INTRODUCTION

Welcome to Vertera Privacy Policy! Here we explain what data we collect when you visit and use our Websites. We also explain why we collect this data and to whom your data is transferred. Please, read this and contact us with any questions regarding this document. Before you register your personal account with Vertera, please, read this Privacy Policy and agree to the various sections.

Vertera Beauty and Health Laboratory Limited Liability Company (Vertera LLC LKZ, INN: 6950216249, Address: 170006, Russia, Tver Oblast, Tver, Sofya Perovskaya Street, building 6, room XIII) (hereinafter referred to as the Company) shall protect personal data collected or received from visitors (hereinafter referred to as the Visitors) of the Website www.vertera.org , as well as other websites and applications operated by the Company (hereinafter referred to as the Websites) and other used interactive media which contain the link to this Policy. It also describes how we use the Personal Data collected when you register as a Client (hereinafter referred to as the Client) or as an Independent Partner of Vertera Beauty and Health Laboratory (hereinafter referred to as the Independent Partner of Vertera Beauty and Health Laboratory).

In this Privacy Policy (hereinafter referred to as the Policy) we explain how we collect, use, store, transfer, disclose and delete (hereinafter referred to as the Processing) your personal data, i.e. any information related to a directly or indirectly identified or identifiable natural person (personal data subject) (hereinafter referred to as the Personal Data) which we may store about you.

The Personal Data Processing Policy is drawn up in accordance with clause 2 of Art. 18.1 of the Federal Law of the Russian Federation “On Personal Data” No. 152-ФЗ dated July 27, 2006 and applies to all Personal Data processed by the Company and which can be received both from an individual and a legal entity (counterparty) bound by any agreement with the Company.

The Clients, Independent Partners of Vertera Beauty and Health Laboratory, expressly consent to processing of their Personal Data as described in this Policy. We do not collect personal information about a person aged under 18. Please, contact our customer service if you think that a person aged under 18 provided us with personally identifiable information.

This Policy only applies to the information processed by us. This shall not apply to the companies, which are not held or controlled by us, or employees not managed by us. The information about our products may contain links to third party websites, and any information you provide to those websites will be covered by any privacy policies they may apply. Be sure to read privacy policy of any third party websites you visit. These websites are obliged to protect any information you provide to them, so we cannot be liable for misuse of your personal information.

The legal basis of this Policy is the Federal Law of the Russian Federation “On Personal Data” No. 152-ФЗ dated July 27, 2006 (Federal Law “On Personal Data”).

Upon registration on the Website the Clients, Independent Partners of Vertera Beauty and Health Laboratory, confirm their consent to the terms of this Policy and their consent to processing of their Personal Data in accordance with the terms of this Policy.

We may update this Policy from time to time and notify you of any changes to this Policy, affecting your rights, by e-mail and/or by publications on our Websites.

WHAT PERSONAL DATA WE COLLECT AND WHY WE DO THIS?

Every time you visits the Websites, the Company will automatically collect the following Personal Data:

• Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Information about your visit to the Websites, including full URL address of Uniform Resource Locators (URLs) on the Websites, through and from them (including date and time); the products you viewed or searched for; page response time, loading errors, duration of visits to certain pages, information about page interactions (such as scrolling, clicking and mouse hovering), and the methods used to navigate away from the page.

We collect this information to improve our Websites, products, fulfill our administrative purposes and protect our business interests.

In addition, we collect your contact data, such as name, e-mail address, through the communication channels available on the web page “Contact Us”. We collect this information in order to provide you with the relevant responses to your questions or comments.

If you register as a Client, we may collect the following Personal Data from you:

Your Name, Surname. This is a contractual obligation. If you do not provide this data, you cannot be registered as a Client;

Password. This is a contractual requirement. You cannot create your account in our online system without a password, because the data must be protected;

E-mail address. It is required for confirmations and sending messages. You cannot receive confirmation without e-mail. We also use it to communicate with you;

Telephone number. We collect this information to manage your registration as a Client, create and manage your online user account and communicate with you. It is also required to confirm and deliver your orders;

Information about your purchases with Vertera, as well as information about your preferences for certain types of products, shopping habits, purchase history and spending behavior. We collect this information to improve our Websites, products, fulfill our administrative purposes and protect our business interests;

Postal address. This is a contractual requirement. We are not able to deliver your order if you do not provide your postal address.

