Appendix 1

to the DELSE user agreement



PERSONAL DATA PRIVACY POLICY



The purpose of this Personal Data Privacy Policy (hereinafter referred to as the "Privacy Policy") is to ensure proper protection of the information about the Users (who are individuals), including personal data, against unauthorized access and disclosure.

This Personal Data Privacy Policy applies to all types of information that is collected through the DELSE mobile application (hereinafter referred to as the "Application") or through other channels related to the Application (for example, via e-mail messages received by the customer support service).

By using the Application and/or the Application services, the User fully agrees to the terms of this Privacy Policy. In case of disagreement with the terms of this Privacy Policy, the User is advised to refrain from using the Application and/or any Services available when using the Application.

A written consent to processing of the User's personal data is obtained at the time of registration in the Application.

All copyright and other rights to the results of intellectual activity contained in the Application (including the Application itself) and in its contents, including (but not limited to): design, trademarks and service marks, commercial name, text and numerical information, photographs, images, audio and video recordings, systematization, location, and other materials (their elements), are owned by DELSE, Inc. or have been lawfully provided to it by third parties.

The use of the listed information is permitted only with the consent of DELSE, Inc.



1. TERMS AND DEFINITIONS



1.1. The following terms are used in this Privacy Policy:

1.1.1. Application or Mobile Application shall mean the software designed to work on smartphones, tablets and other mobile devices that provides access to the DELSE parcel delivery service. The Application can be downloaded on a free-of-charge basis to the User's device from such online Application Stores as App Store, Google Play etc. The rights to the mobile application belong to the Company. Any reference to the "Application" or "Mobile Application" in the text of the Agreement shall mean "DELSE Application".

1.1.2. Company DELSE, Inc., managing the Application, which organizes and/or performs the processing of personal data, as well as determines the purpose of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

1.1.3. Personal Data shall mean any information directly or indirectly related to an identified or identifiable individual (personal data subject).

1.1.4. Personal Data Processing shall mean any action (operation) or a set of actions (operations) performed with or without the use of automation equipment with personal data, including collection, recording, systematization, accumulation, storage, specification (update and alteration), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.1.5. Confidentiality of Personal Data shall mean a requirement binding upon the Company to prevent deliberate dissemination of personal data without the consent of the subject of personal data or existence of other legal grounds.

1.1.6. User shall mean any legally capable individual of age who has installed the Application on a mobile device and passed the registration procedure in order to receive the Company's Services.

1.1.7. Announcement shall mean the information about the Parcel, the relevant terms of delivery and the required delivery point;

1.1.8. Sender shall mean an Application User who places a request for the delivery of a Parcel to the point designated by such a User.

1.1.9. Carrier shall mean an Application User who offers the service of transporting the Sender's Parcel;

1.1.10. Website or Site shall mean Internet-based information portal located on the Internet at https://delse.net, containing the information about the Application and the documents governing the relations between the Company and Users.



2. GENERAL PROVISIONS



2.1. The processing of personal data shall be carried out in compliance with international legislation applicable to processing and protection of personal data, as well as the effective legislation of the USA

2.2. Registration and use of the Application means acceptance of this Privacy Policy and the terms of processing of the User's personal data.

2.3. In the event of disagreement with the terms of the Privacy Policy, the User must stop using the Application.

2.4. This Privacy Policy applies only to the DELSE mobile application. The Company does not control and is not responsible for third-party websites which may be visited by the User with the use of the links available in this Application.

2.5. The Company is not obliged to verify the accuracy of all personal data provided by the User.

2.6. In order to enable the use of the Application, personal data are collected and used by Delse, Inc, established under the legislation of the USA.



3. SUBJECT OF THE PRIVACY POLICY



3.1. This Privacy Policy establishes the Company's obligations to intentionally not disclose and ensure the safety of personal data provided by the User upon various Company's requests (for example, at the time of registration in the Application, while placing a request, or subscribing to notifications, etc.).

It is understood that the User understands and agrees that the Internet cannot provide absolute protection of personal data against threats that exist in it. The User hereby gives his/her unconditional consent for the Company to determine the sufficient level of protection of Personal Data, as well as the methods and place (territory) of their storage.

3.2. When registering or using the Application, the Company may process the following personal data or information about the User:

3.2.1. surname, name, patronymic of the User;

3.2.2. e-mail address;

3.2.3. information about the User's payment details, including, but not limited to, data on the fact of making a payment via third-party payment systems, as well as particular payment details of the User;

3.2.4. information about location, including geolocation data (navigation data), IP address, time zone, and the information about the mobile service provider;

3.2.5. information collected with the use of cookies and other tracking technologies, in particular, the elements and functions of the Application visited by the User, usage patterns in general, tracking interaction with certain features, etc. To collect this information, the Company may send cookies to the User's electronic device;

3.2.6. any other personal data or information transmitted as part of the information traffic between the User and the Company, when using the Application, the Website, as well as in the process of conclusion or fulfilment of the User Agreement.

3.3. Registration and use of the Application by minors is not allowed. The Company undertakes to immediately delete the account and/or personal data of the User if it becomes known for certain that the account and/or personal data belong to a person who hasn't attained the age of majority.



4. PURPOSES OF COLLECTING USER'S PERSONAL DATA



The Company may use the User's Personal Data for the following purposes:

4.1.1. User registration in the Application;

4.1.2. Conclusion and fulfilment of the User Agreement;

4.1.3. Granting the User access to the DELSE parcel delivery service.

4.1.4. Identification of the User registered in the Application in order to place or search for an Announcement.

4.1.5. Establishing feedback with the User, including sending notifications, requests related to the use of the Application, service provision, processing Announcements and responses to them.

