Documents

The Cookie Policy (hereinafter referred to as the "Policy") applies in addition to the general The Privacy Policy, which applies to the products and services of the My Media Library Bot Project (hereinafter referred to as the "Media Bot") and/or its affiliates. The policy describes the types of cookies, the purpose of their use and the ways in which you can opt out of them.

1. What are cookies and what does a Media Bot use them for

Cookies are small pieces of data with service information about site visits that the server sends to your device. Cookies store information about your preferences and allow you to view the visited sites in a more convenient mode for you for a certain time. For example, thanks to cookies, Services offer you to view information in the language you normally use.

The media Bot uses cookies in order to:

  • to help you stay logged in to the Services;
  • improve the quality of your work with the Services;
  • show information that is of priority to you;
  • save your advertising preferences and secure search settings;
  • display ads that may be of interest to you;
  • analyze Service usage statistics.

Based on the data obtained using cookies, the Media Bot develops the most useful functionality for the Services you use, conducts statistical and marketing research, corrects errors in the Services and tests new functions to improve the performance of the Services, personalizes them and shows the most relevant information for you.

2. What cookies does the Media Bot use

The media bot uses various types of cookies. The main task in using them is to ensure the convenience of your work with the Services, maintain a high level of security in their work, count the audience, help with payments, page transitions, and so on. All Media Bot cookies are of one of the following types:

(i) Technical cookies that are necessary for proper operation and provision of full functionality of the Services. One of the most common technical cookies, for example, is media_bot_uid or session_id. They are installed automatically and provide the possibility of authentication and subsequent authorization in the Services. secure_session_id cookies are used to authorize users and ensure the security of credentials when making payments.

(ii) Analytical and marketing cookies that allow you to:

  • recognize users, count their number and collect information, for example, about operations performed, pages visited and views on Services;
  • identify your hardware or software, for example, browser type or device (using the device_id cookie);
  • collect information about how you interact with the Services, for example, whether a service or product has been purchased;
  • ensure the relevance of advertising, increase the effectiveness of advertising campaigns.

(iii) Other cookies perform various service functions and make it easier to work with Media Bot sites and services. These files help you remember the state of the page, select a region (for example, using the gid cookie), save personal preferences, for example, such customizable site elements as text size, font (for example, using the font_loaded cookie), and more.

A media bot can use web beacons (pixel tags) to access cookies previously placed on your device. Their use is necessary to analyze your actions when working with the Services by accessing and using cookies stored on your device to collect statistics on the operation of the Services themselves or the products and utilities of the Media Bot.

The web analytics tool of the Media Bot, which is used by the Media Bot, allows you to collect impersonal information about traffic sources, site traffic and evaluate the effectiveness of advertising. To keep track of visitors, the Media Bot uses anonymous browser identifiers that are stored in cookies.

Disabling some of these types of cookies may make it impossible to use certain sections or functions of the Services. For example, access to sections of Services that require authorization is provided by technical cookies and the site may not work correctly without using them.

3. How long are cookies stored on your device

The Media Bot uses session cookies to make it easier for you to work with the Services. For example, using the cookie cookie_check, your authorization data in the Services is stored and when you switch to another domain zone, you no longer need to go through the authorization process again. Session cookies expire at the end of the session (when you close the page or browser window).

The Media Bot may also use cookies that are stored for a longer period, for example, to remember your preferences on Services, such as language or location. The data retention period depends on the type of cookies. Such cookies will be automatically deleted after they have completed their task.

The Media Bot uses the information contained in cookies during the terms and conditions specified in this Policy, as well as in Privacy Policy.

4. Manage cookies

When visiting the Services for the first time in a pop-up window (or using another technical solution) You may be asked to select the types of cookies that will be recorded on your device. At the same time, technical cookies are set automatically when the page loads, unless otherwise specified in the browser settings. If you approved the use of cookies, but then wanted to change your mind, then you can do it yourself by deleting the saved files in your browser.

You can also change the settings for displaying personalized ads or disable such ads using the functionality posted at: (still in development).

The Media Bot does not require mandatory consent to install cookies on your device when using the Services. If you do not want cookies to be stored on your device, disable this option in your browser settings. Saved cookies can also be deleted at any time in the browser's system settings. You can change your browser settings to accept or reject by default all cookies or cookies from certain sites, including Media Bot Services.

If you have approved the use of cookies on one of the Yandex services, this will mean that you have given such consent for the use of cookies on all Media Bot Services.

5. Who-besides-the-Media-Bot-has access to the information contained in the cookies

The information that is collected using cookies placed on your device is stored in accordance with applicable law in accordance with the terms of sections 7 and 8 Privacy Policy.

Media Bot partners may also collect information about users using cookies or pixel tags as part of their use of the Services. The use of cookies and other technologies allows the Media Bot and its partners to analyze activity when using the Services, counting the number of visits or showing ads adapted to the services of the Service.

Information collected using cookies placed on your device can be transferred and made available to the Media Bot and/or partners on the terms of Privacy Policy. The use of the collected information outside the Services may be subject to separate user agreements available on partner sites. The Media Bot and/or partners may also provide you with the opportunity to opt out of the personalization of advertising, in accordance with the laws and regulations applicable to such products and offers.

Date of publication: 16.06.2024 г.


Living on Earth, We are constantly learning something new, experimenting with creativity and sharing experiences with other people, learning a lot in practice, participating in each other's lives and helping with both word and deed — this is the essence of a Media bot. During the existence of the team, we have formulated for ourselves the rules that we adhere to in our work. This is not a strict code, but a set of conclusions that help Media Bot employees in different cities and countries make decisions. We are publishing this internal document so that our users and partners also know what is important to us. These principles are not set in stone, from time to time we change something, so you can keep an eye on updates.

General principles of creating services

  1. We create services that benefit people and give them new opportunities. We make services that we would like to use ourselves, share with friends and family. We don't create services just for the sake of making money.
  2. We strive to create objective services based on the fullest and most accurate reflection of the reality around us. To do this, we aggregate various data, such as web pages or user reviews.
  3. Our work is based on the principles of honesty and transparency. We assume that any internal dialogue, document, or source code can become public under certain circumstances. And if that happens, we shouldn't be ashamed.
  4. The user is our main customer, that is, the one for whom we work and make services. This applies not only to people who turn to the Media Bot for solving everyday tasks, but also to our partners: shops, restaurants, couriers, drivers, content creators and everyone else. They are all our users.
  5. We are aware of our responsibility for the services these people use, and we try to develop them in such a way as to maximize the benefits and minimize the harm. Therefore, for example, we try to take into account many aspects that may be related to our services at the development stage.
  6. We create services with respect for the local peculiarities of the market: legislation, culture, language, mentality and other manifestations of human activity. We call this the translocality principle.
  7. Technology is our core competence. We create services based on technology. Therefore, when we decide to develop a service, we think about how to use technology to create additional value in it.
  8. We are not afraid to admit our own mistakes and close services that have ceased to benefit people. Creating something useful is more important for us than not making mistakes.
  9. We try to look critically at everything we do and evaluate our services, anticipating user reactions. And although it does not always succeed, We try to ensure that these reactions are always positive.

Commerce

  1. We strive to ensure that our services can exist and be useful to people in the long term. To do this, we create services that will contribute to the general welfare and free comprehensive development of each member of society, which will make it necessary for people.
  2. We are developing some services despite the fact that they will never become profitable. We do this because we believe in their value and benefit to people.
  3. The media bot develops business services that are available to a large number of companies at once, and does not develop on the order of individual organizations.
  4. We do not deceive users and do not earn money by cheating.
  5. We do not create services aimed at monetization through sweepstakes and casinos. We also do not advertise casinos, sweepstakes, pyramids, or other zero-sum or negative-sum attractions.
  6. We place social and charitable advertising according to special rules that were developed together with experts and differ from the rules for commercial advertising. In order for the process to be transparent for advertisers and users, we have published these rules, and we are also releasing a report on social advertising, where we indicate all the details of the campaigns. Social advertising is marked with a special sign.

