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Privacy Policy

Alekseenko Company Inc. · Действует с 25 августа 2026 г.

PRIVACY POLICY

Alekseenko Company Inc. · thevitacode.com

Version dated August 25, 2026. Effective date: August 25, 2026.

1. General Provisions

1.1. This Privacy Policy (hereinafter — the Policy) defines the procedure for the collection, use, storage and protection of personal data by Alekseenko Company Inc., a California corporation, USA (hereinafter — the Company).

1.2. The Policy applies to all services of the Company:

the website thevitacode.com, including all of its sections in the Russian, Ukrainian and English languages;

the online gaming platform with online versions of transformational games and decks of metaphorical associative cards;

the mobile and browser application, including the personal account, the catalog, the store and the sections of the application;

the client's personal account, the wholesale buyer's account and the internal sections;

the sale and delivery of printed products: games, decks of metaphorical associative cards, books and workbooks;

online courses and training programs, including the Academy of Experts.

1.3. By using any of the said services or purchasing the Company's products, you confirm that you have read this Policy.

1.4. If you do not agree with this Policy, use of the Company's services is not permitted.

2. Categories of Data Processed

2.1. Data provided by you

first name and last name;

email address;

telephone number — when arranging delivery, if the carrier requires it;

the recipient's postal address — when ordering printed products;

payment details — processed directly by the Stripe payment system. The Company does not receive, process or store bank card numbers;

information provided upon registration in the personal account and on the platform;

the content of correspondence with the Company;

answers to assignments, working notes and reflection materials that you enter in the games, courses and application.

2.2. Data collected automatically

IP address, browser type, operating system, interface language;

date and time of the visit, pages viewed, duration of viewing, referral source;

cookies (Section 7);

a technical device identifier (of the browser or mobile device) used to maintain the authorized session and to detect the simultaneous use of one account by several persons. The device identifier is read only after your consent has been obtained in the cookie banner;

information about progress through courses and games: lessons completed, sections opened, results;

events in the application: sections viewed, adding of items to the cart.

2.3. Data that the Company does not collect

The Company does not collect and does not request information about racial and ethnic origin, political views, religious beliefs, biometric data, information about sexual orientation, or medical information: diagnoses, examination results, prescriptions and treatment data.

The Company's products are informational, educational and coaching in nature. The answers to assignments and working notes entered by the user are processed solely for the purpose of providing access to the purchased product. The Company does not analyze their content and does not use it for marketing purposes or for profiling purposes.

Entries made are accessible only to the user, are stored in encrypted form and may be deleted by the user independently in the personal account or upon request sent to info@thevitacode.com.

3. Purposes of Data Processing

The Company processes personal data for the following purposes:

provision of purchased products: granting access, dispatching an order, tracking progress through courses and games;

processing payments and issuing refunds in the cases provided for;

handling inquiries;

sending service messages: payment confirmation, access information, shipment number, notices regarding the subscription and upcoming charges;

sending informational and advertising messages — solely where your consent is present (Section 12);

saving user settings: interface language, authorized device;

analysis of traffic and improvement of the services;

protection of the Company's exclusive rights, including the detection of the transfer of access to third parties and of the reproduction of materials (Section 11);

compliance with legal requirements, including tax reporting and responses to lawful requests from governmental authorities.

The Company does not sell personal data.

The Company uses advertising and analytics technologies that under the law of the State of California may qualify as sharing of personal data for advertising purposes. Such technologies are disabled in the cookie settings on the website, as well as upon receipt of a Global Privacy Control signal from your browser.

4. Legal Bases for Processing

Consent may be withdrawn at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal.

5. Rights of Users from the State of California

The Company grants users residing in the State of California the following rights: to obtain information about the personal data collected about them; to request their deletion; to request their correction; to opt out of the sharing of data for advertising purposes; not to be subjected to adverse treatment in connection with the exercise of the said rights.

A request is sent to info@thevitacode.com. A response is provided within 45 calendar days; where necessary, the period may be extended by a further 45 calendar days with notice to the requester. The Company is entitled to request verification of the requester's identity in order to prevent disclosure of data to third parties.

6. Rights of Users from Other States

Users residing in other states are granted rights with respect to their personal data to the extent established by the applicable law of the state of their residence.

