AGHANIM

PRIVACY NOTICE

(Last updated November 12, 2024)

1. INTRODUCTION

Who are we?

We are AGHANIM INC., a company with a registered address at 254 Chapman Rd Ste 208, Newark, Delaware 19702-5422, United States, with EIN 93-2059669 (“Aghanim”, “we” or “us”), and we are a mobile game commerce company.

This Privacy Notice is governed by and part of our General Service Terms and describes how we treat information collected through the Environment and our website.

“Personal data” generally means information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual consumer or household. References to “personal data” in this notice have the meaning given that or a similar term in applicable consumer privacy laws. We update this notice from time to time, so you should check back in on a regular basis.

What’s this notice about?

This notice explains how we process personal data, as a controller, in relation to the Aghanim Environment (including all related technologies, applications, products, software, services, and other materials under the “Aghanim” brand) (“Environment”), as made available by Aghanim.

Here is a quick summary of our privacy practices:

• Aghanim only uses your personal data to provide you with services and features on the Environment and to communicate with you according to your stated communication preferences.
• Where we decide the means or purpose of processing your personal data, we are the “controller."
• We will never sell your personal data to third parties.
• Developers may use your personal data to market to you or send you other communications, but Aghanim will not share your personal data with third parties for cross-contextual behavioral advertising.
• Developers may use the Environment to communicate with End Users, such as sharing information about their games and Game Hub. End Users can opt out of these messages anytime.
• Aghanim is the merchant of record for payments made on the Environment. We are not a payment processor or financial institution.

Third-Party Services

We may provide access to third-party online services through links or integrations. These services can include third-party platforms, APIs, login options, and other third-party service integrations. These third-party services operate independently of this Privacy Policy, and we do not control the type of data they collect or how it is processed. Your use of these Third-Party Services is governed by the terms of service agreements of the respective providers, and you are solely responsible for compliance with those terms. For example, if you choose to watch an embedded YouTube video within our Environment—a feature provided through our use of YouTube API services—you are thereby agreeing to Google’s Privacy Policy, available at https://policies.google.com/privacy.

Whose personal data is processed?

In relation to the Environment, we will process personal data relating to:

• individuals who use the Environment in the capacity of an end user (“End User”); and
• both: (i) individual sole trader developers on the Environment, and staff members who are employed by developers on the Environment and who are accessing the Environment on behalf of that developer; and (ii) individual sole trader developers, and staff members who are employed by developers, who have created an account on the Environment but have not proceeded with entering into an agreement with Aghanim in order to use the Environment (“Developer”).

After a Developer has created an account on the Environment (“Dashboard”), they can use the Dashboard to:

• Create their own website which can be used by Aghanim to sell content, developed by Developers in connection with the Developer’s games, to End Users (“Game Hub”).
• Make changes to the Game Hub (including to the content featured on the Game Hub).
• View sales performance data relating to the content featured on the Game Hub.
• Communicate with End Users via email, text messages, or in-game push notifications.

On our website, we will process personal data as follows:

• Of website visitors and other users, including Developers and End Users, to share information about the Environment and to respond to inquiries and complaints.
• We also use this information to provide customer service and to test and improve the Environment.

In this notice, “you” refers to any individuals whose personal data we process in relation to the Environment or website.

How do you contact us?

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: privacy@aghanim.com. Alternatively, you can submit your request through our chatbot located at https://support.aghanim.com/.

If we are unable to resolve your issue to your satisfaction, please note that you may have the right to lodge a complaint with a data protection authority or supervisory body in your jurisdiction. For individuals in the European Union, you can find your local data protection authority through the European Data Protection Board’s (EDPB) list of supervisory authorities at the EDPB website. For individuals outside the European Union, we recommend contacting or reviewing the website of your local data protection or consumer protection agency for more information on your rights and how to submit a complaint.

2. CHILDREN’S PRIVACY

Minimum Age

To set up an End User Account, you must be at least 13 years old, or the minimum age required by the laws of your jurisdiction. Aghanim will not deliberately gather personal data from anyone who is younger than the minimum required age. Where required by applicable law, Aghanim will ask for parent or guardian permission before permitting an End User Account for a child. Aghanim further recommends that parents and guardians monitor their child’s activities online and guide their children on the importance of not disclosing personal data online.

