Preamble

This document (hereinafter referred to as the Offer) represents an offer from Individual Entrepreneur Olga Vasilievna Zabara (hereinafter referred to as the Entrepreneur) to enter into an agreement with the Customer (as defined below), who is a legal entity, individual entrepreneur or individual, on the terms set out below (hereinafter referred to as the Agreement).

This Offer is unlimited. The Entrepreneur may revoke the Offer at any time, which should not affect the Agreements that were concluded with Customers before the date of such revocation.

The entrepreneur has the right to unilaterally make changes to this Offer (for the avoidance of doubt, including, but not limited to, the terms of the Agreement concluded through acceptance of the Offer) by publishing a new version of the Offer at the following link on the Internet: https://els-filipino.com .

Updated versions of the Offer come into force from the moment they are published via the above links on the Internet. The Customer, in the event of concluding an Agreement, undertakes to regularly familiarize himself with this Offer with a view to making changes to it.

The procedure for accepting the Offer by the Customer
The Customer accepts the Offer by collectively performing the following actions:

1) register on an accessible resource (web interface) of the Entrepreneur, as well as provide complete, accurate and reliable information requested during registration (hereinafter referred to as the Registration Procedure), as well as provide other documents and information, if such documents and information are requested by the Entrepreneur in Customer's personal account. If the Entrepreneur is found to have provided incomplete and/or inaccurate and/or unreliable data and documents, the Entrepreneur may offer the Customer to correct the information provided or may refuse to conclude the Agreement.

2) Clicking on the button “I have read, agree and fully accept the terms of the Offer” (or similar in meaning) available on the resource (web interface) of the Entrepreneur.

3) Creation of an invoice for payment for Services in the Personal Account (as defined below) for the amount of the selected tariff and payment of the specified invoice. Access to the Personal Account is provided to the Customer after completing clause 1. above; a link to access the Personal Account is provided to the Customer by email to the email address specified by the Customer when completing the Registration Procedure.

The Customer's acceptance of this Offer in the manner provided above gives rise to the conclusion of an Agreement in the manner provided for in Art. 438 of the Civil Code of the Russian Federation, on the terms of this Offer.

Acceptance is confirmation of the Customer’s full and unconditional consent to the terms of this Offer. Acceptance of the Offer with exceptions/additions is not permitted.

By accepting this Offer, the person accepting the Offer in the prescribed manner confirms and assures that he is authorized to perform such an action on behalf of the Customer and has all the necessary rights and permissions necessary to perform such an action on behalf of the Customer. In case of violation of such assurance, the person who accepted the Offer undertakes to compensate losses to the Entrepreneur upon written request.

Terms of the Agreement concluded by accepting the Offer:

1. Terms

1.1. ELS Filipino Service, Service - a software and hardware complex that allows the Customer to receive the Service for accessing materials and conducting distance learning, and processing such Services.

1.2. User - whose telephone number was transferred by the Customer to the Entrepreneur in the manner established by clause 4.1.2. Agreement.

1.3. Service - information requested by the User and/or an authorized representative of the Customer in the Personal Account for materials and services for conducting distance learning.

1.4. Personal Account - a section of the Entrepreneur’s Website that contains information about the Customer, statistical data and other information regarding the Services (as defined in clause 2.1 of the Agreement), and which also provides the opportunity for remote interaction between the Parties under the Agreement, including for maintaining the list Users in an up-to-date state, available to the Customer after authorization on the Entrepreneur’s Website using the Customer’s login and password.

1.5. Statistics data - data from automated accounting systems of the Entrepreneur's information in electronic form, which may contain information for calculating the cost of Services and other information related to the process of providing Services under this Agreement.

1.6. Service area is the territory within which the Services can be provided to the Customer under the conditions specified in this Agreement.

1.7. Reporting period - a period during the validity period of this Agreement, equal to a calendar month. In this case, the first Reporting period is the period of time from the date of entry into force of this Agreement until the end of the corresponding calendar month, and the last Reporting period is the period of time from the date of the beginning of the corresponding calendar month until the date of expiration or termination of this Agreement.

1.10. A personal account is a unique identifier of the Customer, which is used for a single summary record of the Services provided by the Entrepreneur under this Agreement, information on payments for the Services and the Customer’s debt for the provision of Services under the Agreement. A personal account is of a technological and informational nature and does not have the status of a current or bank account. The Personal Account number is indicated in the Customer’s account in the “Balance” section.

1.11. Self-employed is a person applying a special tax regime as part of an experiment in accordance with the legislation on professional income tax, providing Services to Partners in accordance with the legislation of the Russian Federation.

1.12. The Entrepreneur's website is a resource on the Internet, available at the following link https://els-filipino.com.

1.13. Tariff - a system of payment rates for various Services available to the Customer in the Personal Account.

1.14. Balance is a resource on the Internet. Access to the Balance is carried out using the login and password from your Personal Account.

1.15. Depositing funds to the Personal Account - payment by the Customer to the current account of the Entrepreneur according to the invoice issued by the Entrepreneur or pay by credit card online. The current account of the Entrepreneur is indicated in the invoice. In the purpose of payment, the Customer must indicate the Customer's Personal Account number. In the event of a difference between the current account of the Entrepreneur specified in the details of this Agreement and the current account of the Entrepreneur specified in the invoice, the current account of the Entrepreneur specified in the invoice has priority.

