shareit 茄子快传

Terms of Service

    The following terms of service ("TOS") constitute a binding legal agreement (the "Agreement") between You and SHAREit (hereinafter referred to as "SHAREit"/"we"/"us"), (which expression shall include its successors and assigns), setting forth the terms and conditions ("Terms") under which the SHAREit application ("Application") and any related services (collectively "Services") will be licenced to You by SHAREit.

    By accessing, downloading, installing the Application, and using the Services, You represent to SHAREit that You are competent to enter into a contract (i.e. You a major according to applicable law, of sound mind and not disqualified from entering into a contract under the applicable law) and You have read this Agreement, understand it and agree to be bound by its Terms. Please review the Agreement carefully before accessing, downloading and installation.

    Meanwhile, by accessing, downloading, installing the Application, and using the Services, You are agreeing to be bound by the YouTube's Terms of Service (

    If You are using Services on behalf of a company, partnership, association, government or other organisation (Your "Organisation"), You warrant that You are authorised to do so and that You are authorised to bind Your Organisation to these Terms. In such circumstances, "You" will include Your Organisation.

    1. Who May Use the Service

    Age Limit:You must be at least 16 years old to use the Service. If you are at least 13, but are still a minor (this depends on where you live), you must have your parent or legal guardian's permission to use the Service. Please have him or her read this Agreement with you.

    Notice To Parents And Guardians:By granting your child permission to use the SHAREit Service, you agree to the terms of this Agreement on behalf of your child. You are responsible for monitoring and supervising your child's use of the SHAREit Service. If your child is using the SHAREit Service and is either under 16 or does not have your permission, please contact us immediately so that we can disable his or her access. If you have questions about whether the SHAREit Service is appropriate for your child, please contact us.

    Warning:Even if you are old enough to use the SHAREit Service and/or have your parent's or guardian's permission, some of the content available within the SHAREit Service may not be appropriate for you. Some content may contain "R-rated" material, nudity, profanity, and mature subject matter. If you are under 18, do not view such content.

    2. License

    2.1 Subject to the Terms and compliance of the Terms hereof we shall grant You a license to use the Services provided that (a) You shall use the Application solely for Your personal and lawful use only; (b) You will not, nor allow third parties on Your behalf (i) to resell or charge others for use of the Application (ii) to duplicate, disassemble, decompile, transfer, exchange or translate the Application, create derivative works of the Application of any kind whatsoever or attempt to reverse engineer, alter or modify any part of the Application; and (c) You warrant to otherwise comply with the terms and conditions of this Agreement.

    2.2 For avoidance of any doubt this License is personal, nonexclusive, nontransferable, non-sub licensable, revocable and a limited license to download and use the Application on a mobile device that You own or control.

    2.3 All rights not expressly granted are reserved.

    3. Application Stores

    The Application can also be downloaded from third party application stores including but not limited Google Play, Nokia Ovi Store and Apple App Store etc. You agree to comply with all third party terms and conditions & privacy policy, if any, applicable to the use of the Application or related services. We shall not be responsible for violation and infringement of any third party right, terms and conditions in connection with access, download or installation of the Application by You.

    4. Your Content

    4.1 When You submit, upload, transmit or display any data, information, media or other content, including but not limited any photos, profiles (including Your name and image), messages, text, video, music, third party links), in connection with Your use of Services (" Your Content"), You understand and agree that:

    (a) You will continue to own and be responsible for Your Content;

    (b) we will not sell Your Content to any third party;

    (c) You are giving us and our affiliate companies the right to use Your Content (with no fees or charges payable by us to You) solely for the purposes of providing, promoting, developing and trying to improve Application and our other services, including new services that we may provide in the future. All such use will be in accordance with our Privacy Policy;

    (d) in using Your Content for these purposes, we and our affiliate companies may copy, reproduce, host, store, process, adapt, modify, translate, perform, distribute and publish Your Content worldwide in all media and by all distribution methods, including those that are developed in the future;

    (e) we may share Your Content with third parties that we work with to help provide, promote, develop and improve Services, but these third parties (other than our affiliate companies) will not make any separate use of Your Content for their own purposes (i.e. for any purposes that are not related to Services);

    (f) we may use the name that You submit in connection with Your Content (whether that be your account name, real name or otherwise); and

    (g) You will comply with these Terms in your submission of Your Content.

    4.2 In addition, You agree that we and our affiliate companies (subject to these Terms, our Privacy Policy and applicable laws and regulations):

    (a) are allowed to retain and continue to use Your Content after You stop using Services – for example, where You have shared Your Content with other users of Services;

    (b) may be required to retain or disclose Your Content in order to: (i) comply with applicable laws or regulations; (ii) comply with a court order, subpoena or other legal process; or (iii) respond to a lawful request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere); and

    (c) may need to retain or disclose Your Content in order to enforce these Terms, protect our rights, property or safety, or the rights, property or safety of our affiliate companies or other users of Services.

    4.3 You understand that even if You seek to delete Your Content from Application, it may as a technical and administrative matter take some time or not be possible to achieve this – for example, we may not be able to prevent any third party from storing or using any of Your Content that you have made public via Application.

    4.4 We reserve the right to block or remove Your Content for any reason, including as is in our opinion appropriate or as required by applicable laws and regulations.

    4.5 You are solely responsible for Your Content and we recommend that You keep a back-up copy of it at all times. You must at all times ensure that: (i) you have the rights required to submit, transmit or display Your Content, and to grant us the rights as set out in these Terms; and (ii) Your Content (and our use of Your Content in accordance with these Terms) does not infringe or violate the rights of any person or otherwise contravene any applicable laws or regulations.

    5. Third Party Content and Advertising

    5.1 We are not responsible for and we do not endorse, support or guarantee the lawfulness, accuracy or reliability of any content submitted to, transmitted or displayed by or linked by Application, including content provided by users of Application or by our advertisers. You acknowledge and agree that by using Services, You may be exposed to content which is inaccurate, misleading, defamatory, offensive or unlawful. Any reliance on or use of any content on or accessible from Application by You is at Your own risk. Your use of Services does not give You any rights in or to any content You may access or obtain in connection with Your use of Services.

    5.2 We also do not guarantee the quality, reliability or suitability of any third party services provided, made available, advertised or linked through Services and we will bear no responsibility for Your use of or relationship with any such third parties or third party services.

    5.3 We may review (but make no commitment to review) content or third party services made available through Application to determine whether or not they comply with our policies, applicable laws and regulations or are otherwise objectionable. We may remove or refuse to make available or link to certain content or third party services if they infringe intellectual property rights, are obscene, defamatory or abusive, violate any rights or pose any risk to the security or performance of Services.

    5.4 There may be, from time to time, third party content and services on Application that are subject to further terms – for examples, terms from the relevant third party that originally produced or created such content or service, or terms from the relevant third party in relation to promotional activities being held on SHAREit. You agree to comply with any such further terms and conditions as notified to You in relation to your use of such third party content and services.

    5.5 Application may include advertising or commercial content. You agree that we are allowed to integrate, display and otherwise communicate advertising or commercial content in Application and that (where reasonably practicable) we will identify paid such advertising or commercial content. You also agree that we use targeted advertising to try to make advertising more relevant and valuable to you.

    6. Our Intellectual Property Rights

    You acknowledge and agree that the Application, the Services and all trademarks, service marks and trade names and other intellectual property rights associated therewith are, and shall remain, the property of SHAREit and its licensors, as applicable. All content related to Services, including any text, graphics, logos, button icons, images, audio clips and software, is the exclusive property of SHAREit or its licensors and is protected by applicable legislation concerning protection and preservation of intellectual property rights. All software used on the Application is the property of SHAREit or its software suppliers. Any use except as specifically permitted, including the reproduction, modification, distribution, transmission, republication, display or performance, of the content on the Application is strictly prohibited except as otherwise permitted by law.

    7. Use of Your Device by SHAREit

    7.1 In order for us to provide Services to You, we may require access to and/or use of Your relevant device (e.g. mobile phone or tablet) that You use to access Application – for example, we may need to use Your device's processor and storage to complete the relevant Application installation, or we may need to access Your contact list or camera to provide certain interactive functions within Application. You agree to give us such access to and use of Your device.

    7.2 You understand that if You do not provide us with such right of use or access, we may not be able to provide Services to you.

    7.3 Any Personal Information (as defined in the Privacy Policy) that we use or access within Your device will be treated in accordance with these Terms, including our Privacy Policy.