4.1.6. Confirmation of the accuracy and completeness of personal data provided by the User.

4.1.7. Providing the User with effective customer and technical support in case of problems related to the use of the Application.

4.1.8. Providing the User with his/her consent the relevant service updates, special offers, price information, newsletters, and other information.

4.1.9. Carrying out advertising activities with the User's consent.

4.1.10. Improving the quality of User service by processing User requests and applications;

4.1.11. Providing data at the request of authorized bodies in cases stipulated by legislation;

4.1.12. Protecting the interests of the Company or third parties, collecting debts or damages, identifying the person who has committed a violation of the law;

4.1.13. Making decisions or performing other actions that give rise to legal consequences for the User or other persons, as well as for achieving other purposes of Personal Data processing;



5. METHODS AND TERMS OF PERSONAL DATA PROCESSING



5.1. The processing of the User's personal data is carried out without time limit in any legal way, including in personal data information systems with or without the use of automation equipment.

5.2. When processing personal data, security procedures are observed to prevent unauthorized access to personal data and their unauthorized use.

5.3. The User agrees that the Company is entitled to transfer personal data to third parties, in particular to other Users, solely for the purpose of placing and processing the Announcements, as well as responses to them with the use of the Application.

The transfer of the Carrier's personal data to the Sender, as well as the Sender's personal data to the Carrier is necessary to ensure the possibility of further interaction between Users after response initiation and acceptance of the terms of the Announcement.

5.4. Personal data may be transferred to national and/or international regulatory authorities, law enforcement agencies, central or local executive authorities, other official or state bodies or courts where the Company has a duty to provide information in accordance with the laws of the User's country of residence or other countries, in order to prevent, detect or suppress criminal acts and fraud, or if there is another legal obligation to transfer such data.

Personal data are transmitted to the Company or its representative on the territory of the European Union at the appropriate request of the authorized bodies.

In addition, the Company can transfer personal data to the authorized bodies in order to protect its rights, as well as the rights of Users.

5.5. In case of loss or disclosure of the Personal Data, the Company is not responsible if such confidential information:

5.5.1. Became public domain before its loss or disclosure.

5.5.2. Was disclosed with the User's consent.

5.6. The Company is responsible for the deliberate disclosure of the User's Personal Data, except for the cases set out in clauses 5.3., 5.4. and 5.5. of this Privacy Policy.



6. OBLIGATIONS OF THE PARTIES



6.1. The User shall:

6.1.1. Provide correct and reliable information about personal data necessary for using the Application.

6.1.2. Update or supplement the provided information about personal data in case of any changes to this information.

6.1.3. Take measures to protect access to his/her confidential data stored in the Application.

6.2. The Company shall:

6.2.1. Implement proper security procedures at an appropriate level to prevent unauthorized access to or unauthorized use of personal data being processed.

6.2.2. Use the information obtained exclusively for the purposes specified in section 4 of this Privacy Policy.

6.2.3. Intentionally not disclose the User's personal data, except for the cases set out in clauses 5.3., 5.4. and 5.5. of this Privacy Policy.

6.2.4. Block personal data related to the relevant User from the moment of receipt of the request or application filed by the User or his/her legal representative, or authorized body for the protection of the rights of personal data subjects for the period of verification, in case of identification of inaccurate personal data or illegal actions.



7. USER RIGHTS



7.1. The User has the right to control the Company's use of his/her personal data. This right may be exercised in the flowing way:

7.1.1. Request an overview of personal data in Company's disposal;

7.1.2. Inform about any changes in the User's personal data or ask to correct any information in the personal data stored by the Company. At the same time, the User can also make such changes independently through his/her personal account;

7.1.3. Require the Company to delete personal data or a part thereof, to block or restrict their processing, and send a refusal regarding specific ways of using personal data;

7.1.4. Revoke consent to the processing of personal data.



8. SETTLEMENT OF DISPUTES



8.1. This Privacy Policy is governed by and interpreted in accordance with international law, as well as the effective laws of the USA.

8.2. The User and the Company undertake to take all measures to resolve disputes and disagreements arising in the course of using the Application or in connection with it, through negotiations.

8.3. Should the Parties fail to settle a dispute through negotiations, the disputes arising out of the relations between the Parties shall be resolved by the relevant US judicial authority in accordance with US law.

8.4. Before applying to the court regarding the disputes arising from the relationship between the User and the Company, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute).

8.5. The recipient of the claim shall within 30 calendar days from the date of receipt of the claim notify the claimant in writing of the results of its consideration.

12.6. The claim, as well as the response to it, can be sent by a message in the Application or to the User's e-mail specified during registration and to the Company's e-mail support@delse.by.

9. ADDITIONAL PROVISIONS



9.1. The Company shall be entitled to make changes to this Privacy Policy without the User's consent.

9.2. The new Privacy Policy takes effect from the moment it is posted on the website https://delse.net and/or in the Application, unless otherwise provided for by the new version of the Privacy Policy.

9.3. The User must monitor changes to the Privacy Policy on the Website and/or in the Application on his/her own.

9.4. This Privacy Policy forms an integral part of the User Agreement. In the event of any contradictions between the terms of the Privacy Policy and the User Agreement, the terms of the Privacy Policy shall apply with regard to the issues related to personal data collection and processing.

9.5. This Privacy Policy has been drawn up in Russian and may be translated into other languages at the Company's discretion. In case of any discrepancies, the Russian version shall prevail.





Delse, Inc.

1201 N.Orange Street, Suite 7160

19801, Wilmington, DE

United States