PERSONAL DATA PROCESSING POLICY

(PRIVACY POLICY)

ESCA Global LTD

21/07/2020

This policy is covered on usage by websites, which are operated under the group of companies ESCA Global LTD, if it is third-parties application, original site-pages, on behalf of group of the companies ESCA Global LTD used on the platforms such as Facebook either YouTube, also, the applications which mentioned here ( next — " Ours/web-site/s " ).

WHAT IS "PERSONAL DATA"?

Personal data is any information that relates to an identified or identifiable living individual.



WHY DO WE NEED PERSONAL DATA TO PROVIDE SERVICES?

When you visit our website, certain data (for example, your IP address, type of device, type of browser, etc.) is automatically collected by our devices. In some jurisdictions, including EU countries, such information is classified as personal in the relevant regulatory acts on the protection of personal data.

Also the website stores data about how, in what sequence you interacted with the site, including the pages you visited and the links that you clicked on. Data processing and storage of such data allows us to personalize the content of the site and make the visit more efficient and convenient. This data is partially collected using cookies, more detailed information you can find in the Cookie Policy section.

HOW WE COLLECT YOUR PERSONAL DATA?

We receive your personal information from different sources, such as :

Data that you provide voluntarily:

• When you register and fill out forms and questionnaires on the website, communicate over the phone, send us emails, you leave your identification, contact and other data;

• When you use ESCA Global LTD products or services;

• When you subscribe to publications of ESCA Global LTD or third parties related to;

• When you agree to receive promotional materials and newsletters;

• When you participate in loyalty programs, promotions, surveys, contests ESCA Global LTD;

• When you leave feedback and comments on the ESCA Global LTD website.

ESCA Global LTD in some cases may request certain personal data that you can provide at your discretion. Please note that the request must list the exact personal data that you are requested to provide.

DATA COLLECTED BY THE COMPANY AUTOMATICALLY:

When you visit our website, certain data (for example, your IP address, type of device, type of browser, etc.) is automatically collected by our devices. In some jurisdictions, including EU countries, such information is classified as personal in the relevant regulatory acts on the protection of personal data.

The website also stores data about how, in what sequence you interacted with the website, including the pages you visited and the links that you clicked on. Processing and storage of such data allows us to personalize the content of the site and make the visit more efficient and convenient. This data is partially collected using cookies, information about which can be found in more detail in the Cookie Policy.

WHAT PERSONAL INFORMATION DO WE COLLECT AND STORE?

Providing customer service

Type of data:

Provision of the Services Type of data: identification information (name, surname, country of residence, address and other similar information), contact details (email address, phone number, web page and others), copies and images of national identification documents (passport, id-document, permission of residence and others). Purpose: register you as a client, the provision of the opportunity to use the services of the Company, the provision of the opportunity to carry out non-trading operations in accordance with the Rules for Non-Trading Transactions, the receipt of the opportunity to collect information regarding the occurrence of possible debt to the Company. Marketing Type of data: contacts, consent, and correspondence. Purpose: marketing activity and the provision of information regarding the products and services of the Company. Automated decisions/ Type of data: The psychological profiling by analyzing personal data, using software that evaluates your specific personal characteristics and predicts risks or outcomes. For example, we can analyze personal information about your general behavior on the website and the decisions which you made. Purpose: adoption of automatic decisions, including profiling, assignment to a certain category of interests, risks, offers of loyalty packages, according to potential interests. Automated decision-making is the process of making a decision by automated means without any human involvement. In cases of making an automated decision, you have the opportunity to challenge the decision and require a decision to be reviewed by an employee of the Company.

Common purposes, for which we can use Your personal data:

• for our services and the fulfillment of our treaty obligations to customers and other third parties;

• for the analysis, processing, and settlement of claims;

• for data analysis, which helps us assess risks, determine the cost of our products and improve the quality of our services;

• to prevent and use cases of fraud, legalization of illegally obtained money, terrorism and other crimes;

• to develop new and improve the quality of existing services;

• to conduct and expand our business activities;

• to perform verified biographical data, if it is permitted by law;

• to provide administrative activities;

• for the implementation and protection of our customers or third parties;

• to cooperate with oversight bodies by which we going under and met its legal obligations;

• for research and development of new products;

• for marketing purposes.