Parental rights

As a parent, you have the right to request a review of your child's personal data collected by us, request deletion, and refuse further collection or use of your child's information. To exercise your rights, please contact us at: privacy@aghanim.com. Alternatively, you can submit your request through our chatbot located at https://support.aghanim.com/.

3. YOUR PRIVACY RIGHTS

Your Rights

Depending on where you live, you may have certain rights over your personal data. This section provides a courtesy notice of rights that may be available to you.

Residents of California and other certain states in the United States may have some or all of the rights described below. Depending on where you live, you may have the right to:

• Know how we process your personal data, as provided in this notice.
• Reasonably expectations that we will collect, use, and disclose your personal data responsibility and not for any other purpose than stated at the time of collected or described in this notice.
• Ask us to correct, delete, or send you a copy of your personal data.
• Receive certain, specific information about how we collect and process your personal data.
• Ask us to make your personal data available to transmit to you or someone else.
• Opt-out of the sale or sharing of your personal data to third parties, in some cases.
• Limit our use of your sensitive personal data so that we do not use or disclose it to others to infer characteristics about you.
• Restrict our processing, in certain situations.
• Opt-out of profiling and automated decision-making.
• Not experience discrimination in your receipt of services, pricing, quality, or employment because you exercised a privacy right.
• Control your health data. Aghanim does not collect health data, however, some states entitle consumers to receive certain details about health data collected about them (e.g., confirmation of health data processing, third parties that have received health data, withdrawal of consent related to use of health data, and deletion of health data).

Residents of EMEA may have some or all of the following rights, although these rights may be limited in some circumstances:

• Ask us to send a copy of your personal data to you or someone else.
• Ask us to restrict, stop processing, or delete your personal data.
• Object to our processing of your personal data.
• Object to use of your personal data for direct marketing purposes.
• Ask us to correct inaccuracies in your personal data.

If you do not reside in the United States or EMEA, you may have some or all of the above rights over your personal data. See Section 9 for Supplemental Notices of Privacy Rights, and please contact privacy@aghanim.com or chat with us at https://support.aghanim.com/ to learn more.

PLEASE SEE OUR SUPPLEMENTAL NOTICES IN SECTION 9.

Exercising Your Rights

The rules around how long we keep your information, as set out in Section 4 (Your personal data and how we use it) below, may be subject to your exercise of some of these rights.

If we rely on consent to process personal data, or send direct marketing, you can withdraw consent by email to the email address below.

Please note that consumer privacy laws sometimes do not apply to information that is publicly available, aggregated (meaning data about a group or category of services or users from which individual identities and other personal data has been removed), or deidentified so that it cannot be easily linked back to the individual.

To exercise your rights, please contact us at: privacy@aghanim.com. Alternatively, you can submit your request through our chatbot located at https://support.aghanim.com/

4. YOUR PERSONAL DATA AND HOW WE USE IT

Aghanim only collects personal data as is adequate and relevant to the specific, express purposes described in this notice or as reasonably necessary and proportionate to provide the Environment or our website. Our legal basis for processing may be one or more of the following:

• Your consent, such as when you voluntarily give us your personal data or if we ask for your consent to use it.
• Our contract with you, for example our End User Service Terms if you are an End User, the Developer Terms of Service if you are a Developer, or our General Service Terms for your use of the website.
• A legitimate interest, meaning a commercial or business interest that is important to us or another company, and which we’ve balanced against your privacy rights.
• Our legal obligations, such as our legal and regulatory obligations to respond to court orders and cooperate with law enforcement.

How we collect and use your personal data and our legal basis for processing depends on how you use the Environment or website and how you interact with us.

DEVELOPERS

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SERVICES

PURPOSE – We process certain information relating to Developers to provide them with the Environment. This includes processing certain information relating to Developers in order to:

• Undertake “know your business” checks on Developers.
• Register Developers with a Dashboard.
• Enable Developers to create a Game Hub.
• Authenticate Developers’ login attempts to their Dashboard and the Game Hub.
• Enable Developers to use the functionalities on the Dashboard.
• Process payments via the Environment.
• Send Developers email notifications in relation to the Environment.