Moreover, when you communicate with us through various communication channels, we collect your contact data, such as name, e-mail address. We collect this information to provide you with the relevant responses to your questions or comments.

We may collect other types of personal data only by way of exception. If we need to process additional types of Personal Data about you, we will make sure that you are informed about processing of your Personal Data and there is a legal basis for doing this (for example, your consent).

If you register as an Independent Partner of Vertera Beauty and Health Laboratory, we may collect the following Personal Data from you:

• Your Surname, Name, Patronymic. If you do not provide this data, we cannot register you as an Independent Partner of Vertera Beauty and Health Laboratory;
• Your birth date. In accordance with the law the registration is only available for persons who attained the age of 18;
• Your personal code (ID). We will use this data to verify that you are a specific Independent Partner of Vertera Beauty and Health Laboratory and to pay remuneration in accordance with the Marketing Plan of the Company;
• Copy of passport / identity certificate. . We will use this data to verify that you are a specific Independent Partner of Vertera Beauty and Health Laboratory and to pay remuneration in accordance with the Marketing Plan of the Company and legal requirements;
• Postal address. This is a contractual requirement. We are not able to deliver your order if you do not provide your postal address;
• Registration address. This is our statutory requirement. We cannot offer Company bonuses without information about your current address;
• E-mail address. It is required for confirmations and sending messages. You cannot receive confirmation without e-mail. We also use it to communicate with you;
• Telephone number. It is required to confirm and deliver your orders;
• Account number (bank / payment system). These are our legal obligations to pay you bonuses;
• Password. This is a contractual requirement. You cannot create your account in our online system without a password, because the data must be protected;
• Information about your purchases with Vertera, as well as information about your preferences for certain types of products. We collect this information to improve our Websites, products, fulfill our administrative purposes and protect our business interests.

Please, contact us if you object to use of your Personal Data for any of the purposes set out above. Though your decision to provide your Personal Data to the Company is generally voluntary, but if you do not provide certain information, the Company may not be able to fulfill some of the purposes set out in this Privacy Policy. For example, we cannot deliver products to you without knowing your postal address.

ON WHAT GROUNDS DO WE USE YOUR PERSONAL DATA?

Performance of the agreement: as required to enter into and perform the agreement with you (General Terms and Conditions), for example, when you make any purchase. This will include accepting payments, communicating with you, providing services to the Clients, Independent Partner of Vertera Beauty and Health Laboratory, arranging delivery or other provision of products or services. We will also need to verify your identity, accept payments, communicate with you, provide partner services and provide you with bonuses and rewards in order to establish partner contacts.

Legitimate interests: In accordance with the requirements in order to pursue our own legitimate interests, in particular:

• to communicate with you (including providing you with the information which will help you improve your business (for example, providing you with training materials and classes);
• to invite you to participate in research or market research, as well as to invite you to attend a conference;
• to enable you to control, improve, administer and protect your products, content, services and Websites, both online and offline;
• to control and ensure that you comply with all policies and regulations;
• to control any user account of a Client or an Independent Partner of Vertera Beauty and Health Laboratory in order to prevent, investigate and/or report about fraud, terrorism, misrepresentation, security incidents or crime in accordance with the applicable legislation; and
• to analyze effectiveness of the advertising it serves for you and others, and to provide you with the relevant advertising (including customer satisfaction scores and similar studies).

Legal compliance: Ensuring compliance with the applicable laws and protecting the legitimate business interests and legal rights of the Company, including, but not limited to, use in connection with the legal actions, compliance with regulatory, tax and investigative purposes (including disclosure of such information) in connection with the legal proceedings.

Consent: subject to the following, the Company will send you direct marketing in relation to the Company products and services similar to those which you have already purchased, or other products and services provided by the Company. Marketing will be sent only if you have given your consent for the Company to participate in the process of registering a Client or an Independent Partner of Vertera Beauty and Health Laboratory. You may manage your preferences or unsubscribe at any time by clicking through the links in the e-mails sent by us to you.

TO WHOM WILL WE TRANSFER YOUR PERSONAL DATA?

In order to provide you with quality services, we transfer your Personal Data to the following partners:

• companies providing courier services which deliver goods to the postal addresses specified by you;
• post offices;
• product suppliers who deliver goods directly to you;
• other Vertera group companies, including WR International AG for the purposes of group-level analytics;
• government authorities and/or law enforcement officials if required for the above purposes, if required by law or required for the legal protection of own legitimate interests in accordance with the applicable legislation.

