Privacy policy

Extracode Inc. , legal entity duly incorporated under the laws of the British Virgin Islands, adopts the present Privacy Policy, which describes how Extracode Inc. collects, uses, discloses, and manages Customers, Stores, Cards, Transaction data and other information obtained from the Store and the Customer under Services agreement available over the Internet at network address or obtained via the Website, Store’s Program and Customer’s Program. The Privacy Policy is an important document which may affect your rights, so please, read it carefully.

1. Terms and Definitions
1.1. The following terms used in this Privacy Policy have the meanings set forth in this paragraph:

  • «Agreement» - Services agreement available over the Internet at network address
  • «Personal Data» - Any data directly or indirectly relating to the Customer.
  • «Privacy Policy» - The present Privacy Policy.
  • «Processing» - Any operation or set of operations which is performed with data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
  • «Traffic Data» - The information of IP addresses, domain servers, types of computers accessing the Website or the Store’s Program or the Customer’s Program, types of web browsers used to access the Website.
  • «Protection level» - List of measures taken in the location of services using which the Processing is carried out
    • authorized personnel access with card access control system;
    • 24/7 life guard;
    • video recording;
    • electronic security system;
    • other measures aimed to protection of Processing data.
  • «Service» - EXTRACODE Inc., a legal entity duly incorporated under laws of the British Virgin Islands on April 20, 2006, registration number 1022672, legal address First Floor, Mandar House, Johnson’s Ghut, P.O. Box 3257, Road Town, Tortola, British Virgin Islands, represented by Alexey Chernykh, acting on the basis of Appointment of First Director of the Company.
  • «Store’s information» - Information about Store’s Service plan, Transaction data, Store’s payments under the Agreement and services rendered by the Service.

1.2. The rest of terms and definitions in the text of the Agreement are interpreted by the Parties according to the international practice and established the Internet the usual rules of interpretation of relevant terms.
1.3. The headings (of articles) of the Privacy Policy are for convenience only and shall not in any way affect the meaning or interpretation of the Privacy Policy.
1.4. The Privacy Policy shall be governed and construed in accordance with the law of the Russian Federation and Directive of the European Parliament and of the Council No. 95/46/EC.

2. Collected Information
2.1. A Customer may generally visit the Website or use the Customer’s Program without revealing any Personal Data. A Customer provides to the Store some information, including Personal Data, when he or she gets the Cards or use special functions of the Website and the Customer’s Program.
2.2. The Service may Process the following information:

  • Traffic Data;
  • Personal Data;
  • Transaction Data.

2.3. Traffic Data is not regarded as Personal Data, however the Service uses cookies that may to some extend identify the Customers. Cookies are small text files that enable the Service to collect the information about web-browsing activities of the Customer such as the pages visited by the Customer and the time the Customer spent on viewing the page. The Customer may decline the cookies at his or her discretion in the personal settings of the web-browser.
2.4. The Service collects the Personal Data that the Customer provides to the Store to get the Card or the Discount and/or Bonus or which the Customer provides via the Customer’s Program. Personal Data may include Customer’s contact information, such as name, email address and phone number.
2.5. The Service Processes Personal Data, Traffic Data and Transaction data as long as it is necessary to provide services to the Stores under the Agreement.
2.6. The Service Processesthe information described in Article 2.2 of Privacy Policy using the servers located on the territory of the European Union.
2.7. The Service does not Process any of the following information:

  • Store’s and Sellers’ personal data (name, passport data and etc.);
  • information about instruments of payments (card number, account number and etc.) using which the Store pays fees for the services provided by the Service under the Agreement.

2.8. The Service guarantees that Store’s information is available only to the Store in the Personal account and shall not be disclosed to third parties without written consent of the Store.

3. The Purposes of Personal Data Usage
3.1. Processing is necessary for the performance of the Agreement and the Service is not required to get the Customer’s consent for Processing of Personal Data.
3.2. The Service uses the Personal Data in order to:

  • Provide services to the Stores under the Agreement;
  • Simplify the Card issuance and Discount granting procedures;
  • Provide to the Store information about Customer’s Discounts and/or Bonuses;
  • Respond to the Customer’s requests;
  • Use for marketing and promoting of the Website, the Store’s Program and the Customer’s Program;
  • Contact Customer about the Service or the Store news, updates, promotions and new services.

3.3. If Customer wish to stop receiving marketing notifications from the Service, the Customer shall contact the Service at to unsubscribe.

3.4. The Service uses Traffic Data in order to:

  • Get information on traffic patterns and the number of visitors to the Website and users of the Customer’s Program;
  • Get information how the Customers use and interact with the Website and the Customer’s Program;
  • Improve the Website, the Store’s Program and the Customer’s Program;
  • Build up statistical data for auditing, research, and reporting for the Service’s Customers and other partners;
  • Provide services to the Stores under the Agreement.

3.5. The Service uses the Transaction Data in order to provide services to the Stores under the Agreement.

4. Security and Transfer of Personal Data to Third Parties
4.1. The Service undertakes a number of standard adequate security measures to ensure the confidentiality of the Personal Data and Transaction Information and prevent it from loss, theft, unauthorized access, misuse, alteration or destruction. The Service may use software, secure socket layer technology (SSL) encryption, password protection, firewalls, internal restrictions and other security measures to help prevent unauthorized access to Customer’s Personally Data and Transaction Information.
4.2. The Service guarantees that Processing of the information described in Article 2.4 of Privacy Policy is performed using the servers located on the territory of the European Union with established Protection level.
4.3. The Customer understands that the Service may share and transfer information, including Personal Data and Transaction information, to the Stores under the Agreement. But the Service is obligated not to share and transfer Personal data other third parties without the Customer’s written consent.
4.4. The Service may share the Personal Data with government officials and other authorities when the Service is legally bound to do so or to protect the Customers’ interests.

5. Updating, Correcting and Deleting Personal Data
5.1. If the Customer believes that the Service has incorrect Personal Data, provided by the Customer via the Store’s Program, the Customer’s program or the Website, the Customer may contact the Service by e-mail at to correct, amend, or delete that information.

6. Changes to the Privacy Policy
6.1. The Service reserves the right to add to, change or update the Privacy Policy. Any such change or update will be effective immediately when posting on the Website.

photoCustomer satisfaction and loyalty. Differences and method to work withRead more>>>
photoGuerrilla Marketing
photoMulti-tiered, discount and intangible loyalty programmes