CATEGORIES OF PERSONAL DATA – We collect the following information directly from Developers when they sign-up to create their Dashboard: name, email address, phone number, company's website, current business priorities, confirmation on how the Developer heard about the Environment.

We collect the following information relating to each Developer’s company, when entering into an agreement with them: company name, business address and registration number and bank details.

And, when Developers use the Environment, we will collect correspondence which we send to, and receive from, Developers.

HOW WE USE IT – We process this personal data on the basis of our legitimate interests, being to: (i) promote the success of our business (including the Environment and our related services); and (ii) ensure that Developers and End Users receive a good service when using the Environment. Such interests are not overridden by Developers’ interests or fundamental rights and freedoms.

RECIPIENTS – We share this information with:

• Okta, Inc., to use their authentication and authorisation Environment “Auth0”.
• Twilio Inc, to use their programmable communications tools for making and receiving phone calls, sending and receiving text messages, and performing other communication functions using its web service APIs.
• Salesforce, Inc., to help us to keep track of our interactions with Developers and sales data.
• Our “know your business” provider for the purpose of undertaking “know your business” checks on Developers.

HOW LONG DO WE KEEP THIS INFORMATION? – We retain this information until: (i) the Developer closes their Dashboard; or (ii) after the final payment from Aghanim to the Developer is processed (in relation to any information required to process payments from Aghanim to the Developer in relation to the Environment after the Developer closes their Dashboard).

MARKETING

PURPOSE – We process certain information relating to Developers to send them emails to keep them informed about our news, updates, latest projects, goods, services, promotional offers, and partnerships which may interest them. Where we rely upon their consent to do this, they can withdraw their consent at any time by clicking the “unsubscribe” link at the bottom of any of our emails.

CATEGORIES OF PERSONAL DATA – We collect Developers’ names and email addresses directly from Developers when they sign-up to create their Dashboard.

HOW WE USE IT – We generally process this personal data where we have a Developer’s consent to do so. In other cases, for example if a Developer chooses not to opt-out of marketing communications when purchasing a product or service from us, we process this personal data on the basis of our legitimate interests, being to promote the success of our business, our Environment and related services.

RECIPIENTS – We share this information with the Rocket Science Group in order to use their marketing automation and email marketing Environment “Mailchimp” for the purpose of sending marketing communications.

HOW LONG DO WE KEEP THIS INFORMATION? – We retain this information until the Developer withdraws their consent to send them this information.

END USERS

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SERVICES

PURPOSE – We process certain information relating to End Users to provide them with the Environment. This includes processing certain information relating to End Users in order to:

• Register End Users on the Environment with an account (“End User Account”).
• Send payment receipts to End Users.
• Send OTP codes to End Users in order to authorise any payments made via the payment processing interface on each Game Hub.
• Create an account, via the Environment, to manage previous payments and payment methods (“Payment Account”).
• Process payments via the Environment, and calculate taxes relating to such payments.

CATEGORIES OF PERSONAL DATA – We collect the following information directly from End Users when they sign-up to create an End User Account, or enter information into Payment Account: name, in-game user ID, email address, phone number, billing address, the last four digits of a payment card, BIN number and information relating to transactions made via the Payment Account.

HOW WE USE IT – We process this personal data on the basis of our legitimate interests, being to: (i) promote the success of our business (including the Environment and our related services); and (ii) ensure that Developers and End Users receive a good service when using the Environment. Such interests are not overridden by End Users’ interests or fundamental rights and freedoms..

RECIPIENTS – We share this information with:

• Twilio Inc, in order to use their programmable communications tools for making and receiving phone calls, sending and receiving text messages and performing other communication functions using its web service APIs.
• Avalara, Inc, in order to use their software to calculate any tax payable on transactions made via the Environment.
• Sift Science, Inc, in order to use their software to evaluate risks associated with transactions made via the Environment.
• Our third-party payment service providers (including Text Inc.).
• Pursuant to the End User's engagement with specific Game Hubs created via Environment, we may disclose certain personal data of the End Users to the respective Developers, for facilitating an enhanced gaming experience provided by the developers.

HOW LONG DO WE KEEP THIS INFORMATION? – We retain this information until 18 months following the date on which the End User closes their End User Account. If you withdraw your consent on which a processing of your Personal Data or of the Personal Data of your child is based, we will delete your Personal Data or respectively the Personal Data of your child.

