---- PRIVACY AND COOKIES

InstantChess Ltd, (hereinafter "the Company"), the rightful owner and operator of ----, (hereinafter "the Service",) places great importance in  protecting the rights of its customers, (hereinafter "Users"), with special regard to the confidentiality of their personal information and information on their activity on the Net.

While working with the Service, each User creates a certain set of information about himself/herself and his/her preferences in actions, (hereinafter "Information").

This Privacy and Cookies is aimed at keeping Service Users informed of the set of data collected and stored by the Service, and the ways of protecting and handling it.

This Policy shall apply to all of the Service's devices accessible both through the Internet browser and special software loaded on the User's computer or mobile phone.

The Policy guarantees protection of the right to personal information privacy within the Service but shall not apply to third parties' web sites recommended or advertising through it.

Should any User come across a case of the Company defaulting on its obligations under this Policy that User would be required, first of all, to contact the Service Staff using the technical support forum at www.instantchess.com/support.

GENERAL PROVISIONS

The Company is the sole and rightful owner and operator of all information collected by the Service.

The Company shall neither sell nor exchange nor lease for temporary use nor share the information with any third party, except as provided for herein and other than in cases when a special public authority may require that the Company should provide this information under applicable international law.

The Company shall not use, change or operate information other than for the purposes of providing services specified in the User Agreement and of improving services and the way of proving them.

All possible ways of collecting, storing, backing-up, using and handling information are described in this Policy.

INFORMATION COLLECTION DURING USER REGISTRATION

To ensure full use of the Service, the User shall have to be registered. During registration, entering of contact information (full name, e-mail, country of residence) and  date of birth (to ensure the User passes the age limit) is essential. Contact information is basic for identifying a User in the Service and for executing identification data recovery methods.

The Company shall reserve the right to use contact information to inform Users of its new products and services as well as new functionality, technical work and other events related to the operation of the Service.

The Company does not process credit/debit cards but contracts this function to secure and reputable operators so the Company is never in possession of any User's credit/debit card details.  Information on payment processing operators is available on the same page as the Service fees are listed.

INFORMATION COLLECTION USING COOKIES TECHNOLOGY

Cookie enables web sites to record files (cookie-files) in specially allocated space on the hard disk of the User's computer. These files comprise a series of non-personalized (not containing contact information) data - a set of randomly generated digits. These digits enable a web site to ensure a User's operations in such space of that web site that requires authorization; to store and provide the work of personal settings in generally accessible sections of the web site; to track the User's preferences when he or she navigates the site.

Cookie files are textual files  rather than program files. They do not provide any technical capacities for launching any external software and cannot serve as a means of taking control over the User's computer or as a computer virus carrier.

With the majority of the Service's functionalities located within the site's closed area (which is only accessible after registration and authorization), the Company shall include cookie support into the list of mandatory technical requirements of the User's software. If the cookie support function is switched off or not available to the User, the Company does not guarantee that the Service will be operational.

To perfect the Service, the Company shall constantly study methods of its use and the convenience of its functionalities. The Company shall reserve the right to track and fix Users' traffic across the site and to identify locations which cause difficulties to them or, on the contrary, give rise to preferences by them. Cookies are basic when log files required to generate such reports are compiled.

The Company may make use of third parties' services and software to generate statistical reports; it is permitted for this software to use its own cookies for this purpose.

According to the general terms and conditions of this Policy, the Company shall undertake not to link cookies generated by third parties' software to its Users' contact databases, thus negating  any chance of reports on the conduct of any given user being linked with his or her contact information.

Additionally, it is permitted that when any third parties have paid for their advertising on the Service , they may also be given the opportunity of handling cookies. Their actions are normally aimed at obtaining statistical information on their advertising campaigns (audience coverage, number of responses, etc.). In this case, just as in the aforementioned, the Company excludes all chances of its Users' contact databases being  linked with such cookies.

INFORMATION COLLECTION USING LOG FILES TECHNOLOGY

Log files are files automatically generated by the server where records on all queries arriving at the server are stored (page queries, action, etc.). The frame data for each query is an IP address, from which such query arrives.

Based on log file analysis, errors in the server, its components and the software installed on it are detected.

Log files are also used when drafting statistical reports on Users' conduct on the site. Where one IP address is frequently used by a group of people within the same local network, log file data must be matched with cookie file data to draw up correct statistical reports. Information on the purpose of these reports and their importance is available at the Information Collection Using Cookie Technology section of this Policy.

All obligations of the Company with respect to cookies equally apply to log files.

INFORMATION COLLECTION CHANNEL SECURITY

The Company shall exercise all reasonable efforts to ensure information collection channel security.

The registration process during which a User enters his/her contact information is secured by a reliable cryptographic protection method by using SSL (Secure Socket Layer) network protocol. This protocol is subject to certification by an authorized entity. Prior to registration, a User may verify the authenticity of the Company's certificate by using a special sign located on the registration page.

As described in the Information Collection during Payment Acceptance section, the Company has no access to Users' credit card data and does not independently ensure transmission channels for this data. However, the Company, under its agreement with the bank providing it with the payment processing services sees that the channels through which such data are transmitted. are highly secure.  These security efforts applied to financial data are described in greater detail on the web sites of credit card providers.

Abbreviated data on payments insufficient for repeated or other payments and only required for payment identification arrive at the Company's server through SSL-protected channels that virtually exclude any chance of their interception by third parties.