Data

  1. We use user behavior data only to create new services for them and improve existing services. In particular, we never sell data about our users.
  2. We are aware of the responsibility that storing a large amount of data about users entails for us, for example, what they are looking for in a search. Therefore, the security of user data is one of our priorities. We carefully protect our users' data and treat them very carefully.
  3. If we are required to disclose data at the request of law enforcement agencies, we do so strictly according to the law and only to the extent necessary. We consider only those requests from government agencies that come through official communication channels and meet all formal requirements. On a separate page of the corporate website, we collect data on the number of such requests and publish reports every six months.

State and society

  1. We, the employees of the Media Bot, may have different political opinions, religious views and positions. However, the products of our activity — that is, the services of a Media bot - have no position and no political coloring: they work equally well for everyone. We do not create services that lead to the division of society on political, racial, religious or other grounds. We are international, i.e. we understand the importance of each ethnic group, its cultural and religious characteristics, and consider each ethnic group to be part of a single family - Humanity.
  2. The media bot is open to dialogue with society and the state. The ability to listen to society and respond to public demands, while remaining in the legal field, is a necessary condition for the development of the company.
  3. We comply with the laws of the countries in which we operate, and we are also aware of our role in the development of the market. We try to promote the constructive development of legislation related to the impact of new technologies on society.
  4. We provide government agencies with the same services as the rest of the market. At the same time, we interact with them according to the same principles and on the same terms (including price) as with commercial customers. We do not change products by order of the state and do not develop special services for the state.
  5. We do not develop military technology.
  6. Since it is impossible to draw a clear line between personal opinion and the company's position in social networks and other modern communications, company executives do not speak publicly on political topics. These restrictions do not apply to all other employees who express their personal opinions in their statements, and not the position of the company.
  7. In cases of emergencies, as well as other threats to life, health, freedom or other human rights, we make services that help people receive information necessary to ensure their safety and improve their well-being, both material and psychological.

Competitors

  1. We do not support competition, because we consider cooperation, co-creation and constructive criticism between different market players to be better than competition, when each market player does not strive to maximize personal profit, but strives to improve the life of the whole society. Nevertheless, in terms of opportunities, we advocate for equal conditions for all companies. We don't want our competitors to lose their rights. We want to win in a fair competition with those who lead it. We proceed from the fact that the principle of equal applicability of working conditions and rules should apply to all companies in the market, including the Media bot. We are ready to interact and have a dialogue with everyone.
  2. We also do not support competition between global and national companies, as this, among other things, contributes to the emergence of conflicts between countries, therefore we are against the fragmentation of the Internet and do not make decisions that contribute to it. Nevertheless, competition with global players encourages us to be stronger, more patient and wiser.
  3. If we hire employees from competing companies, we do it with the sole purpose of getting a qualified employee, and not for competitive intelligence. We respect someone else's NDA as much as our own.
  4. We do not publicly criticize competitors and their products. We can only be responsible for our services and we only talk about them. At the same time, we are ready to conduct a constructive dialogue with representatives of these companies, including ways to improve their products and integrate with ours.
  5. We give the opportunity to advertise within our general offer to any businesses permitted by law. But at the same time, we believe that it is fair if the platforms that are advertised with us would also provide us with access to promotion on their platforms.
  6. We assume that competing services on the Internet are just a click away for the user, and if the user does not like something about one service, he can quickly switch to another. We do not restrict people in any way in the right to switch to services competing with us and receive information about these services.
  7. The ranking of search results is based on the criterion of usefulness — how much a specific element in the appropriate place solves the user's task along with other elements on request. Media Bot services are also ranked according to this principle.
  8. We are convinced that the user has the right to independently choose which services to use "by default", and we oppose market practices that restrict this right.

Artificial intelligence

  1. Our goal is to create AI algorithms whose solutions strive for what we would do ourselves. Artificial intelligence systems learn from the examples that people give them. Therefore, when training our algorithms, we take a very careful approach to preparing samples on which they train to make decisions.
  2. Security is primary for AI. All decisions and predictions of our algorithms must be reproducible. The trained algorithms are tested in the laboratory before launch. We carefully monitor all the decisions that our algorithms make.
  3. Ranking should always take place according to an algorithm, the principles of which can be clearly and transparently told publicly. This is especially true for all kinds of tops and ratings.

Distribution

  1. Before installing the application, we explicitly tell the user what he is installing. We don't hide this information behind a click or in small print. If it is necessary to accept the license agreement during installation, the person must be given the opportunity to read this document.
  2. We do not install one program or application as part of another unnoticed by the user. Also, we do not create shortcuts on the desktop without the user's consent to install the program.
  3. Before adding new functionality to the application, we collect the maximum amount of objective data to verify its usefulness.

Company culture

  1. In a Media bot, they trust each other - this is the basic principle of creative freedom. We proceed from the fact that any Interlocutor of a Media bot is a professional who does not need to be monitored, he does not need to be followed. The right to act and make decisions is given to the interlocutor in exchange for insight into his whole, actions and results.
  2. The culture of a Media bot is not hierarchical. We try to express a professional opinion regardless of the employee's responsibilities. It is customary to bring and explain, but it is not accepted to command and order, because these are primitive ways of interaction, and we strive for more complex, high-level interactions.
  3. we value honesty and do not deceive each other.
  4. A career in a Media bot depends solely on the professional qualities, abilities and results of a person. Regalia and connections do not play any role when we take root, who to hire or perform duties.
  5. From now on, we treat each other according to ethnicity, age, gender, sexual orientation, traditions and views.

Sustainable development

  1. We believe that education is one of the most reliable means to change the world for the better, and we develop educational programs in the field of mathematics and IT for people of different ages and from different regions. We train IT specialists for everyone, not just for ourselves.
  2. We strive to build services that are accessible to all users, including people with disabilities. Our technologies help transform the barrier not only into the digital environment, but also beyond it.
  3. We are betting on system usefulness. That's why we include mechanics in our services, which allow people to help non-profit organizations, loved ones or other people in everyday life, and help themselves.
  4. we take responsibility for the air that the company exerts on the environment: we give priority to energy-efficient solutions, striving to reduce the volume of packaging and use recyclable materials.

Valid from July 20, 2024

These Rules of Business and Corporate Ethics (hereinafter referred to as "these rules") apply to all employees of the Media Bot, as well as to members of the Board of Directors. These rules are based on the principles set out in applicable legislation and in international documents: Universal Declaration of Human Rights, The Guiding Principles of Business Activity in the context of Human Rights of the United Nations, ILO Conventions, Principles of the UN Global Compact.

The media bot strives to adhere to the highest standards of business ethics when conducting business activities. The company expects that we will also adhere to the requirements of business ethics by participating in business activities on behalf of the Media Bot.

The media bot adheres to the principle of zero tolerance for any violations of the rules of corporate ethics.

These rules include provisions that are mandatory for all employees of the Media Bot Group companies and members of the Board of Directors. Failure to comply with these rules can lead to negative consequences, including legal ones, both for us and for the Media Bot.

We should study these rules, as well as other policies, rules and The principles adopted in the Media Bot. Each of us is responsible for ensuring that we all comply with the requirements of legislation, other regulations, as well as the requirements of business and corporate ethics applicable to the activities of a Media bot. It is the responsibility of each of us to know and understand the provisions contained in these rules, as well as to comply with the policies and rules adopted in the Media Bot. Managers must take the necessary measures to ensure that their team members understand and comply with the requirements of these policies and rules.