MARKETING

PURPOSE – We process certain information relating to End Users to send them marketing communications via the Environment, email and SMS to keep them informed about news, updates, latest projects, goods, services, promotional offers and partnerships, which may interest them, in relation to Developers, Aghanim and the Environment. Where we rely upon their consent to do this, they can withdraw their consent at any time by clicking the “unsubscribe” link at the bottom of any of our emails.

CATEGORIES OF PERSONAL DATA – We collect names and email addresses from End Users when End Users sign-up to marketing communications on the Environment or on a Game Hub.

HOW WE USE IT – We generally process this personal data where we have an End User’s consent to do so. In other cases, for example if an End User chooses not to opt-out of marketing communications when purchasing products or services from us, we process this personal data on the basis of our legitimate interests, being to promote the success of our business, our Environment and related services.

RECIPIENTS – We share this information with The Rocket Science Group in order to use their marketing automation and email marketing Environment “Mailchimp” for the purpose of sending marketing communications.

HOW LONG DO WE KEEP THIS INFORMATION? – We retain this information until the End User withdraws their consent to send them this information.

MARKETING MESSAGES FROM DEVELOPERS – Developers have the option to use the Environment to communicate with End Users about their Game Hub, including marketing emails or other messages. The Developer sending the message, and not Aghanim, is responsible for the contents of the message and for ensuring these messages are only sent to End Users in a manner that complies with the End User’s privacy choices. If you do not wish to receive messages from a Developer, you can opt-out by replying to the Developer or by contacting privacy@aghanim.com.

ADVERTISEMENTS

PURPOSE – We use third-party advertising Environments, such as Meta and Google, to send targeted messages to End Users, based on their behaviour and browsing pattern, to increase the efficiency of our advertising campaigns.

CATEGORIES OF PERSONAL DATA – We may collect the following information from End Users using the cookies described in Section 8 (Cookies, analytics and similar technologies) below: device information (including IP address) and browsing information (including clicks and other interactions with advertising media).

HOW WE USE IT – We process this personal data where we have an End User’s consent to do so.

RECIPIENTS – We share your personal data with third-party advertising Environments, such as Meta and Google, who will attempt to match your profile in their database to determine the optimal time and place (the page you are browsing) to show you an advertisement from Aghanim. We also use third party solutions such as Google Analytics to help us to target our campaigns and messages for End Users, and analyse necessary information to understand the impact of our campaigns.

HOW LONG DO WE KEEP THIS INFORMATION? – We retain this information for as long as necessary to fulfil the purposes outlined above.

WEBSITE VISITORS AND OTHER USERS

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ENQUIRIES

PURPOSE – We process certain information about visitors to our website and other users, including Developers and End Users, to: (i) review and respond to their enquiries, complaints or questions about the Environment; (ii) provide responsive customer care services; and (iii) improve, test and monitor the quality and delivery of the Environment.

CATEGORIES OF PERSONAL DATA – We collect the following information directly from Developers and End Users when they submit any enquiries, complaints or questions: name, contact information (such as email address or telephone number) and any other information that Developers and End Users submit as part of their enquiries, complaints or questions.

HOW WE USE IT – We process this personal data on the basis of our legitimate interests, being to: (i) understand how Developers and End Users use our Environment; (ii) promote the success of our business; and (iii) provide responsive customer care services. Such interests are not overridden by Developers’ and End Users’ interests or fundamental rights and freedoms.

A NOTICE ABOUT OUR CHATBOT – You can use our chatbot located at https://support.aghanim.com/ to ask questions about the Environment, receive customer service, submit a privacy request, or submit a complaint. Please be aware that Aghanim will collect and record any personal data you choose to include in your conversations using the chatbot. Additionally, the chatbot is made possible through our relationship with Text.Inc., a third-party service provider, and Text, Inc. will have real-time, simultaneous access to your chats on the chatbot. BY USING THE CHATBOT, YOU CONSENT TO TEXT, INC. ACCESSING YOUR CHATS. IF YOU DO NOT CONSENT, YOU SHOULD NOT INITIATE OR PARTICIPATE IN A CONVERSATION USING THE CHATBOT.

