Data Protection Policy of

Scope of policy

This policy applies to the branches of in Russia, Germany, the United States of America and the following entities: Targetix LLC, Kontektno-mediynye tekhnologii LLC, Gibrid LLC, Hybrid Adtech Inc., Hybrid Adtech GmbH.

Policy operational date

This policy will be effective starting on May 25, 2018.

Policy prepared by’s data protection team.

Date approved by Board/ Management Committee

This policy has been approved by’s Chief Executive Officer, Dmitry Cheklov.

1. Introduction (either of entities mentioned in “Scope of policy” above) is committed to conducting its business in accordance with all applicable Data Protection laws and regulations and in line with the highest standards of ethical conduct. This policy sets forth the expected behaviours of’s Employees and Third Parties in relation to the collection, use, retention, transfer, disclosure and destruction of any Personal Data belonging to a hybrid’ai (i.e. the Data Subject). Personal Data is any information (including opinions and intentions) which relates to an identified or Identifiable Natural Person. Personal Data is subject to certain legal safeguards and other regulations, which impose restrictions on how organisations may process Personal Data. An organisation that handles Personal Data and makes decisions about its use is known as a Data Controller., as a Data Controller, is responsible for ensuring compliance with the Data Protection requirements outlined in this policy.’s leadership is fully committed to ensuring continued and effective implementation of this policy, and expects all Employees and Third Parties to share in this commitment. Any breach of this policy will be taken seriously and may result in disciplinary action or business sanction.

2. Definitions and Interpretation
3. Policy has adopted the following principles to govern its collection, use, retention, transfer, disclosure and destruction of Personal Data:

The disclosures may be given orally, electronically or in writing. If given orally, the person making the disclosures should use a suitable script or form approved in advance by the Office of Data Protection. The associated receipt or form should be retained, along with a record of the facts, date, content, and method of disclosure.

4. Application of these Controller Terms
5. Roles and Restrictions on Processing
6. Data Transfers
7. Privacy Shield Onward Transfer Provisions
8. Liability
9. Priority
10. Changes to these Controller Terms
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