The data will be shared for the purposes set out above or in accordance with the specific legal obligations which we are governed by.

As a rule, the Company transfers your Personal Data to the countries which provide adequate protection for personal data subjects and based on your consent provided during registration on the Website. In the event that your Personal Data are transferred to the countries which do not provide adequate protection of the rights of personal data subjects, the Company is obliged to obtain your prior written consent to such transfer which meets the requirements of the legislation of the Russian Federation, or to transfer your Personal Data on other legal grounds provided for by the legislation of the Russian Federation.

When sharing your Personal Data with any third parties mentioned in the Policy, the Company ensures strict observance of the confidentiality of the transferred Personal Data, as well as other requirements of the legislation of the Russian Federation in the field of personal data protection. For this purpose the Company enters into the relevant agreements with third parties which meet the requirements of the legislation of the Russian Federation and, in particular, the Federal Law “On Personal Data”.

You can request the information about any third parties who have access to your Personal Data, as well as process your Personal Data on behalf of the Company, by contacting us at the address specified in the section “How to contact us”. We will endeavor to respond promptly to any of your requests. In any case, we will answer your request in compliance with the deadlines established by the legislation of the Russian Federation.

WHERE DO WE STORE YOUR PERSONAL DATA?

When collecting your Personal Data, the Company ensures recording, systematization, accumulation, storage, refinement (updating, change), retrieval of your Personal Data using the databases located on the territory of the Russian Federation.

WHAT COOKIES DO WE USE ON OUR WEBSITES?

Our Websites use Cookies (small files placed on the hard drive of website users) to distinguish you from other Clients and Independent Partners of Vertera Health and Beauty Laboratory. This helps us provide you with high-quality browsing experience on the Websites and allows us to improve the Websites. We use cookies to analyze the flow of information; to set the services, content and advertising; to measure effectiveness of advertising; and to promote trust and security.

We offer certain services which are only available when using the cookies. We generally use the following categories of the cookies:

1. Strictly necessary Cookies

Some Cookies are necessary for operation of the Website. For example, some Cookies allow us to identify registered Clients or Independent Partners of Vertera Beauty and Health Laboratory and to provide them with access to the Website. If the registered Client or Independent Partner of Vertera Beauty and Health Laboratory chooses to disable these cookies, the Client, Independent Partner of Vertera Beauty and Health Laboratory may not be able to access all content on the Websites.

2. Performance Cookies

Other Cookies may be used to analyze how Visitors, Clients, Independent Partners of Vertera Beauty and Health Laboratory use the Website, and to monitor performance of the Websites. This allows us to deliver high quality experience by customizing the offer and quickly identifying and resolving any issues which arise. For example, performance Cookies may be used to keep track of the pages which are most popular and to determine why certain pages receive error messages.

3. Functional Cookies

Functional Cookies are used to enable us to remember preferences of Visitors, Clients, Independent Partners of Vertera Beauty and Health Laboratory and to adapt the Website to provide enhanced features.

4. Google Analytics

We use Google Analytics to understand how visitors interact with our Websites. This means that when you visit our Website, your browser automatically sends certain information to Google. For example, this includes web-address of the page you are visiting and your IP address. Detailed information on how Google technology collects and processes the data can be found by clicking this link.

If you do not want Google Analytics to be used in your browser, you can install the Google Analytics browser add-on. You can find more information о about Google Analytics and Google privacy policy.

Visitors, Clients, Independent Partners of Vertera Beauty and Health Laboratory can always refuse cookies, provided that their browser allows it, although this may interfere with their use of the Websites. Detailed information on how to disable cookies can be found by clicking this link.

Detailed information on how the Company uses cookies can be found by clicking this link.

HOW LONG DO WE STORE YOUR PERSONAL DATA?

Personal data, processed by us for any purposes, must not be stored longer than necessary for those purposes. The Company will store your Personal Data during the term of your contractual relationships with the Company and, to the extent permitted, after termination of such relationships, as long as necessary to fulfill the purposes set out in this Policy.

Personal data is stored in a form enabling to determine the subject of personal data for no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by the federal law, agreement to which the subject of personal data is a party, beneficiary or surety. Processed personal data is subject to destruction or depersonalization upon achievement of the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by the federal law.