1.16. Write-off of funds from the Personal Account - write-off by the Entrepreneur of funds from the Customer's payments as payment for Services, carried out in the current mode.

1.17. Personal Account Balance is the difference between two amounts of funds at a certain point in time. The first amount consists of funds deposited into the Personal Account up to this point in time; the second amount consists of funds written off from the Personal Account up to this point in time.

1.18. Customer is an individual entrepreneur/legal entity registered on the territory of the Russian Federation in accordance with the established procedure or an individual who entered into this Agreement by accepting the Offer in the manner specified in the preamble of this Offer.

1.19. Parties - joint mention of the Entrepreneur and the Customer in the text of the Agreement.

1.20. Party - a reference to the Entrepreneur or Customer in the text of the Agreement.

The Agreement may use other terms not defined in Section 1 of the Agreement, the interpretation of which is made in accordance with the text of the Agreement. If there is no unambiguous interpretation of the term in the text of the Agreement, you should be guided by the interpretation of the term: first of all, as defined on the Service, and secondly, as established on the Internet.

2. Subject of the Agreement

2.1. The Entrepreneur undertakes, during the term of this Agreement, to provide the Customer with services available for order using the Service, under the conditions and in the manner specified in this Agreement.

2.2. The Customer undertakes to pay for the Services provided under this Agreement by the Entrepreneur on the terms and in the manner specified in this Agreement.

2.3. In order for the Entrepreneur to provide Services to the Customer under this Agreement, the Entrepreneur, without additional written consent of the Customer, engages Partners who provide Services in accordance with the legislation of the Russian Federation. The Entrepreneur hereby confirms that the terms of the contracts concluded by the Entrepreneur with the Partners contain the obligation of the latter to carry out their activities exclusively in accordance with the requirements of the applicable legislation of the Russian Federation. Responsibility for improper provision of Services lies solely with the Partners, information about which is provided to the Customer upon a written reasoned request.

2.4. The parties have agreed that the required volume of Services is determined by Users and/or authorized representatives of the Customer independently and is subject to payment by the Customer in full, specified in the relevant unilateral Certificate of Services Rendered, drawn up in accordance with Section 5 of this Agreement (hereinafter referred to as the Certificate) or by check, including in cases of provision of Services outside the Service Area.

3. Rights and obligations of the Entrepreneur

3.1. The entrepreneur undertakes:

3.1.1. Provide the Customer with the Services provided for in this Agreement in accordance with the terms of this Agreement. This obligation is counter to the Customer’s obligation specified in clause 4.1.4. Agreement.

3.1.2. Send the Certificate or check to the Customer in the manner prescribed in Section 5 of this Agreement.

3.1.3. When providing Services under the Agreement, ensure that the Customer can familiarize himself with the Statistics Data through his Personal Account, while the Entrepreneur shall not be liable if the Customer is unable to familiarize himself with the Statistics Data for reasons beyond the control of the Entrepreneur.

3.1.4. If motivated complaints are received from Users and/or authorized representatives of the Customer regarding the provision of Services by Partners, consider such complaints and provide assistance in resolving any disagreements between the Customer and the Partner.

3.2. An entrepreneur has the right:

3.2.1. Make changes to the Tariffs by publishing them in a new edition in your Personal Account and/or on the website. These changes come into force at the time of their publication. The Entrepreneur has the right to notify the Customer of such changes.

3.2.2. Receive sums of money from the Customer in payment for the Services provided by the Entrepreneur under this Agreement, in the manner and under the conditions specified in this Agreement.

3.2.3. Suspend the provision of Services if the Customer has a debt to the Entrepreneur under this Agreement.

3.2.4. Notify the Customer by e-mail of suspicions that the Services of Partners on behalf of the Customer are used by third parties who are not recognized as Users in accordance with this Agreement.

4. Rights and obligations of the Customer

4.1. The customer undertakes:

4.1.1. Appoint, for your part, persons responsible for operational interaction on issues of execution of the Agreement during the term of the Agreement.

4.1.2. Before the Entrepreneur begins to provide Services under the Agreement, indicate in the Personal Account the mobile phone numbers of the Users, as well as other information necessary for the provision of Services under the Agreement. At the same time, the Customer assures that the provision by the Customer of such information, the content of the information, and the use of the Entrepreneur’s information in accordance with the terms of the Agreement does not violate the rights of third parties, the norms of current legislation, including legislation on personal data, is not burdened with the rights of third parties, and will not entail obligations for the Entrepreneur for payment of remuneration to third parties.

4.1.3. Maintain the list of Users, as well as information about such Users specified in the Personal Account, up to date throughout the entire term of the Agreement. For the purposes of this Agreement, the User is considered a User as long as information about such User is indicated in the Personal Account. The Customer undertakes to independently ensure that requests are not posted by persons other than Users.

4.1.4. Accept the Entrepreneur's Services provided in accordance with this Agreement in the manner and on the terms provided for in the Agreement, and pay for the Entrepreneur's Services in the manner and within the time limits provided for in Section 6 of the Agreement.

