PRIVACY POLICY

Current version of the Twenty-fifth of May Two Thousand Eighteen

This Privacy Policy (hereinafter referred to as the Policy) constitutes an agreement between You (hereinafter referred to as the User) and « GLOBAL CLARITY HOLDINGS LLP » (hereinafter referred to as the Company) concerning the Company's information policy and the selection of objectives, conditions and ways to use Your information

WHEREAS

GLOBAL CLARITY HOLDINGS LLP has responsible attitude to the respect of each User’s right to the confidentiality of his personal data and takes all measures, depending on the Company, to protect any information that You provide. Confidentiality of the information when using OVOLIVE Application and its Services is one of our top priorities. User’s information and personal data of the User are stored on a "throughout the lifetime" basis - throughout the entire period of the Application use. All Your personal information received by the system is contained in your account and You have permanent access to Your data in your personal account (section "Account Settings"), where You can view, correct or delete your personal data. Also, modification or deletion of data is possible on the User’s (controller’s) personal request. You also have other rights detailed in this policy. This document contains explanations of the Company's information policy and the selection of objectives, conditions and ways to use Your information in the Application. The latest version of this Policy may be found any time at the following address: https://ovolive.com/privacy-policy. If you have any questions regarding this Policy, contact us with the feedback form or write to the following address: https://ovolive.com/contact-us.

1. TERMS AND DEFINITIONS

1.1. For the purpose of this Policy, the expressions below shall be understood as follows: 1.1.1. Company means «GLOBAL CLARITY HOLDINGS LLP», registration number 01-09-324793, location 21 Botanic Avenue, Suite 15, Belfast, BT7 1JJ, UK. 1.1.2. Content, Materials mean information materials in any form (text, audio, video, graphic files, photos, images and any other files) posted, sent, published, stored, distributed, transmitted by the User in any form (for example, in the form of a text message, an attached file of any format, links to Internet publications etc.) within or in connection with the use of the Application and its Services. 1.1.3. Third party Content means third party content which may be included to the Application. 1.1.4. Materials containing personal information mean information materials containing Personal data in any form. 1.1.5. Processing of personal information means any operation or set of operations with respect to the User's personal data. 1.1.6. Personal information means any information relating to identified and to be identified individual (data subject), under which he can be identified directly or indirectly. 1.1.7. Policy means this Privacy policy. Current version of the Policy is always on the Internet page https://ovolive.com/privacy-policy. 1.1.8. User agreement, Agreement means User agreement between the Company and the User, as amended and modified, published in the Appendix. Current version of the Policy is always on the Internet page https://ovolive.com/license-agreement. 1.1.9. Application is a collective term used for the purposes of the User Agreement and Privacy Policy as a set of OVOLIVE electronic information systems currently existing or to be created in the future, as a website, OVOLIVE mobile application, and any other related media- platforms or media channels. 1.1.10. Services mean free and paid electronic services accessed through the Application, including functional possibilities, services, instruments, means of communication, search, posting, storage and transfer of all kinds of information and materials (content), personalization of content, virtual purchases, including electronic bonuses - coins of the Application, available to the User. 1.1.11. User Account means the User's Internet space in the Application, protected by a password and including all User's personal data transmitted by the latter during registration in the Application and its use, and allowing each User to be identified (authenticated) by unique login. 1.1.12. Cookie file means a small piece of text information transmitted to the Company from a web-site visited by the User, including without limitation: type of browser and operating system, Internet page from which the User switched to the current page, page path on this site, Internet provider domain. 1.2. All other terms and definitions found in the text of the Policy are interpreted by the Parties in accordance with the User Agreement and applicable law.

2. USER’S CONSENT

2.1. If You have provided Your consent with the Policy’s provisions and use the Application, You give Your consent to collection and processing of Your personal data in accordance with this Privacy Policy, which includes the procedure of cookies files use by the Company.

3. PERSONAL INFORMATION OF USERS RECEIVED AND PROCESSED BY THE COMPANY

3.1. This Policy is applicable only to OVOLIVE Application and its Services. 3.2. Personal information of Users received and processed by the Company is, generally, e-mail, gender, age, country, region and city of residence, unless other additional information has been provided by the User. 3.3. Company / Application does not collect or store information about Users from other sites, including social networks 3.4. Under no circumstances, Company/Application does not collect and store the information about underage persons, as the Service is not intended to be used by such persons, and any information about health, race, sexual orientation, religion and political views (sensitive personal data). 3.5. In any case and under no circumstances, Company does not receive and does not store payment details and data of the User's bank card. Payment data of the User are always encrypted by payment service having PCI DSS safety certificate. 3.6. Company believes that the User provides reliable and sufficient personal information required to use the Application, and keeps this information up-to-date. Personal data, which are inaccurate, will be immediately deleted or corrected (on the User’s request). 3.7. Pursuant to the general rule, the Company does not verify the authenticity of personal information provided by Users and does not exercise control over their legal capacity, however the Company has the right to do so in accordance with the User Agreement. Personal data, which are inaccurate, will be immediately deleted or corrected (on the User’s request). 3.8. The consequences of unreliable information provision by the User are determined in the User Agreement. 3.9. Obligatory information required to provide Services (provision of services) in the Application is directly defined in the Application as such, other information is provided by the User solely at his risk and its discretion. 3.10. The user will be offered to include the information about himself in the account, for example, education, photos, etc. The User should not publish, post, specify in his or her account personal data that is not intended for unlimited number of persons other Users.