It is important for us that our business partners also adhere to ethical behavioral practices: Supplier Code of Business Conduct.

1. We work for users

2. Working in a Media bot

3. Compliance with the law

4. Conflict of interest

5. Confidential information

6. Making deals

7. Environmental responsibility

8. Reporting

9. Complaints and liability for violation of the rules

10. Making changes and deviations from the rules

1. We work for users

The key goal of our activity, and this is reflected in various internal documents of the Media Bot, is to provide high-quality services for millions of Internet users. It is extremely important that each of us strive to achieve this goal. First of all, we think about the user characteristics of the service, how much people will like and use it.

The company expects all of us to be responsible not only for our part of the work, but also for the product as a whole.

Be not indifferent to user reviews. Suggest improvements. If you notice that something is not working or is not working correctly on one of the Media Bot services, be sure to inform the responsible managers about it.

Our business is largely based on the high reputation of the Media Bot and the trust of our users. This trust is the result of many years of hard work by many people and one of the core values of the Media Bot brand.

Keep in mind that when using our services, people trust us with their data. This may be the user's personal information (for example, passport or payment data), our correspondence with him, knowledge of his social connections, and much more. Our internal procedures restrict access to any non-public user information. It is strictly confidential and can only be used for the purposes for which it was collected. When working with such personal data, you must keep them confidential and prevent their disclosure and dissemination.

2. Working in a Media bot

Equal rights

We consider discrimination unacceptable in making any work decisions — nationality, gender, race, political or religious views, sexual orientation and other characteristics unrelated to a person's professional qualities and performance of official duties do not matter to us. When applying for a job, the Media Bot provides all candidates with equal opportunities. We hire those who are able to best cope with the proposed tasks. We respect human rights and support the protection of these rights. The use of illegal child and forced labor in any form is unacceptable in the Media Bot. Any exploitation of a person by a person is unacceptable, therefore, cooperative principles are applied in the Media Bot.

Working relationship

We should be guided by exactly the same principles in professional communication. Violence or threats of violence, insults, rude statements on topics of gender, race, nationality, religious and political views, sexual orientation, and so on are unacceptable in a media bot. Any form of sexual harassment — unwanted sexual acts against another person - is also prohibited. Such actions are strictly suppressed.

Working hours, wages, occupational safety and health

The media bot complies with applicable local laws governing labor relations (including wages, working hours, overtime).

The Company recognizes the right of employees to freedom of association and collective bargaining and respects this right, as well as the right to the result of their work, including personal contribution to the result of collective work.

We consider it important that the Media Bot be and remain a safe place to work, therefore, we commit ourselves to ensuring safe working conditions and monitoring the level of exposure of employees to harmful and dangerous industrial factors, as well as taking the necessary measures to prevent emergencies.

The media bot monitors the proper condition of the equipment, informs employees about the rules of labor protection, and, if necessary, provides personal protective equipment.

The Company undertakes to identify and eliminate the causes of incidents, keep appropriate records of them, and provide affected employees with the opportunity to receive the necessary medical care.

The offices of the Media Bot are arranged in such a way that employees can work in them as conveniently, comfortably and safely as possible, as well as spend time after work.

Company property and resources

The company provides us with everything we need to work. This is the property of a Media bot. The company expects us to treat it with care. Despite the fact that the use of such resources for personal purposes is not prohibited, the company expects that we will use them responsibly and within reasonable limits. Maintaining offices in such a way that it is pleasant and comfortable to work in them is also the work of our colleagues, which we respect.

We have open offices, and all employees can bring their guests. At the same time, remember that you are fully responsible for ensuring that your guests do not interfere with anyone's work and that confidential information does not leak. While the guests are in the office, they should not be left alone, unaccompanied.

Intellectual property

Our intellectual property includes, among other things, the logo, trademarks, patents, software products, etc. These are very important and valuable assets of a Media Bot, and any use of them by our external partners or use for external events must be agreed in advance with the head of the PR service. If you come across an object of intellectual property of a Media bot and you doubt the legality of its use, please report it to the legal department.

The media bot respects the intellectual property of third parties. Misuse of someone else's intellectual property can lead both a team member and a Media bot to lawsuits and fines, as well as negatively affect our reputation. If your project involves the use of any content or software that does not belong to a Media bot, you should definitely consult with lawyers.

3. Compliance with the law

It is the responsibility of each of us to comply with the requirements of applicable legislation. We expect each of us to comply with the requirements of applicable laws and other regulations when carrying out activities on behalf of a Media Bot. It is important to know the legal requirements, because we have services, some of the functions of which may depend on the legislation of a particular country.

We must comply with the requirements of applicable legislation governing import, export and other trade aspects of business activities in the countries of our presence. In addition, it is necessary to comply with trade and economic sanctions restrictions imposed in various states, if they apply to our companies, team members and the activities of the Media Bot.

We must take into account that part of the legislation of all countries and territories of our presence that directly relates to our professional duties, that is, regulates the provision of that service in a certain country and in a certain territory for which we are responsible. For advice, you need to contact the lawyers of the Media bot, and this must be done at the design stage of the service.

Bribery is a crime in all countries where the Media Bot is present. We strictly prohibit any form of bribery, including bribes, commercial bribery, as well as other types of illegal payments in order to obtain or maintain advantages in carrying out business activities or obtaining approvals from regulatory authorities. We must follow the requirements of the policy regarding receiving gifts and entertainment. We prohibit making such illegal payments even if such payments are acceptable in certain places where the Media Bot is present. It should be remembered that local customs or practices are in no way an excuse for committing a crime.

We must not offer, give, demand or accept money or valuable gifts, services, etc. for the purpose of (1) obtaining, maintaining advantages in carrying out business activities, (2) guaranteeing or receiving any more favorable treatment. A direct or indirect promise of a bribe is equivalent to giving a bribe in accordance with the law. When we make a decision on behalf of a Media Bot to purchase any resources or services, we should choose contractors impartially, taking into account the competitiveness of the prices offered, the quality of goods or services, as well as the reliability of potential suppliers. We must not accept bribes or other illegal or inappropriate payments, gifts or services.

The Company is committed to the principle of fair, fair and free competition and undertakes to conduct business in full compliance with antitrust and competition laws in force in the regions in which the company operates.

4. Conflict of interest

We have certain obligations to the Media Bot. In particular, the company expects that in our professional activities we are guided primarily by the interests of our users and our common interests as a team. A conflict of interest is a work situation in which there is a contradiction between the personal interests (or the interests of your friends, close relatives, partners) and the interests of the Media Bot team.

In the context of corporate ethics, close relatives include parents, children, siblings, official and de facto spouses; people with whom you are in a romantic relationship, and any other people important to you who may influence your work decisions.

To understand how much a particular situation contains a conflict of interest, think about how it looks from the outside. Can you tell your boss and other colleagues about it? If a description of this situation appears in newspapers and blogs, how will it affect the Media Bot? Each of us should avoid conflicts of interest, as well as situations that can be interpreted as a conflict of interest.

Corporate opportunities

You cannot use for personal purposes (or use for your close relatives or friends) any opportunities that the company's resources, information or position open up to you. These opportunities are the sole and exclusive prerogative of the Company. For example, if you find out about a potential deal with a Media bot as part of your job responsibilities, you will not be able to independently conclude this deal on your behalf - this right belongs to the Media Bot. It is your duty and responsibility to promote the legitimate interests of the Company whenever the opportunity arises.

Work and personal life

You cannot use your position in a Media bot to benefit close relatives, friends and partners: this is a conflict of interest between the company and your friends or relatives. Conflicts of interest when working with close relatives happen:

  • if one of the relatives works under the other;
  • if relatives are involved in the same business process or both are involved in decision-making on the same interdependent issues and other employees of the Media Bot are not involved in decision-making.

