PRIVACY POLICY

        Last updated on May 20, 2021.

        This Privacy Policy (the "Policy", the "Privacy Policy") is an integral part of
        the User Sublicense Agreement which defines the rules for processing Personal
        Information that Rapidcatch (KRAPKA s.r.o.; hereinafter referred to as "KRAPKA
        s.r.o.", "we") can collect about the Users (the "User" or "you") in relation to
        the usage of the Rapidcatch service (the "Service") by the User, and stipulates
        the types of the information collected, the ways and methods of collecting the
        information, the purposes of collecting the information, measures to ensure the
        information protection, as well as the rights of the User regarding their
        Personal Information.

        The User hereby agrees to the processing of their Personal Information under the
        terms of this Privacy Policy. The User's actions aimed at using the Service mean
        the User’s unconditional acceptance of the terms of this Policy and the terms of
        their Personal Information processing specified therein. We urge you to read
        this Policy and make sure that you fully understand and agree to it before you
        start using our Service. If you have not read the entire text of the Privacy
        Policy, do not understand or accept the terms of this Privacy Policy, you shall
        immediately stop using the Service.

        The User guarantees that in accordance with the User's jurisdiction, they have
        reached the age that allows them to independently agree to the processing of
        their Personal Information (but not younger than 16 years old) or the User can
        confirm they have got the corresponding permission from the holder of parental
        responsibility in accordance with the established procedure and form.

        We draw special attention to the fact that you are not legally obliged to
        provide us with any information, however, providing this information is a
        compulsory condition for using our Service. You hereby confirm, guarantee and
        agree that any information you provide us with is submitted of your own free
        will, is accurate, unambiguous and complies with your desire to use your data
        for the purposes described below.

        You can withdraw your consent to the processing of your Personal Information at
        any time as we are willing to make the procedure for revoking consent as well as
        providing it as simple as possible. Withdrawal of the consent does not affect
        the legitimacy of the information processing that took place prior to the
        consent withdrawal.



        TERMS AND DEFINITIONS


        Personal Information is any information about a specific or identifiable natural
        person.

        Agreement is a sublicense agreement between the User and on the use of the
        Service

        Service means a software package available on the Internet at the website
        address https://rapidcatch.com. The Service includes but is not limited to the
        set of information, texts, graphical elements, designs, images, photos and
        videos, and other intellectual properties, as well as computer programs
        contained in the information system, which makes such information available on
        the Internet at the website address https://rapidcatch.com.

        User is a natural person or a legal entity who uses the Service.

        All other terms and definitions found in the text of the Policy shall be
        interpreted in accordance with other rules governing the use of the Service,
        with the rules of interpretation established on the Internet and the applicable
        law regulating the processing of Personal Data.



        1. COLLECTED PERSONAL INFORMATION


        1.1. We act in accordance with the Directive of the Council of Europe on the
        collection and storage of personal data (GDPR) and its principles, as well as
        with the current legislation of the Russian Federation in the field of personal
        data processing.

        1.2. According to the principle of data minimization, we collect as much
        Personal Information as is sufficient for comfortable use of the service and
        accomplishing the objectives of its collection.

        1.3. In the process of using the Service by the User, we collect two types of
        Personal Information: Personally Identifiable Information and Non-Personally
        Identifiable Information.

        1.3.1. Personally Identifiable Information. Such information includes individual
        data that identifies a particular User and which the User provides us with in
        the process of the Registration.

        Required types of Personally Identifiable Information that are necessary for
        using the Service include:

        email address.

        Additionally you can provide on your own the following:

        data for authentication at the selected auctions
        phone number;

        This information is not obligatory for receiving access to the Service and is
        passed to us at your sole discretion, however, we want to note that such
        information greatly simplifies your interaction with the Service. Thus, the
        phone number will allow us to promptly react to your requests, while the name
        will allow us to address you correctly.

        1.3.2. Non-Personally Identifiable Information. Non-Personally Identifiable
        Information is data that does not identify a particular User, and is collected
        automatically during the process of the Registration and usage of the Service.