4.1.5. Inform Users about Tariffs, as well as bring to the attention of Users all other information about the Services received from the Entrepreneur.

4.1.6. If the information specified in clause 4.1.2. of the Agreement, contains personal data, the Customer undertakes to obtain the permissions (consent) provided by law from Users for the transfer of their personal data to the Entrepreneur, as well as for their processing by the Entrepreneur for the purposes and methods necessary to fulfill obligations under the Agreement, for the duration of the Agreement and 5 (five) years after its termination, as well as store the said consents for the specified period and provide them to the Entrepreneur upon his request. In the event of termination of the Customer's legal grounds for processing the User's personal data (including withdrawal of consent), the Customer is obliged to notify the Entrepreneur about this within three working days.

4.1.7. Within 1 (one) business day, respond to the Entrepreneur to notifications sent in accordance with clause 3.2.4. actual agreement.

4.2. The customer has the right:

4.2.1. Get access to statistics data when using your Personal Account.

4.2.2. Send a reasoned complaint to the Entrepreneur regarding the provision of Services by Partners of inadequate quality before the end of the Reporting Period in which the relevant Services were provided. If the Entrepreneur acknowledges (satisfies) such a complaint, the cost of the Services provided by the Entrepreneur for the specified Reporting period may be revised by the Parties downwards.

In the event of sending a reasoned complaint after the expiration of the Reporting period (but not more than 15 (fifteen) calendar days from the end of the Reporting period) and subsequent recognition (satisfaction) of such a complaint by the Entrepreneur, the Parties agreed that the amount by which the cost is subject to reduction The Entrepreneur's Services, recognized by the Entrepreneur based on the results of consideration of the complaint, will be taken into account when determining the cost of the Entrepreneur's Services in the Reporting Period in which such a complaint was recognized (satisfied) by the Entrepreneur.

In addition, the Parties agreed that direct proven damage, taking into account the restrictions provided for in clause 7.3. of the Agreement may be reimbursed by the Entrepreneur to the Customer by transferring funds to the Customer’s bank account based on the invoice issued by the Customer. The Entrepreneur undertakes to make payment within 30 calendar days from the date of receipt of a copy of the invoice, provided that the Entrepreneur recognizes such a reasoned complaint.

5. Procedure for delivery and acceptance of Services

5.1. During the validity period of this Agreement, monthly, within 7 (seven) working days from the end of the Reporting period, the Entrepreneur sends the Customer a unilateral Certificate in accordance with the volume of Services actually rendered during the Reporting period, which can be performed in accordance with clause 4.2.2 . Agreement.

5.2. The Act is sent by the Entrepreneur to the Customer by mail, while simultaneously sending a copy of the text of the Act by email. The parties acknowledge that a copy of the text of the Act sent by the Entrepreneur to the Customer by email will be used by the Customer in the process of accepting the Services provided by the Entrepreneur until the original of the Act is received.

5.3. The date of receipt of a copy of the text of the Act sent by the Entrepreneur to the Customer by e-mail is considered to be the next business day after the day of sending.

5.4. The parties have established that the Services of the Entrepreneur are considered to be provided properly and accepted by the Customer to the extent specified in the Certificate, if within 13 (thirteen) calendar days from the date of the Certificate the Entrepreneur has not received from the Customer a reasoned written refusal of the Certificate. After the expiration of the period specified above, claims regarding deficiencies in the Services provided by the Entrepreneur and/or Partners, including quantity (volume), cost and quality, will not be accepted.

6. Amount and payment procedure

6.1. The cost of the Entrepreneur's Services is calculated based on the statistical data available to the Customer in the Personal Account, according to the applicable Tariffs.

6.2. Payment for Services is carried out in advance by depositing funds into the Personal Account.

6.3. The minimum initial payment under the Agreement is RUB 1,000. (one thousand rubles).

6.4. Payment for Services is collected by debiting funds from the Personal Account in the amount calculated in accordance with clause 6.1. Agreement.

6.5. The Parties hereby have established that at any given time the Personal Account Balance should not be less than 1 (one) lesson (hereinafter referred to as the Shutdown Threshold). If the Personal Account Balance is less than the Disconnection Threshold, the Entrepreneur has the right not to provide Services to the Customer until the Personal Account Balance exceeds the Disconnection Threshold.

6.6. The Entrepreneur has the right to provide the Customer with the opportunity to order Services on deferred payment terms, i.e. the Customer's right to receive Services in the event of a negative Personal Account Balance by changing the Disconnection Threshold. The Entrepreneur undertakes to notify the Customer about the occurrence of this opportunity by sending a corresponding letter to the email address or by notifying in the Personal Account indicating the start date of the possibility of using the above opportunity, the maximum amount for the provision of the Entrepreneur's Services on deferred payment terms (the new size of the Shutdown Threshold) and other conditions for ordering Services in case of a negative Balance of the Customer’s Personal Account. In this case, if the Personal Account Balance is less than the updated Disconnection Threshold, the Entrepreneur has the right to stop providing Services to the Customer on deferred payment terms. Renewal of the Customer's right to order Services on deferred payment terms is subject to the Depositing of funds into the Personal Account in the amount of at least 100% (one hundred percent) of the cost of the Services ordered but not paid for by the Customer, while the Balance of the Personal Account after replenishment must be no less Shutdown threshold.

