Please read the Privacy Policy carefully. When reading the text of this document, you must associate yourself with the User.

This Privacy Policy applies to all data and information that you, as a User, leave in the course of using and interacting with the https://asgard.estate/ site (hereinafter referred to as the Site) and regulates the processing (that is, collection, storage, use, systematization, etc.) of information received about you as a User of the Site.

This Policy does not apply in cases where the User clicks on Internet links that may be available on the Site.

Any interaction with the Site (for example: viewing, registering, using services, accepting offers) means that you have expressed unconditional consent to this document and the conditions specified therein.

In case of disagreement with these terms, you must refrain from interacting with the Site, using the services, and also stop the registration process on the Site.

For all questions regarding the conditions for processing information and your data, you must contact the support service through a special service on the Site or by e-mail [email protected].

1.1. This personal data processing policy has been drawn up in accordance with the requirements of Personal Data Protection Law, Federal Decree Law No. 45 of 2021 regarding the Protection of Personal Data, Data Protection Law, DIFC Law No. 5 of 2020, General Data Protection Regulation (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by ASGARD ESTATE FZCO (license No. 24755, DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, UAE (hereinafter referred to as the Operator).

1.2. The operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms in the processing of their personal data, including the protection of the rights to privacy, personal and family secrets.

1.3. This privacy policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can obtain about visitors and Users of the https://asgard.estate/ website

2.1. Automated data processing – processing of personal data and other information using computer technology.

2.2. Data blocking – is a temporary suspension of the processing of information and personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website – a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at https://asgard.estate/

2.4. Data information system — a set of personal data and information contained in databases, and ensuring their processing of information technologies and technical means.

2.5. Depersonalization of personal data — actions, as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other subject of personal data.

2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed with or without the use of automation tools, with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator – ASGARD ESTATE FZCO (license No. 24755, DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, UAE

2.8. User – any visitor to the Site.

2.9. Personal data – any information relating directly or indirectly to a specific User of the Site and allowing him to be identified.

2.10. Personal data authorized by the subject of personal data for distribution - personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data authorized by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter - personal data permitted for distribution).

2.11. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons.

2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquaintance with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – is the transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual or a foreign legal entity.

2.14. Destruction of personal data – any actions as a result of which personal data is destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and (or) material carriers of personal data are destroyed.

3.1. The operator has the right to:

• – receive reliable information and/or documents containing personal data and other information from the User;
• – if the User withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the User if there are grounds specified in the Law on Personal Data;
• – independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged to:

• – provide the User, at his request, with information regarding the processing of his personal data and other information about him;
• – organize the processing of information and personal data in accordance with the procedure established by applicable international law;
• – respond to requests and requests of the User in accordance with the requirements of the Law on Personal Data;
• – report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 30 days from the date of receipt of such a request;
• – publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
• – take legal, organizational and technical measures to protect personal data and other information from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
• – stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
• – perform other duties provided for by the Law on Personal Data.

4.1. The user has the right to:

• – receive information regarding the processing of his personal data, with the exception of cases provided for by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data relating to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. Each User can obtain such information by contacting the support service through a special service on the Site or by e-mail [email protected];
• – require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights. All requirements must be sent by e-mail to [email protected];
• – put forward a condition of prior consent when processing personal data in order to promote goods, works and services on the market;
• – to withdraw consent to the processing of personal data. The withdrawal of consent must be sent by e-mail to [email protected] in free form;
• – appeal to the authorized body for the protection of the rights of subjects of personal data or in court against illegal actions or inaction of the Operator in the processing of his personal data;
• – to exercise other rights provided for by international law.

4.2. The User is obliged to:

• – provide the Operator with reliable data about themselves;
• – inform the Operator about the clarification (update, change) of their personal data.

4.3. Users who have provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with international law, as well as in accordance with the legislation of the country of their residence.