    7.4 You may also be required to activate certain functionalities within Application in the manner described within Application. You may not be able to use certain functionalities within Application if You do not comply with such requirements.

    7.5 Please note that we are not responsible for any third party charges You incur (including any charges from Your internet and telecommunication services providers) in relation to or arising from Your use of Services.

    8. Your Account

    8.1 You may need to create an account with us in order to access and use Services.

    8.2 Any account that You open with us is personal to You and You are prohibited from gifting, lending, transferring or otherwise permitting any other person to access or use Your account. Your account name, user ID and other identifiers You adopt within Application remains our property and we can disable, reclaim and reuse these once Your account is terminated or deactivated for whatever reason by either You or us.

    8.3 You are responsible for: (i) safeguarding Your account details, including any passwords used to access Your account, and (ii) all use of Services under Your account. We will regard all use of Your account on Application as being by You.

    8.4 If You change or deactivate the mobile phone number or Facebook ID that You used to create an account, You must update Your account information through Settings as soon as You can.

    9. Infringement Indemnity

    9.1 Neither SHAREit, nor its affiliates, subsidiaries nor the Licensors will have any liability for any claim based upon or arising out of (a) intentional or negligent acts of anyone other than SHAREit; (b) the combination, operation or use of the Application with any equipment, devices or software not supplied by SHAREit; or (c) the alteration or modification of the Application.

    9.2 To the full extent permitted by law, this section states the entire liability of SHAREit, its affiliates, subsidiaries and the Licensors and Your sole remedy with respect to any claim of infringement.

    10. Limited Warranty and Safety

    10.1 We does not represent or warrant that the Application will operate without interruption or will be error free. Especially in the following cases:

    (a) modification or alteration of the Applications made without the prior written approval of SHAREit;

    (b) accident, neglect, misuse or abuse, or

    (c) exposure to conditions outside the range of the environmental, power and operating specifications provided by SHAREit.

    10.2 By using the Services, You agree that You will not:

    (a) use the Services for any purpose that is illegal or prohibited in these Terms;

    (b) use any robot, spider, crawler, scraper, or other automated means or interface to access the Services or extract other user’s information.

    (c) use or develop any third-party applications that interact with the Services or other user’s content or information without our written consent;

    (d) use the Services in a way that could interfere with, disrupt, negatively affect, or inhibit other users from fully enjoying the Services, or that could damage, disable, overburden, or impair the functioning of the Services;

    (e) use or attempt to use another user’s account, username, or password without their permission;

    (f) solicit login credentials from another user;

    (g) post content that contains pornography, graphic violence, threats, hate speech, or incitements to violence;

    (h) upload viruses or other malicious code or otherwise compromise the security of the Services;

    (i) attempt to circumvent any content-filtering techniques we employ, or attempt to access areas or features of the Services that You are not authorized to access;

    (j) probe, scan, or test the vulnerability of our Services or any system or network;

    (k) encourage or promote any activity that violates these Terms;

    10.3 We also care about Your safety while using our Services. So do not use our Services in a way that would distract You from obeying traffic or safety laws.

    11. Disclaimer and Limitation of Liability

    11.1 We only provide You an application which can play and upload healthy and legitimate contents. Please do not use the Application to hurt anyone or engage in illegal activities. If Your behavior causes any damages or infringes any third party's legitimate rights, You may solve Yourself and bear corresponding liabilities of compensation.

    11.2 We will not assume any guarantee or warranty liabilities for any third-party software, services, or applications.

    11.3 Except as expressly set forth in this TOS, neither SHAREit, its affiliates, subsidiaries nor the Licensors make any other warranties, express or implied, including any implied warranties of merchantability and fitness for a particular purpose. SHAREit, its affiliates, subsidiaries and the Licensors expressly disclaim all warranties not stated in this TOS. Any implied warranties that may be imposed by law are limited to the terms contained in this TOS to the maximum extent permitted by law.

    11.4 To the maximum extent permitted by applicable laws, under no circumstance shall SHAREit, its affiliates, subsidiaries and the Licensors be liable to You or any third person for personal injury, or any special, incidental, indirect, punitive or consequential damages whatsoever, including, but not limited to, damages for loss of profits or revenues, goodwill, failure to transmit or receive any data, loss of confidential information, business interruption, loss of privacy, corruption or loss of data, failure to receive or backup Your data (or archived data), for any cause of action, including contract, tort (including negligence) or otherwise and any other loss whatsoever arising out of or in any way arising from or related to the use of Application, or following a failure, suspension or withdrawal of all or part of the Application at any time, any third party content, software or functions used in connection with the Application even if SHAREit, its affiliates, subsidiaries and the Licensors have been advised of the possibility of such damages.

    11.5 You agree to indemnify, defend and hold harmless SHAREit, its subsidiaries, affiliates and Licensors and each of their respective officers, directors, employees, successors and assigns from and against any claim, proceeding, loss, damage, liability, cost, demand or expense (including but not limited to attorney's fees) of any kind arising out of: (a) Your access to or use of the Application and related services; (b) any breach by You of Your obligations under this Agreement; (c) Your violation of the rights of a third party, including but not limited to infringement of any intellectual property, proprietary right or trade secret of any person or entity, or of any privacy or consumer protection right that is implicated herein; (d) any violation of law or contractual obligation and any claims, demands, notices pursuant to such violation; (e) Your negligence or willful misconduct. These obligations will survive termination of this Agreement.

    11.6 If your behavior does not comply with the Terms of Service or related laws and regulations and is found out by means of notification or report, we have the right to make independent judgment. We also have the right to terminate some or all of the services provided to you immediately without informing you. If your behavior causes any third party to lodge claims or causes damage or loss, you may assume full responsibility.

    12. Privacy Policy

    This Agreement is deemed to incorporate the Privacy Policy posted on the terms and accessible in the Application.

    13. Termination

    13.1 This Agreement commences on the date You accept the Terms of this Agreement. We may terminate or suspend use of the Application at any time in our discretion, without notice to You. Upon any termination for any reason, we shall have no liability to You and no further obligations under this Agreement.

    13.2 Immediately upon termination, (a) the rights granted to You herein shall terminate; (b) You must cease all use of the Application and related services.

    13.3 Your rights under this Agreement will terminate automatically if You fail to comply with any term(s) of this Agreement including misuse of the Application.

    13.4 All sections that may be reasonably interpreted to or are intended to survive this Agreement will survive this Agreement.

    14. Governing Law and Disputes

    14.1 This Agreement shall in all respects be governed by and construed and enforced in accordance with the laws of China. You irrevocably consent to the exclusive jurisdiction of competent courts in Beijing, China for all disputes arising out of or relating to this Agreement. The United Nations Convention on Contracts for the International Sale of Goods will not apply to this Agreement.

    14.2 For any dispute you have with us, you agree to first contact us and attempt to resolve the dispute with us informally.

    15. General Terms and Conditions

    15.1 Entire Agreement

    You acknowledge that You have read this Agreement, understand it and agree to be bound by its terms and conditions. You also agree that this Agreement read with the terms of the Privacy Policy is the complete and exclusive statement of the Agreement between SHAREit and You and supersedes all proposals, representations or prior agreements, oral or written, and any other communications between SHAREit and You relating to the subject matter of this Agreement.

    15.2 Severability

    The invalidity or unenforceability of any provision of this TOS will not affect the validity or enforceability of any other provision, the remaining provisions being deemed to continue in full force and effect.

    15.3 Assignment

    We may assign this TOS or any of the rights or obligations hereunder, and any causes of action arising hereunder, to any third party without necessity or obligation of notice to you.

    15.4 Amendments to this Agreement

    We may in our sole discretion amend this Agreement from time to time without any prior notice. This may include adding new or different terms to, or removing terms from, this Agreement. Such change shall be notified in the Application. Your use of the Application after such notice of any change shall be deemed to be an acceptance to the amended Agreement.

    15.5 No Waiver

    The waiver or failure of either party to exercise in any respect any right provided for herein will not be deemed a waiver of any further right hereunder.

    15.6 Force Majeure

    We will not be responsible for any failure to perform its obligations under this TOS due to circumstances beyond its reasonable control, including without limitation acts of God, war, riot, terrorism, embargoes, acts of civil or military authorities, fire, flood or accidents. You agree that SHAREit will be entitled to all legal and equitable remedies otherwise available to it to protect the intellectual property, proprietary rights and Confidential Information of itself and its Licensors, including without limitation, the right to seek and obtain injunctive relief and enforce the same against you without the necessity of having to post bond or other such guarantee.

