Privacy Policy of KenshōThis Application collects some Personal Data from its Users.

POLICY SUMMARY
Personal Data collected for the following purposes andusing the following services:oContacting the User
§ Mailing list or newsletter
Personal Data: email addressoManaging contacts and sending messages§ MailChimp
Personal Data: email address

Contact information
oOwner and Data Controller
FIFTYTWO, OOO
Varvarskaya 32, 403 office, Nizhny Novgorod, Russia, 603006
Owner contact email: hello@wefiftytwo.com

FULL POLICY
Owner and Data Controller
FIFTYTWO, OOOVarvarskaya 32, 403 office, Nizhny Novgorod, Russia, 603006
Owner contact email: hello@wefiftytwo.com

Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through thirdparties, there are: email address.
Complete details on each type of Personal Data collected are provided in the dedicatedsections of this privacy policy or by specific explanation texts displayed prior to the Datacollection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected
automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure toprovide this Data may make it impossible for this Application to provide its services. In cases
where this Application specifically states that some Data is not mandatory, Users are free notto communicate this Data without consequences to the availability or the functioning of theService.
Users who are uncertain about which Personal Data is mandatory are welcome to contact theOwner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of
third-party services used by this Application serves the purpose of providing the Service
required by the User, in addition to any other purposes described in the present document andin the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared throughthis Application and confirm that they have the third party's consent to provide the Data tothe Owner.

Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure,modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following
organizational procedures and modes strictly related to the purposes indicated. In addition tothe Owner, in some cases, the Data may be accessible to certain types of persons in charge,
involved with the operation of this Application (administration, sales, marketing, legal,system administration) or external parties (such as third-party technical service providers,
mail carriers, hosting providers, IT companies, communications agencies) appointed, ifnecessary, as Data Processors by the Owner. The updated list of these parties may berequested from the Owner at any time.

Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:••••

Users have given their consent for one or more specific purposes. Note: Under somelegislations the Owner may be allowed to process Personal Data until the User objects
to such processing (“opt-out”), without having to rely on consent or any other of thefollowing legal bases. This, however, does not apply, whenever the processing ofPersonal Data is subject to European data protection law;provision of Data is necessary for the performance of an agreement with the User
and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner issubject;
processing is related to a task that is carried out in the public interest or in the exercise
of official authority vested in the Owner;•

processing is necessary for the purposes of the legitimate interests pursued by theOwner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to theprocessing, and in particular whether the provision of Personal Data is a statutory orcontractual requirement, or a requirement necessary to enter into a contract.

Place
The Data is processed at the Owner's operating offices and in any other places where theparties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a
country other than their own. To find out more about the place of processing of suchtransferred Data, Users can check the section containing details about the processing of
Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside theEuropean Union or to any international organization governed by public international law or
set up by two or more countries, such as the UN, and about the security measures taken by
the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of
this document or inquire with the Owner using the information provided in the contact
section.

Retention time
Personal Data shall be processed and stored for as long as required by the purpose they havebeen collected for.
Therefore:••

Personal Data collected for purposes related to the performance of a contract between
the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be
retained as long as needed to fulfill such purposes. Users may find specificinformation regarding the legitimate interests pursued by the Owner within therelevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User hasgiven consent to such processing, as long as such consent is not withdrawn. Furthermore, theOwner may be obliged to retain Personal Data for a longer period whenever required to do sofor the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right toaccess, the right to erasure, the right to rectification and the right to data portability cannot beenforced after expiration of the retention period.

The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Services, as well
as for the following purposes: Contacting the User and Managing contacts and sending
messages.
Users can find further detailed information about such purposes of processing and about thespecific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:•Contacting the User
Mailing list or newsletter (this Application)
By registering on the mailing list or for the newsletter, the User’s email address will
be added to the contact list of those who may receive email messages containing
information of commercial or promotional nature concerning this Application. Youremail address might also be added to this list as a result of signing up to thisApplication or after making a purchase.
Personal Data collected: email address.

•Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone
contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message
was viewed by the User, as well as when the User interacted with it, such as byclicking on links included in the message.
MailChimp (The Rocket Science Group, LLC.)
MailChimp is an email address management and message sending service provided
by The Rocket Science Group, LLC.
Personal Data collected: email address.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:••••••••Withdraw their consent at any time. Users have the right to withdraw consent
where they have previously given their consent to the processing of their PersonalData.
Object to processing of their Data. Users have the right to object to the processingof their Data if the processing is carried out on a legal basis other than consent.
Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by theOwner, obtain disclosure regarding certain aspects of the processing and obtain acopy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their
Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain
circumstances, to restrict the processing of their Data. In this case, the Owner will notprocess their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right,
under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have theright to receive their Data in a structured, commonly used and machine readable
format and, if technically feasible, to have it transmitted to another controller without
any hindrance. This provision is applicable provided that the Data is processed byautomated means and that the processing is based on the User's consent, on a contract
which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent dataprotection authority.

Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority
vested in the Owner or for the purposes of the legitimate interests pursued by the Owner,
Users may object to such processing by providing a ground related to their particularsituation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing
purposes, they can object to that processing at any time without providing any justification.
To learn, whether the Owner is processing Personal Data for direct marketing purposes,
Users may refer to the relevant sections of this document.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details
provided in this document. These requests can be exercised free of charge and will be
addressed by the Owner as early as possible and always within one month.

Additional information about Data collection andprocessing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in thestages leading to possible legal action arising from improper use of this Application or therelated Services.
The User declares to be aware that the Owner may be required to reveal personal data uponrequest of public authorities.

Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide
the User with additional and contextual information concerning particular Services or thecollection and processing of Personal Data upon request.

System logs and maintenanceFor operation and maintenance purposes, this Application and any third-party services maycollect files that record interaction with this Application (System logs) use other Personal
Data (such as the IP Address) for this purpose.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested fromthe Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handledThis Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track”
requests, please read their privacy policies.

Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by giving
notice to its Users on this page and possibly within this Application and/or - as far as
technically and legally feasible - sending a notice to Users via any contact information
available to the Owner. It is strongly recommended to check this page often, referring to thedate of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent,
the Owner shall collect new consent from the User, where required.

Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information —including a personal identification number — allows for the identification or identifiability ofa natural person.
Usage Data
Information collected automatically through this Application (or third-party services
employed in this Application), which can include: the IP addresses or domain names of thecomputers utilized by the Users who use this Application, the URI addresses (UniformResource Identifier), the time of the request, the method utilized to submit the request to theserver, the size of the file received in response, the numerical code indicating the status of theserver's answer (successful outcome, error, etc.), the country of origin, the features of thebrowser and the operating system utilized by the User, the various time details per visit (e.g.,
the time spent on each page within the Application) and the details about the path followed
within the Application with special reference to the sequence of pages visited, and otherparameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with theData Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which processes Personal
Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointlywith others, determines the purposes and means of the processing of Personal Data, including
the security measures concerning the operation and use of this Application. The DataController, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
ServiceThe service provided by this Application as described in the relative terms (if available) andon this site/application.

European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union
include all current member states to the European Union and the European Economic Area.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations,including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Application, if not stated otherwise within thisdocument.
Latest update: December 05, 2018