5.1. The Operator may process the following data about the User:

• – Last name, first name, patronymic.
• – Email address, phone number, username in various messengers.
• – Year, month, date and place of birth.
• – Photographs.
• – Information about citizenship, residence permit, etc.
• – Details of the identity document.
• – Other information about the User that he provided on the Site or via e-mail [email protected]
• – Data that is automatically transmitted in the process of using the Site using the software installed on the User's device, including such data may be data on the use of services, data on viewing messages, date and time of access to services, and other similar information.
• – Data and information that is transmitted by the User when contacting the support service.
• – Data and information that are transmitted by the User by e-mail to the Operator.

5.2. The site also collects and processes anonymized data about visitors (including cookies) using Internet statistics services.

5.3. The processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.

5.4. The processing of personal data permitted for distribution from among the special categories of personal data specified in Articles 9.10 of the Law on Personal Data is allowed if the prohibitions and conditions provided for in Articles 9.10 of the Law on Personal Data are observed.

5.5. The Operator reserves the right to verify the accuracy of the information provided by the User, as well as to assess his legal capacity. At the same time, the Operator assumes that the User provides reliable and sufficient information about himself and keeps this information up to date. In case of revealing the facts of providing false information by the User, the Operator has the right to block the User and restrict his access to the Site.

6.1. The Operator collects and stores only the information that is necessary for the User to visit the Site, use its services and receive services.

6.2. The User's information is processed for the following purposes:

• (а) Identification of the User in the process of using the Site / receiving services.
• (b) Providing the User with personalized services and providing services, as well as concluding agreements and contracts.
• (с) Communication with the User, including sending notifications, requests and information regarding the use of the Site and the receipt of services.
• (d) Improving the quality of services provided, receiving feedback from Users, increasing the usability of the Site, developing new products and services.
• (e) Conducting statistical and other studies.
• (f) Sending promotional offers, including offers of services.
• (g) Conclusion of agreements with the Operator or other legal entities, information about the services (goods) of which is posted on the Site.

6.3. The User agrees that the information provided by him will be used to personalize the content on the Site.

6.4. The processing of personal data and information is carried out on a legal and fair basis.

6.5. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. It is not allowed to process personal data that is incompatible with the purposes of collecting personal data.

6.6. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

6.7. Only personal data that meet the purposes of their processing are subject to processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.

6.8. The storage of personal data is carried out in a form that makes it possible to determine the subject of personal data, no longer than required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

6.9. The Operator has the right to send notifications to the User about new products and services, special offers and various events. The user can always refuse to receive informational messages by sending an email to the Operator at [email protected] with the note "Refusal of notifications about new products and services and special offers".

7.1. The User agrees that some of the information provided by him will be available to other Users of the Site, namely: nickname or name, e-mail and other means of communication. If it is necessary to hide any data from other Users, the User must use the appropriate functionality of the Site or send an email to the e-mail address: [email protected].

7.2. The User's data specified by him on the Site, transmitted by him through the support service or by e-mail are processed by the Operator. In cases where the User is not in the UAE, the User agrees to the cross-border transfer of his data to the Operator.

7.3. The Operator has the right to transfer the User's information to third parties in the following cases:

• (а) when the User has consented to such actions, or
• (b) when the transfer is necessary for the execution of a certain agreement or contract, including an offer with the User, or
• (с) at the request of public authorities, judicial authorities and officials, or
• (d) in other cases provided for by international law.

The data of the User who has entered into any agreement using the Site (information on the Site) is also transferred by the parties to the concluded agreement.

If it is necessary to withdraw consent or change the data, the User must send a corresponding application to the e-mail address [email protected].

7.4. If necessary, in order to conclude agreements and provide services, at the request of the Operator, the User undertakes to provide his personal data. Personal data is any information relating directly or indirectly to the User, including, but not limited to: last name, first name, patronymic, date and place of birth, passport data, status. If personal data is not provided at the request of the Operator, the User's access to the services and the Site may be limited.

7.5. In case of transfer of his personal data, the User expresses his unconditional consent to their processing and storage.

7.6. The User is responsible for any information published by him on the Site, in services and chats dedicated to the ASGARD ESTATE project, and agrees that this information will be available to other Users. The User agrees that any information posted by him on the Site in services and chats dedicated to the ASGARD ESTATE project can be read, collected or used by other Users and third parties (if it is in the public domain).