6.7. The Customer undertakes to pay for the Entrepreneur’s Services provided on deferred payment terms, as provided for in clause 6.6. Agreement, no later than 15 (fifteen) calendar days from the end of the Reporting Period in which the specified Services were provided, by depositing funds into the current account of the Entrepreneur specified in the invoice, with the obligatory indication of the Personal Account number. However, the Entrepreneur has the right at any time to demand payment for the Services provided to the Customer, and the Customer is obliged to satisfy this demand within 5 (five) working days from the moment it is sent.

6.8. The parties agreed that the Shutdown Threshold may be changed by the Entrepreneur unilaterally. Information about the current Shutdown Threshold is available to the Customer in the Personal Account.

6.9. The parties acknowledge that for the purposes of this Agreement, in particular, to determine the volume of Services provided by the Entrepreneur and their cost, exclusively the statistical data reflected in the Personal Account are used.

6.10. The Customer's obligations to pay for the Services in the manner provided for in this Agreement are considered fulfilled from the moment funds are received in the corresponding correspondent account of the Entrepreneur's bank.

7. Responsibility of the Parties

7.1. For violation of the obligations provided for in the Agreement, the Parties are liable in accordance with the current legislation of the Russian Federation.

7.2. If the Customer violates the terms of payment for the Services provided by the Entrepreneur under this Agreement, the Entrepreneur has the right to demand payment of a penalty in the amount of 0.2% (two tenths of a percent) of the amount of the overdue payment for each day of delay.

7.3. The total liability of the Entrepreneur under the Agreement is limited to compensation to the Customer for direct proven damage.

7.4. The Parties are released from liability for non-fulfillment and/or improper fulfillment of obligations under this Agreement if such non-fulfillment was the result of force majeure circumstances (force majeure) beyond the control of the Parties, which, among others, include natural disasters, fires, man-made accidents and disasters, accidents on engineering structures and communications, mass unrest, military actions, terrorist acts, riots, civil unrest, strikes, regulations of state authorities and local governments that prevent the Parties from fulfilling their obligations under this Agreement, that is, extraordinary and insurmountable under these conditions, circumstances occurring after the conclusion of this Agreement. The Party citing the impossibility of fulfilling obligations due to the occurrence of force majeure circumstances is obliged to immediately notify the other Party about this. The fact of the occurrence of force majeure circumstances must be confirmed by the relevant competent organizations.

8. Duration of the Agreement. Procedure for termination and amendment of the Agreement

8.1. The Agreement comes into force from the moment of acceptance of the Offer, as stated in the preamble, and is valid for 1 (one) year.

8.2. If neither Party notifies the other Party of its desire to terminate cooperation at least 30 (thirty) calendar days before the expiration date of the Agreement, the term of the Agreement is automatically extended for a year. The number of such automatic renewals is unlimited.

8.3. This Agreement may be terminated:

8.3.1. by agreement of the Parties at any time;

8.3.2. any of the Parties unilaterally out of court with mandatory preliminary written notification to the other Party at least 10 (ten) calendar days before the expected date of termination;

8.3.3. The Entrepreneur unilaterally out of court with mandatory preliminary written notification to the Customer at least 3 (three) calendar days before the expected date of termination, in the event that the Entrepreneur withdraws the Offer in the manner specified in the preamble of the Offer.

8.4. The obligations of the Parties under the Agreement, which by their nature must continue to apply (including, but not limited to, obligations regarding mutual settlements), remain in force after the expiration of the Agreement.

9. Personal data

9.1. Each of the Parties is an operator of personal data, including those processed as part of the fulfillment of obligations under the Agreement. For the purposes of the Agreement, personal data means information that is such in accordance with the legislation of the Russian Federation and relates to employees, other representatives of the Parties, including those directly involved in the execution of the Agreement, and third parties whose data is transferred to the other Party.

9.2. The transfer of personal data is not considered by the Parties as an order to process personal data.

9.3. Each Party ensures the confidentiality of personal data received under the Agreement from the other Party, compliance with the requirements for the processing of personal data established by Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” and the regulatory legal acts adopted in its implementation, and bears responsibility for taking all necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution of personal data, as well as from other unlawful actions with such data.

9.4. Responsibility for the legality and reliability of the personal data provided by the Parties to each other for the purpose of fulfilling the Agreement, as well as for obtaining the consent of the subjects to transfer their personal data to the other Party in the manner prescribed by the legislation of the Russian Federation, rests with the Party transmitting the personal data.

9.5. The Party that received personal data from the other Party does not undertake the obligation to inform the subjects whose personal data was transferred to it about the beginning of their processing, since the obligation to provide appropriate information upon obtaining consent to such a transfer lies with the Party that transferred the personal data.

9.6. The Party receiving personal data has the right, in order to fulfill the Agreement, to the extent necessary for this purpose, to involve in the processing of the received personal data persons affiliated with such Party, or companies included in the same group of persons with such Party.

9.7. At the same time, the Parties acknowledge that the Services provided by the Entrepreneur under this Agreement cannot be provided in relation to Users who have not provided or have withdrawn their consent to the processing of their personal data in the manner prescribed by the legislation of the Russian Federation.

