Terms and Conditions
Privacy Policy

1. General Provisions
1.1. This Privacy Policy is adopted in accordance with the Russian Federation Law on "Personal Data" No. 152-FZ of 26 July 2006 and sets out the procedure for processing of personal data as well as the measures to secure and protect the personal data by Multipoint Investments LLC (hereinafter – the Operator).
1.2. The first and foremost purpose of the Operator's actions related to personal data is observance of human rights and freedoms while processing personal data, including protection of right to a private life, personal and family secret.
1.3. This Privacy Policy related to processing of personal data (hereinafter – the Policy) shall apply to any information that can be obtained by the Operator with respect to visitors of the following website: www.multipointinvestments.com.


2. Key Terms
2.1. Automated personal data processing – processing of personal data using means of computer technology;
2.2. Personal data blocking – temporary suspense of personal data processing (excluding situations when processing is required for any kind of clarification of personal data);
2.3. Website – combination of graphic and information materials as well as hardware and databases that make such materials available in the Internet at: www.multipointinvestments.com;
2.4. Personal data information system — combination of personal data contained in databases as well as information technologies and technical means allowing processing of such personal data;
2.5. Personal data anonymization – actions with personal data resulting in inability to identify personal data of a particular User or any other personal data subject without an additional information;
2.6. Personal data processing – any action (operation) or combination of actions (operations) with personal data including collection, record, systematization, accumulation, storage, clarification (update, change), extract, use, transfer (circulation, provision, granting access), anonymization, blocking, deletion and destruction using automatic means or without them.
2.7. Operator – a state body or municipal authority, legal entity or natural person that is responsible, individually or collectively with other persons, for organization and/or processing of personal data, definition of purposes of personal data processing, scope of personal data to be processed, as well as any actions (operations) related to personal data;
2.8. Personal data – any information directly or indirectly related to a being identified or already identified User of the website www.multipointinvestments.com;
2.9. User – any visitor of the website: www.multipointinvestments.com;
2.10. Provision of personal data – actions aimed at disclosure of personal data to a specified person or unspecified group of people;
2.11. Distribution of personal data – any action aimed at disclosure of personal data to an unspecified group of people (distribution of personal data) or at making such personal data publicly available, including by means of mass media, data telecommunication networks or any other means;
2.12. Cross-border personal data transfer – transfer of personal data to either the territory of a foreign state, or the foreign state body, or the foreign legal entity or natural person;
2.13. Destruction of personal data – any actions resulting in irrevocable destruction of personal data without possibility of further recovery of its contents within the defined personal data information system and/or resulting in destruction of physical storage of such personal data.



3. Scope of Personal Data being processed
3.1. The Operator can process the following personal data of the User:
  • Name, Patronymic and Surname;
  • E-mail address;
  • Phone numbers;
  • Anonymized users' data (including "cookies") via third-party web analytics services such as Yandex.Metrica, Google Analytics and others.
3.2. The abovementioned data hereinafter collectively referred to as Personal Data.



4. Purposes of Personal Data processing
4.1. Key purpose of the Personal Data processing is general informing of Users via e-mail; conclusion, performance and termination of contracts; granting Users' access to the services, information and/or materials on the website.
4.2. Operator can notify Users of new products and services, personal offers and various events. The User can unsubscribe from any such newsletter at any time by sending a request to hello@multipointinvestments.com with a headline "Unsubscribe".
4.3. Anonymized Personal Data collected using various web analytics tools is necessary for general evaluation of Users' activity on the website and further improvements of the website's content and quality.



5. Legal grounds for Personal Data processing
5.1. Operator processes Users' Personal Data only when the specific forms located on the website www.multipointinvestments.com are completed and/or sent to the Operator by Users. By completing the respective forms and sending the Personal Data to the Operator the User agrees to the terms and conditions of this Policy.
5.2. Operator processes anonymized data of Users only if it is allowed by the respective settings of a particular User's web browser (storage of "cookies" and JavaScript settings are on).



6. The way Personal Data is collected, stored, transferred and processed
6.1. Security of Personal Data processed by the Operator is guaranteed by the implementation of necessary legal, organizational and technical measures that are defined by current legislation of the Russian Federation in the field of personal data protection.
6.2. Operator guarantees protection of Personal Data and takes all necessary measures in order to prohibit access of any unauthorized persons to Personal Data.
6.3. Users' Personal Data shall in no case be transferred to an unauthorized person, unless such transfer is required by the terms of current legislation.
6.4. In case of any discrepancies found in Personal Data, the User can make necessary clarifications by sending an e-mail to the Operator at hello@multipointinvestments.com with a headline "Personal Data Update".
6.5. The term of processing of Personal Data by the Operator is unlimited. The User can withdraw his/her consent to personal data processing at any time by sending an e-mail notice to the Operator at hello@multipointinvestments.com with a headline "Personal Data Consent Withdrawal".



7. Cross-border Personal Data Transfer
7.1. Before initiating the cross-border Personal Data transfer the Operator shall make sure that the foreign state receiving any such data provides reliable protection of the personal data subjects' rights.
7.2. Cross-border Personal Data transfer to territories of the foreign states that do not provide adequate level of data protection can be conducted either with the written consent of the personal data subject for any such cross-border data transfer, or under the terms of an agreement for which the personal data subject is a party to.



8. Final Provisions
8.1. User can obtain all necessary information and clarifications related to processing of his/her Personal Data by way of a direct request to the Operator at: hello@multipointinvestments.com.
8.2. This Policy shall be in effect for an unlimited period unless it is amended by the Operator and replaced by the new version in due course.
8.3. The current version of the Policy can be found at: www.multipointinvestments.com/terms-and-conditions.