    16. Changes to this TOS

    We may revise this TOS from time to time. You can always check the latest version of our Privacy Policy at []. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised TOS.


    If you are a user of our services in the United States of America, the below terms are incorporated into this TOS, and override this TOS to the extent of any inconsistency.

    If you are a California resident, you agree to waive California Civil Code Section 1542, and any similar provision in any other jurisdiction (if you are a resident of such other jurisdiction), which states: "A general release does not extend to claims which the creditor does not know or suspect to exist in his favor at the time of executing the release, which, if known by him must have materially affected his settlement with the debtor."

    Each of the parties hereto irrevocably waives any and all right to trial by jury or to participate in a class action in any legal proceeding arising out of or relating to these terms or the transactions contemplated hereby.


    If you are a user of our services in Australia, the below terms are incorporated into these Terms, and override these Terms to the extent of any inconsistency.

    All express or implied guarantees, warranties, representations, or other terms and conditions relating to these Terms or their subject matter, not contained in these Terms, are excluded from these Terms to the maximum extent permitted by law.

    Nothing in these Terms excludes, restricts or modifies any guarantee, warranty, term or condition, right or remedy implied or imposed by any applicable law which cannot lawfully be excluded, restricted or modified.

    If any guarantee, condition, warranty or term is implied or imposed by any applicable law and cannot be excluded (a "Non-Excludable Provision"), and we are able to limit your remedy for a breach of the Non-Excludable Provision, then our liability for breach of the Non-Excludable Provision is limited to one or more of the following at our option:

    (a) In the case of goods, the replacement of the goods or the supply of equivalent goods, the repair of the goods, the payment of the cost of replacing the goods or of acquiring equivalent goods, or the payment of the cost of having the goods repaired; or

    (b) In the case of services, the supplying of the services again, or the payment of the cost of having the services supplied again.

    Privacy Policy

      At SHAREit(hereinafter "SHAREit"/"we") recognize that privacy is significant. We provides this Privacy Policy to inform users of the SHAREit application (the "Application" or "Applications"), the related services we provide ("Services") and the Site about our policies and procedures regarding the collection, use and disclosure of information.

      This Policy is part of our Terms of Service and applies to the information that is collected in connection with the download, installation and use of the Application, related services and the Site. By using the Application, related Services or the Site you signify your assent to this Privacy Policy and agree that we may collect, use and share your Information (Personal Information and Non-Personal Information) in accordance with this Privacy Policy, as revised from time to time. If You do not agree with this Policy, or with our Terms of Service, do not download, install and / or use the Application.

      This Policy covers our collection, use and disclosure of Your information through the Applications, the Services and the Site. It does not cover any collection, use or disclosure by third parties through any applications, Web sites, products or services that we do not control or own, or any third party features or services made available via an Application, the Services or the Site. All trademarks, trade names, and logos of third parties featured on the Applications or the Site belong to their respective owners.

      The Application is intended for people who are competent to contract under applicable law. Individuals who are considered a minor in applicable jurisdictions are not permitted to use this application unless the complete Agreement is seen and agreed by parents or their legal guardians under applicable law.

      1. What Kind of Information We Collect

      In providing Application, we collect, store and use the following Information relating to you:

      1.1 Personal Information

      "Personal Information" is information that identifies you or another person. Personal Information may include the following:

      1.information you make available to us when you open a SHAREit account or use another service (Twitter,Facebook), such as your name, telephone number, email address;

      2.any information included in your publicly visible Application profile, which may include your profile ID, name and photo;

      3.information you make available to us and/or public via your use of Application and/or another service which you use to open your SHAREit account;

      4.information made available by another user about you via their use of Application; and

      5.information we collect as you use Application, such as certain Location Data and Log Data.

      i." Location Data" is information that we collect regarding your location (when you use a location-enabled service), including:

      • the location of your device when you use Application, such as from the GPS, Wi-Fi, compass, accelerometer or other sensors in your mobile device;
      • the IP address of the device or internet service you use to access Application; and
      • other information made available by you or others that gives an indication as to where you are or have been located, such as account information that indicates where you are located, and shared information that you or others post which indicates your location.

      ii." Log Data" is technical information that is automatically collected by us when you use Application, whether through the use of cookies, web beacons, log files, scripts and e-tags or otherwise, including:

      • technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access Application, your IP address and your device's version and identification number;
      • information about what you have searched for and looked at while using Application, such as web search terms used, social media profiles visited and details of other information and content accessed or requested by you in using Application;
      • information about communications you have made using Application, such as the people you've communicated with and the time, data and duration of your communications; and
      • metadata, which means information related to items you have made available through Application, such as the date, time or location that a shared photograph or video was taken or posted.

      1.2 Non-Personal Information

      Non-Personal Information is any information that relates to you but from which it is not practicable to directly or indirectly identify you, which may include the information about your devices (such as Your hardware model, operating system version, unique device identifiers, and mobile network information), the list of installed apps on your devices, and technical information about users means of connection to our apps, such as the versions of phone model and other similar information.

      2. How We Use Collected Information

      2.1 We may use your Information for any purpose as below: provide Application and Services (and the features within Application) to you, such as to show to other users in SHAREit such as your connected friends or other users on the platform; provide you with advertising and direct marketing that is more relevant to you; better understand how you access and use Application, in order for us to improve Application and respond to customer desires and preferences, including for us to provide language and location customisation, personalised help and instructions, or other responses to your and other customers' usage of Application; help develop our service and provide, maintain, improve and modify the Applications, Services and the Site and develop new services; assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with Application.

      2.2 If any of your Personal Information comprises Your Content (as defined in the Terms of Service), we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the "Your Content" section of the Terms of Service.

      2.3 The data we collect depends on the context of your interactions with us, the choices you make, including your privacy settings, and the products and features you use. The data we collect can include SDK/API/JS code version, browser, Internet service provider, IP address, platform, timestamp, application identifier, application version, application distribution channel, independent deice identifier, iOS ad identifier (IDFA), Android ad master identifier, network card (MAC) address, and international mobile device identification code (IMEI) The equipment model, the terminal manufacturer, the terminal device operating system version, the session start / stop time, the location of the language, the time zone and the network state (WiFi and so on), the hard disk, the CPU, and the battery use, etc.

      2.4 To improve our product and provide you better service, we also share personal data with vendors or agents working on our behalf for the purposes described in this privacy policy. For example, companies we've hired to provide data analytical services may need collect and access to personal data to provide those functions. In such cases, these companies must abide by our data privacy and security requirements.

      2.5 We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process personal data includes processing that is: necessary for the performance of the contract with you (for example, to provide you with the services you request and to identify and authenticate you so you may use the Sites); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests (for example, to manage our relationship with you, to ensure the security of our services, to communicate with you about our products and services); and based on consent by our customers (for example, to place certain cookies and to share your information with third parties for advertising purposes). In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Sites.

      2.6 Our business may require us to transfer your Personal Data to countries outside of the European Economic Area ("EEA"), including to countries such as the People's Republic of China or Singapore. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as standard contractual clauses. A copy of those clauses can be obtained by contacting our Help Center.

      2.7 Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your Personal Data, and to request access to, rectification, erasure and portability of your own Personal Data.

      Where the use of your information is based on consent, you can withdraw this consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. Requests should be submitted by contacting us through [].

      If you are aware of changes or inaccuracies in your information, you should inform us of such changes so that our records may be updated or corrected. You may lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes applicable law.

      We retain your Personal Data as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.

      3. How Your Information May Be Disclosed

      3.1 Without your consent, we will not disclose your information to any third party except the following circumstances:

      1.With your prior authorization or consent;

      2.Under the mandatory requirement from government authorities or in accordance with laws, rules, regulations and legal procedures;

      3.For the purpose of academic research or public interest;

      4.To safeguard our legitimate rights and interests, such as finding, defending, and settling infringement or security problems;

      5.When you select the sharing function;

      6.Other circumstances that are in accordance with Terms of Service and Privacy Policy.

      3.2 We and our affiliate companies may share your Personal Information within our group of companies and with joint venture partners and third party service providers, marketing partners, contractors and agents, in each case, for the following purposes: (i) providing Services to you; (ii) assisting us in carrying out the purposes set out under the "How We Use Your Information" section above; (iii) carrying out our obligations and enforcing our rights under the Terms of Service or this Privacy Policy; and/or (iv) helping us understand and improve Services.