10. Rules of corporate ethics

10.1. In all of their activities, the Entrepreneur and other companies of the group adhere to the principles and working conditions contained in the Rules of Corporate Ethics. The entrepreneur and other companies of the group expect their counterparties to comply with the business principles specified in these Rules.

10.2. The Parties acknowledge and confirm that each of them pursues a policy of zero tolerance for bribery and corruption, which implies a complete prohibition of corrupt practices and payments for assistance/payments, the purpose of which is to simplify formalities in connection with business activities and ensure faster resolution of certain issues .

10.3. The Parties shall comply with, apply and act in accordance with the following national and international legal acts:

10.3.1. Fundamental Principles of the OECD Convention on Combating Bribery of Foreign Public Officials in International Business Transactions;

10.3.2. The US Foreign Corrupt Practices Act of 1977;

10.3.3. Federal Law of the Russian Federation of December 25, 2008 N 273-FZ “On Combating Corruption”;

10.3.4. other provisions of applicable laws regarding corruption and commercial bribery.

10.4. If a Party suspects that a violation of any provisions of this section of the Agreement has occurred or may occur, the relevant Party undertakes to immediately notify the other Party of its suspicions in writing.

10.5. Clauses 10.1 - 10.3 of the Agreement are assurances about circumstances that are of significant importance to the Entrepreneur. The Customer relies on such representations when concluding the Agreement.

11. Other conditions

11.1. The contract and its execution are regulated in accordance with the legislation of the Russian Federation.

11.2. Any notices under this Agreement are sent by the notifying Party to the notified Party by email, fax, courier or post with return receipt requested. In this case, copies of documents delivered by e-mail or fax are recognized by the Parties as having legal force until the exchange of originals, which the Parties make as soon as possible.

11.3. The parties have established that any messages or notifications within the framework of the execution of this Agreement must be sent to the email addresses directly named by this Agreement. For Entrepreneur: any email addresses with the domain els-filipino.com. For the Customer: the email address specified by the Customer during the Registration Procedure, as specified in the preamble of the Offer. In the event of a change in the email addresses or domain names of the corporate domains specified in this paragraph, the Party must notify the other Party in writing within 1 (one) business day from the date of such change. The Party bears the risk of adverse consequences caused by failure to notify the other Party of the fact of changing email addresses or domain names of corporate domains.

11.4. The Parties assume full responsibility for the actions of persons who have access to the communication channels specified in clause 11.3. actual agreement. All actions performed using the above communication channels are performed by duly authorized representatives of the Parties.

11.5. In the event of a change in the details of the Parties, as well as the list of persons responsible for interaction under the Agreement, the Parties are obliged to notify the other Party of the changes within 5 (five) business days by sending a written notification to the other Party, as well as sending a copy of the text of the notification to the email address.

11.6. All acts, annexes, additional agreements and additions to the Agreement are an integral part of the Agreement.

11.7. If one or more provisions of the Agreement are declared invalid, such invalidity does not affect the validity of any other provision of the Agreement and the Agreement as a whole.

11.8. All disputes and disagreements between the Parties under the Agreement, in connection with the Agreement and/or its execution, the Parties will strive to resolve through negotiations. The use of a mandatory pre-trial (claims) procedure for resolving disputes is mandatory. The Party whose rights have been violated, before going to court, is obliged to present a written claim to the other Party outlining its demands. The period for consideration of a claim is 30 (thirty) calendar days from the date of its receipt. If the requirements are not satisfied within the specified period, the dispute must be resolved in the Moscow Arbitration Court.

11.9. The information contained in the Agreement, as well as the fact of conclusion of the Agreement, are confidential. Except for cases expressly specified in the Agreement or previously agreed upon by the Parties in writing in the form of an additional agreement to the Agreement, neither Party has the right to in any way use the full, abbreviated company name, trademarks, commercial designations and other means of individualization owned by to the second Party, without the latter's prior permission.

11.10. Words that mean only the singular also include the plural and vice versa, depending on the context.

11.11. After the conclusion of this Agreement in the prescribed manner, all previous negotiations and correspondence of the Parties, both oral and written, relating to its subject matter become invalid.
_________________________

Date of publication: 09/15/2023

Publication date: September 15, 2023

The current version is available at: https://els-filipino.com

1. What this privacy policy covers
This privacy policy (hereinafter referred to as the Policy) applies to all information, including personal data within the meaning of applicable law (hereinafter referred to as Personal Information) that Olga Vasilievna Zabara Individual Entrepreneur and/or its affiliates, including those included in the same group with Zabara Individual Entrepreneur Olga Vasilyevna (hereinafter referred to as the Entrepreneur) may receive information about you in the process of your use of any of the websites, programs, products and/or services of the Entrepreneur (hereinafter collectively referred to as the Services), information about which you can find on the websites https://els-filipino. com, https://els-filipino.ru and other websites owned by the Entrepreneur (hereinafter collectively referred to as the Sites), as well as during the execution by the Entrepreneur / its affiliates of any agreements and contracts concluded with you in connection with your use of the Services. An entrepreneur may also receive Personal Information from its partners (hereinafter referred to as Partners), sites, programs, products or services that you use. In such cases, the transfer of Personal information is possible only in cases established by applicable law, and is carried out on the basis of special agreements between the Entrepreneur and each of the Partners.