For example, the Company may store special information even after deletion of user account if this is necessary to comply with the legal requirements, resolve a dispute, prevent fraud or abuse, and enforce the provisions of this Privacy Policy. Personal data of visitors, who did not log in the account, are stored for 12 months for analysis of behavioral activity in an anonymized form. Personal Data of the Clients, who have not ordered products from the Company, will be fully deleted 12 months after approval of your request to delete an account in order to analyze Client activities and improve the Websites, our products.

For the Clients, who have ordered any Vertera products, our data deletion policy is as follows:

Order processing information will be stored by Vertera for 5 years or until completion of the tax audit, whichever occurs later. Other Personal Data will be deleted 12 months after approval of your account deletion.

For Independent Partners of the Vertera Beauty and Health Laboratory:
Order processing information will be stored by Vertera for 5 years or until completion of the tax audit, whichever occurs later. The Company may use your Personal Data when you work with the Company. When deciding how long to store personal information after you stop working with the Company, we take into account any current obligations we may have (for example, to store information for accounting purposes), or time duration allotted for initiation or defense of any legal claims.

We will stop processing your data for direct marketing, including profiling, if you object to such processing of your data or if you withdraw your consent to processing if your consent was obtained earlier.

YOUR RIGHTS

Here we provide the summary of the main rights you have in accordance with the Federal Law “On Personal Data”.

Clients, Independent Partners of the Vertera Beauty and Health Laboratory (Personal Data Subjects) have the right to:

• make decisions whether to provide their Personal Data to the Personal Data Processor;
• withdraw consent to processing of your Personal Data;
• enter, supplement or change the Personal Data processed;
• request exclusion of your Personal Data from publicly available sources of Personal Data;
• to receive the information regarding processing of their Personal Data, including information on:

- confirmation of the fact of Personal Data processing by the processor;

- legal grounds and purposes of Personal Data processing;

- purposes and methods used by the processor to process Personal Data;

- name and location of the processor, information about persons (except employees of the processor) who have access to the Personal Data or to whom Personal Data may be disclosed on the basis of agreement with the processor or on the basis of the Federal Law “On Personal Data”;

- processed Personal Data related to the relevant subject of Personal Data, the source of their receipt, unless the other procedure for provision of such data is stipulated in the Federal Law “On Personal Data”;

- terms of Personal Data processing, including the terms of their storage;

- procedure for exercise by the subject of Personal Data of the rights provided for by the Federal Law “On Personal Data”;

- information about the performed or proposed cross-border data transfer;

- name or surname, first name, patronymic and address of the person who processes Personal Data on behalf of the processor if processing is or will be assigned to such person;

- other information provided for by the Federal Law “On Personal Data” or other federal laws of the Russian Federation.

The right of the subject of Personal Data to access his/her Personal Data may be restricted in accordance with the federal laws of the Russian Federation.

You may exercise any of your rights in relation to your Personal Data by contacting our customer service.

LINKS TO OTHER WEBSITES

The Websites may contain links to websites operated by third parties whose information and privacy practices differ from ours. We are not liable for the information or privacy practices of such third parties. We recommend that you read the privacy statements of all third party websites before using such them or providing any personal data or any other information on or through such websites.

UPDATES OF PRIVACY POLICY

This Privacy Policy may be revised, changed, updated and / or supplemented at any time without notice and at the sole discretion of the Company. When doing so, we will post a notice on the home page of our Websites and change the update date at the top of that page. We encourage the Clients, Independent Partners of Vertera Health and Beauty Laboratory to regularly check this page for changes in order to keep track of how we help to protect the Personal Data we collect. Each Client, Independent Partner of Vertera Health and Beauty Laboratory must acknowledge and agree that he/she is personally liable for periodical reviewing of this Privacy Policy and reviewing the changes.

By using our Websites, the Client, Independent Partner of Vertera Health and Beauty Laboratory, automatically confirms acceptance of this Privacy Policy. If the Client, Independent Partner of Vertera Health and Beauty Laboratory, does not agree with this Privacy Policy, we would require not using our Websites. If the Client, Independent Partner of Vertera Health and Beauty Laboratory, continues to use the Websites after publication of changes to this Privacy Policy, this will be considered as acceptance of these changes.

HOW TO CONTACT US

If you have any comments or questions about our Privacy Policy, if you want to update the information we have about you, or if you want to exercise your rights, you can contact us at support@vertera.org

Vertera Beauty and Health Laboratory Limited Liability Company

Address: 170006, Russia, Tver Oblast, Tver, Sofya Perovskaya Street, building 6, room XIII

Telephone: 7 (920) 191-61-87, 8 (800) 707-25-39