      4. Third Party

      4.1 We may provide links to third-party Web sites. The Site may also carry advertisements from other companies. When you click on links of third parties in an Application, the Services or the Site, you may leave the Application, the Services or the Site. We do not collect your information on and through and this Privacy Policy does not address, and we are not responsible for, the privacy practices of Web sites operated by third parties, whether they are linked to or otherwise accessible from an Application, the Services or the Site. The inclusion of a link or accessibility of third party Websites does not imply endorsement of such third party Website by us.

      4.2 The information that you transfer, send and/or share through the Application, the Services and/or the Site may be intercepted, collected, used and disclosed by third parties. We are not responsible for any interception, collection, use and disclosure of your information by any third party. Please choose other ways to transfer and share if you have higher security requirements.

      5. Account Security

      Please do not buy, sell, transfer, rent, and/or lease your account and/or password to other people. We will not take any responsibility for the illegal use of your account by others that is caused by hacking or negligent password keeping.

      6. Security

      We are very concerned about safeguarding the confidentiality of your information. We employ administrative, physical and electronic measures designed to protect your Information from unauthorized access and use. Please be aware that no security measures that we take to protect your information are absolutely guaranteed to avoid unauthorized access or use of your Information which is impenetrable.

      7. International Users

      Your Information may be stored and processed in any country where we have facilities, and by using an Application, the Services or the Site you consent to the transfer of your Information to countries, including the United States, which may be outside of your country of residence and may provide for different and less stringent data protection rules than in your country. If you object to your Information being transferred or used as described in this Policy, please do not use any Application, the Services or the Site and immediately delete all Applications from your User Devices.

      8. Sensitive Information

      We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, sexual orientation, criminal background or membership in past organizations, including trade union memberships) on or through an Application, the Services or the Site or otherwise to us.

      9.Children's Information

      SHAREit does not knowingly collect any personal identification information from children under the age of 13 (or such legally required age of consent for Juveniles as defined under applicable laws) or knowingly allow such person to register on SHAREit. In the event that we are notified that we have collect personal information from a child under the age of 13 (or such legally required age of consent for Juveniles as defined under applicable laws) without parental consent, we will suspend the account and delete relevant information as quickly as possible. If you believe that we might have any information from a child under 13(or such legally required age of consent for Juveniles as defined under applicable laws), please contact us at

      10. Contacting Us

      If you have any questions or comments about this Policy or our privacy practices, or to report any violations of the Policy or abuse of an Application, the Services or the Site, please contact us at

      11. Changes to This Privacy Policy

      We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at []. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

      12. YouTube Privacy Policy

      Please note that we are using YouTube API Services (defined in YouTube's Terms of Services). By using the Services, You are agreeing to be bound by the Google Privacy Policy (

      Advertising Policy

      Effective: February 28, 2019

        The SHAREit Advertising Platform (the "Platform", "Platform" means any application and website of SHAREit that may display advertising contents on it.) is intended not only to provide a means for organizations of all sizes and budgets to promote their products and services, but also to enhance a user's experience by providing engaging, relevant, accurate, and fair advertisements. To ensure the furtherance of these objectives, SHAREit Advertising Policy (the "Policy") is formulated. SHAREit reserves the right to amend this Policy at any time without notice and to modify, reject, or remove any advertisements, including advertisements not explicitly prohibited by the Policy, in its sole discretion, so please check in and review them regularly.

        I) Compliance with the Policy and Legal Requirements

        Our Advertising Policy provide guidance on what types of ad content are allowed. When advertisers place an order, each ad is reviewed against these policies. While the guidelines below may reflect certain legal requirements that are applicable to advertisers within particular industries, these guidelines are not legal advice. It is the responsibility of the advertiser to ensure that its advertisements and materials comply with all applicable laws and regulations, the Policy, and any instructions provided by SHAREit. If the contents of this policy is inconsistent with the laws and regulations of the targeting countries, the local laws and regulations shall govern. Indeed, adherence to these guidelines may not be sufficient to fulfill the legal requirements and regulations applicable to your industry. SHAREit urges advertisers to consult with their legal counsel regarding appropriate advertising practices for their industries, locations, and any additional locations targeted for advertising.

        II) Disclosures

        All required disclosures and mandatory warnings in ads must be clear and conspicuous.

        Advertiser(s) must be accurately and clearly identified in the ad.

        III) Third-Party Services

        If you use a service, feature, or functionality that is operated by a third party and made available through our Services (including Services we jointly offer with the third party), each party’s terms will govern the respective party’s relationship with you. SHAREit is not responsible or liable for a third party’s terms or actions.

        IV) Prohibited Advertisements and Practices

        SHAREit maintains a general prohibition on advertiser conduct that is designed to circumvent the Policy or to abuse the capabilities of the Platform. While this prohibition includes conduct that results in advertising-platform arbitrage, that disseminates malware, that exploits data from users in an irresponsible manner, that redirects users to unknown destinations, or that endeavours to circumvent SHAREit’s review systems, whether specific conduct falls within this general prohibition is determined in the sole discretion of SHAREit. In addition to this general prohibition, SHAREit prohibits advertisements related to the following categories of products and services on its Platform:

        1. Products or Services that Facilitate Illegal, Fraudulent, or Misleading Behavior

        Products or services may not be advertised on the Platform that facilitate illegal, fraudulent, or misleading behavior. Examples of such products or services include those used for hacking or obtaining unauthorized access to wire, electronic, or other networks, those designed to circumvent copyright limitations, those designed to cause inflation of website metrics, such as clicks, impressions, likes, or followers, those designed to produce inauthentic documents, work product, or credentials, those which obscure the transparency of the blockchain, those designed to assist in evasion of law-enforcement activities, and those related to unlawful, improbable, or unsubstantiated financial products and services, investment, or contribution strategies and schemes.

        2. Counterfeit Goods

        Advertisements may not promote or offer for sale counterfeit goods, including inauthentic collectibles or memorabilia and goods with a mark or logo that is likely to be confused with the trademark of another.

        3. Hazardous Products or Services

        Advertisers may not use the Platform to promote the use or sale of hazardous, dangerous, or injurious products or services, including products subject to consumer recalls, explosive materials or fireworks, recreational drugs or substances, weapons, guns, ammunition, explosives, tobacco products, and related products or services.

        4. Obscene, Offensive, or Inappropriate Content

        Advertisers may not use the Platform to disseminate obscene, offensive, or inappropriate content. Such prohibited content includes content that depicts intolerant or overly contentious political or cultural topics or views, that uses vulgar or sexually explicit words or images, that is designed to evoke visceral reactions, or that is improperly targeted toward minors.

        5. Inappropriate Targeting

        SHAREit strives to offer useful and relevant ads to its users. As such, all targeting must be relevant, appropriate, and in compliance with relevant legal obligations of the advertiser. Examples of inappropriate targeting may include (but are not limited to):

        • Goods or services targeted to regions where they are illegal;
        • Age-restricted products or services targeted to minors;
        • Ads whose targeting illegally discriminates;
        • Ads whose targeting is likely to provoke or cause outrage.

        Ads disapproved for inappropriate targeting may be resubmitted with targeting revisions.

        6. Deceptive, Untrue, or Misleading Advertising

        Advertisers using the Platform must ensure their advertisements are truthful, non-deceptive, and defensible. Thus, advertisers may not employ techniques that are deceptive, untrue, or misleading, including failing to disclose material terms of an offer or service, irresponsible use of the term "free," offering software that includes undisclosed collection of personal data or malicious applications, promoting products that facilitate spam, making factual claims unsupported by a reasonable basis, or using sensational, exaggerated, or overly provocative content.

        Ads must not mislead users into interacting with their creative content; this includes ads that simulate system or site warnings/error messages or appear to offer a functionality that is not present within the ad.

        7. Prohibited Financial Products and Services

        Ads must not promote financial products and services that are frequently associated with misleading or deceptive promotional practices.

        The following types are not allowed:

        • Initial Coin Offerings

        • Binary Options

        8. Sale of Body Parts

        Ads must not promote the sale of human body parts or fluids.

        9. Spyware or Malware

        Ads must not contain spyware, malware, or any software that results in an unexpected or deceptive experience. This includes links to sites containing these products.

        10. Automatic Animation

        Ads must not contain audio or flash animation that plays automatically without a person's interaction or expands within Facebook after someone clicks on the ad.

        11. Unauthorized Streaming Devices

        Ads must not promote products or items that facilitate or encourage unauthorized access to digital media.