        The Non-Personally Identifiable Information may include:

        information obtained with the help of cookie files, pixel tags, web beacons,
        browser analysis tools and web server logs, as well as other similar
        technologies and tools; information about devices that the User uses to access
        the Service, including the type of operating system, device model, browser type,
        system settings, including the information about the language that the User’s
        system uses, location (country / region), time zone of the User’s device, mobile
        operator; logs of actions stored on the server which record IP addresses of
        devices that the User uses to interact with the Service, the access time, the
        sequence of the User's actions when using the Service, information about the
        session, including the response time, download errors; information from the
        User's social media account (depending on the privacy settings configured by the
        User for their social media account) so we can get information about your
        interests and preferences as well as access to your photo; other information
        that does not identify the User  depending on the permissions you granted. 1.4.
        The User understands and agrees that in some cases, we are entitled to request
        additional information about the User as well as scanned copies of the User’s
        documents for confirming the provided information, and to make any other
        requests when this is necessary based on reasonable assumptions and legitimate
        interests.


        2. METHODS OF COLLECTING PERSONAL INFORMATION


        2.1. The legal basis for collecting Personal Information is the User's consent
        to collect information in accordance with subparagraph A of paragraph 1 in
        Article 6 of the Directive of the Council of Europe on the collection and
        storage of personal data.

        2.2. Personal information is collected by us at the moment the User registers
        with the Service. The Registration with the Service can be made in a standard
        way by submitting the User’s Personal Data by the User, or through the User’s
        account on social media when Personal Information is automatically transferred
        from the social media page.

        2.3. The Non-Personally Identifiable Information is collected by us in the
        process of using the Service by the User.



        3. OBJECTIVES OF COLLECTING PERSONAL INFORMATION


        3.1. We use Personal Information for the following purposes:

        3.1.1. To provide access to the Service and its further use.

        3.1.2. To improve the Service, make its use and adjustment of the necessary
        settings more convenient based on general or individual preferences, experience
        of use or difficulties encountered by the Users.

        3.1.3. To provide technical support, feedback, including sending notifications,
        requests and information regarding the use of the Service (update notifications,
        security information, changes to our rules and terms of use of the Service).

        3.1.4. To generate statistics summary reports which include analytics and
        monitoring of trends in the use of the Service and the Users actions in the
        Service.

        3.1.5. To send advertising newsletters to your email address or to your mobile
        phone with the help of notifications about products, services, promotions,
        events and other news and information which, in our opinion, might be
        interesting to the User. We can send you promotional information. You can easily
        refuse receiving advertising messages by selecting the "Unsubscribe" option
        offered in these messages.

        3.1.6. To prevent fraud or violation of the applicable law, in particular to
        detect, investigate and prevent fraudulent transactions and any other illegal
        activities, and to protect the rights and property of KRAPKA s.r.o. as well as
        the right and property of other users and third parties.

        3.1.7. To comply with any applicable law.

        3.2. Personal Information of the User will not be used for purposes other than
        the above.

        3.3. The User confirms that the objectives of using their Personal Information
        correspond to their interests, and the consent to the processing of the Personal
        Information by us expressed by the User at the beginning of the use of the
        Service is given for each purpose of the processing specified in clause 3.1 of
        the Agreement.



        4. DISCLOSURE OF PERSONAL INFORMATION


        4.1. We undertake not to disclose the User's Personal Information to third
        parties, unless:

        4.1.1. The User expressed the explicit consent to the disclosure of their
        Personal Information.

        4.1.2. The information disclosure is necessary for the use of the Service by the
        User, as well as for the fulfillment of the Sublicense Agreement or any other
        binding documents that regulate the relationship between us and the User.

        4.1.3. When the information disclosure is necessary for the work of the Service
        and its functionality (information transfer to hosting, communications and
        content delivery networks (distribution), data protection and cyber security
        services, billing and payment processing services, fraud detection and
        prevention services, web analytics, distribution of emails and monitoring the
        status of the Service, including measuring performance and data optimization,
        marketing and advertising services), third parties (recipients of Personal
        Information) can receive or have access to the User’s Personal Information in
        full or in part, depending on the role and objectives of each such person in
        maintaining the operability of the Service or in improving it; in addition, they
        can use the received information only for the purposes specified in this Policy.

        4.1.4. Personal Information is passed in accordance with the applicable law on
        requests of the entities authorized for the receipt of such information
        (inquiries made by juridical authorities and law enforcement bodies) when we are
        obliged to disclose such information, if in good faith we reason from what the
        law requires of us and act accordingly.

        4.1.5. Ownership of or control over all parts or a part of the Service is
        transferred to the new owner.

        4.1.6. Personal Information is disclosed in order to ensure the protection of
        our rights and legitimate interests, or the rights and interests of third
        parties in case the User violates this Privacy Policy or other binding documents
        regulating the relationship between us and the User, and the applicable law. The
        above cases cannot be regarded as an unauthorized disclosure of Personal
        Information as these actions are aimed at fulfilling the objectives of
        processing Personal Information.