With cookie data being of no practical value without being linked to Users' databases, transmission channels for handling these files are protected at the level customary for the Internet.

Log files are only generated and processed within the server where they were generated, so no data transmission channels apply to them.

DATA STORAGE AND BACKING-UP

All data, other than cookies, are stored for an indefinite period on the Company's servers. Data security measures shall be equal to those applied to ensure security of the Company's servers.

The Company shall take all reasonable efforts to protect its servers and its business.

Cookies are individually kept on the User's PC and are only protected by the means applied by the User to ensure his/her computer's security.

Data is backed up in real-time environment. As soon as data appear they are stored both in the main database and in the duplicating base located on the reserve server. Also, the reserve server database is copied from time to time, with physical separation of server hardware, which will then be stored in a secure place and will be updated based on a specially drafted schedule for backup circulation.

DATA ADMINISTRATION

The Company is striving to make handling of the web site Users' data as automatic as possible, which for this purpose, means making it possible for the User to resolve his/her own administrative problems independently, interacting with the server only to change his/her data, retrieve passwords, extend the account validity period. This method is being developed, implemented and refined. All operations with Users' data are performed automatically, at the level of the server's software and do not require the Company's personnel to intervene. In this data-handling mode, their preservation and security are ensured by the same means as those described in the Information Collection Channel Security section.

In some cases, such as when the solution to a problem is beyond the previously envisaged framework, an employee of the Company is allowed to participate in their resolution.

Each employee of the Company is a responsible person of the Company, and all of his/her actions are governed by the provisions of this Policy, i.e. when performing any actions that envisage access to a User's data, the employee shall ensure data preservation and security to the fullest extent provided for in this Policy.

When working on the User's problems, the employee shall not be entitled to transfer to the User any account data (passwords, contact data, etc.) but shall seek to help the latter in independent retrieval of lost or forgotten data.

Users' questions are only collected and processed at www.instantchess.com/support. In the case of approaches for help to the Company's mail addresses, employees' personal mail addresses, and other means of communication, envisaged by the web site, the Company does not guarantee quality in addressing Users' problems. Additionally, due to the absence of control methods and the insufficient security level provided for in such information transmission channels, the Company does not guarantee that obligations contained in this Policy will be fully performed.

DATA AMENDMENT AND ADJUSTMENT

If a User's contact data change or were incorrectly indicated during registration, the Service shall provide the opportunity of their updating or adjusting. The option of changing both confidential contact information and generally accessible information is available in the Settings section of the Service's site.

With the game archive being the intellectual property of the Service (see the User Agreement), the Service is not able to delete the User's account fully - the latter is directly linked to the game archive, and generally accessible information on the account is part of InstantChess.com, the Game Archive. However, the Company shall undertake to perform its obligations described in this policy to keep confidential personal information privacy in cases when the User opted to give up the Service's services, i.е. decided not to renew his/her subscription. This provision has no limitation period and applies during the entire life of the Service. Moreover, during the entire data storage period, the User shall have the option of changing his/her data, even if his/her subscription has expired.

PUBLIC PUBLICATIONS

In addition to confidential contact information (mandatory for inclusion), the Service presents the User with the option of incorporating any demographic and generally accessible contact information about himself/herself. This information is optional and generally accessible, and the User has the right to decide whether or not to enter it. The Company advises to include this information in order to create helpful information space within the User community.

The Company shall reserve the right to use demographic information on its Users in generally accessible publications but in the aggregated form only, i.e. without individually referring to each User and without supplying these publications with lists of specific Users.

ADVERTISING AND LINKS

The Service shall contain links and advertising materials that direct the User to other sites. The Company emphasizes the fact that it shall not be held liable for the practice of regulating private rights to personal information privacy by these sites.

The Company shall strongly recommend to Users of its Service to read through the measures for regulation of private rights to personal information privacy of those sites to which they move from the Service's pages. The Company advises to read policies of those sites with special care where any User information is collected.

This Policy only applies to the Company's Service and data it processes.

POLLS AND CONTESTS

From time to time, various polls and contests may be held on the Service's pages. These may gear towards collecting additional demographic information on the Service's Users, which the Company needs in order to develop or improve the Service. Also, to cover the Service's operations for the general public. Results of these polls and contests may be published in generally accessible space. The same rules as those described in the Public Publications section apply.

If a contest caters for not-yet-registered users of the Service, contact information required to communicate with the contest winners may be requested. Such collected information is identical to information collected during registration, and the same rules as those described in the Information Collection during the User Registration apply to it.

TELL A FRIEND AND CORRESPONDENCE GAMES FUNCTIONS

If a User decides to employ such Service option as Tell a Friend, the User should enter the contact information of the person to whom the letter containing the proposal will be automatically forwarded. Also, the data of anyone who is not yet a registered User will be requested during this process. Therefore this collected information is identical to information collected during registration, and the same rules as those described in the Information Collection during User Registration section shall apply to it.

PROCEDURE FOR AMENDING THE POLICY

The Company shall undertake to notify the Service's Users in advance (in any event within 14 days) of all supplements and amendments made to this Policy. Users shall be notified of upcoming changes by changing the colour of the link of the wording of the Policy on the home page of the Service, from permanent blue to temporary red. In the period of notification of upcoming changes, both versions, the current (applicable) and the updated one, become available.

Last updated: July 2012