CONFIDENTIALITY POLICY

(as amended on December 28, 2017)

MESSAGGIO Ltd., Company ID C86217, (the COMPANY hereinafter) pays considerable attention to keeping confidential any information shared with the COMPANY by Users (the USERS hereinafter) of the Internet-resource https://client.messaggio.com (the Internet-resource hereinafter) for the purposes of possible cooperation.

The COMPANY makes every effort for protection, safe storage and nondisclosure of the confidential information shared by the USERS.

This Confidentiality policy (the CONFIDENTIALITY POLICY hereinafter) shall apply to any information which the COMPANY may receive about the USER in the course of his/her using any of the COMPANY’s resources, including information provided by the USER independently upon registration (creation of an Account) or in the course of using the Internet-resource (the INFORMATION hereinafter).

The CONFIDENTIALITY POLICY constitutes an official document of the COMPANY.

The COMPANY shall keep to principles ensuring confidentiality according to requirements set forth by the applicable laws and regulations of the Republic of Malta, and according to general ethical standards and rules.

Using the Internet-resource shall mean unconditional consent of a User to the CONFIDENTIALITY POLICY and the terms and conditions of processing the INFORMATION contained therein, and if a USER disagrees to these terms and conditions a USER shall restrain from using the Internet-resource or shall cease using the same.

1.GENERAL PROVISIONS

1.1. The CONFIDENTIALITY POLICY shall set a list of the INFORMATION, which the COMPANY may receive about a USER, and shall further set forth a procedure for processing the INFORMATION.

1.2. The purpose of this CONFIDENTIALITY POLICY is to ensure due INFORMATION protection from unauthorized access by third parties and from unlawful disclosure.

1.3. This CONFIDENTIALITY POLICY constitutes a public document placed in the Internet-resource.

1.4. This CONFIDENTIALITY POLICY shall apply to any relations between USERS and the COMPANY. The COMPANY shall bear no liability for any third party actions.

1.5. The COMPANY shall not generally verify the INFORMATION provided by USERS, and shall not control their capacity. However, the COMPANY shall assume that a USER shares true and sufficient INFORMATION and keeps the INFORMATION updated.

2.THE PROCEDURE FOR THE INFORMATION PROCESSING AND DISCLOSURE TO THIRD PARTIES

2.1. In the course of the INFORMATION processing the COMPANY shall follow the following principles:

2.1.1. The INFORMATION must be processed on legal and fair basis.

2.1.2. The INFORMATION processing must be limited to achieving specific, pre-determined and legitimate objectives. No processing inconsistent with the purposes for the INFORMATION collection shall be allowed.

2.1.3. No integration of databases containing the INFORMATION, which processing is implemented for any inconsistent purposes, shall be allowed.

2.1.4. Only INFORMATION meeting processing requirements shall be processed.

2.1.5. Contents and scope of processed INFORMATION must meet stated processing objectives. No processed INFORMATION shall be excessive with regard to stated processing objectives.

2.1.6. Accuracy and sufficiency must be ensured in the course of the INFORMATION processing, and relevance with regard to the INFORMATION processing objectives, in case of necessity.

2.1.7. The INFORMATION shall be kept in a form allowing USER identification, and only as long as is needed for the INFORMATION processing objectives.

2.1.8. If no storage term is set forth for the INFORMATION by a contract, whereto the USER constitutes a party, a beneficiary or a sponsor, any processed INFORMATION shall be subject to destruction or depersonalization upon achievement processing objectives or in case of no further need to achieve the same.

2.2. The COMPANY shall store the INFORMATION about a USER according to internal rules of a respective information system.

2.3. In regard to USER INFORMATION it shall be kept confidential, except when a USER willfully shares INFORMATION about himself/herself for general public access.

2.4. The COMPANY shall be entitled to disclose the INFORMATION about a USER to third parties in the following situations:

2.4.1. A USER expressed his/her consent to such actions.

2.4.2. The disclosure is required for rendering services to a USER.

2.4.3. The INFORMATION disclosure is set forth by the CONFIDENTIALITY POLICY.

2.4.4. The disclosure is set forth by the laws and regulations of the Republic of Malta as part of a legally established procedure.

2.5. By accepting the terms and conditions of the CONFIDENTIALITY POLICY a USER shall give his/her consent for receipt, storage and processing of the INFORMATION required for giving access to the Internet-resource, rendering services, execution, performance and termination of contracts and agreements with a USER.

3.INFORMATIONPROCESSING

3.1. INFORMATION processing for the purposes of this CONFIDENTIALITY POLICY shall mean a complex of the COMPANY’s actions, including acquisition, recording, systematization, accumulation, storage, refinement, retri, usage, disclosure, destruction of the INFORMATION.

3.2. The COMPANY shall process INFORMATION shared by USERS according to a USER’s consent to process the same.

3.3. The INFORMATION about a USER shall be collected:

- in the course of using the Internet-resource;

- upon execution, amendment, termination of contracts/agreements with USERS;

- in other cases.

3.4. The COMPANY may store the INFORMATION about USERS in soft or in hard copies.

3.5. A USER shall herewith give his/her consent for the INFORMATION disclosure by the COMPANY, which INFORMATION is listed in the Internet-resource provided that such persons shall accept obligations in ensuring confidentiality of any disclosed INFORMATION.

3.6. The COMPANY shall be entitled to destroy the INFORMATION about a USER, i.e. perform actions resulting in impossibility to restore the INFORMATION contents.

4.INFORMATIONPROTECTION

4.1. The COMPANY shall take necessary and sufficient organizational and technical measures for protecting INFORMATION about USERS from illegal or accidental access, destruction, modification, blocking, copying, distribution as well as from other illegal actions in its regard by any third parties

5.AMENDMENTS IN THE CONFIDENTIALITY POLICY. GOVERNING LAW

5.1. The COMPANY shall be entitled to amend this CONFIDENTIALITY POLICY, in which case a date of the most recent amendment shall be stated in a renect version. A new version of the CONFIDENTIALITY POLICY shall become effective upon its placement in the Internet-resource, unless otherwise set forth in a most recent version of the CONFIDENTIALITY POLICY.

5.2. The COMPANY shall be entitled to amend the terms and conditions of the CONFIDENTIALITY POLICY any time without prior announcement.

5.3. This CONFIDENTIALITY POLICY and relations between USERS and the COMPANY resulting from application of this CONFIDENTIALITY POLICY shall be governed by the laws and regulations of the Republic of Malta.

6.CONTACTS.QUESTIONS AND SUGGESTIONS

Please, forward any questions and suggestions related to this CONFIDENTIALITY POLICY to the following COMPANY’s addresses:

Registered address:Level 3, Ewropa Business Centre, 701, Dun Karm Street, Birkirkara, BKR9034, Malta

Contact phone: +356 99552288

E-mail: info@messaggio.com