However, conflicts of interest should be avoided when working together not only with close relatives, but also in any form of relationship, when the impartiality and independence of your decisions may suffer.

For example, if you have a loved one working under you, there is a possibility that you will provide him with more favorable working conditions, and evaluate the results more loyally than the results of other employees. And even if your decisions are not influenced by a special attitude towards this person, other employees may believe that this is not the case. In this case, it is worth conducting surveys and discussions with colleagues to get a more objective picture and eliminate this conflict.

Combining work in a Media bot with other work

Each of us can work part-time or engage in personal business in our free time. However, such work should not conflict with working in a Media bot. Combining work in a Media bot with other professional activities may lead to a conflict of interest if:

  • at the same time as working in a Media bot, you work for a competing company or consult with it;
  • you use or can use the results of your work or the work of your colleagues in the Media Bot or the equipment, premises, software of the Media bot to perform other work;
  • you use or can use your official position and authority in the Media Bot to obtain favorable conditions for your second company or your business;
  • you use the Media Bot's working hours to do other work;
  • you use the confidential information of the Media Bot to perform work outside the company or to obtain favorable terms for another company or business that you own, participate in or are interested in.

The best solution would be to coordinate this combination with colleagues and management.

Business gifts and hospitality

One of the situations that can create a conflict of interest or look like a conflict of interest is accepting gifts, gratuitous services, or signs of hospitality from partners (for example, entertainment, trips, lunches or dinners).

The media bot expects that all gifts and hospitality that we receive or provide will comply with the following principles:

  • have a reasonable cost;
  • do not create a conflict of interest;
  • are legal;
  • comply with local customs and business rules;
  • do not make the recipient feel obligated;
  • are not and do not give anyone a reason to consider them a bribe or commercial bribery;
  • should not be extorted by the recipient.

The company has procedures for approving gifts that must be followed when giving or receiving gifts.

How do we accept gifts

We should not accept expensive gifts from business partners, the cost of which exceeds 11 thousand rubles, as well as money and cash equivalents (certificates, e-money cards, etc.), regardless of their nominal value.

It is acceptable to accept standard products of service partners as a gift: subscriptions and other marketing products of partners (promo codes, certificates, discounts, etc.) if their annual cost does not exceed 11 thousand rubles or this is done within the framework of agreed promotions.

It is important to remember that when accepting such gifts from a partner, you need to be guided not only by the acceptable value of the gift, but also by whether you personally make business decisions regarding this partner. For example, you can accept discounts from a partner if they apply to all employees. But if a partner offers such a gift for the personal use of a certain employee, then additional approval will be required in accordance with the company's procedures. Gifts of minor value (and not in the form of money), such as flowers, fruit baskets, pens and other promotional items, can be accepted. You can also accept invitations to business breakfasts, lunches, dinners or festive events — unless you believe that this invitation complies with the above principles and is not a means to influence you.

There are no more universal definitions here, so you need to think about each specific situation. For example, you can accept a notebook, but not a new iPhone or an expensive watch. If we are talking about a collective gift, for example, for all employees of a particular department, evaluate how expensive a gift each of them receives as a result. It is also worth considering if a partner offers you to go on vacation at his expense or invites you to an event abroad and promises to pay for your business class flight and a suite at the hotel.

How we give gifts

We try to comply with the same rules by providing gifts and hospitality to our partners. We also do not want to create a sense of conflict of interest in relation to them.

You can give business gifts within the acceptable cost and corresponding to the principles of business gifts of a Media bot, branded souvenirs of a Media bot, standard discount products of a Media bot, including promo codes and other standard discount products, subscriptions of Media bot services, if the annual cost does not exceed the acceptable cost or it is done within the framework of agreed promotions.

It is unacceptable to give money and cash equivalents to partners (cash certificates, e-money cards, etc.) regardless of their nominal value.

In addition to these rules, local laws or regulations may prohibit or severely restrict the provision of gifts or hospitality to government employees (for example, employees of ministries, departments, services). Therefore, before giving something to a government employee or inviting him somewhere at the expense of a Media bot, make sure that this does not violate local legislation. Some types of gifts, including those that go beyond the above rules, require prior approval according to the procedures established in the company.

Other examples of conflict of interest:

  • if you have a stake or other significant interest in a company that competes with a Media bot or is a supplier or client of a Media bot;
  • if in a transaction that you make on behalf of a Media bot, you have personal financial interests that can influence your decisions;
  • if you use the name of the Media bot for personal purposes, for example, for your personal business. We have to take a survey regarding conflicts of interest when it is conducted by a Media bot. Each of us must notify the Media Bot about each case of a conflict of interest through a survey form.

5. Confidential information

Privacy

We have a lot of confidential information that concerns our technologies, partnerships, finances, etc. For example, this is technical information about the functioning of our products and services, user data, user logs, product promotion strategies, planned transactions, business plans, financial results of the Media bot before their public announcement. Disclosure of such information can cause significant harm to a Media bot, therefore it is prohibited before public disclosure, and when applying for a job, each of us signs an Obligation not to disclose confidential information and agrees to comply with the Trade Secret Provision.

Even if you think that due to your job responsibilities you do not have access to any confidential information, working in a Media bot, it is quite difficult not to find out anything secret. For example, you can hear a conversation between colleagues or find a printed document in the printer. Remember that you have committed not to disclose any confidential information (even to colleagues if they do not have access to such information) and use it only for the performance of your official duties. You should not attempt to gain access to confidential information unless your official duties imply obtaining such access.

Information security

One of the important aspects related to maintaining the confidentiality of information is compliance with the requirements of the information security service. If you: notice suspicious network activity, computer behavior similar to a manifestation of a virus infection; suspect that some Media Bot services have been hacked, or know about other security violations, be sure to inform the information security service.

Communication with the outside world

In answering questions from third parties related to the Media Bot, follow common sense, the recommendations of the PR service, as well as the Provision on Trade Secrets of the MEDIA BOT. In the process of negotiations with partners, a situation may arise when you need to provide certain confidential information. This can only be done by signing a Non-disclosure Agreement with a partner. Please make sure that this agreement is actually signed before you tell us anything secret.

When communicating with colleagues from competing companies, do not specifically try to find out anything confidential. There are companies that we compete with, and we do it honestly, without trying to get their secrets. If your friends or close relatives work in competing companies, please be careful when talking to them about professional topics.

When interacting with government authorities in the countries of presence, it is necessary to follow the recommendations of the GR-service of the Media bot (Department of Corporate Relations). You can communicate with government officials on behalf of a Media Bot only if you are authorized to do so. When communicating with officials, you can only express the official position of the Media bot. If you do not know the position of the Media Bot on a particular topic, you should forward the question to the GR managers. If questions are received from the media, they should be forwarded to the PR service.

6. Making deals

When making deals, we must always strive for the best deal and always act in the best interests of the Media Bot team. It is important to pay attention not only to the cost, but also to other factors, such as the reputation of the company with which we are starting to cooperate.

The Media Bot has internal procedures governing the access of certain employees to funds, as well as giving some people the right to sign contracts on behalf of the company. Information about who can sign and approve certain expenses and contracts is contained in internal documents.

We expect all people authorized to sign contracts and manage any amounts from the Media Bot's budget to be attentive and take a reasonable approach to spending, and signing contracts only after receiving the necessary internal approvals. If you sign a contract, make sure that you understand everything in it and agree with everything. All contracts must be approved in accordance with internal procedures. Before entering into a contractual relationship, an analysis of the counterparty's integrity should be carried out, as well as verification of the signatory's authority.

