Terms of Use

1. Document Description

Use of this Website (including without limitation by visitors) is subject to the terms and conditions set forth in the following documents:
1. The User Agreement, a non-fee agreement between the Operator and the User regulating the use of the Website
2. The Monitoring Terms and Conditions, an appendix to the User Agreement regulating data processing and use of monitoring technologies, and
3. The Privacy Policy, which outlines the Operator’s policies on data processing and privacy related to the use of the Website.
The Operator may update this Document at any time at its own discretion without prior notice. All changes/revisions will be posted on the Website, stating when the changes come into effect. By continuing to use the Website after the updated Document has been released, the User confirms their agreement to the revised terms. Every time the User accesses the Website, they agree to review the current version of the Document for any updates.
A hard copy of the current Document is kept at the Operator’s registered office; the electronic version is available on the Website.
For any questions or queries with respect to the Document or the Website, the User may contact the Operator:
1. by using the Subscribe section of the Website,
2. by mail at Room 40, Office I, Floor 5, 2 Tsvetnoy Boulevard, 127051 Moscow
3. by submitting the webform available at https://asari.legal, or
4. by email at info@asari.legal.

This Document uses the following terms and abbreviations:

Automated Data Processing	PD processing by automated means; this involves the processing of PD based on predefined algorithms using computer infrastructure, including without limitation PIMS, information and telecommunication networks, AWS, and/or machine-readable media.
AWS	an automated workstation consisting of software and hardware (i.e. desktop or portable computing devices) designed to execute specific tasks without human intervention for a particular category of users or tasks.
Document	this Website User Agreement.
PIMS	a personal information management system that includes all PD stored in databases, as well as the information technologies and hardware used to process such data.
Physical Data Medium	a physical object, such as a paper document or a hardware device, used to record and store voice, sound, or visual information (including PD and processed information).
Manual Data Processing	PD processing without the use of automated means; this involves algorithm-based searching, accessing, using, updating, disseminating and/or destroying the PD of each PD Subject¹ stored on physical data media and/or organised PD sets (such as paper-based filing systems, PIMS databases, electronic files stored on AWS) with direct human intervention.
PD Processing	an action/operation or a set of actions/operations performed on PD by automated means and/or manually.
Operator	Asari Legal AB, a Moscow-based law firm(having its registered office at Room 40, Office I, Floor 5, 2 Tsvetnoy Boulevard, 127051 Moscow) which, independently or jointly with other parties, organises and/or performs PD processing, defines the purposes of the PD processing, sets the scope of PD to be processed, and determines operations/actions to be executed on PD.
PD	personal data, i.e. any information relating to a directly or indirectly identified or identifiable individual (a PD Subject).
Policy	the Operator’s Policy on personal data processing and privacy.
User or PD Subject	an individual who accesses or visits the Website and/or otherwise uses its functionality, including but not limited to viewing or searching information available on the Website, registering an account on it, submitting web forms, etc.
Russia	the Russian Federation.
Website	an Internet site operated for the Operator’s benefit and located at https://asari.legal/.
PETs	privacy-enhancing technologies.
Agreement	a non-fee agreement between the Operator and the User regulating the use of the Website.
Content	legally protectable intellectual property on the Website, including literary works (texts, titles, forewords, and annotations); articles; illustrations and cover artwork; music with or without words; graphics and photographs; any derivatives or compilations thereof; user and visual interfaces; brand names and logos; computer software and databases; creative design, structure, specific choice, and coordination of information, its visual representation, the overall “look and feel” and layout of the Website, as well as any other intellectual property elements, whether viewed individually or as a whole.
Monitoring Terms and Conditions	an appendix to the User Agreement regulating data processing and the use of monitoring technologies.
Services	access to the Website’s electronic content, including the right to view and download this content, and to its search and navigation tools.
Law 152-FZ	Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data”.