7.7. The user independently decides on the provision of his personal data and gives consent freely, of his own free will and in his own interest.

8.1. The user can at any time change (update, supplement) the information provided by him or part of it by sending an email to the email address: [email protected].

8.2. The user can delete the personal information provided by him at any time by sending an email to the email address: [email protected].

8.3. The rights provided for in clauses 8.1. and 8.2. of this Policy may be limited in accordance with the requirements of the law. In particular, such restrictions may provide for the obligation of the Operator to save the information changed or deleted by the User for the period established by law, and to transfer such information in accordance with the legally established procedure to the state body.

8.4. The user can withdraw consent to the processing of his personal and other data at any time by sending an email to: [email protected]. In some cases, the withdrawal of consent may result in the impossibility of receiving services (both in whole and in part).

9.1. The information provided by the User is stored for 6 months from the date of its provision, except for the cases specified in clause 9.2. of this Policy.

9.2. In case of acceptance by the User of offers, conclusion of agreements, the information provided by the User is stored for the entire period of the offer/agreement, as well as for 3 (three) years after the termination of the offer/agreement.

9.3. If it is necessary to reduce the storage period of the information provided by the User, the User can send a letter describing the situation to the email address: [email protected].

10.1. The Site may use cookies to personalize the capabilities of the Site and services, to provide the User with personalized services, to target advertising, for statistical and research purposes, as well as to improve the operation of the Site and the provision of services.

10.2. The user is aware that the equipment and software used by him to visit sites on the Internet may have the function of prohibiting operations with cookies (for any sites or for certain sites), as well as deleting previously received cookies.

10.3. The Operator may establish that the use of the Site and services is possible only if the acceptance and receipt of cookies is allowed by the User. In such cases, by using the Site, the User agrees to the placement of cookies in his browser.

10.4. The counters posted on the Site and in the services can be used to analyze the User's cookies, to collect and process statistical information about the use of the Services, as well as to ensure the operability of the services as a whole or their individual functions in particular. The technical parameters of the meters are determined by the Operator and are subject to change without prior notice to the User.

11.1. The legal grounds for the processing of personal data by the Operator are:

• – DATA PROTECTION LAW DIFC LAW NO. 5 OF 2020;
• – international legislation in the field of personal data protection;
• – Users' consent to the processing of their personal data, to the processing of personal data permitted for distribution.

11.2. The Operator processes the User's personal data only if they are filled in and / or sent by the User independently through special forms located on the Site or sent to the Operator via e-mail.

11.3. By filling out the appropriate forms and / or sending your personal data to the Operator, the User agrees with this Policy.

12.1. The operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by applicable law.

13.1. The User is obliged to ensure the safety of all data (login, password, ID, login and password from e-mail) of the User necessary to use the Site and receive services.

13.2. If there is information or suspicion of unlawful acquisition by third parties of the User's data, the User is obliged to immediately take all measures in his power and notify the Operator by e-mail [email protected].

13.3. All actions performed by Users on the Site, in services under the name (login) of the User are considered to be performed by the User.

14.1. The Operator takes the necessary and sufficient organizational and technical measures to protect the User's information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties with it.

14.2. In cases where any leakage of User data occurs, the Operator undertakes to inform the Users about it within 72 hours from the moment such a leak is detected.

15.1. This Privacy Policy is subject to change. When making changes in the current version, the date of the last update is indicated. The new version of the Policy comes into force from the moment it is posted, unless otherwise provided by the new version of the Policy.

15.2. In case of disagreement with the changes in the Policy, the User is obliged to stop using the Site. Continued use of the Site and its services means acceptance of the changes made to this Policy.

16.1. The user can receive any clarifications on issues of interest regarding the processing of his data by contacting the Operator via e-mail [email protected].

16.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.

16.3. The current version of the Policy is freely available on the Internet at: https://asgard.estate/

16.4. This version of the Policy is valid from 30.01.2023.