7. Environmental responsibility

We are aware of our responsibility to society for environmental protection and adhere to the following principles in our work.

The media bot is attentive to its responsibilities in relation to environmental protection, work with hazardous materials, emissions of harmful substances into the air and water, and waste.

The company strives to efficiently use energy, water, raw materials and other resources, pay attention to combating climate change and energy efficiency issues.

We give preference (as far as possible) to the use of recycled, reused and recyclable materials, and encourage contractors to use the most environmentally friendly packaging materials.

8. Reporting

Data accounting

The media bot keeps complete and accurate records of the business and financial aspects of its activities. We must keep accurate, complete and timely records of all assets, debts, income and expenses, as well as Media Bot transactions. Misrepresentation of records and reports, as well as concealment of information, the accounting of which is necessary, is strictly prohibited and may result in dismissal. From the moment we receive or create records and reports, we must ensure that they are properly stored.

Audit

The Media Bot, like all public companies, has internal and external auditors whose task is to check financial statements and evaluate the internal control system. If you have received a request from the auditor to provide any information, you must understand that you are obliged to provide complete and reliable information without any distortion or manipulation.

9. Complaints and liability for violation of the rules

Filing and handling complaints

We have a confidential hotline that employees can use,

users, partners and clients for reporting violations of these rules. The hotline is open in the form of a special form through which you can send a request.

The line is organized by a third party independent of the Media Bot. Each request is assigned a number during registration, which can later be used to review the decision or provide additional information.

Reports received by the hotline are reviewed by the complaints review group, which includes members of the ethics committee.

Questions about the operation of the Media Bot services should be posted via feedback forms on the pages of these services.

Any form of harassment against those who in good faith seek help, provide information or otherwise assist in the investigation of any known or alleged violations is strictly prohibited in the Media Bot.

Bringing to justice

Each employee of the company is personally responsible for compliance with these rules (from disciplinary to criminal). The leaders of the violators, if they knew about the violation but did not do anything, also bear disciplinary responsibility.

Issues related to non-compliance with the principles of business corporate ethics of a Media bot by business partners of a Media Bot are addressed in the Supplier Code of Business Conduct.

Deviation from the rules

Deviations from these rules may be allowed in relation to specific situations and only in exceptional cases. Deviations from these rules may be allowed or prohibited at the discretion of the Media Bot and must be publicly disclosed if such a requirement is provided for by applicable law, regulation or rules.

10. Making changes and deviations from the rules

The Ethics Committee may amend these rules as necessary.

Employees must take part in trainings conducted in the Media Bot aimed at familiarizing themselves with the requirements of these rules. These trainings are conducted by the ethics committee annually or at other intervals.


adopted on July 20, 2024,

valid from July 22, 2024

Introduction

This Code of Business Conduct for Suppliers of the Media Bot group of companies (hereinafter referred to as the "Code") contains the principles of work that all contractors, including consultants, agents, distributors, and other persons working for the company (or with the company) belonging to the group, undertake to adhere to Media Bot companies (hereinafter referred to as "suppliers"). Failure by suppliers to comply with these principles within the framework of our joint work may result in the inability to continue business relations with the Media Bot. In addition, all suppliers must familiarize their employees and subcontractors who will interact with the Media Bot with this Code.

The media bot adheres to the highest standards of business ethics. Therefore, this Code must be considered in inseparable connection with The rules of business and corporate ethics of the Media Bot Group of companies and The principles of the Media Bot, which the Media Bot undertakes to follow in order to be a reliable and conscientious partner for its suppliers. It is important for us to build mutually beneficial relations based on the principles of openness and mutual respect. We want to share views and intentions with our partners, including the intention to benefit society and take care of the environment.

The main thing about the Code

1. What is the basis of the principles of business behavior of suppliers?

The principles are based on the Rules of business and corporate ethics of the Media Bot. We expect our suppliers to behave as responsibly as we do ourselves and our employees.

The Code and Rules are based on the principles set out in applicable legislation and in international documents: Universal declaration of human rights, Guiding principles of entrepreneurship UN human rights activities, ILO Conventions, Principles of Global UN treaties.

2. What to do if the principles of the Code do not comply with the applicable

legislation?

If the Code contains stricter requirements, we and our suppliers are guided by the provisions of the Code. And if the applicable legislation sets out stricter requirements, we focus on it.

We have made sure that this Code can serve as a universal guide in most cases, taking into account the requirements of applicable legislation.

3. Will the Media bot check compliance with the Code?

We trust our partners, who confirm that they share the principles of business conduct set out in the Code, and are happy to get acquainted with their public reports. At the same time, the Media Bot reserves the right to implement verification procedures.

For example, a media bot can initiate an audit. At the same time, the audit itself, its scope and other details will be agreed in advance with the supplier.

We will also respond to reports of violations and verify their authenticity.

4. How can I report violations of the Code?

Our Hotline is available 24/7 via the link.... You can track the status of your application and see the decision made by the number that will be assigned to the application when it is registered in the system.

Key principles

1. Honest and conscientious doing business

Competition

Our supplier strives to maintain an open, honest commercial environment and comply with applicable antitrust laws. It does not allow unfair competition, does not conclude agreements that may infringe on the capabilities of other market players, including agreements with some of them, on the division of the market according to territorial principle, volume or assortment of goods, according to the composition of buyers and sellers, to the detriment of others. Our supplier must not use any immoral business practices and must choose between personal gain and the interests of society to give preference to the interests of society.

Anti-corruption

Corruption is a crime in all countries where the Media Bot is present. We strictly prohibit any form of corruption: bribes, bribes and other illegal payments to obtain or maintain advantages in business activities.

We choose contractors impartially: We take into account the competitiveness of the prices offered, the quality of goods or services and the reliability of future suppliers. We do not give or accept any illegal or inappropriate payments, gifts or services. We prohibit such actions, even if such payments are considered acceptable in certain regions of the Media Bot's presence. Our supplier should remember that local customs or practices do not justify committing a crime.

Our supplier, its affiliated companies, its employees, representatives and other persons involved in relations with the Media Bot should not offer, give, demand or accept money, valuable gifts, services or other payments in order to maintain business advantages or obtain a more favorable relationship.

If our supplier suspects that a violation of the provisions of this section has occurred or may occur, he is obliged to tell the Media Bot in writing about his suspicions. To do this, write to the following email: This email address is being protected from spambots. You need JavaScript enabled to view it. .

Business gifts and hospitality signs

We expect that all gifts and hospitality that we receive from suppliers, and that our suppliers transmit and receive as part of a business relationship with a Media Bot, comply with the following principles:

· have a reasonable cost;

· does not create a conflict of interest;

· are legal;

· comply with local customs and business rules;

· do not make the recipient feel obligated;

· are not and do not give anyone a reason to consider them a bribe or commercial bribery;

· are not extorted by the recipient.

There are approval procedures in the Media Bot that we follow when giving or receiving gifts and hospitality tokens.

We categorically do not accept money and cash equivalents (certificates, e-money cards, etc.) from business partners, regardless of their nominal value.

More information about how gifts are accepted and given in the Media Bot, including limits, can be found in Rules of business and corporate ethics.

Conflict of interest

Our supplier, its affiliated companies, employees, representatives and other persons involved in relations with the Media Bot strive to avoid conflicts of interest in relation to the Media Bot.

By conflict of interest, we mean any circumstance that may cast doubt on the ability of the company's employees to act objectively in the interests of the employer and the transaction. Conflicts of interest include situations in which our supplier, its affiliates, employees, representatives, contractors and other persons involved in relations with the Media Bot:

· are close relatives of Media Bot employees who make decisions, participate in the conclusion or execution of contracts within the framework of relations with the supplier;

· are full-time Media Bot employees, work part-time or provide any services to Media Bot group companies;

· have a significant impact on the companies of the Media Bot group;

· are significantly influenced by the companies of the Media Bot group.