        4.2. We shall never sell Personal Information of the Users to third parties.

        4.3. Information can only be disclosed strictly in accordance with this Privacy
        Policy and under the applicable law.



        5. STORAGE AREA AND TRANSBOUNDARY TRANSFER OF PERSONAL INFORMATION


        5.1. We store and process Personal Information of visitors to Rapidcatch site,
        you and your users in the United States and European Union. The storage and
        processing of the User's Personal Information is carried out either directly by
        us or with the help of third parties specializing in the information storage
        that are obliged to protect and preserve Personal Information in accordance with
        this Privacy Policy.

        5.2. If you reside in a jurisdiction that imposes "data localization"/”data
        residency” obligations (i.e. requires its residents’ personal information to be
        kept within the territorial boundaries of that jurisdiction), we provide storage
        of your Personal Information within such territorial boundaries, provided we are
        legally obligated to do so.

        5.3. We pay special attention to the fact that the United States is included in
        the list of states providing adequate protection of personal data, and the
        European Commission considers the United States able to offer a sufficient level
        of Personal Information protection to residents of the EU states.

        5.4. We strive to ensure the User's Personal Information is protected and
        preserved in accordance with the internal industry standards regardless of any
        lesser legal requirements as compared to those that may apply in the User’s
        jurisdiction.



        6. USE OF TRACKING TECHNOLOGIES


        6.1. We use certain monitoring and tracking technologies in order to maintain,
        provide and improve the operation of our Service on an ongoing basis, and in
        order to provide a comfortable usage of the Service’s environment for the User.
        By default, we use several such technologies in order to identify the User and
        the start of the session, to provide security, to save the User’s preferences
        (for example, with respect to the default language and settings), to ensure the
        connection stability, to monitor the performance of our Service and marketing
        campaigns, and to provide and improve our Services.



        7. USER RIGHTS


        7.1. In accordance with this Privacy Policy, each User has the following rights
        with respect to their Personal Information:

        7.1.1. The right of access to the User’s Personal Information. To ensure this
        right, the Service provides a special section in the User’s Account where all
        Personal Information we received about the User is indicated. The User can go to
        the Personal Information section and see the Personal Information of theirs
        which we currently have. At the request of the User, we provide a complete list
        of the Personal Information we have collected about the User, the legal basis
        and purpose of the processing, the Personal Information categories, the list of
        third parties to whom their Personal Information has been or will be disclosed,
        the period during which the Personal Information will be stored, measure of the
        Personal Information protection. The answer to the User’s request shall be given
        within a reasonable time in accordance with the applicable law.

        7.1.2. The right to have inaccurate Personal Information rectified. The User has
        the right to correct their Personal Information through their Account at any
        time, in case the User has problems with correcting their Personal Information
        for some reason, they can send a corresponding request to us, we will make
        corrections within a reasonable time. Taking into account the purposes of
        Personal Information processing, the data Subject has the right to provide
        incomplete Personal Information specifying only the obligatory types of Personal
        Information that are necessary to access the Service.

        7.1.3. The right to withdraw consent to the processing of Personal Information.
        The User has the right to withdraw their consent at any time. The consent
        withdrawal does not affect the legality of the processing that was made on the
        basis of the consent prior to its withdrawal. The Service provides the
        possibility to withdraw the consent as easily as it is given. Thus, the User can
        forward us a request to delete their Account at any time, and we will delete the
        Account within a reasonable time after receiving the request.

        Please note that you can correct, update or delete certain pieces of your
        Personal Information on your own.

        In case the User makes corrections to their Personal Information or revokes the
        consent, we shall notify all third parties that have access to the User's
        Personal Information about this.

        7.1.4. The right to erasure («the right to be forgotten»). The User has the
        right to demand their Personal Information to be removed, and we are obliged to
        do so without undue delay, if:

        Personal Information is no longer needed for the purposes for which it was
        collected; the data subject withdraws consent to the processing of their
        Personal Information, which is the basis for its collection; Personal
        Information was processed illegally; Personal Information shall be erased in
        accordance with the law. 7.1.5. The right to data transfer. The User has the
        right to receive their Personal Information in a structured, commonly used and
        machine-readable format. The User can receive all their Personal Information,
        that was ever received by us, in a structured form by sending a corresponding
        request to the Support Team. The User has the right to have their Personal
        Information transmitted directly from one controller to another, where
        technically feasible.