1. Document Description. 1

2. Scope of Agreement 6

3. Acceptance of the Terms and Conditions of the Agreement 6

4. Eligibility. 7

5. Disclaimer 7

6. Website Use. 7

7. PD Confidentiality and Processing. 8

8. Communication Methods. 10

9. Disclaimer of Warranty. 11

10. Website Modification and Discontinuance. 11

11. Termination. 11

12. External Links. 12

13. Indemnity. 12

14. Severability. 12

15. Survival 12

16. Governing Law and Jurisdiction. 13

17. General 13

18. Cookie Compliance. 14

19. Cookie Consent 14

20. Cookie Categories and Preferences. 16

21. Approval and Updates. 17

2. Scope of Agreement

This Agreement regulates the provision of Services to the User in connection with the use of the Website.
This Agreement covers all Services currently available on the Website, including any future modifications thereof, and any additional features that may be introduced to the Website from time to time.
Access and use of the Website is provided free of charge.
The Operator will not accept any revisions to the Agreement proposed by the User.
The Operator reserves the right to assign or otherwise transfer its rights and obligations in relation to the User arising from the execution, performance, modification, or termination of this Agreement.
Use of the Website content and features is subject to applicable Russian law.

3. Acceptance of the Terms and Conditions of the Agreement

This Agreement is a public offer. By performing any of the intentional activities listed below to use the Website, the User agrees to be legally bound by the terms and conditions of the Agreement and confirms their complete and unconditional acceptance of such terms and conditions as they may from time to time be amended and supplemented (i.e. the User is deemed to have acceded to the Agreement as amended and supplemented):
1. during one session, viewing at least three (3) pages of the Website containing text, audio, video, or images,
2. using the Website’s search and/or navigation feature and/or clicking links to external websites/resources/services,
3. downloading or streaming texts, images, audio, video, or other files for personal use or for distribution/demonstration to third parties,
4. copying content posted on the Website,
5. submitting data via webforms available on the Website (by clicking “Send” or otherwise),
6. accessing the Website on each subsequent occasion.
If the User does not accept these terms and conditions, they must immediately cease access to and use of the Website, and refrain from uploading or providing any content, data, or files via the Website.

4. Eligibility

This Website is intended for users based in Russia. The Operator does not intend this Website to be accessed by individuals under the age of 18, and any use of the Website by such individuals is strictly prohibited. Should the Operator become aware that the Website is used by underaged persons or minors, the Operator reserves the right to immediately terminate their access to Website and/or take any further actions permitted by law to prevent future violations.

5. Disclaimer

The Operator accepts no liability for any direct or indirect consequences resulting from the User’s actions or omissions taken in reliance on the information, features, or other content posted on the Website. While the Operator strives to keep information on the Website accurate, complete, and up-to-date, the Operator makes no representations or warranties of any kind regarding the accuracy, completeness, or timeliness of such information, and expressly disclaims any liability for damages that may result from such information being inaccurate, incomplete, or out of date.

6. Website Use

The User agrees to use the Website solely for personal, non-commercial purposes; access is provided to the User free of charge. The User further agrees that the Website and all intellectual property rights therein are the sole property of the Operator, and the User may not use them except in accordance with the terms and conditions of the Agreement. The Operator will not be liable for any damages resulting from the use of the Website for commercial purposes or other use not expressly permitted under this Agreement. The Operator reserves the right to deny or terminate access to the Website at its discretion. Access to the Website is provided free of charge; the Operator is under no obligation to provide Website maintenance or support services and bears no liability for any damages resulting from the failure to support or update the Website.
The User may only use the Website for legitimate purposes as permitted under this Agreement. The User is granted a non-exclusive, non-transferable, and revocable limited licence to view, print out, and distribute the Content, provided that the User agrees not to remove or conceal copyright notices or other notifications incorporated into the Content.
Further, the User agrees:

not to use the Website in a manner that may deactivate, overload, damage, or impair the Website, or otherwise interfere with other parties’ use of the Website, including their ability to engage in online activities via the Website;
not to use bots, crawlers, or other technologies, processes, or automated methods to access the Website for any purposes, including but not limited to capture or extract data, or to control or copy any contents of the Website;
not to copy the Website or any elements thereof, and not to use the Website for any unauthorised purposes without the Operator’s prior consent;
not to otherwise use any devices, software, or algorithms that may interfere with the normal operation of the Website;
not to otherwise attempt to interfere with the normal operation of the Website;
not to use the Website to distribute any information protected under the Russian legislation with respect to individuals or legal entities without a valid legal basis;
not to use the Website to distribute advertising materials without the Operator’s prior consent;
not to use the Website to:
- upload content which is illegal; violates third parties’ rights; promotes violence, cruelty, hatred, or discrimination based on race, ethnicity, gender, religion, or social status; contains false information and/or insults directed at individuals, entities, or government agencies;
- encourage illegal activity or facilitate the violation of regulatory restrictions and prohibitions currently in effect in Russia;
- violate the legal rights of minors or cause them harm in any other way;
- impersonate any other person or falsely claim affiliation with any organisation and/or community, including but not limited to the Operator.

