This Privacy Policy is part of the Terms of Service for the Jazz Up website and includes any
separate privacy notices and/or notices posted on particular pages of the Website that may provide more
detail regarding the information we collect on those pages, why we need that information, and choices
you may have about the ways we use that information. No matter where your information is collected,
used, transferred or stored, if it was collected through the Website, it will be subject to the terms of this
Privacy Policy.
The Operator in the context of this Regulation on the processing of personal data is the Jazz Up
Ltd., registered as a company under the law of the Russian Federation in the state register of legal entity
under registration number 1047796781020 dated October 15, 2004. As part of ensuring the operation
of the Jazz Up website, the Operator may transfer part of the collected information for analytics, the
formation of development strategies and other activities that ensure the effective operation of the mobile
Website, to other legal entities and individuals (performers, subcontractors, agents and employees)
under contracts to the extent permitted by law and is reasonable and justified for commercial purposes,
while being responsible for the actions of these persons.

We may collect and use the following personal information that identifies, relates to, describes,
is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly,
with a particular consumer:
· Information provided to us directly by you; and
· Information collected automatically when you use the Website.
Personal data of end users: data about the device, including the version of its operating system
and location; anonymized IP address, advertising identifiers GAID (for Android) and IDFA (for iOS),
information about user behavior in the data exporter’s mobile Website/ website, other data provided by
the data exporter to importer.
Information You Provide To Us Directly
When you download, register with, or use this Website, we may ask that you provide:
· User Content (e.g., photos, facial scans, comments, feedbacks and other materials) that you post
to the Website.
· Information you provide to other users through the Website.· Information you provide for customer service (e.g., email, country\region information, records
and copies of your correspondence, etc.)
· Communications between you and Jazz Up. (For example, we may send you Website-related
emails. Note that you may not opt out of Website-related emails insofar as this is due to the policies of
the platforms (services) from which you download the Website.)
Information We Collect from Your Use of the Website
When you use the Website, it may use technology to automatically collect:
· Analytics Information.
We use third-party analytics tools to help us measure traffic and usage trends for the Website.
These tools collect information sent by your device to our Website, including the content and ads that
you view or click, analytics events (all actions in the Website) linked to device_id (unique identifier of
the user's device) and other information that assists us in improving the Website. We collect and use
this analytics information in the aggregate with analytics information from other users so that it cannot
reasonably be used to identify any particular individual user.
· Location Information.
Upon your consent, we may collect different types of information about your general location
(e.g., IP address) or more specific location information (e.g., precise location from your mobile GPS)
through methods such as mobile “SDKs” which allows us to periodically determine your location,
including your location relative to and within third-party merchant locations, and share such information
with third parties, for purposes related to advertising (e.g., customized ads in the Website), analytics,
attribution (e.g., measuring ad performance), and research (in this case, the correctness of such data in
the case of using VPN services is received and processed in the mode declared by the user's device).
You may prevent location information from being collected by this or other apps through your device
settings (but this may affect the functionality of certain Website features). We may collect this
information when the Website runs in the background on your device.
· Behavioral Advertising Information
When you use the Website, we allow third-party companies to collect certain information. These
companies may utilize cookies, pixels, or other similar technologies to collect and use non-personally
identifiable information in order to provide advertisements about goods and services likely to be of
greater interest to you.
· Log Information.
When you use the Website, we may automatically collect and store certain information in server
logs. This may include:
- Information on how you interact with the Website (e.g. google account).
- Your IP address.
- Device event information such as crashes, system activity, hardware settings, browser type,
browser language, the date and time of your request and referral URL.
· Metadata.
Metadata refers to technical data associated with user content. Put simply, metadata is data that
describes data. For example, metadata can describe the analysis results of facial features, the characters
in photos, and other elements contained in photos, which are generated and tagged by the computer
algorithm and artificial intelligence. When you use the Services, we will use photo metadata to provide
you with certain features including precise “Facial Recognition,” “Key-Points Recognition”, “Region
Segmentation, “Content Tags” and other custom features based on a combination of these basic features.
We may use your photo metadata to provide you with more suitable filters and better photo effects when
the Website processes your photos; we may also make use of the metadata to serve up more contextually
relevant products or services to you.
· Local Storage.
- We may access metadata and other information associated with other files stored on your device.
This may include, for example, photographs and contacts for the purpose of inviting friends to use the
Website.Information Collection and Tracking Technologies
· Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be
possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone.
However, if you select this setting you may be unable to access certain parts of our Website.
· Web Beacons. Pages of the Website may contain small electronic files known as web beacons
(also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example,
to count users who have visited those pages and for other related app statistics (for example, recording
the popularity of certain app content and verifying system and server integrity).

In addition to some of the specific uses of information we describe in this Privacy Policy, we
may use information that we receive and the choices you make in your settings:
· To provide the functionality of the Website;
· To help us develop, deliver, test and improve the Website;
· To monitor metrics such as total number of visitors, traffic, and demographic patterns;
· To provide personalized content and information to you and others, which could include sending
you promotional messages, marketing, advertising and other information that may be of interest to you;
· To diagnose or fix technology problems;
· To allow us to keep you posted on latest product announcements, Website updates, and
upcoming events;
· To provide customer support and respond to your inquiries and requests;
· To allow professionals to contact you through the Website (as further described below);
· To administer referral programs, rewards, surveys, contests, or other promotional activities or
events sponsored or managed by us or our third-party business partners;
· To find and prevent fraud;
· To comply with our legal and regulatory obligations;
· For the performance of any contract with you or to take steps at your request before entering
into a contract;
· In any other way we may describe when you provide the information;
· Where you have given consent; or
· For any other legitimate interest or those of a third party, including the third parties identified
in Section 4 (Information Sharing and Disclosure to Third Parties), below