        12. Payday Loans, Paycheck Advances, and Bail Bonds

        Ads may not promote payday loans, paycheck advances, bail bonds, or any short-term loans intended to cover someone's expenses until their next payday.

        13. Surveillance Equipment

        Ads may not promote the sale of spy cams, mobile phone trackers or other hidden surveillance equipment.

        V) Restricted Advertisements

        In addition to the prohibitions on certain categories of advertisements, SHAREit also enforces limitations how certain products and services may be advertised on the Platform. These restrictions are designed to ensure that controversial or age-restricted products or services appear only to the appropriate users. These restricted categories of advertisements are discussed in more detail below:

        1. Adult-Oriented Products or Services

        Only certain categories of products or services that are intended for adult audiences may be advertised on SHAREit. If promotion of the product or service is permitted, SHAREit restricts the method of promotion.

        The following categories of adult-oriented products and services are strictly prohibited:

        (i) products or supplements claiming to provide sexual enhancement; and

        Promotion of permissible adult-oriented products and services must not:

        (i) violate applicable laws and regulations, which may include those applicable to the location of your business or of your target audience;

        (ii) target minors;

        (iii) include sexually explicit images or text; or

        (iv) promote products or services with unlawful themes or content.

        (v) utilize the video ad format.

        2. Alcohol

        Advertisements related to alcoholic beverages or products must:

        (i) comply with applicable laws and regulations, which may include those applicable to the location of your business and of your target audience;

        (ii) comply with industry standards, as may be reflected in the Distilled Spirits Council Code of Responsible Practices, the Beer Institute Advertising and Marketing Code and Guidelines, or the Wine Institute Code of Advertising Standards; and

        (iii) target individuals above the legal-drinking age.

        3. Third-Party Rights

        Advertiser shall not infringe upon or misappropriate any copyrights, patents, trademarks, design rights or registrations, trade secrets, confidential information, or similar intellectual property rights (collectively "IP Rights") of any third party. If a proposed advertisement includes third-party content that has been authorized for such use, advertisers may be required to submit documentation to SHAREit evidencing such authorization.

        4. Dating Services

        SHAREit allows dating sites, apps, and associated services to advertise, with restrictions. All advertisers within this vertical must be pre-approved and working directly with a SHAREit sales representative.

        The following types of sites, apps, and services are prohibited:

        • Those centered on infidelity
        • Those that provide for casual sex, international matchmaking, escorts, prostitution, intimate massages or other, similar services
        • Those focused on fetish communities
        • Those that exclude persons of specific races, sexualities, religions, political affiliations, etc.

        5. Political Advertisements

        SHAREit permits responsible political advertising, and expect all political ads and destinations to comply with local legal requirements, including campaign and election laws and mandated election "silence periods," for any geographic areas they target. The content of political ads shall be neutral and unbiased, focusing on factual situation and statics, and no any form of slandering, hate speech, etc. This policy applies to political content which consist of political campaigning and issue advocacy advertising. Advertisers can run political, election related and issue ads, provided the advertiser complies with all applicable laws and have a written agreement with SHAREit.

        Note that election ads don’t include ads run by non-political entities promoting political merchandise like t-shirts, or ads run by news organizations to promote their coverage of political parties, election campaigns, candidates, or current elected political members.

        For example, In India, election ads are ads for Lok Sabha Elections that feature a political party, a political candidate, GOVERNMENTAL OR MINISTRY BODY or current member of the Lok Sabha, or any ads that are run by a political party, GOVERNMENTAL OR MINISTRY BODY political candidate, or current member of the Lok Sabha. In India, election ads don’t include ads run by non-political entities promoting political merchandise like t-shirts, or ads run by news organizations to promote their coverage of political parties, Lok Sabha election campaigns, candidates, or current Lok Sabha members.

        6. Gambling and Gambling-Related Services

        All gambling advertisements must be manually approved and certified by SHAREit. All approved gambling advertisers must comply with applicable laws, regulations, and licensing requirements, which may include those applicable to the location of your business, those applicable to the location of your target audience, and those related to responsible gambling. They must also comply with industry standards, as may be reflected in the American Gaming Association’s Code of Conduct for Responsible Gaming (or country equivalent) and ensure minors are not the target of such advertisements.

        The following products and services will be affected by this policy:

        • Online casinos and gambling where real money is exchanged
        • Sports betting
        • Fantasy sports games where real money (or other items of value) is exchanged
        • Lotteries
        • Brick and mortar casinos
        • Games/apps played for money or other items of value, such as gift cards

        The following products and services will not be affected by this policy:

        • Gaming where nothing of value is exchanged
        • Gambling-related merchandise
        • Hotel-casinos that primarily promote the casino

        7. Health and Pharmaceutical

        SHAREit restricts the promotion of certain health and wellness products and services. In addition to our own policies, all advertisements must comply with applicable laws, rules, regulations, licensing requirements, and industry standards. Advertisers are responsible for geo-targeting in compliance with country-specific laws and regulations.

        Further, advertisements may not make false, misleading, or exaggerated health claims; promote products that are subject to any regulatory action or warning; or promote a non-government-approved product in a manner that implies safety or efficacy in diagnosing, mitigating, treating, curing, or preventing a particular disease or ailment.

        Subject to the preceding requirements and pre-approval by SHAREit, the following products or services may be advertised, except as noted:

        (i) Pharmacies, including online pharmacies, that are certified by a third-party licensing organization such as the NABP or LegitScript. Proof of licensing may be necessary for approval.

        (ii) Pharmaceutical and medical products that are approved by the FDA (or foreign equivalent, depending on the advertisement’s geographic targeting) including but not limited to:

        • Prescription drugs

        • Over-the-counter medicines

        • Medical devices

        • Pharmaceutical manufacturers

        (iii) Approved supplements with a demonstrated record of safety, subject to SHAREit’s sole discretion. All ads for supplements must include appropriate, clearly legible disclaimers in the advertisement creative. Additionally, supplement advertisements may not do the following:

        • Make unsubstantiated claims
        • Promise unexpected results
        • Imply that the product can diagnose, cure, mitigate, treat, or prevent a disease
        • Imply that a product is as effective or more effective than an FDA (or equivalent) approved prescription drug or medical treatment

        (iv) Clinical trials with proof of approval by the relevant regulatory authority.

        (v) Appropriately licensed (including FDA or foreign equivalent approval where necessary) medical services, procedures, and tests including but not limited to:

        • Licensed medical professionals
        • Telemedicine providers with proper medical licensing and registration
        • Family planning tests and services
        • HIV and other infectious disease tests
        • Genetic testing services
        • Medical and cosmetic surgery

        (vi) The advertisement of addiction treatment centers and services is prohibited.

        8. Financial Services Including Cryptocurrencies

        Ads related to the exchange, management or investment of funds (fiat or virtual) must comply with known applicable laws, regulations, licensing obligations, and industry requirements.

        For all ads within this category, at minimum we require the following disclosures to be easily accessible in the ad or from the landing page:

        • Proper disclosure of all fees;
        • Evidence of appropriate regulator and/or third-party accreditations or certifications.

        Subject to the preceding requirements and approval by SHAREit, the following non-exhaustive list of products or services may be advertised:

        • FDIC (or foreign equivalent) registered banks and their associated products and services;
        • Tax filing services;
        • Apps that track/monitor stocks or financial trends, including cryptocurrency trackers so long as they do not require wallet integration;
        • Budgeting apps;
        • Brokerage or trading platforms and associated apps for traditional stocks/bonds as well as for cryptocurrency exchanges with a demonstrated record of legitimate business practices;
        • Apps or services that facilitate payment or transfer of funds;
        • Events related to business, finance, cryptocurrencies, and related subjects, so long as there is easily accessible disclosure in the ad copy or landing page clarifying that the information presented is not investment advice.

        The following non-exhaustive list of products or services are prohibited from being advertised on the site:

        • Single securities or other tradable financial assets
        • Bail bonds
        • Payday loans
        • Debt assistance programs
        • Get rich quick schemes
        • Pyramid schemes and multi-level marketing
        • Penny auctions
        • Binary options
        • Cryptocurrency wallets
        • Unaccredited digital banks that perform any traditional bank-like functions
        • Cryptocurrency credit or debit cards
        • Initial coin offerings, token sales, or other means of promotion or advertisement of individual digital currencies or tokens.

        9. Live Animals

        Advertisements promoting the sale of live animals are generally prohibited; however, SHAREit permits advertisements related to pet adoption from bona fide animal-welfare organizations.