The User is prohibited from:

using any devices, software, procedures, algorithms, or routines, either automated or manual, to access, obtain, copy, or monitor the Content,
interfering with the proper operation of the Website,
circumventing the Website’s navigation architecture to extract or attempt to extract any data, documents, or content using any tools, other than the tools provided directly through the Website’s functionality,
gaining unauthorised access to the Website’s features, or any other systems or networks related to the Website, or other services provided through the Website,
interfering with the security or authentication system of the Website or other network related to the Website,
performing reverse lookup on other Users, mining or attempting to mine user data,
using the Website or Contents for any purposes prohibited under Russian law or inciting others to engage in any illegal conduct or other activities that infringe upon the rights of the Operator or third parties.

Should the User fail to comply with the terms and conditions of the Website or the provisions of any other documents provided for under this Agreement, the Operator reserves the right to block such User’s access to the Website Content.
The Operator may impose restrictions on the use of the Website for all or certain Users.
The Operator reserves all rights except as expressly licensed to the User.

7. PD Confidentiality and Processing

This Agreement, along with the Monitoring Terms and Conditions (Section II of the Document) and Privacy Policy (Section III of the Document), governs the Operator’s processing and protection of the User’s data collected through the use of or access to the Website or its features.
By using the Website, the User authorises the Operator to process the User’s PD in order to enable the User and Operator to execute, perform, modify, and terminate the Agreement and to allow them to exercise, perform, and observe their respective rights, obligations, and prohibitions under the applicable laws and regulations, including without limitation PD laws.
For PD processing purposes, the Operator:
1. may engage third parties for PD processing by outsourcing PD processing to third-party providers and/or by sharing (receiving and transmitting) PD with third parties without outsourcing. The Operator may only engage third parties provided that their engagement is strictly limited to the extent necessary to achieve the purposes of PD processing, and will ensure that each third party is bound by obligations of confidentiality and PD protection (should a third party fail to comply with the provisions of this clause, it will be held liable under the corresponding contracts with the Operator and/or under applicable laws). Such third parties may be:
  1. persons authorised under applicable law to receive PD to the extent necessary for them to perform and exercise their functions, powers, and duties,
  2. persons to whom the Operator assigns and/or transfers its rights and/or obligations with respect to PD processing under the Document,
  3. the Operator’s successors/investors and/or affiliates, where the Operator and/or its affiliates are involved in corporate reorganisations, mergers, acquisitions, liquidations, or disposals,
  4. certain Affiliates of the Operator (as defined in Article 9 of Federal Law No. 135-FZ dated 26 July 2006 “On the Protection of Competition”);
2. may, subject to reasonable restrictions on frequency and timing and for the purposes of data processing (including, without limitation, to respond to User inquiries and requests), from time to time without prior notice send to the User, directly and/or via third parties, using contact details provided to the Operator by the User, information or service notices, updates, or messages, which may relate to, for instance, legal relations between the Operator and the User or changes in their terms and conditions. Subject to the restrictions above, the Operator may send to the User information or service messages regarding the Website and its operation, Website updates, and other Website-related news.
3. may process PD from the date of collection until the expiration of the Agreement (in particular, until the full discharge or termination of the Operator’s and User’s obligations under the Agreement) and for three (3) years thereafter, except as otherwise required by a separate agreement between the Operator and the User or applicable law. The Operator will cease processing or cause it to cease by destroying PD within ten (10) business days upon the discovery of a PD breach, or within thirty (30) days:
  1. after the processing purpose has been achieved or is no longer required,
  2. after the completion of the Operator’s liquidation or reorganisation;
4. agrees to only process PD that is relevant to the processing purposes, and to ensure confidentiality and privacy of the data during processing as required by applicable law.
For PD processing purposes, the User:
1. may at any time opt out of receiving the Operator’s information or service updates by following instructions in the Operator’s messages or by contacting the Operator directly;
2. agrees to provide accurate, complete, and up-to-date PD to the Operator and/or its authorised persons for processing. In the event of any changes in their personal data, the User agrees to promptly notify the Operator of this by:
  1. contacting the Operator directly;
3. agrees to cease the processing of PD received from the Operator, upon the achievement of the stated processing purpose or if such processing is no longer required or becomes illegal, unless otherwise required by applicable law;
4. agrees to ensure PD confidentiality and privacy during processing as required by applicable law;
5. agrees to cooperate with the Operator in good faith and provide reasonable assistance in processing and resolving inquiries (including but not limited to complaints, orders, claims, or legal actions) related to the processing of the User’s or other PD subjects’ PD under this Agreement.
If, for the stated processing purposes, the User shares with the Operator third-party PD, then the User, acting in this case as a data operator, represents and warrants that such sharing complies with applicable law; the User further represents and warrants that, to the extent required by law, the corresponding individuals were duly notified that their PD was being shared with and subsequently processed by the Operator. Within five (5) business days of the Operator’s request, the User shall provide information and/or documents confirming either the individuals’ consent to the sharing of their PD by the User, or other legal grounds for the data transfer, along with proof that due notice was given. The scope and contents of the information and/or documents provided will be determined in accordance with applicable law, with due regard for the rights and legitimate interests of PD subjects, the User, and third parties.
The User hereby acknowledges that they have read and understood the above terms and conditions of the PD processing, including their rights as a PD subject. The User understands that failing to provide PD to the Operator, providing inaccurate, incomplete, or outdated PD, or failing to notify the Operator (or giving late notice) of any changes in the PD may prevent the Operator from achieving the stated processing purposes. The User further represents that sharing information and/or documents containing PD with the Operator and/or the Operator’s authorised representatives does not violate applicable law or infringe upon the legal rights and interests of third parties.