4. MODIFICATIONS TO PERSONAL INFORMATION AND OTHER RIGHTS OF USER

4.1. User's unconditional rights are also: - the right to know who and why process their personal data - these data are provided in this Policy; - the right to access personal information, the right to personal data correction, the right to clear data, or the right to be “forgotten” - all user's personal information received by the system is stored in his account and he has constant access to his or her personal data in personal account, where the User can view, correct or delete personal data; - the right to restrict or block data processing; - the right to transfer personal data from one Service to another; - the right to object to data processing; - the right to request sending of personal data to yourself or third party - the right to personally influence the automated collection and profiling systems. 4.2. User has the right to delete personal information provided by him within the limits of his particular account, using the function delete an account. 4.3. User has the right to demand to delete, correct or verify personal data, exercise other rights regarding protection of personal data by sending e-mail to the Company at: DPO@ovolive.com in any form convenient to the User.

5. COOKIES FILES AND GOOGLE ANALYTICS

5.1. Use of cookies files 5.1.1. For safe login of the Users to the Application, the Company uses monitoring technology - cookies (httpOnly, secure flags) to collect non-personal information, including without limitation: type of browser and operating system, Internet page from which the User switched to the current page, page path on this site, Internet provider domain. 5.1.2. Company may use cookie for advertising, analytics and functioning of the project. User confirms his consent to the use of cookies for legal purposes of the Company. 5.1.3. Cookies files are used by the Company solely for security purposes and the need determines by them for the Company to understand the process how Users use the Application. 5.1.4. Company stores the information received with the help of cookies for a short period of time in a format that does not allow to identify the person. The cookies files stored on the User's devices include the User’s IP address, and not his identification personal data. 5.1.5. Upon the end of the User's session with the Application, all information contained in the cookies is no longer available to the Company. This information, received from cookies, will not be transferred by the Company to third parties. 5.2. Recommendations to the User about cookies 5.2.1. The User shall make sure on his own that the settings of the device and its browser are consistent with the User's desire to accept cookies or not. The User can configure the browser so that the latter warns the User before accepting cookies or rejects them immediately. In the latter case, the User may not be able to fully use all functions of the Application. It should be kept in mind that when using other devices, the User will need to make sure that the cookies settings in the browser that the User will use correspond to his desires. 5.3. Use of Google Analytics 5.3.1. Application in cookies will use Google Analytics to collect and analyze data how visitors use the Application (web-site), number of visitors on the web-site, wherefrom these visitors accessed the web-site and what pages they visited. This information includes your IP address, which is transmitted to Google's servers and stored there. 5.3.2. Google generates reports on the web-site operation and provides other services related to the Internet use. Google may also transmit this information to third parties, if required by law, or when these persons process information on behalf of Google. Google does not link your IP address with other information stored by Google. 5.4. Recommendations to the user about Google Analytics 5.4.1. You can disable Google Analytics by following this link: https://tools.google.com/dlpage/gaoptout 5.4.2. For more information about Google's privacy policy, please visit http://www.google.com/intl/en/policies/.

6. PURPOSES FOR THE PROCESSING OF THE USER’S PERSONAL INFORMATION

6.1. Personal information of the Users is processed solely to achieve the purposes for which it was collected so that to identify the data subjects for a period not exceeding processing purposes. 6.2. The User's personal information is processed by the Company for the following purposes: 6.2.1. to provide the User with the services of the Application; 6.2.2. to ensure protection and improvement of the Application, comfortable atmosphere for communication of the Users in the Application; 6.2.3. for communication of the Company with the User, including for sending notices, requests and information regarding the use of the Application, providing of services, informing the User about new services, promotions of the Company or advertising offers of third parties cooperating with the Company; 6.2.4. to process requests and applications from the User; 6.2.5. to protect the interests of the Company and the Users of the Application; 6.2.6. for other legitimate purposes aimed at improvement and security provision of the Application. 6.3. The Company collects and stores only those personal data that are specified in this Policy and which are objectively required for the purposes specified above.