        VI) Editorial Requirements

        The size and format of the Ads Content provided by Advertiser shall meet the requirements of SHAREit. Should Advertiser fail to meet the requirements, SHAREit may request Advertiser to make amendments accordingly.

        1. Style Policies

        Advertisements on the Platform that appear clearly and concisely both add to a user’s experience and are more likely to produce the advertiser’s desired results. Below are general guidelines for effective communication using the Platform:

        (i) Use correct spelling, grammar, and punctuation.

        (ii) Use punctuation, capitalization, or symbols reasonably.

        (iii) Unless required by law or by a regulatory authority, do not include personal information in the headline title, such as a telephone number.

        2. Quality

        SHAREit requires that all ads on the platform meet high professional and editorial standards. To ensure users are presented with high quality and useful ads, we require the following:

        • The ad should not purposely withhold information as a way to persuade users into interacting with it (eg "clickbait")
        • The ad should be free of any "worm", "virus" or other device that could impair or injure any person or entity

        3. URL and Landing Page Policies

        Advertisers must ensure that the destination URL and the landing page corresponding to the advertised product or service maintain the same level of quality expected for content on the Platform. In addition, the landing-page URL must match that of the advertisement, must not be solely designed to send a user elsewhere, and must not contain or refer to any content that would be otherwise prohibited by the Policy.

        VII) Content Display

        (i) The ads pages shall be safe, stable, and normally browsing.

        (ii) No major changes may be made to the content displayed on the Ads pages, such as changing the original product to a product that requires special business license to operate. Should any modification is required, Advertiser shall be notified in advance and resubmitted to SHAREit for re-reviewing.

        (iii) No automatic page forwarding may be made based on region, time, ip, etc., to result in the links between Ads pages and Ads submitted for reviewing are inconsistent.

        (iv) No violation of Laws, Regulations or the provisions of this Policy by setting malicious code, viruses, etc. on Ads pages.

        VIII) Consequences for Violations

        In its sole discretion, SHAREit will determine the consequences for a violation of the Policy or of the rejection of any submitted content. Consequences may include the following:

        (i) Disapproval: Advertising content in conflict with this Policy or determined to be inappropriate for the Platform in SHAREit’s sole discretion may be disapproved by SHAREit.

        (ii) Restriction: SHAREit, in its sole discretion, may restrict or entirely prevent certain domains, websites, or services from using the Platform.

        (iii) Suspension: SHAREit, in its sole discretion, may suspend an advertiser’s account from contributing content to the Platform. If an account is suspended, any related accounts and content from such accounts will be suspended as well.

        Global Anti-Corruption Compliance Policy

          1.Information about this Document

          This Global Anti-Corruption Compliance Policy (the "Policy") represents a part of commitment of group of companies SHAREit to conducting our business ethically and in compliance with all applicable laws wherever we operate.

          This Policy focuses on anti-corruption laws, including the U.K. Bribery Act 2010 as amended (the "UKBA"), the U.S. Foreign Corrupt Practices Act of 1977 as amended (the "FCPA"), and other laws to which the Company (as defined in clause 1.4 below) is subject.

          1.1 Purpose

          This Policy establishes the basic principles and requirements for compliance with the provisions of Applicable Anti-Corruption Laws by the Company, the Employees of the Company, and any Agents of the Company.

          This Policy pursues the following goals:

          • Describing the Company’s prohibitions against bribery and corruption in all of its business operations.
          • Preventing any manifestations of corruption, both on behalf of and in regard to the Company and/or its Employees; compliance with the requirements of applicable Anti-Corruption Laws when the Company engages in its business activities.
          • Reinforcing the Company’s commitment to conduct business globally with the highest standards of honesty and integrity.
          • Perfecting and developing the Company’s corporate culture, implementing the best practices and standards of responsible business conduct, including in the area of Anti-Corruption Compliance.

          1.2 Scope and Application

          The Policy applies to all of the Company’s Employees (as defined in clause 1.4 below), including the Company’s directors, officers and contractors hired through third-party staffing arrangements.

          Every Employee is required to become familiar with, and abide by, this Policy.

          All Employees have a personal responsibility and obligation to conduct the Company’s business activities ethically and in compliance with the law. Failure to do so may result in disciplinary action, up to and including dismissal. Employees may also be subject to regulatory and criminal action, which may lead to fines, debarment from certain positions, reputational harm and other sanctions up to and including imprisonment.

          1.3 Definitions and Abbreviations

          Term Definition
          Agents (Company Agents) Agents, distributors, consultants, representatives, independent contractors, joint venture partners, intermediaries, and other third parties engaged by the Company that have the authority to represent the Company before other parties, including but not limited to government entities.
          Anti-Corruption Compliance A system of measures, procedures and controls operating in the Company for purposes of compliance with Applicable Anti-Corruption Laws.
          Anything of Value The term "Anything of Value" is broad and can include any item of monetary value, including, but not limited to, the following:
          • Cash or the equivalent (including gift cards);
          • Benefits and favors (such as special access to a government agency);
          • Performing services that would otherwise have to be paid for or purchased;
          • Gifts;
          • Contracts or other business opportunities awarded to a company in which a Government Official has an ownership or other beneficial interest;
          • Favorable or steered contracts;
          • Employment opportunities, including those given to a family member or friend of a Government Official or representative of a commercial organization, such as positions in joint ventures or consultancy opportunities;
          • Charitable donations;
          • Political contributions;
          • Medical, educational, or living expenses;
          • Travel, meals, lodging, shopping, or entertainment expenses; or
          • Investment opportunities or stock options.
          Applicable Anti-Corruption Laws Any laws and regulations applicable to the Company dealing with combatting against bribery (whether public or private), including the UKBA and other UK anti-corruption laws, the FCPA and other US anti-corruption laws, the laws of the corresponding countries where the Company conducts its activities.
          Company The group of companies, SHAREit as a whole, as well as all legal entities belonging to this group individually (depending on the context).
          Employees (Company Employees) Individuals engaged in long-term or temporary labor relationships with the Company who have concluded a contract of a civil law character with the Company and contractors hired by the Company with the engagement of outside organizations dealing with the supply of personnel.
          Improper Advantage The term "Improper Advantage" covers any improper payment made in a business context, such as (but not limited to) paying or giving Anything of Value to a Government Official or private individual or entity, directly or indirectly, in order to:
          • Influence or prevent a governmental action, or any other action, such as the awarding of a contract, imposition of a tax or fine, or the cancellation of an existing contract or contractual obligation;
          • Obtain a license, permit, or other authorization from a government entity or Government Official that the Company is not otherwise entitled to;
          • Obtain confidential information about business opportunities, bids, or the activities of competitors;
          • Influence the award of a contract;
          • Influence the termination of a contract that is disadvantageous to the Company; or
          • Secure any other Improper Advantage.
          Governmental Entity Any bodies of any national, regional, local or other government, including but not limited to state ministries and offices, services, agencies and their structural subdivisions, as well as all legal entities directly or indirectly controlled by the state as well as the judiciary. For purposes of this Policy, the term comprises also political parties and international organizations.
          Government Official Any employee or officer of a Governmental Entity, as well as any other individual or legal entity acting at the proposal, request, or instruction, or in the interests of a Governmental Entity.

          2.General Provisions

          2.1 The Company is committed to maintaining the highest level of ethical standards in the conduct of its business.

          2.2 The Company does not accept any forms of corruption on the part of private individuals or Government Officials. The Company does not participate in any forms of unethical incentivizing or payments.

          The Company does not engage in, nor does it accept any activity which does not comply with this Policy or with Applicable Anti-Corruption Laws.

          2.3 The Company, Company Employees, and Company Agents are forbidden to offer, promise, approve, engage or authorize, directly or through an intermediary, in the transfer of Anything of Value to any Government Official or an agent or employee of a commercial organization with the purpose of influencing his or her actions (or ensuring inaction) and/or obtaining improper commercial advantage.

          2.4 The Company, Company Employees, and Company Agents are forbidden to give consent to the obtainment or to obtain, solicit or otherwise receive, directly or through an intermediary, any payments in the form of money, securities, other property, render services of a property-related nature, grant other property-related rights or any other valuables, as well as any financial or other benefit or advantage or Anything of Value, if a condition for the obtainment of such payments, benefits or advantages is the commission of actions, the fulfillment of official duties in the interests of the giving party, as well as if these payments, benefits or advantages constitute remuneration, direct or indirect, for the fulfillment of such duties.