Third-Party Service Providers
We use a variety of third-party service providers to help us provide the Website including
business analytics, marketing, and other services. These providers have limited access to your
information, including in some instances User Content, to perform these tasks on our behalf and are
contractually obligated to use it consistent with this Privacy Policy.
Third-Party Advertising Network
We may share or disclose non-personally identifiable information, aggregated, usage
information, geolocation information or device-level information (such as anonymous usage data,
platform types, number of clicks, location data, etc.) with unaffiliated partners and third parties (e.g.,
advertising networks) that wish to market products. You can control or disable the use of location
services for the Website in the device’s settings menu. See Section 6 “Your Choices About Your
Information” of this Privacy Policy for further instructions.
Professionals and Other Users
Any information that you provide to other users via the Website are shared and disclosed to them.
By sending your information to other users, you acknowledge and agree that they may contact you via
the Website.
Business Transfers and AffiliatesWe may share your information with companies or organizations connected or affiliated with
Jazz Up. We may also transfer your information to an affiliate, a subsidiary or a third party in the event
of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any
portion of Jazz Up’s business, assets or stock, including, without limitation, in connection with any
bankruptcy or similar proceeding.
Legal Disclosures
Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose
your information if we believe that it is reasonably necessary to comply with a law, regulation, legal
process, or governmental request; to protect the safety of any person; to address fraud, security or
technical issues; or to protect our or our users’ rights or property. However, nothing in this Privacy
Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including
a government’s, request to disclose your information.

Further to Section 4 of this Policy, we would like to clarify that such information is categories of
personal data that identifies, relates to, describes, is capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular consumer:
· Identifiers:identifiers such as a real name, alias, postal address, unique personal identifier (such
as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology;
customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or
probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, and
other similar identifiers
· Online Activity: Internet and other electronic network activity information, including, but not
limited to, browsing history, search history, and information regarding your interaction with websites,
Websites or advertisements
· Sensory Information: audio, electronic, visual, and similar information
· Inferences: inferences drawn from any of the information identified above to create a profile
about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes.

Promotional Communications
You may opt out of receiving promotional communications from us by following the instructions
in those messages. If you opt out, please note that we may still send you Website-related
communications, such as those about your account or our ongoing business relations.
Opting Out of Interest-Based Advertising Services
You may opt-out from any interest-based advertising by turning on “Limit Ad Tracking” in your
device settings.
To limit Ad Track on an Apple device, see instructions at:
https://support.apple.com/en-us/HT202074
To limit Ad Tracking on an Android device, see instructions at:
https://support.google.com/ads/answer/2662922
Please note that opting-out will not block general advertisements that are sent at random and not
tied to your perceived interest.
Control or Disable the Collection of Geolocation Information
You can control the collection of certain precise location information by changing the preferences
on your mobile device (but certain services may lose functionality as a result).
The withdrawal of consent to the processing of personal data by the subject of personal data is
carried out by the Operator within 10 days from the date of such withdrawal. To withdraw consent to
the processing of personal data, the subject can use the functionality of the Website by: (1) deleting theprofile in the profile settings; (2) contacting technical support using the contact information published
in the relevant tab on the technical page of the Website.

The Operator may process and retain your personal information for the period necessary to get
consent from you or to accomplish the purpose of the task specified in the Terms and Conditions and
Privacy Policy.
If the period specified below expires, all information, including personal information, will be
deleted.
· Records on the provision of goods or services: until the supply of goods or services is
completed, or the use of the service is terminated.
· Inquiries about the use of services: until the troubleshooting is completed.
However, in any of the following events, the information may be stored until the relevant issues
are resolved.
· In the event that an investigation is in progress due to violation of relevant laws and
regulations in each service country: until the investigation is completed.
· In the event that residual claims and debt relationships result from service use: until the
relevant claims and debt relationships are settled.
· If otherwise specified in the laws of the country providing the service: until the deadline
required by the applicable laws.

This Website is not intended for children under 18 years of age. We do not knowingly collect or
solicit any information from anyone under the age of 18 or knowingly allow such persons to register
for the Website. If you believe that we might have any information from or about a child under 18,
please contact us at info@up-jazz.ru.

Your information collected through the Website may be stored and processed in the Russian
Federation or any other country in which Jazz Up, its affiliates or service providers maintain facilities.
As such, we and our service providers may transfer or access your personal information in jurisdictions
that may not provide equivalent levels of data protection as your home jurisdiction. By registering and
using the Website, you consent to the transfer of information to the Russian Federation or any other
country in which Jazz Up, its affiliates or service providers maintain facilities, and to the use and
disclosure of information about you as described in this Privacy Policy.

The Operator cannot fully ensure the security of any information you transmit to the Jazz UpKE
Website or guarantee that information on the Website may not be accessed, disclosed, altered, or
destroyed. You are responsible for maintaining the secrecy of your unique password and account
information at all times. Your privacy settings may also be affected by changes that the social media
services you connect to Jazz Up to their services. We are not responsible for the functionality, privacy,
or security measures of any other organization.

The Website may contain links to third-party sites or online services. We are not responsible for
the practices of such third parties, whose information practices are subject to their own policies and
procedures, not to this Privacy Policy.

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences
regarding tracking by advertisers and other third parties. We do not currently respond to DNT signals.

The Operator may modify or update this Privacy Policy from time to time, so please review it
periodically. We may provide you additional forms or notice of modifications or updates as appropriate
under the circumstances. Your continued use of the Website after any modification to this Privacy
Policy will constitute your acceptance of such modification.

If you have questions or concerns about Jazz Up’s Privacy Policy or to submit a request for
information, please contact us at info@up-jazz.ru.