sale, acquisition, or merger of the Company with another organization, the transfer of substantially all of the Company's assets to another organization, or in the course of bankruptcy proceedings;

— in accordance with legal requirements, litigation, a court order, or other legal process, for example in response to a subpoena;

— where the Company considers it necessary to investigate, prevent, or address illegal activity, suspected fraud, security-threat situations, violations of the Terms of Use or this Policy, or as evidence in litigation involving the Company;

— in the form of aggregated or de-identified information about users — to third parties and publicly, for product development, marketing, advertising, research, or similar purposes.

6. Profiling and Automated Decision-Making

6.1. Profiling is the automated processing of personal data for the purpose of evaluating certain personal aspects of a user, in particular analyzing or predicting their preferences, interests, behavior, or location.

6.2. The Company carries out profiling on the basis of its legitimate interest — for personalized offers and marketing, and for calculating a user's rewards for participation in the Partner Program. The Company provides users with available tools for managing their privacy settings.

6.3. The Company may apply automated decision-making with respect to a user. Automated decisions that produce legal effects for the user are made only in the course of concluding or performing the Agreement between the Company and the user, or on the basis of the user's explicit consent.

6.4. The user has the right not to be subject to a decision based solely on automated processing (including profiling) where such a decision produces legal effects for the user or otherwise significantly affects them, except in cases provided for by law. The user may request a review of such a decision by a human by contacting support at support@market-up.co.

7. Cookies

The Platform uses its own and third-party cookies and similar technologies to store information on the user's device — for the purposes of ensuring the site's operation, personalizing content, and obtaining analytical information. Strictly necessary cookies are set without the user's separate consent; other categories (for improving site performance, functional, and targeting/advertising cookies) are set only with the user's consent, which may be withdrawn at any time.

A detailed description of the cookie categories, the purposes of their use, retention periods, and methods for disabling them is provided in the Cookie Policy on the website www.market-up.co.

8. Third-Party Analytics

8.1. The Company uses automated tools and applications, such as Google Analytics and Yandex.Metrica, to assess use of the Platform and to improve its performance and the user experience. These services may use cookies and other tracking technologies to provide their services; their use is governed by the user's consent to analytics cookies, as set out in Section 7 of this Policy.

8.2. The Company does not directly transfer identifying personal data of the user (such as their name or email address) to these third parties for their own purposes.

9. Links to Third-Party Websites

9.1. The Platform may contain links to third-party websites. Use of such websites is not governed by this Policy but by the privacy policy of the relevant third-party website. The Company is not responsible for the personal data practices of third-party websites.

10. Security of the User's Personal Data

10.1. The Company takes reasonable measures, in accordance with applicable legislation, to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, and destruction. The user understands that no security measures can guarantee absolute protection of data, and should, for their part, follow the recommendations below:

— keep their password and personal-account access details secret and not share them with third parties;

— be alert to fake resources and phishing websites — the Platform has only one official address: www.market-up.co;

— install and keep up to date antivirus, anti-spyware, and firewall software on their devices;

— regularly update the operating system and protective software;

— limit shared access to files and printers on devices connected to the internet;

— regularly back up important data;

— consider using encryption to protect particularly sensitive information;

— log out of the personal account and clear the browser cache after finishing each session on the Platform;

— not install software of unknown origin and not open attachments from unfamiliar senders;

— not disclose personal and financial data to little-known or suspicious websites;

— not use public computers or internet cafés to access the Platform or carry out transactions.

10.2. The user must immediately notify the Company at support@market-up.co if they become aware of any unauthorized use of or access to their account or account credentials. The Company is not liable for lost, stolen, or compromised user credentials, or for any actions taken on the user's account as a result of unauthorized use of such credentials, provided this did not occur through the Company's fault.

11. User Rights With Respect to Personal Data

With respect to their personal data, the user has the right to:

— access their personal data and information about how it is processed;

— request correction of inaccurate or incomplete data;

— request deletion of their data when its further retention is no longer necessary;

— request restriction of the processing of their data in cases provided for by law;

— receive their data in a structured, machine-readable format and transfer it to another controller (the right to data portability);

— object to the processing of their data based on the Company's legitimate interest, as well as to the use of their data for direct marketing purposes and any profiling related to such marketing;

— withdraw previously given consent to the processing of their data at any time, without affecting the lawfulness of processing carried out prior to the withdrawal of consent;

— lodge a complaint with the personal data protection supervisory authority of their country if the user believes their rights have been violated.

The user may exercise these rights by accessing their account settings or by sending a request to support@market-up.co. The Company will respond to the request within a reasonable time, not exceeding the time limits established by applicable legislation.

In certain cases, the Company may not be able to fully satisfy a user's request — for example, if this is necessary to comply with legal requirements (including accounting and tax requirements), to carry out an investigation at the request of authorized bodies, to protect the Company's legal rights, if the requested data contains legally protected information about another person, or if fulfilling the request would jeopardize the rights and freedoms of third parties. In such a case, the Company will provide the user with an explanation of the reasons for the refusal and contact details for further inquiries.

Before responding to such a request, the Company will take reasonable steps to verify the user's identity, including compliance with any applicable legal requirements for such verification.

12. Transfer of Data Outside the User's Country

12.1. The Company may store the user's personal data on servers located in the countries where the main offices of the Company or its service providers are located. If such a jurisdiction differs from the jurisdiction of the user's residence, such data transfer is carried out for the purpose of providing the Platform and with due regard to applicable personal data protection legislation, including, where applicable, the use of appropriate contractual safeguards for the data being transferred.

13. Data Retention

13.1. The Company retains the user's personal data for as long as the user's account on the Platform is in use. The Company ceases to retain personal data, or de-identifies it, as soon as it can reasonably be assumed that: the purpose for which the data was collected no longer requires its retention, and retention is no longer necessary for legal, accounting, or business purposes. Certain laws may require the Company to retain transaction or account records for a specific period of time — in which case the period established by law applies.

14. Children's Privacy

14.1. The Platform is not intended for persons under the age of 18. If the Company becomes aware that personal data has been provided by a person under the age of 18, the Company will delete such information from all of its systems.

15. Contacting the Company

15.1. For questions relating to this Policy and the processing of personal data, the user may contact the Company through the site's internal services (support chat, messages in the personal account) or at the email address support@market-up.co.

16. Changes to This Policy

16.1. This Policy takes effect from the moment it is published. The Company may make changes to it; the new version takes effect from the moment it is published on the site. The user is advised to check the site regularly for updates to the Policy.

Please note: requirements for the processing of personal data, the scope of user rights, and the procedure for cross-border data transfers vary significantly depending on the country and region (for example, the European Union has the GDPR, Brazil has the LGPD, Turkey has the KVKK, the Republic of Korea has the PIPA, and China has the PIPL). Before publishing this Policy on the site, it is recommended that its compliance with the mandatory legislation of all jurisdictions in which the platform operates be reviewed with the involvement of qualified legal counsel.