RECIPIENTS – We share this information with:

• LiveChat Software S.A., in order to use their online customer service software.
• We, Text, Inc., in order to use their IT service desk software.
• Apple Inc., in order to use their Apple Messages for Business service.
• Meta Environments, Inc., in order to use their Messenger from Meta service.

HOW LONG DO WE KEEP THIS INFORMATION? – We retain this information until the End User closes their End User Account, or the Developer closes their Dashboard.

ANALYTICS

PURPOSE – We process certain information relating to the device on which Developers and End Users are accessing the Environment to: (i) identify Developers and End Users; (ii) understand how Developers and End Users use our Environment; (iii) improve, test and monitor the quality and delivery of the Environment; (iv) identify and correct any problems on the Environment; and (v) perform essential business operations.

CATEGORIES OF PERSONAL DATA – We may collect the following information directly from Developers and End Users when they access our Environment: location information, identity information, payment information, transaction information, mobile device information and browsing information.

HOW WE USE IT – We process this personal data on the basis of our legitimate interests, being to: (i) promote the success of our business, our Environment and related services; (ii) further our commercial interests; and (iii) understand how Developers and End Users use our Environment. Such interests are not overridden by Developers’ and End Users’ interests or fundamental rights and freedoms.

RECIPIENTS – We share this information with:

• Google LLC, in order to use their web analytics services “Google Analytics”.
• Cloudflare, Inc., in order to detect bots and to allow the web application firewall to block malicious traffic.

HOW LONG DO WE KEEP THIS INFORMATION? – We retain analytics data for as long as necessary to fulfil the purposes outlined above.

5. PERSONAL DATA STORAGE AND DISCLOSURE

Storage & Transfers

Aghanim provides the Environment and website from our offices in the United States. We store data related to our business on servers located in the United States and Europe. For additional details, please contact us at: privacy@aghanim.com or submit your request through our chatbot located at https://support.aghanim.com/.

Disclosure

Aghanim discloses personal data to certain third parties to achieve our business purposes. We will only disclose personal data as described in this section, with your permission, or as required by law. In the preceding 12 months, we have disclosed personal data from all categories that we collect. We may disclose your personal data:

• Where required by law, government, competent authorities, or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
• With suppliers and subcontractors, as necessary for the purposes set out in this notice.
• With other members of our corporate group and our international network of partners.
• If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.

6. CROSS-BORDER DATA TRANSFERS

Where is my personal data processed?

We are based in the United States, regularly collaborate with an international network of partners and may from time-to-time use subcontractors based in other countries.

Will my personal data be transferred to other countries?

Yes, sometimes your personal data will go to other countries as part of the uses described in this notice. Aghanim is owned and operated in the United States. If you access the Environment or website from outside the United States, the personal data we collect about you may be transferred outside of your country of origin to our servers in the United States or other countries. Some countries’ laws are more restrictive than in the United States, or result in governments, courts, law enforcement, or regulatory agencies having access to or obtaining disclosure of your personal data pursuant to the laws of the applicable foreign jurisdiction. Aghanim is committed to transferring personal data via an adequacy decision, standard contractual clauses, or other lawful data transfer mechanism. By allowing us to collect personal data about you, you consent to the transfer and processing of your personal data as described in this paragraph. Please also note that our games may not be available to everyone in every country.

7. PERSONAL DATA SECURITY

Data Security Safeguards

Aghanim implements and maintains appropriate technical, organizational, and physical measures in place to help protect your information from unauthorized access, processing, or disclosure. We maintain internal policies to govern the collection, processing, access, and handling of data. We use technical safeguards to protect information online and stored on our systems. Please note, however, that no transmission of data over the Internet is 100% secure, and we cannot guarantee that unauthorized third parties will not defeat our security measures or use your Personal Information for improper purposes.

Securing Your Account

When you create an Account on the Environment, you will have a login and password. Please choose a robust password, keep your credentials secret, and sign out of your Account after each session to protect against unauthorized access to your Account. We are not responsible for any lost, stolen, or compromised login credentials or for any activity on your account via unauthorized activity.