8. Communication Methods

Information sharing via the Website is considered electronic communication. Whether the User interacts with the Operator through the Website or using other forms of electronic communication, such as email, such communication is considered electronic. The User agrees that the Operator may contact them with information or service updates electronically, or using telecommunication systems (phone calls), SMS/text messages, or instant messaging platforms in accordance with applicable law; the User further acknowledges that such communication, as well as any notices, disclosures, agreements, or other correspondence given in this way are equal to and have the same legal standing as if they were provided in writing and signed by the party sending them.

9. Disclaimer of Warranty

The Website is provided on “as is” and “as available” basis. Unless this Agreement expressly states otherwise, and to the maximum extent permitted by applicable law, the Operator expressly disclaims warranties of any kind, whether express, statutory, or implied, including but not limited to warranties of merchantability, fitness for a specific purpose, and non-infringement.
The Operator makes no guarantees that the Website will meet the User’s requirements, that access to the Website will be uninterrupted, timely, safe, or error-free, or that defects, if any, will be corrected. The Operator makes no guarantees regarding the results obtained from the use of the Website, or the accuracy, quality, or reliability of any information obtained using the Website.
The User understands and agrees that any content and/or data downloaded or otherwise obtained through the Website is used at their own risk, and that the User is solely responsible for any damage they may suffer, or for any loss of data resulting from such downloads.
No advice or information, whether oral or written, obtained by the User from the Operator or through the Website creates any warranty unless expressly provided for in this Agreement.

10. Website Modification and Discontinuance

The Operator agrees to make reasonable efforts to keep the Website available; however, from time to time the Operator may be required to interrupt, limit, modify or discontinue, either temporarily or permanently, operation of the Website or parts thereof without notice. The Operator will not be responsible for any damage the User may suffer as a result of these actions.

11. Termination

The Operator reserves the right to terminate the use of, or access to, the Website for the User at any time, and delete the User’s account, in whole or in part, both without prior notice, for good cause, including but not limited to a breach of these terms and conditions. The Operator will not be responsible for damage resulting from such termination of access. Upon termination, the User must immediately cease all use of the Website.

12. External Links

This Website may contain links or references to external websites, resources, or services (including without limitation mobile applications). Such links are provided solely for the User’s convenience. Third-party information, data, content, or links hosted on, referenced by, included or linked in, or redirecting to this Website do not constitute an endorsement by the Operator, whether express or implied, of any third-party products, services, or data. All information, data, opinions, recommendations, products, or services accessible via links to external websites, resources, or services or otherwise through third-party websites, resources or services, are the sole property of such third parties and are not owned by the Operator. Use of external websites, resources, or services is subject to the terms and conditions and privacy policies of their respective providers.