We also consider any situations in which the objectivity of making work decisions within the framework of interaction with a Media bot can be violated to be a conflict of interest.

If our supplier finds out about a possible conflict of interest situation, he is obliged to take measures to eliminate it and immediately notify the Media Bot about this situation in writing. To do this, write to the following email: This email address is being protected from spambots. You need JavaScript enabled to view it. .

Money laundering

We expect our supplier to accurately document all business and commercial transactions and reflect them in accounting statements in accordance with applicable law. Moreover, our supplier should not participate in or facilitate money laundering.

Insider trading

Our supplier cannot use confidential information related to the Media Bot to participate in insider transactions. He undertakes not to share this information with other people who may use it to trade securities.

Privacy

Our supplier must consider confidential all business, technical, commercial and financial information about the Media Bot, its products, technologies and partners. The Supplier makes efforts to protect the confidential information of the Media Bot: it uses it only to fulfill obligations to the Media Bot, does not publish, transmit or disclose it to other persons without the permission of the Media Bot. In the process of working with the Media Bot, the supplier strives to prevent the misuse of confidential information of third parties, not to disclose or transfer it to the Media Bot without their permission.

Personal data protection

The media bot carefully protects the personal data of its users and others and treats them very carefully. Our supplier must comply with the legislation on personal data when collecting, storing, changing, using, transferring and other processing of personal data in the framework of cooperation with or in connection with a Media Bot. In particular, when processing personal data, our supplier must comply with the principles of legality, data security and confidentiality, fairness and transparency of processing, data minimization and data accuracy. It limits the purposes of processing and retention of personal data, as well as controls actions with data.

Intellectual property

The media bot respects the intellectual property rights of others and expects to be treated with respect for its intellectual property rights. Our supplier may not use the intellectual property of the Media Bot (including its software products, databases, proprietary solutions, trademarks, logos, documentation, etc.) without written permission. When working with a Media Bot, the supplier must not allow the misuse of third-party intellectual property.

Disclosure of information

We expect our supplier to adhere to the principle of transparency and strive to regularly inform stakeholders about the results of their work, including in the field of sustainable development. For example, in the format of public reporting. And if disclosure of information is not possible, then he will be ready to share data and materials at the request of the Media bot (in the case when there are no restrictions on the confidentiality of this information).

2. Respect for human rights and freedoms

Prohibition of child and forced labor

Our supplier does not use illegal child labor and employs only persons who have reached the legally permitted age for work.

Our supplier does not accept any forms and methods of forced labor and slavery, including but not limited to those defined in national legislation and applicable international documents (ILO Convention No. 29 On Forced and Compulsory Labour). The supplier strives to build relationships with employees based on the principles of voluntary agreements. He does not participate in or facilitate human trafficking, and also takes measures to exclude human trafficking within the framework of business relationships and facilitate the suppression of this activity by others.

Non-discrimination and support for diversity

The media bot considers discrimination in any form unacceptable, ensures equality of opportunity and recognizes the value of diversity. Our supplier must adhere to the same principles. He undertakes to comply with all applicable laws and strives to prevent discrimination in employment and in the course of work. It does not accept harassment and harassment on any basis, including nationality, gender, age, race, political or religious views, sexual orientation and other characteristics. Our supplier makes efforts to ensure equal opportunities for its employees and partners, encourages socio-cultural diversity and, if possible, strives to cooperate with enterprises of different sizes, with individual entrepreneurs and self-employed partners.

We believe that it is respect for each other and the desire for integration that contributes to the universal well-being and free comprehensive development of all members of society.

Prevention of harassment

Our supplier does not accept any form of sexual harassment — unwanted sexual acts against another person and strives to prevent such manifestations, if possible, if they appear in his field of vision.

Fair pay

Our supplier must comply with all applicable legal requirements regarding pay, benefits, payments and overtime pay. He strives to ensure timely and full fair pay, which guarantees a decent human existence for him and his family, and also strives to involve him in the work process so that he can approach his work with love and creative enthusiasm.

Respect for the right to rest

Our supplier must respect and ensure the legally enshrined right of its employees to rest. He undertakes to comply with the requirements of applicable legislation regarding working hours and overtime, as well as to measure the intensity of the work process and the fatigue of employees, their physical and mental condition.

Trade union freedoms

Our supplier recognizes and respects the right of its employees to freedom of association and collective bargaining. In addition, we strive to engage in dialogue with employees in every possible way.

Cooperative initiatives

Our supplier recognizes the natural desire of employees and/or partners for creative unification and the desire to take maximum responsibility for their lives, therefore, strive to support such initiatives in which people decide to unite in various forms of cooperation, either integration with other teams, or reorganization of production.

3. Ensuring occupational safety, health and safety

Organization of safe working conditions

Our supplier strives to provide working conditions that minimize health and safety risks. It maintains working equipment in good condition, conducts occupational safety training, informs employees about risk factors, responds to incidents and eliminates their consequences, maintains appropriate reporting and implements other measures to comply with legal requirements and improve working conditions.

4. Environmental responsibility

Compliance with environmental legislation

Our supplier must comply with applicable environmental laws, including with regard to hazardous materials, waste, and emissions of harmful substances into the air and water. Moreover, he should be guided by world experience and strive to adhere to stricter standards applied in world practice.

Rational use of resources

The media bot is attentive to its responsibilities in relation to environmental protection and strives to make rational use of natural resources. Our supplier shares the principles of rational consumption, tries to optimally use energy, water, raw materials and other resources and pays attention to the fight against climate change. And, as far as possible, prefers the use of such types of packaging materials that are less harmful to the environment.

Handling of hazardous materials

Our supplier should not use chemicals and materials dangerous to human health and the environment in technological processes, focusing on the lists of such substances fixed in applicable state standards and in agreements with the Media Bot. The supplier must ensure the proper handling, storage and disposal of hazardous materials, as well as the safety of employees and the environment.

Final provisions

We will regularly review the Provisions of the Code in order to integrate best practices and possible legislative changes into them.

Questions about the content of the Code can be sent to the following email address: This email address is being protected from spambots. You need JavaScript enabled to view it.


1. What does this privacy Policy regulate

This Privacy Policy (hereinafter referred to as the Policy) applies to all information, including personal data within the meaning of applicable law (hereinafter referred to as "Personal Information"), which the My Media Library Bot Project (hereinafter referred to as the "Media Bot") and/or its affiliates may receive about you in in the process of your use of any Media Bot sites, programs, products and/or services (hereinafter collectively referred to as "Services"), information about which you can find on the Media Bot sites and other Media Bot-owned sites, groups, channels, chats, bots (hereinafter collectively — "Sites"), as well as during the execution by the Media Bot / its affiliates of any agreements and agreements concluded with you in connection with your use of the Services. The Media Bot may also receive Personal Information from its partners (hereinafter referred to as "Partners"), sites, programs, products or services that you use (for example, from advertisers of the Media Bot). In such cases, the transfer of Personal Information is possible only in cases established by applicable law, and is carried out on the basis of special agreements between the Administration of the Media Bot and each of the Partners.

Please note that the use of any of the Sites and/or Services may be subject to additional terms that may make changes and/or additions to this Policy, and/or have special conditions regarding personal information posted in the relevant sections of the documents for such Sites /or Services.

2. Who processes the information

To ensure that you use the Sites and Services, your Personal Information is collected and used by a Media Bot.

3. What is the purpose of this Policy

Protecting your Personal Information and your privacy is extremely important for a Media Bot. Therefore, when you use Websites and Services, the Media Bot protects and processes your Personal Information in strict accordance with applicable law.