Social Networks

If you access the Environment or website from a social network Environment, we may receive your personal data from the social network, as governed by the terms of use and privacy policy of that social network. We may retain this personal data with the information we collect from you by other means. Your use of social networks via a link from our Environment or website is entirely optional and subject to the privacy policy and terms of use of the social network you choose to use.

8. COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES

Aghanim uses cookies and similar technologies (i.e. web beacons, pixels, ad tags and device identifiers) to recognize you and to customize your online experience. To learn more about cookies and the other tracking technologies we may utilize, please refer to our Cookie Policy, which includes a comprehensive overview of cookies and provides further details about how we use cookies and how to control our use of cookies.

Most browsers allow control over cookies, for more information: Google Chrome | Microsoft Edge | Mozilla Firefox | Microsoft Internet Explorer | Opera | Apple Safari.

9. SUPPLEMENTAL NOTICES OF PRIVACY RIGHTS

Canada

Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”) gives Canadian consumers specific rights regarding personal data offering details on an identifiable person without the inclusion of name, title, telephone number and business address of an employee of a business or organization. These consumers have a (i) right to know why their personal data is collected, used, and distributed; (ii) right to expect their personal data to be collected, used, and disclosed responsibly and not for other purposes; (iii) right to personal data accuracy; and (iv) right to access their personal data. Consumers residing in certain Canadian provinces may have additional privacy rights.

China (Mainland)

Aghanim will only collect and use your personal data with your consent or with another lawful basis as described in this Privacy Notice. You can withdraw your consent anytime. When you withdraw consent, the personal data processing based on your previous consent remains valid. Aghanim protects your personal data subject rights under PRC privacy laws, which includes the right to access, rectify, erase, copy personal data, and the like. For more information, see Your Privacy Controls above.

France

In addition to the European Union Privacy Rights listed above, you have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time. You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us. To issue instructions, contact privacy@aghanim.com or submit your request through our chatbot located at https://support.aghanim.com/

Hong Kong

As a Hong Kong data subject, you have legal rights in relation to the personal data we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a Privacy Request to receive a copy of the personal data we process about you, a data correction request as well as a right to reject the use of your personal data for direct marketing purposes. We may charge a fee for a Privacy Request for access.

Mexico

This Privacy Notice is available in Spanish upon request. In case of dispute, the Spanish version of this Privacy Policy shall prevail. The type of personal data we use, purpose of processing, and cookie information is listed above in this Privacy Notice. In general, we do not require your consent to transfer your personal data. By using the Environment or website and providing us with your personal data, you agree to the data transfers detailed in this Privacy Notice that require your consent. The above descriptions of privacy rights to access, rectification, erasure, and object apply to residents of Mexico, as does the right to restrict processing to storage only (which includes the limitation to the use and disclosure of your personal data), and advertising. You also have the right to revoke the consent that you have provided us to process your personal data. To exercise any of your rights, contact privacy@aghanim.com or submit your request through our chatbot located at https://support.aghanim.com/.

Russia

If you are using any services of Aghanim in Russia, by doing so you consent to: (i) the processing of your information in accordance with this Privacy Policy for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations; (ii) if legitimate interests, optimization of the Environment or website or carrying out of the contract are mentioned herein, you agree that, for the purposes of Russian law, the consent so provided can be considered an additional ground for processing (meaning that the processing is conducted with your consent) and this consent also covers the processing of any cookies (to the extent that those qualify as personal data under Russian law); (iii) the cross-border transfer of your information to any country where Aghanim has databases or affiliates, in particular United States or other jurisdictions; (iv) for the purposes of Article 152.1 of the Russian Civil Code, the processing of your image in accordance with this Privacy Policy; and (v) for the purposes of Federal Law “On Marketing/Advertising”, that we may share advertising/marketing communications with you, unless you have opted-out from such communications. You have the rights to access, rectification, erasure/deletion, restrict processing to storage only, object, and you can control the use of your personal data for advertising purposes. We will update this posting if we materially change this Privacy Notice and we may request you to acknowledge such changes. Unless we require your acknowledgment, you shall be deemed to have agreed to the changes if you continue using the Environment or website after the updated posting and any required notification. As regards the representative for Russia, you can contact us at privacy@aghanim.com. Alternatively, you can submit your request through our chatbot located at https://support.aghanim.com/. Please include the word “Russia” in the subject line.