MOSHKA FZ-LLC

Welcome to MOSHKA FZ-LLC — a subscription-based online platform with access to information and educational content about creative practices and skills. We respect your privacy and take care of your personal data. This Privacy Policy explains what data we collect, how we use it, who we share it with, and what rights you have.

1. About This Policy

This Privacy Policy ("Policy") describes how MOSHKA FZ-LLC, a company registered in the United Arab Emirates (UAE) ("MOSHKA FZ-LLC", "we", "us"), collects, uses, stores, shares and protects personal data of its users.

Registered address: Twin Towers, PO Box 4422, Fujairah, United Arab Emirates

Trade License No.: 20346/2026, issued by Fujairah Creative City – Media Free Zone Authority.

Privacy contact: support@moshka.com

Your use of the MOSHKA FZ-LLC Platform is governed by our Terms of Service, this Privacy Policy, our Cookie Notice, and our Cancellation and Refund Policy. These documents are an integral part of our Terms. By using the Platform, you confirm that you have read and agree to all applicable documents.

MOSHKA FZ-LLC acts as the Data Controller under applicable law.

This Policy has been developed in accordance with:

• UAE personal data protection legislation (including UAE PDPL);
• EU General Data Protection Regulation (GDPR) — to the extent of its extraterritorial application;
• UK data protection legislation;
• US consumer data protection legislation (CCPA/CPRA) — where applicable.

Where Article 27 GDPR requirements apply, MOSHKA FZ-LLC appoints a representative in the European Union. The representative's contact details are published on the Platform and available upon request.

Data Processing Principles

MOSHKA FZ-LLC processes personal data in accordance with the principles set out in Article 5 GDPR, including lawfulness, fairness and transparency; purpose limitation; data minimisation; accuracy; storage limitation; integrity and confidentiality; and accountability.

1.1. What Services This Policy Covers

Unless we expressly reference a different policy or state otherwise, this Policy applies when you visit or use MOSHKA FZ-LLC's services, including:

• the MOSHKA FZ-LLC website;
• MOSHKA FZ-LLC mobile apps;
• community and support features;
• online and offline events;
• APIs and related services;
• any other related features (collectively, "Services").

This Policy also applies when you interact with our social media pages or accounts (e.g., leaving comments or sending messages), to the extent we process your data in connection with such interactions. It may apply to prospective customers and enterprise products unless otherwise noted.

By using or accessing our Services, you agree to this Policy. From time to time we may develop new or offer additional services — these will also be governed by this Policy unless stated otherwise at the time of their introduction.

Capitalised terms not defined here have the meanings given in our Terms of Service. Your use of our Services is also governed by our Terms. You should not use our Services if you disagree with this Policy or any other agreement governing your use of the Services.

MOSHKA FZ-LLC does not make decisions based solely on automated processing, including profiling, that produce legal effects or similarly significantly affect users, unless expressly stated and permitted by applicable law. Where such decisions apply, you have the right to request human review, express your point of view, and contest the decision.

For cross-border transfers of personal data to countries that do not provide an adequate level of protection, MOSHKA FZ-LLC uses Standard Contractual Clauses (SCCs), supplementary technical and organisational safeguards, and conducts a Transfer Impact Assessment where required by applicable law.

2. Personal Data We Collect

When you register with us or use MOSHKA FZ-LLC's Services, we may ask you for personal data.

"Personal data" means any information that directly or indirectly relates to an identified or identifiable natural person (e.g., name, contact details, online identifiers, etc.). For purposes of US law (where applicable, including CCPA/CPRA), personal data may also include information relating to a consumer and/or household as defined under the relevant laws.

We may also collect data that does not identify you and is not linked to you (e.g., aggregated data). Such data is not personal data. To the extent such data is stored or associated with personal data, it is treated as personal data; otherwise it falls outside this Policy.

2.1. Information You Provide When Registering, Updating Your Account, or Using Our Services

Account data and identifiers. Personal data required to create an account and use the Services. The specific types of information depend on which Services you use, how you use them, and what you choose to provide. We may collect, for example: name, username, email address, postal or billing address, postal code, account name, phone number, social media profiles, and other similar identifiers.

Payment information. When subscribing or making purchases, payment and billing details (e.g., name, billing address, payment details) are provided directly to payment processors and/or app stores. MOSHKA FZ-LLC does not receive or store full payment details (e.g., full card numbers, CVV/CVC, authentication data), but may receive limited transaction metadata from processors (status, ID, amount/currency, subscription period, etc.) for access provisioning, accounting, support, and fraud prevention.