Following our responsibilities to protect your Personal Information, in this Policy we would like to inform you in the most transparent way about the following points:

(a) why and how a Media Bot collects and uses ("processes") your Personal Information when you use Websites and/or Services;

(b) what is the role and responsibilities of a Media Bot as a legal entity that decides why and how to process your Personal Information;

(c) what tools can you use to reduce the amount of Personal Information collected by the Media Bot about you;

(d) what are your rights within the framework of the ongoing processing of Personal Information.

4. What Personal information does the Media Bot collect about you

The personal information collected during the operation of the Sites and/or the provision of Services may vary depending on whether you use your account to access the Sites and/or Services or not. In cases where you log in to your account, the Personal Information collected about you by the Media Bot during your use of the Sites and Services may be compared and linked to other Personal Information collected by the Media Bot as part of your use of your account (for example, information about your identity, contact details data, age and gender, if they were provided to the Media Bot). The Media Bot does not verify the Personal Information provided by you, except as provided for in the user agreement or the terms of use of individual services, and cannot judge its reliability, as well as whether you have sufficient legal capacity to provide your Personal Information. Nevertheless, the Media Bot assumes that you provide reliable and sufficient Personal Information, as well as update it in a timely manner.

The Media Bot may collect the following categories of Personal Information about you while you use the Sites and Services:

(i) Personal information provided by you during registration (account creation), such as your name, phone number, address and age;

(ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information, wi-fi network data);

(iii) date and time of access to the Sites and/or Services;

(iv) information about your activity while using the Sites and/or Services (for example, search query history, data on purchases in the Services, data on visited organizations, likes and preferences, email addresses of those with whom you correspond, phone book data, information about interaction with other users, as well as files and content stored in Media Bot systems);

(v) geolocation information;

(vi) other information about you necessary for processing in accordance with the terms governing the use of specific Sites or Services of the Media Bot;

(vii) information about you that we receive from our Partners in accordance with the terms of the agreements concluded between you and the relevant Partner and the agreements concluded between the Media Bot and the Partner.

The Media Bot also uses cookies and web beacons (including pixel tags) to collect Personal Information and associate such personal information with your device and web browser (see section 11 of this Policy).

The Media Bot does not purposefully collect sensitive personal information (such as racial origin, political views, health information and biometric data), except in cases provided for by the user agreements of individual Services. However, you can provide them to the Media Bot yourself, and in this case the Media Bot will process them as part of providing Services to you (for example, if you set search queries related to your health). At the same time, you should take into account that the Media Bot cannot request your consent to such processing, since it is not aware in advance of the potentially sensitive nature of the Personal Information that you can provide to the Media Bot.

The Media Bot does not collect data for the purpose of creating a "portrait" of the user to the extent that this may significantly affect your rights and freedoms in accordance with applicable law.

5. What is the legal basis and purpose of processing your Personal Information

A Media Bot does not have the right to process your Personal Information without sufficient legal grounds. Therefore, the Media Bot processes your Personal Information only if:

(i) processing is necessary to fulfill the contractual obligations of the Media Bot to you, including ensuring the operation of Sites and Services (for example, providing you with search results for your search queries);

(ii) processing is necessary to comply with legal obligations;

(iii) where required by applicable law, processing is necessary to ensure the legitimate interests of the Media Bot, if such processing does not significantly affect your interests, your fundamental rights and freedoms. Please note that when processing your personal information on this basis, the Media Bot will always strive to maintain a balance between its legitimate interests and the protection of your privacy.

The Media Bot processes your Personal Information to ensure its legitimate interests, for example, in the following cases:

(a) to better understand how you interact with our Sites and/or Services;

(b) to improve, modify, personalize or otherwise improve the Sites and Services in the interests of all users;

(c) to offer you other products and services of the Media Bot or other companies that, in our opinion, may be of interest to you (i.e., to show you ads that take into account your interests);

(iv) for specific purposes or as required by applicable law, we may request your separate consent to the processing of your Personal Information. For jurisdictions where consent is recognized as a separate legal basis, the beginning of your use of the Sites and/or Services of the Media Bot expresses your consent to such processing. We hereby inform you and you confirm that you have no obligation to provide us with any Personal Information when you use the Sites or Services and is based solely on your free will. However, you are aware that without providing Personal Information, we will not be able to provide you with the opportunity to use the Services, and your use of the Sites will be limited.

The Media Bot always processes your Personal Information for certain purposes and only the Personal Information that is relevant to achieving such goals. In particular, we process your Personal Information for the following purposes:

(i) providing you with access to Sites and/or Services (including providing search results in response to your search queries, taking into account your preferences, search history and other Personal Information about you available to the Media Bot);

(ii) providing access to your account, including the Media Bot's email inbox and file storage, if you are registered with the relevant Services;

(iii) contacting you to send you notifications, requests and information related to the operation of Sites and Services, fulfill agreements with you and process your requests and requests;

(iv) personalization of ads and offers based on your preferences, search history and other Personal Information about you available to the Media Bot;

(v) improving the usability of Sites and Services, including to display the most relevant search results and provide more personalized Sites and Services, as well as to improve other products, applications and Services of the Media Bot;

(vi) creation of new products, utilities and Media Bot offers;

(vii) protection of your rights and the rights of the Media Bot;

(viii) collection, processing and presentation of statistical data, big data and other research.

 

The use of information received from the Telegram API in the Media Bot Services (hereinafter referred to as "Received Data") is carried out in accordance with the provisions of Telegram APIs subject to the restrictions specified in it, namely:

The data collected is used solely for the purpose of providing you with functions. The data obtained cannot be used to transfer to third parties, to display advertising materials and for other purposes related to unauthorized access to the content of your correspondence.

You can find out more about the conditions for processing the Received data at: (https://core.telegram.org/api ).

6. How a Media Bot Protects Your Personal Information

In most cases, Personal Information is processed automatically without access to it by any of the employees of the Media Bot. If such access is needed, it can only be provided to those employees of the Media Bot who need it to perform their tasks. To protect and ensure the confidentiality of data, all employees must comply with internal rules and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect your Personal Information.

The Media Bot has also implemented sufficient technical and organizational measures to protect Personal Information from unauthorized, accidental or illegal destruction, loss, alteration, unfair use, disclosure or access, as well as other illegal forms of processing. These security measures were implemented taking into account the state-of-the-art technology, the cost of their implementation, the risks associated with the processing and nature of Personal Information.

7. Who else has access to your Personal Information and to whom it can be transferred

7.1 Within the Media Bot Group

The Media Bot may share your Personal Information with its employees (within the limits specified in Section 6 of this Policy). The Media Bot may also share your Personal Information with its affiliates, including other companies from the group of persons to which the Media Bot belongs (the "Media Bot Group"). Please note that the level of protection of Personal Information in some countries may not coincide with the level established in your jurisdiction, and by using the Services of the Media Bot, you agree to such transfer.

In all cases, Personal Information will also be processed only for the purposes set out in Section 5 of this Policy, unless otherwise provided by the terms of use of the Sites and/or Services provided by the companies of the Media Bot Group.

In addition, your Personal Information may be transferred to persons belonging to the Media Bot Group and located in the same country with you in order to support you when using the Sites and Services.

7.2 Outside The Media Bot Group

The Media Bot may also transfer Personal Information to third parties outside the Media Bot Group in order to achieve the goals specified in Section 5 of this Policy. Please note that the level of protection of Personal Information in some countries may not coincide with the level established in your jurisdiction, and by using the Services of the Media Bot, you agree to such transfer.