Please note that the use of any of the Sites and/or Services may be subject to additional terms and conditions, which may make changes and/or additions to this Policy, and/or have special conditions regarding personal information posted in the relevant sections of the documents for such Sites /or Services.


2. Who processes the information
To ensure your use of the Sites and Services, your Personal Information is collected and used by the Entrepreneur, including individual entrepreneur Olga Vasilievna Zabara, registered under the laws of the Russian Federation, or its affiliate providing the corresponding Service in other jurisdictions. You can find information about which person provides a particular Service in the terms of use of the relevant Service.


3. What is the purpose of this Policy
The protection of your Personal Information and your privacy is extremely important to an Entrepreneur. Therefore, when you use the Sites and Services, the Entrepreneur protects and processes your Personal Information in strict accordance with applicable law.

Consistent with our responsibility to protect your Personal Information, we would like to inform you as transparently as possible about the following points in this Policy:

(I) why and how the Entrepreneur collects and uses (“processes”) your Personal Information when you use the Sites and/or Services;

(ii) what are the role and responsibilities of the Entrepreneur as the person making the decision about why and how to process your Personal Information;

(III) what tools you can use to reduce the amount of Personal Information about you collected by the Entrepreneur;

(III) what are your rights in relation to the ongoing processing of Personal Information.


4. What Personal Information does the Entrepreneur collect about you?
Personal information collected in the course of operating the Sites and/or providing the Services may vary depending on whether you use your account to access the Sites and/or Services. When you log into your account, Personal Information collected about you by a Business Owner during your use of the Sites and Services may be matched and linked to other Personal Information collected by a Business Owner as part of your use of your account (for example, information about your identity, contact details, age and gender, if they were provided to the Entrepreneur). The Entrepreneur does not check the Personal Information provided by you, except in cases provided for in the user agreement or the terms of use of individual services, and cannot judge its reliability, as well as whether you have sufficient legal capacity to provide your Personal Information. However, the Entrepreneur assumes that you provide reliable and sufficient Personal Information and that you update it in a timely manner.

The Entrepreneur may collect the following categories of Personal Information about you during your use of the Sites and Services:

• (I) personal information provided by you when registering (creating an account), such as your name, telephone number, address and age;

• (ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information, wi-fi network data);

• (III) date and time of access to the Sites and/or Services;

• (IIII) information about your activity while using the Sites and/or Services (for example, search query history, data on purchases in the Services, data on visited organizations, likes and preferences, email addresses of those with whom you correspond, telephone data books, information about interactions with other users, as well as files and content stored in the Entrepreneur’s systems);

• (IIIIII) geolocation information;

• (IIIIII) other information about you necessary for processing in accordance with the conditions governing the use of specific Sites or Services of the Entrepreneur;

• (IIIIIII) information about you that we receive from our Partners in accordance with the terms of the agreements concluded between you and the relevant Partner, and the agreements concluded between the Entrepreneur and the Partner.

The Entrepreneur also uses cookies and web beacons (including pixel tags) to collect Personal Information and associate such personal information with your device and web browser (see Section 11 of this Policy).

The Entrepreneur does not purposefully collect sensitive personal information (such as racial origin, political opinions, health information and biometric data), except as provided in the user agreements of individual Services. However, you may provide them to the Entrepreneur yourself, in which case the Entrepreneur will process them as part of providing the Services to you (for example, if you make search queries related to your health). However, you should take into account that the Entrepreneur cannot request your consent to such processing because it is not aware in advance of the potentially sensitive nature of the Personal Information that you may provide to the Entrepreneur.

The entrepreneur does not collect data for the purpose of compiling a “portrait” of the user to the extent that this could significantly affect your rights and freedoms in accordance with applicable law.


5. What is the legal basis and purposes for processing your Personal Information?
The entrepreneur does not have the right to process your Personal information without sufficient legal grounds. Therefore, the Entrepreneur processes your Personal Information only if:

• (I) processing is necessary to fulfill the Contractual obligations of the Entrepreneur to you, including ensuring the operation of the Sites and Services (for example, providing you with search results for your search queries);

• (ii) processing is necessary to comply with legal obligations;

• (III) when provided for by applicable law, processing is necessary to ensure the legitimate interests of the Entrepreneur in the event that such processing does not have a significant impact on your interests, your fundamental rights and freedoms. Please note that when processing your personal information on this basis, the Entrepreneur will always strive to maintain a balance between its legitimate interests and the protection of your privacy.

• The Entrepreneur processes your Personal Information to ensure its legitimate interests, for example, in the following cases:

• (i) to better understand how you interact with our Sites and/or Services;

• (ii) to improve, change, personalize or otherwise improve the Sites and Services for the benefit of all users;

• (III) to offer you other products and services of the Entrepreneur or other companies that we think may be of interest to you (i.e., show you advertising tailored to your interests);

• (IIII) for specific purposes or as required by applicable law, we may request your specific consent to process your Personal Information. For jurisdictions where consent is recognized as a separate legal basis, your commencement of use of the Sites and/or Services of the Entrepreneur constitutes your consent to such processing. We hereby inform you, and you acknowledge, that you have no obligation to provide us with any Personal Information when you use the Sites or Services and is based solely on your free will. However, you understand that without providing Personal Information, we will not be able to provide you with the opportunity to use the Services, and your use of the Sites will be limited.