TO WHOM PERSONAL DATA IS REFERRED TO?

ESCA Global LTD has the right to provide your personal data to third parties in the following cases:

• For companies related to the ESCA Global LTD group of companies. Since we are an international company, we can share your personal data within the group. Moreover, this information is protected by this Policy and is used for the purposes listed in this document.

• Insurance companies, intermediaries, financial institutions, retrocessionaires and business partners who use your personal information in connection with the provision of services and / or claims processing. For example, we can transfer your personal information to law firms, lawyers for the settlement of claims.

• Service providers who provide us with services and conduct other business with us, for example, IT and analytics service providers, insurance service providers, auditors, and consultants.

• To any law enforcement agency, court, supervisory authority, public authority or professional organization, at their legal request or for the purpose of resolving a conflict.

To any third party, when we sell assets or a company from the ESCA Global LTD group of companies or a significant share in them. In the event of such a sale or transfer, we will take reasonable and measures so that the acquirer of your personal data takes the necessary steps to protect the received data in accordance with the terms of this Policy.

HOW DO WE USE COLLECTED DATA?

The information you provide to ESCA Global LTD is used to identify you and render services. The information we receive when you use the website is stored by us, and we act as its controller. The information may then be used to make contracts and filling documents, to register personal accounts. The information may also be used to support and improve services, develop new services, personalize services, particularly, content and announcements, track performance, communicate with users, etc.

ACCESS TO INFORMATION BY THIRD PERSONS

ESCA Global LTD may share user information with its employees, agents, contractors, partners and other companies associated with ESCA Global LTD for the purpose of rendering services. In doing so, the persons to whom the information has been transferred are required to adhere to Present Privacy Policy.

The persons and entities above may use the information about users only for the purpose of rendering the services, they are not allowed to disclose and use the information for other purposes.

DISCLOSURE OF PERSONAL INFORMATION

We do not disclose/transfer your personal information to companies, organizations and/or any third party not affiliated with ESCA Global LTD for the purpose of rendering services. The following constitute an exception:

(1) The user herewith agreed. In order to provide companies, private persons or other users that are not affiliated with ESCA Global LTD an additional user consent shall be requested. The user may revoke this consent at any time.

(2) Transfer of personal information in cases prescribed by law. Your personal information may be disclosed if required to do so by the competent authorities, in the manner prescribed by applicable law, including but not limited to, if required by law, in connection with any legal proceedings or in order to protect legal rights.

(3) Transfer of personal information in the event of sale or other assignment of corporate rights. In case of sale of the company or any similar assignment of corporate rights, your personal information will be transferred to the new owners of the corporate rights.

(4) Fraud detection and prevention. Your personal information may be shared with law enforcement agencies for fraud prevention and suppression purposes.

(5) Maintenance of technical or security problems.

COOKIE FILES

ESCA Global LTD uses cookies to improve the functionality of the site, to allow users to navigate between pages, to remember the choices of users regarding the settings of the site.

We also use cookies to analyse how you use our service and interact with the website. You can read more about cookies in our Cookie Policy at www.e-s-c-a.com

YOUR RIGHTS

You have the following rights with respect to the personal information that we store:

(1) Right of access. If you ask us, we will confirm whether we process your personal information and, if necessary, provide you with a copy of that personal information within 5 days from the day of receiving such a request. As a result, you will be provided with a .pdf file which will include all personal information we process.

(2) Right to amendment/modification. If the personal information we hold about you is inaccurate or incomplete, you have the right to request for it to be amended or changed. If personal information is amended /modified, if it has been transferred to a third party, the amended personal information will be transferred to the third party again.

(3) The right to delete. You may ask us to delete your personal information if we no longer need it and you are against its storage. You can make such a request via e-mail to __________@____. If the information has been transferred to third parties, you can contact the latter directly with a deletion request.

TERM OF DATA STORAGE

Your personal data is stored for a period no longer than it is necessary for the purposes of processing and rendering services, in accordance with the regulatory requirements. Your information may be stored up until you request its deletion.