7. CONDITIONS OF PROCESSING USER’S PERSONAL INFORMATION AND ITS TRANSFER TO THIRD PARTIES

7.1. The Company’s policy regarding personal information processing and its transfer to third parties 7.1.1. Company will never transfer the User’s personal data to third parties who intend to use them for direct marketing purposes and also to third parties from the jurisdictions having insufficient legislative base, corporate rules or their alternatives for personal data protection. 7.1.2. Company has the right to transfer the User's personal information to third parties in the following cases: 7.1.2.1. the transfer takes place as part of sale or other transfer of business (in whole or in part) by the Company, while all obligations to comply with the terms of this Policy are transferred to buyer in relation to the personal information it has received; 7.1.2.2. with the purpose to ensure possibility of protecting rights and legitimate interests of the Company or third parties in exceptional cases when the User grossly violates the terms of the User Agreement; 7.1.2.3. Company is compelled to disclose information, if required by law, for example, in connection with direct judicial order or upon justified and lawful request of law enforcement agencies. 7.1.3. Application may contain links to other web-sites, where the practice of processing information may differ from the procedure defined by this Policy. 7.1.4. This Privacy Policy is applied to the Application, However, this Policy is not applicable to third party web-sites and other web-resources where the Application is installed. Company does not control and does not bear responsibility for third-party sites to which the User may access by clicking the links available in the Application where other personal information may be collected or requested from the User and other actions may be taken to process it. In addition, the Company can not guarantee the confidentiality of personal information that the User transfers to the Internet or that can be fixed at the time of transfer by others, including contractors providing services to the Company. 7.2. Advertising materials 7.2.1. Company also wants to keep in touch with you to inform you about our promotions and offers, as well as partners’ offers. If you agree to this, we will use your email address to send you such information. 7.2.2. You can change your decision any time in the Application Settings in the Notifications section. 7.3. Recommendations to the User concerning the content of third parties 7.3.1. When accessing other websites clicking the links posted in the Application, the operators of such web-sites may collect personal data of the User. The User should make sure that he agrees with the privacy policies of third-party websites before providing any personal information.

8. TERM FOR INFORMATION STORAGE

8.1. Personal data are processed using automated tools during the time required to achieve the goals for which they were collected. 8.2. Company undertakes to delete the User's personal data at his first request expressed in an arbitrary form and sent to: DPO@ovolive.com. User may also delete by himself personal information provided within his particular account, using account delete function. 8.3. The deleted data of the User is not stored by the Company.

9. PLACE FOR INFORMATION STORAGE

Ovolive will not disclose, sell or transfer any of your Registration Data or Personal information. This information is stored in third-party data centers on servers owned by GLOBAL CLARITY HOLDINGS LLP. This network of hardware is located in Europe, as well as in the United States to provide quick access to the Application. We guarantee that the data will be properly protected and that all necessary measures are taken to prevent unauthorized access to the User's personal data. In order to receive an answer to all the questions that have arisen about our protection measures and how we store information, please send us an e-mail to DPO@ovolive.com.

10. MEASURES UNDERTAKEN TO PROTECT PERSONAL INFORMATION

10.1. Company accepts all organizational and technical measures depending on it to protect users' personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions by third parties. Company collects and stores only personal data that are specified in this Policy and which are objectively required for the purposes specified therein, exclusively on the Company’s servers.

11. AMENDMENT TO PRIVACY POLICY

11.1. Company has the right to amend this Privacy Policy. 11.2. When making modifications and/or amendments to the Policy, current version shall specify the date of the last update. User shall receive a notice and request for consent with new version of the Policy. 11.3. The new version of the Policy shall come into force from its posting, unless otherwise provided by the new version of the Policy. Current version is always available on the page at the address specified in clause 1.1.7. of this Policy.

12. FINAL PROVISIONS

12.1. The policy shall be valid for an unlimited period of time throughout the entire period of the Application use by the User. Therewith, the provisions of the Policy, which, according to their terms, shall be in effect even upon expiration of the Policy, will remain in force upon expiration of the Policy. 12.2. In cases not specified in the Policy, the relationship between the Company and the User with respect to confidentiality is governed by applicable law. 12.3. The legislation defined in the User Agreement as applicable substantive law is subject to application to this Policy and the relationship between the User and the Company arising in connection with the application of the Privacy Policy. 12.4. This document, subject to the reservations contained herein, is an exhaustive agreement between the User and the Company, which determines the Company's information policy with respect to confidentiality and the selection of objectives, conditions and ways to use User's information in the Application. 12.5. In case of disagreements, current text of the Policy, which User has been familiarized with and confirmed his consent, and posted in the Application will prevail over any other text of the Policy. 12.6. . If any provision of the Policy becomes invalid during its period of validity as a result of the provisions of the applicable law, modifications to the legislation, remaining provisions of the Policy are binding on the Parties during the entire period of validity of the Policy. 12.7. The User hereby confirms that he has read and accepts the terms of this Privacy Policy in full and without further reservations.

COMPANY’S DETAILS AND COMMUNICATION FOR PERSONAL DATA PROTECTION ISSUES

The Application is managed by the Company: Name: GLOBAL CLARITY HOLDINGS LLP. Address: 21 Botanic Avenue, Suite 15, Belfast, BT7 1JJ, UK. Registration code: 01-09-324793. You may contact for personal data protection issues at DPO@ovolive.com or by sending a letter by post.