A request is sent to info@thevitacode.com and is considered within the period established by the applicable law, and in the absence of an established period — within a reasonable time.

7. Cookies

7.1. Necessary — provide authorization, the operation of the cart and security. Without them the operation of the website is impossible; disabling is not provided for.

7.2. Functional — save the interface language, user settings, the authorized device and the device identifier. They are not activated by default and require consent.

7.3. Analytics — provide traffic accounting and viewing statistics.

7.4. Advertising — provide for the assessment of advertising effectiveness; may be set by third-party systems.

7.5. On your first visit you are invited to select the categories whose use you permit. A button to decline all optional categories is available on an equal footing with the acceptance button. Declining the analytics and advertising categories does not restrict the ability to use the website and to make purchases.

7.6. Consent may be changed or withdrawn at any time via the "Cookie settings" link placed at the bottom of every page of the website.

7.7. Browser signals. The Company honors the Global Privacy Control signal and, upon receiving it, does not use the user's data for advertising analytics. The Do Not Track signal has no single technical standard; the Company does not carry out separate processing of this signal. To manage settings, use the "Cookie settings" section or the said signal.

7.8. Time of activation. For users located in the European Economic Area, the United Kingdom and Switzerland, analytics and advertising technologies are activated solely after consent has been obtained; they are not loaded before that moment. For users located in other countries whose applicable law does not require prior consent, these technologies are activated when the website is opened; the user may disable them at any time through the “Cookie settings” section at the bottom of every page. The Global Privacy Control signal is honoured regardless of the user’s country.

8. Service Providers Engaged

Data processing agreements have been concluded with providers that process personal data on the Company's instructions. Each provider applies its own privacy policy. The Company bears no responsibility for the processing of data by the said providers on their side.

9. Cross-Border Transfer of Data

Personal data is processed and stored on servers located in the territory of the USA.

Where applicable law establishes requirements for the cross-border transfer of personal data, the Company applies the mechanisms provided for by such law to ensure the protection of the data transferred. Information about the mechanisms applied is provided upon request sent to info@thevitacode.com.

The Company applies additional protective measures when transferring data: encryption in transit and at rest, limitation of the range of persons having access to the data, and minimization of the volume of data transferred.

10. Retention Periods and Protective Measures

10.1. Personal data is stored for the period necessary to achieve the purposes specified in this Policy, but for no more than 3 years from the date of the user's last action. A user action means authorization in the Company's services, the placing of an order or an inquiry to the Company. Exceptions:

account data — for the period during which the access granted to the user to the purchased products remains valid;

confirmations of consent to receive mailings, of acceptance of the offer and of consent to automatic renewal of the subscription — for the term of the contractual relations and 4 years after their termination;

data related to a detected violation of exclusive rights — until the relevant matter is resolved;

payment data — in accordance with clause 10.2.

10.2. Data on payments made is stored for 7 years, based on the periods applicable to tax and accounting reporting.

10.3. The Company applies the following protective measures: encryption of data in transit using the SSL/TLS protocol, restriction of access to the data to a limited group of authorized persons, hosting on protected hosting, regular software updates.

10.4. The Company takes reasonable measures to protect personal data; however, it cannot guarantee absolute security of the data when it is transmitted over the Internet.

10.5. In the event of a personal data security breach, the Company notifies the authorized bodies within the period established by applicable law, and the affected users — by email without undue delay, if the breach creates a risk to their rights.

11. Protection of Exclusive Rights and the Related Data Processing

11.1. The Company's materials — games, decks, cards, courses, videos, texts and images — are objects of copyright. Copyright in the products in the Russian, Ukrainian and English languages is registered in Ukraine. Legal protection is granted in the states party to the Berne Convention for the Protection of Literary and Artistic Works.

11.2. The Keys to Yourself® trademark is registered in the USA and is used in relation to printed products, digital products and training programs. The corresponding marking is applied to printed products.

11.3. The following technical protection measures are applied with respect to digital materials:

application of an invisible watermark linked to the user's account;

linking of access to the account and limitation of the number of devices used simultaneously;

transmission of video materials in protected form without the ability to save them;

recording in the application of the fact that screenshots and screen recordings are made. The Company records solely the fact that such an action has been performed; the content of screenshots is not transmitted to the Company and is not stored by the Company.