If you withdraw your consent to this Agreement, the processing of your personal data will be terminated by ESCA Global LTD and/or third parties and the data will be deleted.

PROTECTION OF PERSONAL INFORMATION

ESCA Global LTD takes necessary and sufficient organizational and technical measures, such as: login and password system and two-factor authentication to protect your personal information from unauthorized or accidental access to prevent the destruction, alteration, blocking, copying, distribution, unauthorized access to your personal information and data obtained during the use of the website or services ESCA Global LTD.

ESCA Global LTD restricts access to your personal information to employees, agents and contractors through strict contractual obligations, in accordance with the General Regulations for the Protection of Personal Data (GDPR 2016/679).

The security of your use of the services is also up to you. You must keep your account details, login and password confidential. You shall report to ESCA Global LTD any suspicion of unauthorized access or use of your account.

LEGAL INFORMATION

The validity, interpretation and enforcement of the Present Policy shall be subject to the laws of the England and Wales.

If any provision of this Policy or its application to any person or circumstance is held invalid or unenforceable, the remainder of the Policy or the application of this provision to other persons or circumstances shall not be affected and shall remain in full force and effect.

All disputes and disagreements that arise upon any matter between the user and ESCA Global LTD and threaten their rights and interests in relation to the preparation or application of the Present Policy, or any costs, obligations under the Present Policy, or in relation to any action related to the Present Policy shall be settled by negotiation.

In doing so, the Parties have agreed on the following dispute resolution procedures:

either party may notify the other party in writing, including by email, of a claim that has arisen in relation to or is related to the terms of this Agreement;

In case of receipt of notification of the claim, the Parties shall appoint a meeting within 10 (ten) working days (including a meeting by teleconference or similar) to discuss the dispute and make efforts to resolve them, or send a written reasoned response to the claim to the available electronic addresses of the Parties within the specified period;

In the event that the dispute has not been resolved within ten (10) business days from the date of receipt of the notice, and the parties do not agree to hold the meeting and take further action to resolve the dispute within that time, the parties can make a written complaint by sending it to the electronic addresses available to the parties;

In case of failure to achieve results through negotiations within 1 (one) month from the date of receipt of the claim, the dispute shall be resolved in accordance with the laws of the England and Wales.

AMENDMENTS TO THE PRIVACY POLICY

ESCA Global LTD may update and amend the provisions of the present Policy at any time. A new version of this Policy will take effect at the time of posting, unless otherwise provided by the provisions of the new version of the Policy.

By continuing to use our website, you accept the latest changes.

ESCA Global LTD recommends you to check the present Privacy Policy on a regular basis to review the most current version of the Policy.

If you do not agree with this Policy, you must stop using or accessing our website and notify us immediately by mail to _______________@_____.

This policy is covered on usage by websites, which are operated under the group of companies ESCA Global LTD, if it is third-party application, original site-pages, ESCA Global LTD partners' behalf on our name can save cookies on your devices when you visit our websites, used on the platforms such as Facebook either YouTube, also, the applications which mentioned here (next — " Ours/website/s ").

ESCA Global LTD uses your cookie files can collect, use and disclose your personal data only in the cases which are required by law. Additional information about usage of personal data, which collected ESCA Global LTD' cookie files, you can receive having seen Policy processing of personal data.

By using our websites, you agree to the use of cookies described in this Policy. If you don't want your cookie-files installed on your PC, you can change your browser settings or revoke your consent to set cookies, as described below in this policy, and also stop using the ESCA Global LTD group of websites.

WHAT IS A COOKIE?

A cookie is a small piece of data (consisting of text and numbers) that is downloaded to your device connected to the Internet (for example, to a personal computer, smartphone or tablet) every time you visit our website. It helps the site remember information about you. Cookies are used by the site in order to recognize your device, to store information about your preferences or previous actions, for example, the language you chose for the website.

For more information about the protection of personal information when using cookies and other data, see our privacy policy.

Please check out our ways of using cookies. You can ask us any questions you may have by sending an email via: sales@e-s-c-a.com.