13. Indemnity

The User agrees to indemnify and hold harmless the Operator and its counterparties for and against any and all claims, liabilities, damages, or expenses, including but not limited to legal fees and expenses arising out of or in connection with:
1. any breach by the User of this Agreement;
2. the User’s use of the Website, including but not limited to sharing or posting Website content or data;
3. claims or complaints that the User-provided content infringes upon the intellectual property rights or other rights, including the right to privacy, of a third party.

14. Severability

Should any part or provision of this Agreement become illegal, invalid, or unenforceable, such part or provision shall be deemed severed from the Agreement and shall not affect the validity or enforceability of the remaining provisions.

15. Survival

All provisions of this Agreement shall survive termination of the User’s right to use the Website.

16. Governing Law and Jurisdiction

This Agreement, all disputes related to the Agreement or the Website, and non-contractual obligations arising out of or in connection with the Agreement, shall be governed, construed, and resolved in accordance with the laws of the Russian Federation, excluding its conflict of law provisions. All legal actions and disputes between the Operator and the User related to this Agreement shall be referred for resolution to a competent court in Russia, and the User hereby submits to personal and exclusive jurisdiction of such courtsв.

Section II. Monitoring Terms and Conditions

17. General

When the User visits the Websites or uses its features, the Operator may use various technologies and processes to passively collect and process technical data from the User’s device. Use of such technologies is essential to support the Internet experience and facilitate access to online resources (websites). This Appendix is an integral part of the User Agreement and sets forth the rules for the collection and processing of technical data through the Website.
The Operator may employ technologies to collect technical data (such as device information and Website usage), including without limitation cookie files, web beacons, scripts, and other tracking and targeting tools (collectively, “cookies”). The Operator may collect technical data using the Website’s internal features or third-party services (see Cookie Categories and Preferences below) to measure traffic and/or analyse Website usage.
The Operator reserves the right to change its third-party service providers without notice. Third-party service providers do not and cannot combine the data they collect through Website visits and use of its features with personally identifiable information collected by the Operator using the Website’s internal tools and/or submitted by the Users via webforms on the Website. Third-party service providers store and process data they collect on their own computer infrastructure, and the Operator is not responsible for the physical location of such infrastructureт.
It may be necessary to collect and use technical data to:
1. ensure continuous access to the Website and its functionality;
2. maintain security while visiting the Website and using its features;
3. manage Website performance and upgrade the Website;
4. support efficient interaction between the Operator and the User and provide technical support to the User;
5. conduct analytical and/or marketing activities.
The Operator does not:
1. directly or indirectly identify PD subjects based on technical data or other information;
2. match (sync) or aggregate (fuse) technical data with other PD or information available to the Operator;
The User may choose to decline authentication cookies of the Website in their browser settings. This may affect the User’s Website experience (for instance, the User may be required to sign in manually every visit).
The Website is not intended for individuals under the age of 18, and the Operator requests that such individuals do not submit their PD via the Website. If the Operator becomes aware that an underage person or a minor has submitted their PD via the Website, the Operator will permanently delete such data or cause it to be permanently deleted within ten business days.
These Monitoring Terms and Conditions do not apply to PD processing and protection by external websites, resources or services (including but not limited to mobile applications) which the User may access via a link on the Website or through redirection. Posting or adding a link to a third-party website or service to the Website does not constitute a warranty or representation by the Operator.

18. Cookie Compliance

Under the applicable PD laws, a cookie can only be stored on the User’s device with proper authorisation (for instance, an agreement between the Operator and the User and/or the User’s consent, if required), and only if the User has been given clear and complete information about how cookies are used on the Website.
To ensure compliance with the applicable PD laws, the Operator has:
1. disclosed cookies and other tracking technologies used on the Website, including their purpose, duration, and whether such cookies are owned by the Operator or third-party providers,
2. analysed the extent to which the use of cookies, taking into account their specific nature, may affect the User’s rights and interests,
3. provided clear and complete information about cookies on the Website, detailing the purpose of each cookie taking into account their impact on the rights and interests of the Website Users as PD subjects (see Cookie Categories and Preferences below),
4. implemented a mechanism to legally authorise the use of cookies (specifically, to obtain the User’s consent), taking into account the specifics of such cookies and their impact on the User’s rights and interests.