11.4. The said technical measures are applied solely for the purpose of protecting the Company's exclusive rights. The data obtained as a result of their application is not used for other purposes.

11.5. Technical protection measures do not entirely exclude the possibility of unauthorized reproduction of the materials. Liability for infringement of exclusive rights arises regardless of the technical measures applied.

11.6. Reproduction, saving, screen recording, publication and transfer of the materials to third parties are prohibited. Upon detecting a violation, the Company is entitled to terminate the user's access to the materials without refunding the funds paid and to seek protection of the infringed rights in the established manner.

12. Electronic Messages and Mailings

12.1. Service messages — payment confirmation, information about access to the product, login credentials for the personal account, shipment number, notices regarding the subscription and upcoming charges. The said messages are sent in all cases, since they form part of the performance of the agreement; opting out of receiving them is not provided for.

12.2. Informational and advertising messages are sent solely where your consent is present. The corresponding checkbox is not pre-checked and is checked by you independently when placing an order, upon registration or in a subscription form.

12.3. You independently determine the subject matter of the messages received: educational materials and practices; information about new products and courses; information about discounts and special offers.

12.4. A subscription placed through a form on the website is confirmed by an email. Until the confirmation link is followed, the address is not included in the mailing list.

12.5. Each message contains a link for changing the subject matter of the mailings and an unsubscribe link that works without authorization in the personal account.

12.6. The Company retains confirmation of the consent obtained: the date, the time, the IP address, the source from which the consent was obtained and the version of the documents in effect on the relevant date.

12.7. Each advertising message contains the Company's name, its postal address and a means of unsubscribing, in accordance with the requirements of US law on commercial electronic messages (CAN-SPAM). An unsubscribe request is fulfilled within no more than 10 business days.

12.8. The Company does not purchase, rent or import email address lists compiled by third parties.

13. Age Restrictions

13.1. The Company's services and products are intended for persons who have reached 18 years of age. The Company does not purposefully collect the personal data of persons under 18 years of age, does not direct advertising to them and does not grant them access to making purchases or to the personal account.

13.2. Materials intended for work with children are designed for use by an adult specialist in work with a child and are not intended for independent use by children. The account, the placing of the purchase and the related data belong to the adult user. A child's personal data is not collected or stored by the Company.

13.3. Upon receiving information that the Company has obtained the personal data of a person under 18 years of age, such data is subject to deletion. The corresponding message is to be sent to info@thevitacode.com.

14. Disclosure of Data upon Request from Governmental Authorities

The Company is entitled to disclose personal data on the basis of a lawful request from a governmental authority, a court order or a subpoena. Unless prohibited by law, the Company notifies the user prior to making the disclosure.

15. Links to Third-Party Resources

The Company bears no responsibility for the privacy policies of third-party resources to which links are placed on the website. The terms of data processing by such resources are to be reviewed independently.

16. Additional Provisions

16.1. Automated decision-making. The Company does not make decisions with respect to users that produce legal effects or otherwise significantly affect their rights solely on the basis of automated processing.

16.2. Account security. Access to the services is linked to the user's email address. The user ensures the security of access to the said address and to the password. Actions performed using the user's account are deemed performed by the user. Any suspected unauthorized access should be reported immediately to info@thevitacode.com.

16.3. Transfer in the event of a reorganization. In the event of a reorganization, merger or disposition of the business, personal data may be transferred to a successor, provided that the successor complies with this Policy. Users are notified of such transfer by email.

17. Amendments to the Policy

The Company is entitled to make amendments to this Policy. The new version is published on the website with an indication of the effective date. Users are notified of material changes by email at least 7 calendar days in advance. Continued use of the services after the amendments take effect constitutes acceptance of the new version.

18. Governing Law and Language of the Document

This Policy is governed by the law of the State of California, USA.

The document exists in the Russian, Ukrainian and English languages. The versions of the document are equally authentic; in the event of an irreconcilable discrepancy between them, interpretation is made in favor of the consumer.

19. Company Details and Contact Information

Alekseenko Company Inc. S Corporation, State of California Address: 442 S Rexford Dr., #105, Beverly Hills, California 90212, USA Email address: info@thevitacode.com Website: thevitacode.com

Effective date: August 25, 2026.