The Entrepreneur always processes your Personal Information for specific purposes and only that Personal Information that is relevant to achieving such purposes. In particular, we process your Personal Information for the following purposes:

(I) providing you with access to the Sites and/or Services (including providing search results in response to your search requests, taking into account your preferences, search history and other Personal information about you available to the Entrepreneur);

(ii) providing access to your account and file storage if you are registered in the relevant Services;

(III) communicating with you to send you notices, requests and information related to the operation of the Sites and Services, fulfilling agreements with you and processing your requests and applications;

(IIII) personalizing advertising and offers based on your preferences, search history and other Personal Information about you available to the Entrepreneur;

(iii) improving the ease of use of the Sites and Services, including by displaying more relevant search results and providing more personalized Sites and Services, as well as improving other products, applications and Services of the Entrepreneur;

(IIIIII) creating new products, utilities and Entrepreneur offerings;

(IIIIIII) protection of your rights and the rights of the Entrepreneur;

(IIIIIIIII) collection, processing and presentation of statistical data, big data and other research.


6. How an Entrepreneur protects your Personal Information
In most cases, Personal Information is processed automatically without any of the Entrepreneur’s employees having access to it. If such access is needed, it can be provided only to those employees of the Entrepreneur who need it to perform their tasks. To protect and ensure the confidentiality of data, all employees must comply with internal policies and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect your Personal Information.

The Entrepreneur has also implemented sufficient technical and organizational measures to protect Personal Information from unauthorized, accidental or unlawful destruction, loss, alteration, unfair use, disclosure or access, as well as other unlawful forms of processing. These security measures have been implemented taking into account the current state of technology, the cost of their implementation, the risks associated with the processing and the nature of Personal Information.


7. Who else has access to your Personal Information and to whom it may be transferred
7.1 Within the Group
The entrepreneur may transfer your Personal information to its employees (within the limits specified in section 6 of this Policy). The Entrepreneur may also transfer your Personal Information to its affiliates, including other companies from the group of persons to which the Entrepreneur (Group) belongs. Please note that the level of protection of Personal Information in some countries may not be the same as in your jurisdiction, and by using the Business Services you consent to such transfer.

In all cases, Personal Information will also be processed only for the purposes set out in Section 5 of this Policy, unless otherwise provided by the terms of use of the Sites and/or Services provided by the Group companies, including:

In addition, your Personal Information may be transferred to persons within the Group who are located in the same country as you, to provide you with support in your use of the Sites and Services.

7.2 Outside the Group
The Entrepreneur may also transfer Personal Information to third parties outside the Group to achieve the purposes specified in Section 5 of this Policy. Please note that the level of protection of Personal Information in some countries may not be the same as in your jurisdiction, and by using the Business Services you consent to such transfer.

Such third parties may include:

(I) Partners, such as site and application owners, advertising networks and other partners who provide services to the Entrepreneur related to the placement and display of advertising on sites, programs, products or services owned or controlled by such partners;

(II) advertisers or other Partners who display advertisements for you on the Sites and/or Services of the Entrepreneur, as well as such Partners as information service providers or consultants.

The Entrepreneur may also transfer Personal Information to third parties outside the Group:

(I) to third parties in respect of whom an assignment of rights or obligations has been made, or novation under the relevant agreement;

(ii) any national and/or international regulatory authority, law enforcement agencies, central or local executive authorities, other official or government bodies or courts in respect of which the Entrepreneur is required to provide information in accordance with applicable law upon request;

(III) to third parties, if you have consented to the transfer of your Personal Information or the transfer of Personal Information is required to provide you with the relevant Service or to fulfill a specific agreement or contract concluded with you.


8. Where is your Personal Information stored and processed?
Your Personal Information will be stored in the Russian Federation and/or the EEA.

For Russian users: The entrepreneur records, systematizes, accumulates, stores, clarifies (updates, changes), and retrieves personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.

For users from the EEA, Switzerland or Israel: Russia is a jurisdiction outside the European Economic Area that has not been recognized by the European Commission as providing an adequate level of protection for personal data. The Entrepreneur has therefore taken appropriate measures to ensure that such transfers are carried out in accordance with current EU data protection regulations.

In particular, the Entrepreneur is guided by the Standard Contractual Clauses approved by the European Commission to ensure an adequate level of protection of your Personal Information transferred to Russia. A copy of these Standard Contractual Clauses is available upon request.

If you are located in a territory where your consent is required for the transfer of your Personal Information to another jurisdiction, then by using the Sites or Services, you give the Entrepreneur your explicit and unambiguous consent to such transfer or storage, and/or processing of information in other specified jurisdictions, including Russia.


9. How long do we store your Personal Information?
The Entrepreneur will retain your Personal Information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal and regulatory requirements.

Unless otherwise required by law or by agreement with You, emails and documents that You store on Entrepreneur's systems as part of the Service will be retained for as long as You have an account, but they may be deleted by You at any time.

If you want any of your Personal Information to be deleted from the Entrepreneur's databases, you can independently delete the necessary Personal Information using your account or through the interface of the Sites and/or Services (where applicable).