Other information. Additional data you may optionally provide includes:

• demographic information (gender or other details);
• user content you share with us, e.g., when uploading a project, materials or other content, submitting a review or question, or participating in public discussions;
• information provided when participating in a survey or research (including feedback);
• participation in promotions, giveaways, contests, or other marketing activities;
• information provided when contacting our Support Team;
• information about others (e.g., email addresses) — for sending referral programme invitations.

2.2. Information Collected Automatically When You Use Our Services

Usage data. When you use our Services, we may collect and analyse:

• Technical data: IP address, browser type and language, operating system, hardware and software characteristics (including device identifiers), online identifiers (e.g., cookies), entry and exit pages and other URLs;
• App data: device type, device identifiers, IP address, OS and version, internet provider, browser type, domain name and similar information; app update facts and times; date and time of use; error logs and other app performance data;
• Interface interaction data: clicks, mouse movements, scrolling, time on page;
• Navigation data: pages viewed and their order, date and time of use, session duration, error logs;
• Content usage data: materials viewed, view duration, content categories you search for;
• Purchase data: content or services you purchase or search for;
• other similar information.

We may use third-party providers for session replay of your interactions with the MOSHKA FZ-LLC interface — this may include visualising interactions (e.g., clicks, scrolling, navigation) to improve the service and diagnose errors. Where consent is required by law (e.g., for EEA/UK users), such tools are only used with your consent via cookie/tracker settings.

General (approximate) location. Your general location may include country, region or state. We may determine it from technical data (e.g., IP address, device language settings) or payment currency.

YouTube API Services. MOSHKA FZ-LLC may use YouTube API Services to allow users to create, schedule or delete live streams on YouTube. In connection with this, we may collect information about your channel name and URL, thumbnails, stream IDs and live chat IDs. For more information about YouTube's privacy practices, see the Google Privacy Policy. To revoke YouTube API access to your data, use your Google account security settings. If you have questions or complaints about MOSHKA FZ-LLC's use of YouTube API Services, contact MOSHKA FZ-LLC Support at support@moshka.com.

2.3. Information Received from Partners and Other Third Parties

Third-party services. If you link, connect or log into MOSHKA FZ-LLC through a third-party service (e.g., Google, Facebook, Apple), you authorise that service to share information with us (e.g., profile and registration data) in accordance with that service's settings and/or your permissions.

Payment partners. If you choose to pay through third parties or by invoice, we may receive data from our payment partners for billing or payment processing. Payments and recurring charges are processed by third-party payment processors and/or app stores, which may act as independent data controllers under their own policies (e.g., Stripe, Apple, Google — depending on country and payment channel). We may receive limited transaction metadata from such providers solely for access provisioning, accounting, user support, fraud prevention, and dispute resolution.

Information from other sources. We may also receive information from other sources, which we protect in accordance with this Policy and any additional restrictions imposed by the data source. Such sources may include:

• providers that help determine location from IP addresses;
• security providers (for system protection, fraud prevention and account security);
• payment processors (e.g., payment status information);
• online and offline data vendors (e.g., aggregated demographic or interest data);
• public sources (e.g., public social media posts and public databases);
• advertising or marketing partners (e.g., inferences about your interests and preferences).

We may use such data for audience segmentation (e.g., by interests) and to improve products, analytics and advertising.

3. How We Use Your Personal Data

We use personal data to provide, administer, analyse, improve and personalise our Services and marketing activities; to analyse subscription/purchase/payment terms; to communicate with you; and to comply with legal obligations. For example, we may:

• create and manage accounts and profiles;
• personalise content and recommendations (including saved materials and viewing history);
• provide access to materials, sessions, live streams and other Service features; provide (where available) non-accredited participation/viewing confirmations that are not educational/qualification/professional documents and do not guarantee outcomes, employment or mastery of a profession;
• structure content on the platform using machine learning algorithms and other models based on collected information;
• administer referral programmes;
• ensure security, prevent fraud and protect accounts and infrastructure;
• detect and stop violations of our Terms of Service and community rules, and prevent unlawful activity;
• analyse and improve the service (audience, interface, performance, content delivery);
• communicate with you (news, updates, offers, technical support);
• fulfil contractual obligations to partners;
• carry out other purposes that you expressly indicate.

3.1. Gift Access

The email address provided by the User during registration may be used to grant gift access to the Platform and to send information about its granting, activation, duration and how to use it.

These messages relate to the use of the Platform and the access granted to the User.

4. How We Share Your Data

4.1. Within Our Group of Companies

We may share personal data within our corporate group to provide, integrate, promote and improve our Services.