19. Cookie Consent

Statutory requirements for cookie authorisation are subject to change. From a legal perspective, obtaining the User’s express consent to use cookies is the most reliable mechanism to ensure cookie compliance; however, this approach may affect the User’s experience with the Website or limit the Website’s ability to legally collect usage data. Alternatively, implied consent can be obtained which is considered granted when the User chooses to not decline cookies after receiving clear and precise information about them and has been given the option to easily adjust the setting of the User’s device to manage their preferences (see Cookie Categories and Preferences below). This mechanism allows the User to accept or decline cookies used by the Website.
The choice between alternative methods of obtaining cookie consent depends on the cookie’s impact on the User’s rights and interests taking into account:
1. whether the cookie is a first-party (Operator-provided) or third-party cookie
2. the nature of the data the cookie collects
3. the cookie’s purpose
4. the cookie’s lifespan
5. nature of the Website through which the cookie is provided.

The Operator uses a three-level approach for cookies which require the User’s consent:

Impact on the User’s rights and interests
Approach
1. Low impact
The Operator discloses detailed information in the Monitoring Terms and Conditions and provides a simple opt-out option. By not opting out, the User provides implied consent.
2. Moderate impact
The Operator uses the same approach as for low-impact cookies, and adds contextual information regarding cookies in specific sections of the Website (for instance, next to targeted advertising or cookie-dependent features).
3. High impact
The Operator requires an active opt-in (for instance, via a banner or a pop-up window in which the User is required to allow cookies before they are deployed on the User’s device).

The cookies used on the Website are of low or moderate impact on the User’s rights and interest (as a PD subject). They can therefore be used with the User’s implied consent. An assessment and analysis of the types of cookies used on the Website is given in the section “Cookie Categories and Preferences”, which lists the purpose and lifespan of cookies, and how to reject them (see the column “Management”).

20. Cookie Categories and Preferences

Cookie Category	Owner	Purpose	Lifespan	Lifespan
First-party Cookies
Strictly Necessary	Operator	These cookies are essential for the Website to function. They support data security (such as authentication cookies) and proper content display.	Cookies used by the Operator for this purpose are automatically deleted from the User’s device one month after the last Website visit.	The User may opt-in or opt-out in the browser settings. The specific setup may vary by browser; more details about cookie preferences are available in the browser’s help section. Opting out may create certain inconveniences when using the Website (for instance, the User may be required to sign in regularly).
Functionality and Performance	Operator	These cookies enable the Operator to enhance Website operation and make it more user-friendly. For instance, they allow the Operator to determine whether the User’s browser supports Website scripts that enhance features or save User’s preferences, such as font size or language.	Cookies used by the Operator for this purpose are automatically deleted from the User’s device once the browser session ends.	The User may opt-in or opt-out in the browser settings. The specific setup may vary by browser; more details about cookie preferences are available in the browser’s help section.
Third-party Cookies
Analytical	Yandex Metrica https://yandex.ru/support/metrica/index.html	These cookies are used to collect data about the way Users interact with the Website. The Operator uses this information to generate reports and enhance the user experience. These cookies collect anonymous data, such as visitor traffic, referral sources, and viewed pages.	Some cookies of this category are automatically deleted from the User’s device once the browser session ends, while others may be stored for up to twenty-four (24) months after the last visit.	The User may opt out of Yandex Metrica at https://yandex.ru/support/metrica/general/opt-out.html
Marketing	Yandex Metrica https://yandex.ru/support/metrica/index.html	These cookies are used to collect data about the way Users interact with the Website and enable targeted advertising on the Website and other sites.	Some cookies of this category may remain on the User’s device for up to 12 months after the last visit.	The User may opt out of Yandex Metrica at https://yandex.ru/support/metrica/general/opt-out.html

21. Approval and Updates

These Monitoring Terms and Conditions are approved and enacted by the Operator and remain in full force and effect until terminated.
The Operator reserves the right to update these Monitoring Terms and Conditions as necessary (the “Updates”). The Updates are approved by the Operator. Once approved, the updated Monitoring Terms and Conditions are posted on the Website.

¹ PD processing may not be considered automated only on the grounds that such data is contained in or was extracted from the PIMS.

² A user session is the period between a User’s first and last action on the Website.

³Except download of the file containing these terms and conditions of the Website use.

⁴ For instance, IP address of the user’s device, time of the visit, pages viewed, downloads, browser type and version, and authentication cookies.