        8. PERIOD OF PERSONAL INFORMATION STORAGE


        We store your Personal Information during the entire period the Service is used
        by you (according to the actions in your Account), or until we no longer need
        this data to provide the Service, or if it is required for a longer period (if
        we are required to store it for a longer period by virtue of applicable law, or
        it is done to resolve disputes in relation to our Users, to prevent fraud and
        abuse, and/or to protect our legitimate interests).



        9. INFORMATION SECURITY


        9.1. We hereby guarantee that we take all necessary and sufficient, in
        accordance with applicable law, organizational and technical measures to protect
        the User's Personal Information from unauthorized or accidental access,
        destruction, modification, blocking, copying, distribution, as well as other
        unlawful actions with it by third parties. We act in accordance with the
        generally accepted industry standards to protect the User’s Personal Information
        and strive to protect and ensure the confidentiality of Personal Information to
        the greatest extent possible. The protection of Personal Information is
        implemented in the Service by default at the stage of its development. The
        security measures include firewalls, pseudonymization, data encryption, data
        minimization, robustness of the processing systems, the ability to timely
        restore availability of and access to Personal Information in case of a physical
        or technical incident, control of physical access to data centers, as well as
        control of the authority to access data. We regularly monitor our systems for
        possible vulnerabilities and attacks, evaluate the effectiveness of technical
        and organizational measures to ensure the security of Personal Information, and
        are constantly looking for new ways and service providers to further enhance the
        security of our Service and protect the privacy of our Users. All third parties
        that can access Personal Information and take part in the process of providing
        access to the Service for the User take the same strict measures to ensure the
        security of Personal Information.

        9.2. However, we can not guarantee absolute protection, and therefore we urge
        you to be cautious, create a strong password for your account and avoid
        providing any sensitive data, disclosure of which can cause you significant
        harm.

        9.3. In the event of any violation of the Personal Information confidentiality,
        we take all possible measures to eliminate or minimize possible negative
        consequences, and also ensure that the authorized supervisory bodies and the
        User are immediately notified of the incident and provided with all available
        information on the confidentiality breach. The facts of such incidents are
        recorded in a special register of incidents, which we are obliged to keep in
        accordance with the applicable law.

        9.4. The violation of the Personal Information confidentiality is understood in
        this Policy as a security breach resulting into the accidental or unlawful
        destruction, loss, change, unauthorized disclosure or access to the transmitted
        or processed Personal Information.



        10. PRIVACY POLICY CHANGES AND INTERPRETATIONS


        10.1. This Privacy Policy, its interpretation, and any claims and disputes
        related to it are regulated, interpreted and carried out solely in accordance
        with the laws of our incorporation, without giving effect to the conflict-of-law
        provisions.

        10.2. You hereby agree that any arising disputes shall be resolved solely by the
        courts at the territory of our incorporation.

        10.3. The Privacy Policy may be changed by us at any time.  In case we consider
        the changes significant (at our own discretion), we shall notify you before the
        changes take effect.

        10.4. We recommend that you regularly review this page for up-to-date
        information about our Privacy Policy. If there’s any conflict between the
        English version of this Privacy Policy and its translated (not English)
        versions, the English version shall prevail.


        11. INTERACTION WITH US AND ANSWERS TO YOUR REQUESTS


        11.1. If you have any questions about this privacy Policy, please contact us at
        support@rapidcatch.com.

        11.2. You can also send a letter to the following addresses:

        KRAPKA s.r.o.
        Vítkova 261/6
        186 00 Prague 8
        Czech Republic

        11.3. We will respond to your request within a reasonable time or the period
        specified by the applicable law.

        11.4. In cases where this Policy or applicable law establishes our obligation to
        provide you with copies of information or any documents, we provide them in a
        single copy for free; for any additional requested copies, we are entitled to
        charge a reasonable fee based on administrative expenses. If you make an online
        request, we provide copies in widely used digital format unless otherwise
        requested by you.

        11.5. If the User's requests are obviously unreasonable or excessive, in
        particular because of their repetitive nature, we are entitled to charge a
        reasonable fee taking into account the administrative costs of providing
        information, or to refuse to act upon request.

        11.6. In the event that we have reasonable doubts about the identity of the
        person making a request, we can ask to provide additional information necessary
        for verifying the identity of the User.