HOW ESCA GLOBAL LTD USES COOKIES

ESCA Global LTD uses cookies in order to improve the functionality of the site, to ensure smooth transition between pages, to remember your choice for settings of the website. We also use cookies to analyze how visitors use our service and interact with the site.

ESCA Global LTD may collect information about users for other purposes without the consent of users in cases stipulated by law.

CATEGORIES AND PURPOSES OF COOKIES USAGE

The categories of purposes for using cookies-files

CATEGORIES OF COOKIES PURPOSES OF COOKIES USAGE Required cookies-files/ These cookies-files required for the ESCA Global LTD that websites can function properly. Without these cookies, it's impossible to navigate the site, use the services you have chosen, or return to the previous page viewed during the session. These cookies used to not identify your identity. All information collected by these cookies is presented in a generalized form and therefore is anonymous. The information collected is used only to increase the efficiency and performance of our website, as it collects data regarding the time, frequency of your visit to the site, pages you visited, services that you used. Cookies-files which use for expanded functional capacities/ Using these cookies, your interaction with the website becomes more personalized, as it saves your chosen options (for example, your username, website language or region of residence, changes made to the text size, and other changes to the settings of web pages, watched videos). Cookies may collect personal data that you disclosed. If you refuse to install these cookies, the negative consequences may be the deterioration of the functionality of the website, as well as the restriction of your access to the contents of the website. Cookie-files which use to collect anonymous and aggregated statistic/ Using these cookies, we analyze the use of our websites by visitors to improve the structure and content of websites, increase the effectiveness of advertising campaigns conducted on the websites of ESCA Global LTD. Cookie-files, which shows targeted ads and advertisement/ o These cookies are aimed at delivering content that is relevant to your interests, showing targeted advertisements or limiting the number of times an individual advertisement is displayed, as well as measuring the effectiveness of advertising campaigns conducted on ESCA Global LTD websites. o Most of these cookies track visitors by identification of device or IP address, so they can collect personal data. Third parties cookies ESCA Global LTD partners' behalf on or name can save cookies on your devices when you visit our websites. In order to identify these cookies, and the purpose of their use until the actual determination, so that you can decide whether you want to install these cookies or not, we apply the following measures: · - we identify cookies, then connect to their providers to find out the information collected by these files. We describe and place in the needed category so that you can manage them. - we cooperate with partners responsible for the implementation of digital technologies and advanced features on our websites. For example, when you visit ESCA Global LTD websites, you may receive third-party cookies that are used to support some functions of these websites (for example, demonstration of YouTube videos). Third-party cookies can be set even if you reject to use them on our website. In this case, you must go to the website of the third-party provider and refuse to set cookies on it. o Attention! It's difficult to track the cookies of third-party providers quickly. This means that it is possible that the information stored in these cookies may contain personal data.

STORAGE DURATION OF COOKIE-FILES WHICH USED BY US

According to the information retention period, cookies set by ESCA Global LTD and / or third-party providers are divided into two varieties:



Session cookies. These are temporary cookies which are stored and collect information on your device as part of your one visit to the website until the moment you leave our website.



Permanent cookies. These cookies are set on your device for the long-term, they are not deleted if you end your visit to the website. Sometimes up to the moment of their manual removal. The duration of the cookie on your device is not the same - it depends on the type of cookie, as well as your browser settings.



HOW CAN I MANAGE COOKIES / DELETE COOKIES

You can refuse to use or block all or specific types of cookies created as a result of your visit to the ESCA Global LTD website by defining your preferences for cookies on our website.



You can also change your preferences on the ESCA Global LTD website and / or on the websites of any third-party suppliers by changing your browser settings.



Most browsers automatically allow cookies, and therefore, if you do not want to use them, you may need to take actions to delete or block cookies. By refusing to use cookies, you will still be able to visit our sites, however, some of the functions may not work properly.



Access to certain ESCA Global LTD functionality is only possible with cookies enabled. Disabling such cookies may lead to the result that you will not be able use all the functions of the site.



Learn how to disable cookies in a web browser according to instructions from the developer:

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If you are using a different web browser, click on the help icon in your browser for more information.