          2.5 The Company, Company Employees, and Company Agents are forbidden to act as intermediaries in public or private bribery, i.e., to directly hand over bribes at the instruction of a bribe giver or bribe taker, or in some other way to assist in the achievement or realization of agreement between them to receive and give a bribe.

          2.6 This Policy constitutes the Company’s basic document in the area of Anti-Corruption Compliance; however, it is not invoked to implement exhaustive rules of conduct for Employees and Agents of the Company. In the event of a conflict between this Policy and other Company policies, Employees must apply the more restrictive policy or procedure.

          2.7 The Company’s management must through its conduct set a standard of ethical behavior and, by their personal example, form an uncompromising attitude among the Employees and Agents of the Company to any forms and manifestations of corruption, which must become an inalienable part of the corporate culture and everyday business practices of the Company.

          3.Basic Principles of the Company’s Anti-Corruption Compliance

          3.1 Consistency in Application of the Policy

          The Company consistently implements the rules and principles specified by this Policy and other policies of the Company in the area of Anti-Corruption Compliance. The Company propagates the principles of ethical business conduct and motivates the Company Employees and Agents to comply with this Policy. In the event of a breach of the rules of Anti-Corruption Compliance by Company Employees and Agents, the Company shall apply the relevant liability measures to them.

          3.2 Monitoring of Legislation and Best Practices in the Area of Compliance

          The Company persistently follows all amendments to the normative requirements of Applicable Anti-Corruption Laws and to the practice of applying it. Taking into consideration the results of that monitoring, and based on the best practices of Anti-Corruption Compliance, the Company takes measures to introduce the amendments into its current policies.

          3.3 Periodic Risk Assessment

          On a regular basis, the Company undertakes measures to bring to light and reduce corruption-related risks, and also measures to assess the efficiency of the current system of Anti-Corruption Compliance.

          Taking into account the results of carrying out these measures, and in case of appropriate necessity, the Company will amend existing policies or develop and introduce additional policies. The measures undertaken must match the character of the risks discovered in a reasonable and proportional way.

          3.4 Informing and Training

          A copy of this Policy will be given to every director, officer, and employee of the Company and to contract workers engaged directly or through third-party staffing arrangements. All updates to the Policy will be circulated internally. The Policy will also be made available via the Company web-site and will be made available to all Company Agents.

          3.5 Problem feedback

          In the event that any Employee, or any agent, of the Company has questions concerning the content of this Policy, including questions of interpretation of any of its provisions, as well as doubts as to the legality or ethical character of his or her actions, the application and realization of the principles of compliance indicated in this Policy, including questions related to the applicability of such principles in this or that situation or business process of the Company, the Employee or the agent shall be obligated to send email to

          3.6 Forming and Upholding the Company’s Reputation

          The Company shall apply reasonable efforts to ensure that persons about whom it is known that they are involved or have been involved in illegal activities will not be admitted to managerial positions or allowed to join the Company’s management bodies.

          The Company’s management bears liability for the maintenance and efficiency of the corporate system of Anti-Corruption Compliance as a whole, and also for ensuring the implementation and execution of controls and procedures of the Anti-Corruption Compliance system in the areas of its functional competence.

          Company Employees, irrespective of the position they hold, are personally liable for observance of the principles and requirements of this Policy and the Applicable Anti-Corruption Laws, as well as for the actions (inactions) of the persons subordinate to them who violate these principles and requirements.

          4.Specific Issues Related to Anti-Corruption Compliance

          4.1 Contractual Compliance Controls

          In the cases designated by the Company’s policies, contracts entered into by the Company with third parties must envisage the obligations of those parties to observe the Applicable Anti-Corruption Laws (the anti-corruption clause), according to the wordings approved by the Company. Furthermore, the contracts must specify the right of the Company to effect immediate unilateral termination in the event of a breach of the obligations specified by the anti- corruption clause.

          In the cases designated by the Company’s policies, contracts which the Company enters into with third parties likewise can envisage the right of the Company to carry out an audit of financial and other documentation pertaining to the implementation of the relevant contract.

          4.2 Due Diligence of Business Partners and Employees

          The Company shall apply reasonable efforts to minimize risks associated with interaction with any third parties, including business, labor and any other relationships with individuals or legal entities.

          For this purpose, the Company has developed and maintains procedures for inspection in relation to Employees and business partners (legal entities and individuals), and with whom the Company plans to enter into a contract.

          In addition, the Company carries out periodical due diligence of business partners with which it has entered into long-term contracts (lasting longer than one year).

          The due diligence procedure in respect of the business partners and Employees has the following goals:

          • assessment of the necessity of hiring a business partner, Employee;
          • assessment of the overall reputation of the Employee or a business partner, its owners and key persons for compliance with the Applicable Anti- Corruption Laws;
          • finding out whether any violations of Applicable Anti-Corruption Laws have been committed in the past;
          • establishing whether the potential Employee or a business partner has any connections to Government Officials and Government Entities, which might influence obtainment by the business partner or the Company of improper commercial advantages;
          • assessment of the impact of these connections on the legality of entering into the contract with the business partner from the point of view of Applicable Anti-Corruption Laws;
          • assessment of commercial reasonableness and arm’s-length basis for a proposed transaction.

          Any Anti-Corruption Compliance red flags raised during the course of the due diligence review must be addressed to the satisfaction of the local compliance manager before formally entering into, or continuing, the relationship.

          The statements in this clause 4.2 of the Policy extend also to contractors under transactions for merger, acquisition, or creation of joint ventures, and so forth. Moreover, also subject to due diligence are legal entities, ownership stakes or rights of control (direct or indirect) of which the Company acquires as a result of the transaction.

          4.3 Gifts and Hospitality Expenses

          The Company’s business decisions and those of its partners must be made objectively, without influence by gifts or favors. A small, reasonably priced gift or gesture of gratitude may sometimes be an appropriate way for business people to display respect for each other. Nevertheless, regardless of value, the giving or receipt of a gift, meal, entertainment, or other hospitality benefit must not be done with the intent to improperly influence a Government Official or any other party doing business with the Company.

          Any gifts and hospitality expenses of the Company (gifts which Employees and Agents of the Company may give on behalf of and/or at the expense of the Company to other individuals or legal entities, or which Employees, in connection with their work at the Company, may receive from other parties, as well as the corresponding hospitality expenses) must be in conformity with the following criteria:

          1. is not made with the intent to influence the recipient in order to obtain or retain any improper business advantage for the Company or any other individual or entity, or as an explicit or implicit exchange for favors or benefits, or for any other corrupt purpose;

          2. must not be prohibited by Anti-Corruption Laws applicable to the Company and recipient;

          3. must not affect the capability of the recipient to make impartial and fair decisions in connection with the official powers he or she has been entrusted with, nor must it impose any moral obligation on the recipient;

          4. must not constitute hidden remuneration for the obtainment of improper commercial advantage, including any service, action, omission or decision, and likewise must not represent an attempt to exert influence on the recipient with another illegal or unethical goal;

          5. must be reasonably justified and not be a luxury item separately or jointly, if gifts or payments are made to a person more than once;

          6. must not create for the Company risks to its reputation in the event of disclosure of information on such gifts or hospitality expenses;

          7. must not contravene the principles and requirements of this Policy and other policies of the Company in the area of Anti-Corruption Compliance;

          8. must be offered and accepted in a transparent manner and not be solicited;

          9. must undergo the approval procedures established within the Company.

          The indicated criteria shall also be applied to expenses on organization on behalf and/or at the expense of the Company of events aimed at attraction, retention or development of clients, as well as events related to communicating with the public, the mass media, and professional society.

          Before the completion of any payment or donation of any gift in an amount exceeding (jointly during one-year period or separately) 100 USD to any third party, including to a Government Official, on behalf and/or at the expense of the Company, the Employee must contact the local compliance manager and provide detailed information about the proposed gift or other paid expenses in order to receive confirmation about the legality and admissibility of such payment or gift. Symbolic gifts, such as pens or calendars bearing the Company’s logo, do not require the prior approval of the compliance manager.

          The compliance managers shall be entitled to block transfer of the gift or payment of expenses if he or she establishes that such actions do not comply with the criteria set forth above, or create risks of violation of Applicable Anti- Corruption Laws for the Company.

          It is not permitted to give gifts on behalf of the Company, Employees and Agents of the Company to any third parties in the form of monetary funds, whether cash or not, as well as any of their equivalents (for example, checks, gift cards, securities and so forth). Also, as a general rule, it is never permissible to pay for air fare and travel for spouses, other family members or other guests of Government Officials or any other third party.