4.2. Content Creators (if applicable)

Where the Platform features content creators, MOSHKA FZ-LLC may provide them with limited information and/or analytics about user engagement with their materials (generally in aggregated form) to improve content and support the community. The scope of data depends on Service functionality and your privacy settings.

4.3. With Your Consent or at Your Request

Where you give explicit consent, we share data within the scope of that consent (e.g., when connecting a third-party app or participating in a partner promotion).

4.4. Service Providers

We may share data with contractors to the extent necessary for their tasks (e.g., payments and security, analytics and marketing, video hosting, development and support).

4.5. Other Third Parties When Necessary

We may share data:

• with other users — if you choose to post content, reviews or comments, or make information available through Service functionality and your privacy settings;
• with social networks — if you use "Sign in with..." or share content;
• with partners — when participating in joint promotions or purchasing their goods/services on our platform.

4.6. Joint Promotions with Partners

By participating in joint promotions, you agree to the transfer to the partner of data required for participation and receiving benefits. In such cases, the partner is responsible for data processing as an independent data controller (unless otherwise stated).

4.7. Aggregated Statistics

We may publish anonymised/aggregated reports about Platform usage.

4.8. To Protect Rights and Safety

We may share information where required by law or necessary to comply with lawful government requests, protect MOSHKA FZ-LLC and users, prevent abuse, and ensure the security of our Services.

4.9. Business Transfers

In the event of a reorganisation, sale of the company, or transfer of assets, personal data may be transferred to the new owner. We require compliance with the data protection terms set out in this Policy.

5. Legal Bases for Processing

5.1. Performance of a Contract

To provide our Services and perform our Terms of Service, we process necessary data (e.g., name, email, password, usage data). If data is required for the contract, refusing to provide it may result in inability to use certain features.

5.2. Legitimate Interests

We may process personal data on the basis of legitimate interests (ours or those of third parties), for example to improve our business and Services, personalise, analyse, market, provide support, prevent fraud, comply with obligations, and carry out corporate transactions. When processing on this basis, MOSHKA FZ-LLC conducts a balancing test, taking into account the nature of the data, the user's reasonable expectations, the impact on rights and freedoms, and the existence of appropriate safeguards.

5.3. Consent

In certain cases, we process data based on your consent (e.g., for marketing cookies/SDKs and some analytics/session recording tools where required by law).

5.4. Other Legal Bases

We may process data to comply with legal obligations, protect vital interests, or perform tasks in the public interest — where applicable.

6. Data Retention

We retain personal data for as long as your account is active or as needed to provide you with our Services, as well as for transaction records and financial reporting.

We may also retain data for as long as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

• Account data is retained until account deletion and for a reasonable period after deactivation to meet legal obligations.
• Financial data is retained in accordance with tax and accounting law requirements.
• Security logs may be retained for a limited period necessary to prevent fraud and protect infrastructure.

7. Data Security

MOSHKA FZ-LLC applies technical and organisational security measures to protect personal data. However, no online activity can be completely safe and error-free, so we cannot guarantee absolute data security.

You are also responsible for the security of your data: use strong passwords, change them regularly, and use secure devices and browsers.

If you suspect a breach or unauthorised access to your account, please let us know using the contact details in the "How to Contact Us" section.

8. International Data Transfers

Given the global nature of our operations, MOSHKA FZ-LLC may transfer personal data internationally to subsidiaries, contractors and partners described in this Policy. Your data may be processed in countries where protection standards differ from those in the EU or your country of residence.

For each cross-border transfer, we use legal mechanisms and agreements to ensure the transfer complies with applicable law and provides a comparable level of data protection.

Some infrastructure and vendors may be located in other countries (including the US), and data may be stored and processed on servers in such countries. For international transfers, MOSHKA FZ-LLC uses appropriate legal mechanisms including Standard Contractual Clauses (SCCs) and/or other permitted tools, as well as additional security measures where necessary. In certain cases where required by law, we may request your explicit consent for such transfers.

9. Cookies and Tracking Technologies

MOSHKA FZ-LLC uses cookies and similar tracking technologies to ensure Platform functionality, security, Service usage analysis, and — with your consent — for analytics and marketing purposes.

Strictly necessary cookies are used without separate consent, as they are required to provide the Services you have requested and to ensure Platform security.

Analytics, functional and marketing cookies are only used with your consent where such consent is required by applicable law.

For more details about the types of cookies we use, their purposes and how to manage them, please see our Cookie Notice.