Such third parties may include:

(i) Partners, such as owners of websites and applications, advertising networks and other partners providing services to the Media Bot related to the placement and display of advertising in products or services owned or controlled by such partners; companies providing transportation services (taxi);

(ii) advertisers or other Partners who display ads for you on Websites and/or on Media Bot Services, as well as Partners such as information service providers or consultants.

The Media Bot can also transfer Personal Information to third parties outside the Media Bot Group:

(i) to third parties in respect of whom the assignment of rights or obligations has been made, or an innovation under the relevant agreement;

(ii) to any national and/or international regulatory authority, law enforcement agencies, central or local executive authorities, other official or state bodies or courts in respect of which the Media Bot is required to provide information in accordance with applicable law upon request;

(iii) to third parties, if you have consented to the transfer of your Personal Information or the transfer of Personal Information is required to provide you with the appropriate Service or to fulfill a certain agreement or contract concluded with you;

(iv) to any third party in order to provide legal protection to the Media Bot or third parties in case of violation of the User Agreement of the Media Bot services by you (https://mymedialib.space/user-agreement ), this Policy or the terms governing the use of certain Services, or in a situation where there is a threat of such a violation.

8. Where your Personal Information is stored and processed

Your Personal Information will be stored in the Russian Federation and/or in the EEA.

For Russian users: The media Bot records, systematizes, accumulates, stores, clarifies (updates, changes), extracts personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.

For users from the EEA, Switzerland or Israel: Russia is a jurisdiction outside the European Economic Area that has not been recognized by the European Commission as providing an adequate level of personal data protection. Therefore, the Media Bot has taken appropriate measures to ensure that such transmission is carried out in accordance with the current EU data protection regulations.

In particular, the Media Bot is guided by the Standard Contractual Terms approved by the European Commission to ensure an adequate level of protection of your Personal Information transmitted to Russia. A copy of these Standard Contractual Terms is available upon request.

If you are located in a territory where your consent is required to transfer your Personal Information to another jurisdiction, then by using the Sites or Services, you give the Media Bot your explicit and unambiguous consent to such transfer or storage, and/or processing of information in other specified jurisdictions, including Russia.

9. How long do we store your Personal Information

The Media Bot will store your Personal Information for as long as necessary to achieve the purpose for which it was collected, or to comply with legal and regulatory requirements.

Unless otherwise required by law or by agreement with you, emails and documents that you store in Media Bot systems as part of the Service will be stored as long as you have an account, but they can be deleted by you at any time.

If you want any of your Personal Information to be deleted from the Media Bot databases, you can delete the necessary Personal Information yourself using your account or through the interface of the Sites and/or Services (where applicable).

10. Your rights

10.1 What rights do you have

If required by applicable law, you have the right to access your Personal Information processed by the Media Bot in accordance with this Policy.

If you believe that any information that the Media Bot stores about you is incorrect or incomplete, you can log in to your account and correct your Personal Information yourself.

If required by applicable law, you have the right to:

  • get acquainted with the information that the Media Bot stores about you;
  • require the deletion of your Personal Information or part of it, as well as revoke consent to the processing of your personal information;
  • require restrictions on the processing of your Personal Information;
  • request a copy of the Standard Contractual Terms authorizing the transfer of your Personal Information to Russia and specified in Section 8 of this Policy;
  • object to the processing of your Personal Information, if required by applicable law.

The Media Bot will fulfill these requests in accordance with applicable law.

In cases provided for by applicable law, you may also have other rights not listed above.

When you use the Services, the transfer of Personal Information is carried out with your consent, expressing your free will and your interest (in particular, on the basis of an agreement with you) and is not an obligation under the law.

10.2 How can you exercise your rights

To exercise the above rights, please log in to your account, and if there is no special function in the interface, contact the Media Bot (see section 13 of this Policy).

If you are not satisfied with how the Media Bot handles your Personal Information, please let us know and we will consider your claim. If you are not satisfied with the response of the Media Bot, you have the right to file a complaint with the competent authority.

11. How we use cookies and other similar technologies on Websites or when you use the Services

11.1 What cookies and why does the Media Bot use them

Cookies are a small piece of data that is received and processed by the device that you use to access Websites. Cookies store and send back to the Sites information that helps you work with the Sites and allows us to remember your preferences after time has elapsed, for example, browser settings or to recognize your account. For more information about cookies, their description, the purpose of use and possible ways to manage them, follow our The Cookie Policy.

The following types of cookies are used on the Sites:

  • strictly necessary cookies / technical cookies: these cookies are necessary for the operation of Websites and the provision of Services to you; among other things, they allow the Media Bot to identify your hardware and software, including your browser type;
  • statistical/analytical cookies: these cookies allow you to recognize users, count their number and collect information such as the operations you have performed on Sites and Services, including information about the web pages you have visited and the content you receive;
  • technical cookies: These cookies collect information about how users interact with Sites and/or Services, which allows you to identify errors and test new features to improve the performance of Sites and Services;
  • Functional cookies: These cookies allow you to provide certain functions to facilitate your use of the Sites, for example, by saving your preferences (such as language and location);
  • (third-party) tracking files / advertising cookies: These cookies collect information about users, traffic sources, pages visited and advertisements displayed to you, as well as the one that led you to the advertised page. They allow you to display ads that may be of interest to you based on the analysis of Personal Information collected about you. They are also used for statistical and research purposes.

11.2 How long are cookies stored on your device

The media bot uses the information contained in the cookies only for the above purposes, after which the collected data will be stored on your device for a period that may depend on the appropriate type of cookies, but not exceeding the period necessary to achieve their purpose, after which they will be automatically deleted from your system.

11.3 Who else has access to the information contained in cookies

Personal information collected through cookies placed on your device may be transferred and made available to the Media Bot and/or to third parties specified in Section 7 of this Policy. The use of Personal Information outside the Sites for advertising purposes, if any, may be subject to separate user agreements available on third-party websites. The Media Bot and/or third parties may also provide you with the opportunity to opt out of the personalization of advertising, which may be subject to the laws and regulations applicable to such products and offers.

When you visit the Sites for the first time, your consent to the use of cookies may be requested. If, after you have approved the use of cookies, you want to change your mind, you can do so by deleting the cookies stored in your browser (this can usually be done in the browser settings — please refer to the browser user manual or the website of its developer). After that, a pop-up window may be displayed again requesting your consent, and you can make a different choice. If you refuse to use cookies, this may lead to the fact that some functions of the Sites will not be available to you, and will affect your ability to use the Sites. You can also change your browser settings to accept or reject by default all cookies or cookies from certain sites, including Media Bot Sites. If you have approved the use of cookies on one of the Media Bot Sites, we will assume that the use of cookies on all Sites has been approved by you.

The media bot can also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:

(i) determining your actions on the Sites and in the process of using the Services by accessing and using cookies stored on your device;

(ii) collection of statistical information related to the operation of Websites, Services or products, utilities and offers of the Media Bot.

12. Updating this Policy

This Policy may be amended. The Media Bot has the right to make changes at its discretion, including, but not limited to, in cases where the relevant changes are related to changes in applicable legislation, as well as when the relevant changes are related to changes in the operation of Sites and Services.

The Media Bot undertakes not to make significant changes, impose additional encumbrances or restrictions on your rights established by this Policy without your notice. You will be notified of such changes. Relevant notifications can be displayed on the Site or in the Services (for example, through a pop-up window or banner) before such changes take effect, or they may be sent to you via other communication channels (for example, by e-mail if you have provided us with your contact information).

13. Questions and suggestions

The Media Bot welcomes your questions and suggestions regarding the implementation or modification of this Policy. Please use our feedback form posted at (under development). You can also use this address to send requests for the exercise of your rights or complaints about the inaccuracy of your Personal Information or the illegality of its processing.

Date of publication 06/02/2024

The current version is available at: https://mymedialib.space/privacy-policy