10. Your rights
10.1 What rights do you have?
If provided for by applicable law, you have the right to access your Personal Information processed by the Entrepreneur in accordance with this Policy.

If you believe that any information that the Entrepreneur holds about you is incorrect or incomplete, you may log into your account and correct your Personal Information yourself.

If provided by applicable law, you have the right to:

(I) get acquainted with the information that the Entrepreneur stores about you;

(II) demand the deletion of your Personal Information or part thereof, as well as withdraw consent to the processing of your personal information;

(III) request restrictions on the processing of your Personal Information;

(IIII) request a copy of the Standard Contractual Clauses permitting the transfer of your Personal Information to Russia and specified in Section 8 of this Policy;

(IIIIII) object to the processing of your Personal Information if required by applicable law.

The Entrepreneur will comply with these requests in accordance with applicable law.

To the extent permitted by applicable law, you may also have other rights not listed above.

When you use the Services, the transfer of Personal Information is carried out with your consent, expressing your free will and your interest (in particular, on the basis of an agreement with you) and is not a legal obligation.


10.2 How you can exercise your rights
To exercise the above rights, please log in to your account, and if there is no special function in the interface, contact the Entrepreneur (see section 13 of this Policy).

If you are not satisfied with the way the Entrepreneur processes your Personal Information, please let us know and we will consider your complaint. If you are not satisfied with the Entrepreneur's response, you have the right to file a complaint with the competent authority.


11. How we use cookies and other similar technologies on the Sites or when you use the Services
11.1 What cookies and why does the Entrepreneur use them?
Cookies are small pieces of data that are received and processed by the device you use to access the Sites. Cookies store and send information back to the Sites that assists your experience on the Sites and allows us to remember your preferences over time, such as browser settings or recognizing your account.

The following types of cookies are used on the Sites:
strictly necessary cookies/technical cookies: these cookies are essential for the operation of the Sites and provision of Services to you; among other things, they allow the Entrepreneur to identify your hardware and software, including your browser type;
statistical/analytical cookies: these cookies allow us to recognize users, count their numbers and collect information such as your transactions on the Sites and Services, including information about the web pages you visit and the content you access;
technical cookies: these cookies collect information about how users interact with the Sites and/or Services, which allows us to identify errors and test new features to improve the performance of the Sites and Services;
Functionality cookies: These cookies enable us to provide certain functions to make your use of the Sites easier, for example by storing your preferences (such as language and location);
(third-party) tracking/advertising cookies: These cookies collect information about users, traffic sources, pages visited and advertisements displayed to you, as well as the one that led you to the advertised page. They allow us to display advertisements that may be of interest to you based on an analysis of the Personal Information collected about you. They are also used for statistical and research purposes.


11.2 How long cookies are stored on your device
The Entrepreneur uses the information contained in cookies only for the purposes stated above, after which the collected data will be stored on your device for a period that may depend on the relevant type of cookie, but not exceeding the period necessary to achieve their purpose, after which they will be automatically removed from your system.

11.3 Who else has access to information contained in cookies
Personal information collected using cookies placed on your device may be transferred and accessible to the Entrepreneur and/or third parties specified in section 7 of this Policy. The use of Personal Information outside of the Sites for promotional purposes, if any, may be subject to separate user agreements available on third party websites. Business and/or third parties may also provide you with the opportunity to opt out of advertising personalization, which may be subject to laws and regulations applicable to such products and offers.

When you first visit the Sites, you may be asked to consent to the use of cookies. If, after you have accepted the use of cookies, you wish to change your mind, you can do so by deleting the cookies stored in your browser (this can usually be done through your browser settings - please refer to your browser guide or website its developer). A pop-up window may then be displayed again asking for your consent and you may make a different choice. If you decline cookies, you may not be able to use certain features of the Sites and may affect your ability to use the Sites. You can also change your browser settings to accept or reject by default all cookies or cookies from certain sites, including the Entrepreneur Sites. If you have approved the use of cookies on one of the Entrepreneur Sites, we will assume that the use of cookies on all Sites has been approved by you.

The Business may also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:

(I) determining your actions on the Sites and while using the Services by accessing and using cookies stored on your device;

(II) collection of statistical information related to the operation of the Sites, Services or products, utilities and offers of the Entrepreneur.


12. Updates to this Policy
This Policy may be subject to change. The Entrepreneur has the right to make changes at his own discretion, including, but not limited to, in cases where the corresponding changes are related to changes in applicable legislation, as well as when the corresponding changes are related to changes in the operation of the Sites and Services.

The Entrepreneur undertakes not to make significant changes, not to impose additional burdens or restrictions on your rights established by this Policy without your notice. You will be notified of such changes. Appropriate notices may be displayed on the Site or Services (for example, via a pop-up window or banner) prior to such changes becoming effective, or may be sent to you through other communication channels (for example, by email if you have provided us with your Contact details).


13. Questions and suggestions
The Entrepreneur welcomes your questions and suggestions regarding the implementation or modification of this Policy. Please send your letters to info@els-filipino.com. You can also use this address to send requests for the exercise of your rights or complaints regarding the incorrectness of your Personal Information or the illegality of its processing.