          Employees are entitled to accept small gifts and payment of hospitality expenses of modest value from third parties with which the Employees interact in the course of work for the Company, subject to the following conditions:

          • the acceptance of the gift or payment of hospitality expenses will not create for the Employee a conflict of interests in regard to his or her official duties in the Company and will not affect the performance thereof;
          • the Employee believes in good faith that the giver has no intention of affecting in some way the performance by the Employee of his or her official duties.

          Employees must not solicit or request gifts. Employees are obligated to inform the compliance manager if they receive any gifts or payment of expenses by third parties for an amount greater than 100 USD (or the quality of that sum in local currency).

          4.4 Retaining Government Officials

          It may be justified to retain a current or former Government Official as an Employee or a business partner of the Company. However, doing so must be handled with caution. Such relationships must be structured so that they meet the requirements of the Applicable Anti-Corruption Laws and other applicable laws of relevant jurisdictions, and must not create a conflict of interest for the Government Official. No such relationship may be negotiated or agreed to without the prior approval of the compliance manager.

          4.5 Sponsorship and Corporate Social Responsibility

          In accordance with this Policy and other implemented procedures, the Company does not finance and does not participate in any other form in charitable and/or sponsorship activities for the purpose of receiving any illegal privileges or preferences in connection with business activity.

          All of the Company’s financial operations associated with sponsorship or charitable activity are recorded in detail and in a trustworthy manner in the accounting records; the project being realized undergo coordination in advance; the monitoring procedures for charitable contributions allow one to be convinced with a reasonable degree of certainty that the contributions made do not constitute a concealed form of bribery.

          Before the Company or an Employee of the Company makes on behalf and/ or at the expense of the Company any donation for an amount greater than 100 USD, it is necessary to consult with the compliance manager, who is entitled to block payment after performing the appropriate due diligence for compliance with Applicable Anti-Corruption Laws.

          4.6 Financing of Political Activity

          The Company does not finance and does not support or encourage in any other way political parties or members thereof, including candidates for political positions, their election campaigns or political events, nor any political organizations or movements.

          4.7 Payments through Intermediaries in Favor of Third Parties

          The Company, its Employees and Agents are forbidden to engage any third parties for the commission of any actions that contravene the principles and requirements of this Policy or the standards of Applicable Anti-Corruption Laws. Such actions by third parties may expose the Company even if they have no actual knowledge or awareness.

          The Company, its Employees and Agents are forbidden to make payments in favor of third parties, if there exists suspicion that all or part of this payment will be used to bribe a Government Official or an agent or employee of a commercial organization.

          The Company ensures inspection of the reasonability and justification of payments or any other provisions to third parties for the prevention and/or discovery of the violations described above for purposes of minimizing the risks of involving the Company in corrupt activities. All commercial relationships with third-party intermediaries must be approved by the compliance manager, and all relationships must be put in the form of a written agreement.

          4.8 Facilitating Payments

          The Policy prohibits "facilitating payments," i.e., unofficial payments provided in order to receive or expedite (speed up) a routine government action, i.e., actions which are ordinarily and commonly performed by Government Officials (e.g., processing governmental papers, such as permits, visas, etc.).

          4.9 Books and Records

          Employees or Agents are not allowed to conclude on behalf of the Company any transactions with fraudulent intent or with knowledge of the fact that the transaction or payment differs from the description in the documents confirming or justifying the transaction or payment.

          For implementation of this prohibition, all financial operations, accounting postings and entries must be credibly recorded with a sufficient level of detail in the Company’s books and records, and be documented and accessible for inspection.

          Any payments to the third-party Agents should be made to bank accounts held by such Agent in the country in which the relevant goods or services were provided or the country where the Agent is registered. Any expenses for which reimbursement is requested by an Employee or Agent of the Company, as well as any expenses of the Company performed using cash resources, must be confirmed in documentary form using proper primary documentation, including original receipts, invoices or other relevant documents. Any requests for expense reimbursements must be approved by the supervisor of the Employee requesting payment.

          4.10 Audit and Control

          On a regular basis, the Company carries out internal and external audits of its financial and business activities, and also carries out ongoing control over the completeness and accuracy of the recording of all business operations in the books and records and observance of the requirements of applicable legislation and the Company’s internal normative documents, including the principles and requirements established by this Policy.

          As part of the internal control procedures at the Company, inspections are carried out into the discipline of implementing the established procedure for performance of business processes, including inspection into the legality of the operations undertaken involving the Company’s assets and their economic justification, the advisability of expenses, including for confirmation by primary accounting documents and conformity with the requirements of this Policy.

          4.11 Informing about Violations

          Every Employee and Agent of the Company who has become aware of facts (or of signs pointing to them) regarding a violation or inclination to violate the provisions of this Policy and/or Applicable Anti-Corruption Laws by Employees or Agents of the Company, as well as by third parties, must inform about it by sending email to

          Within the limits of its powers, the Company shall undertake to ensure the protection of Employees who have conscientiously reported a violation or suspicion of a violation of the provisions of this Policy and/or Applicable Anti- Corruption Laws from persecution or any other form of discrimination on the part of the party in relation to whom the report was made.

          In addition, the Company guarantees that none of its Employees will be held responsible (by being dismissed, demoted, deprived of a bonus, and so forth) by the Company if the Employee reported the presumed corruption in good faith, or if the Employee refused to give or take a bribe or render mediation in acts of bribery, including if such refusal results in foregone profit for the Company, or no commercial or competitive advantages were gained. Retaliation may result in disciplinary action up to and including termination.

          The Company’s guarantees to refuse to hold Employees accountable do not extend to guilty Employees, nor to cases when an internal investigation proves that the report in question was deliberately false, or constituted perjury or libel.


          Inasmuch as the Company may be held liable for the participation of Employees and Agents of the Company and other parties associated with it in corrupt activities, for each justified suspicion or established instance of corruption, internal investigations will be undertaken in accordance with the Company’s rules establishing the procedure for carrying out such an investigation in a context permitted by applicable legislation.

          Parties guilty of breaching this Policy and of Applicable Anti-Corruption Laws may face disciplinary, administrative, civil law or criminal liability at the initiative of the Company, the law enforcement authorities, or other entities in the procedure and on the grounds specified by the Company’s Charter, internal procedures, and also in the appropriate cases and given sufficient grounds, in accordance with Applicable Anti-Corruption Laws and other applicable laws and regulations.


          May indicate a violation of anti-bribery matters

          1. Suspicious invoices, receipts and payments.

          a. Payment to government, government officials, political parties or state-owned enterprises

          b. Abnormal payment to the customer or supplier (for example, additional or separate fees)

          c. License fee

          d. Abnormal name or proxy (for example, "old friend", "Mr. Paris", etc.)

          e. Unusually complex transaction structure or payment process

          2. Suspicious payment to an individual

          3. Suspicious travel and entertainment expenses, gifts, charitable donations or other similar expenses.

          a. The lack of transparency in the accounting records

          b. Unusually high cost

          c. Travel unrelated to the business (eg Las Vegas, Paris, Dubai, Monaco, Disney World, Swiss Alps)

          d. Luxury hotel or tour, expensive tournament tickets, or sightseeing fees

          4. Suspiciously use distributors or sales agents to sell goods, or use service providers such as consultants, agents, intermediaries, intermediaries, or professional companies or individuals (including public relations, lobbying, law, and accounting)

          a. Abnormal payment terms or financial arrangements, such as:

          (1) Advance payment

          (2) Payment to a bank account with a different name

          (3) Payment to the account of the country where the business is located or outside the place where the service is performed

          (4) Agreement to pay "success fee"

          (5) Payment by a person or place (one consultant, but paying two separate payments to different names or locations)

          (6) Any large cash payment

          b. Unusually high or suspicious commissions, consulting fees, expense reimbursement or other payments

          c. Countries with a history of corruption

          d. Invoices including other personnel expenses, inflated invoices, additional commissions or bonuses, or unusual rebates

          e. Employees express concerns and request excessive confidentiality (for example, our employees are told "Don't ask")

          f. The third party does not appear to be a legitimate company (for example, there are not enough employees to perform the agreed work or no actual office location)

          5. Suddenly obtain a license or other government approval after a long delay

          6. Off-book accounts or "bribery funds"

          7. Recently hired government or state-owned enterprise officials or relatives

          (1) Training or internship

          (2) Pay the bonus after the employment

          (3) Any other welfare or convenience