We and our service providers use cookies, pixels, session recording/replay technologies and similar tools to collect information, personalise your experience, conduct analytics and marketing, and show targeted advertising.

For EEA/UK users and other jurisdictions where required, marketing cookies/SDKs, targeted advertising technologies, and some analytics and session recording tools are only used with your consent, which you can give or withdraw via the cookie banner/preference centre (if available) or device/browser settings.

You can change your browser settings to receive notifications when cookies are set/updated or to block them. If you block cookies, some Service features may be unavailable. See our Cookie Notice for more details.

You may withdraw or change any consents you have given, including consents for cookies and marketing communications, at any time through Platform settings, the cookie management interface, or device/browser settings, depending on available functionality.

10. Children's Privacy

Our Services are not intended for children:

• under the age of 13;
• who are not of an age to lawfully consent to personal data processing; or
• whose personal data processing requires parental consent.

We do not knowingly collect or use personal data from children meeting these criteria. For EU residents, we also do not process data of persons under 16 without parental consent. If we become aware that such data has been collected, we will take steps to delete it.

If you believe we may have accidentally collected information about a child, please contact us.

11. Your Rights

You have rights regarding the collection and processing of your personal data (depending on applicable law), including:

• the right to know whether we process your personal data and for what purpose;
• the right to be informed about the categories of data;
• the right to know the source of data (where applicable);
• the right of access, correction and deletion;
• the right to know with whom we have shared data, and for what purposes;
• the right to withdraw consent (where processing is based on consent);
• the right to lodge a complaint with a supervisory authority.

We may decline requests that are unfounded, not required by law, excessive, technically infeasible, or create operational risks (e.g., fraud). We may retain information to the extent required or permitted by law (e.g., for preference records, billing, accounting and rights protection).

If you do not have a MOSHKA FZ-LLC account, we may not have sufficient information to verify your identity and fulfil the request.

11.1. Access, Changes and Corrections

You can change some information in your profile settings. To request correction or supplementation of data, you can also write to us at support@moshka.com.

11.2. Data Deletion

In some jurisdictions, you may request deletion of personal information. Please note:

• we may retain data necessary to prevent fraud and ensure security;
• we may retain data to comply with legal obligations (taxes, reporting, audit);
• some technical records (e.g., logs) may be retained in anonymised/de-linked form;
• backups may be retained for a limited period.

11.3. Requests Through a Representative

You may authorise a representative to submit requests on your behalf. We may require confirmation of authority and/or your personal verification.

11.4. EU and UK Rights (Additional)

Depending on the circumstances, you may also have:

• the right to object to decisions based on profiling/automated processing that produce legal or other significant effects;
• the right to restrict processing or object to processing based on legitimate interests (including direct marketing);
• the right to data portability;
• the right to erasure (where applicable and subject to GDPR exceptions).

To exercise any of these rights, send a request from the email address you believe is linked to your MOSHKA FZ-LLC account to support@moshka.com. Please indicate which right you wish to exercise and the scope of your request.

12. Opting Out of Marketing Emails

We may send you promotional emails. If you are in the European Union, we will not send such emails without your consent.

You can opt out of promotional emails using the unsubscribe link in the email.

Please note: you cannot opt out of transactional messages (e.g., about your account, transactions, support, or notices related to an ongoing business relationship).

If you have installed the app and enabled push notifications, you can turn them off in your device settings or by uninstalling the app.

13. Location Information

If you wish to limit or disable location tracking, you can withdraw the relevant permission for specific Services or turn off location services on your device (see your device/OS manufacturer's documentation).

14. Third-Party Sites and Services

Our Services may contain links to third-party sites or services not covered by this Policy. Their use is governed by the respective parties' privacy policies. We are not responsible for their data processing practices.

15. Stripe

We use Stripe for payment processing, analytics and other business services. Stripe may collect identifying information about devices connecting to its services and use it to provide services and detect fraud. Learn more at: https://stripe.com/privacy

16. Additional Information

The primary (prevailing) version of this Policy is in Russian. Translations into other languages may be provided solely for convenience. In case of discrepancies, the Russian version prevails.

MOSHKA FZ-LLC does not appoint a separate Data Protection Officer, as the nature and scope of processing does not fall within the mandatory requirements of Article 37 GDPR.

For data protection questions, contact us at support@moshka.com.

17. Other Users

Other users of our Services may access your personal data if you choose to make your profile or other information available through Service functionality (e.g., comments, reviews, replies in discussions, posts). We do not control how third parties use information you have made public. Remember: published data may be copied, saved or cached by third parties.