Foreign Investors In Russia Risk Frozen Assets

Welcome to the Inherent Risks website ("Website") which is administered by Inherent Risks Ltd (“Inherent Risks”). Inherent Risks provides and makes available this Website, subject to this Terms of Use Agreement (“Agreement” or “TOU”). This Agreement explains a contractual agreement between you ("user," "you," "your") and Inherent Risks regarding your use of this Website. You should print a copy of this Agreement for your records. Please note, however, that Inherent Risks may update and amend this Agreement from time to time as Inherent Risks deems necessary, in its sole discretion, and without prior written notice to you.

DO NOT USE THIS WEBSITE IF YOU DO NOT AGREE WITH THESE TERMS.

Inherent Risks reserves the right, in its sole discretion, to modify, alter or otherwise update this Agreement, or to change or delete any features of this Website, at any time, with or without prior notice to you. Such modifications, alterations, and updates of this Agreement shall be effective immediately upon posting upon the Website. You agree to be bound by such modified, altered and updated terms if you access or use this Website after Inherent Risks has posted notice of modifications, alterations or updates.

IF YOU DO NOT AGREE WITH ANY OF THE MODIFIED, ALTERED OR UPDATED TERMS, THEN YOU SHOULD NOT USE THIS WEBSITE AFTER SUCH MODIFICATIONS, ALTERATIONS OR UPDATES HAVE BEEN POSTED.

This Website may permit you to link to other websites that may or may not be affiliated with this Website and/or with Inherent Risks. These other linked websites, including the websites of Inherent Risks' affiliated companies, as well as the websites of Inherent Risks' third party service providers, or partners, (collectively the "Third Parties"), may have different terms of use that are not the same as in this Agreement. Your access to and use of such linked websites through links provided on this Website are not governed by this Agreement, but instead are governed by the terms of use and policies of those websites, and Inherent Risks disclaims any and all responsibility for your access to and use of such linked websites.

Personal Information about you, as defined in Inherent Risks’ Privacy Policy that you may submit or provide to Inherent Risks through this Website is subject to Inherent Risks’ Privacy Policy, which can be found at [https://www.inherentrisks.com/privacy-policy] and is incorporated into this Agreement. In addition, by using this Website you expressly consent to Inherent Risks collecting Personal Information and other information about you, as more fully provided in Inherent Risks’ Privacy Policy.

Inherent Risks controls and (either itself and/or through its third party hosts) operates this Website. All content on this Website, including, but not limited to, text, images, illustrations, graphics, logos, digital downloads, data, software, headers, icons, scripts, audio clips, and video clips, is the property of Inherent Risks or its Third Parties, and is protected by copyrights, trademarks, service marks, and/or other intellectual property rights (which are governed by and subject to United Kingdom and international copyright laws and treaty provisions, privacy and publicity laws, and communication regulations and statutes). The content is owned and controlled by Inherent Risks, its affiliated or related entities, or the Third Parties that have licensed or otherwise made available their content or the right to market their products and/or services to Inherent Risks.

You may not use any registered or unregistered trademarks, service marks, copyrighted materials or other proprietary information or intellectual property appearing on this Website, including, but not limited to, any logos, images or characters, meta tags or similar code, or hidden text or elements containing such information or property, without the express written consent of the owner of the mark or copyright. You may not frame any trademarks, service marks, copyrights, logos, images, text, or other proprietary information or intellectual property of Inherent Risks, or otherwise incorporate into another website any of the content or other materials on this Website, without Inherent Risks’ express prior written consent. You may not deep link to any page or portion of this Website without Inherent Risks’ prior written consent.

Violation of trademark and copyright laws ("Infringement") may result in significant civil liability or criminal penalties under United Kingdom and/or international copyright and trademark laws. You recognise that any reproduction or use of content, copyrights, trademarks, service marks, or other intellectual property on this Website, except as authorised by this Agreement, is considered intentional Infringement.

You are specifically prohibited from any use of this Website, and you agree not to use or permit others to use this Website, without limitation, for any of the following:

take any action that imposes an unreasonable or disproportionately large load on, or waste of valuable time for, the Website's infrastructure or resources, including, but not limited to, sending or promoting the distribution of "spam," "junk mail," chain letters, or other such unsolicited or unlawful mass e-mailing techniques; disclose to, or share with, any unauthorised third parties the ID's, assigned confirmation numbers and/or passwords, or use the ID's, assigned confirmation numbers and/or passwords for any unauthorised purpose, or otherwise allow or facilitate others to gain access to Inherent Risks’ information technology systems, environments, networks, files, data or accounts through the use of the ID's, assigned confirmation numbers and/or passwords; access or attempt to access Inherent Risks’ information technology systems, environments, networks, files, data or accounts to which express authorisation has not been obtained (including access to data not intended for You), or log into a server or account that you are not authorised to access; attempt to decipher, decompile, disassemble, modify, remove or reverse engineer any of the software or HTML code comprising or in any way making up a part of this Website; interfere with, disrupt, disable or damage (or attempt to interfere with, disrupt, disable or damage), in an unauthorised manner, the use or operation of this Website or Inherent Risks’, its affiliated or related entities' or the Third Party’s systems, equipment or applications, or service to any user, host, or network, including by use of any programs, scripts, commands, viruses, worms, web bugs, harmful code, Trojan horses, other contaminants, or otherwise. This includes "denial of service" attacks, "flooding" of networks, deliberate attempts to overload a service or to burden excessively a service's resources, attempts to "crash" a host, and/or modifying or rerouting any content or services provided at this Website; attempt to circumvent or subvert system or network security (i.e., authentication) mechanisms, or probe the security of any system, network, or account, associated or used in conjunction with this Website; upload, post, e-mail or otherwise transmit any information, content, or proprietary rights that you do not have a right to transmit under this Agreement, any law or other contractual or fiduciary relationships; and/or use any robot, spider, intelligent agent, meta-searching, other automatic device, or manual process to search, monitor or copy Inherent Risks’ Website pages or the content.

ALL CONTENT, PRODUCTS AND SERVICES ON THIS WEBSITE, UNLESS OTHERWISE EXPRESSLY STATED IN WRITING BY INHERENT RISKS, ARE PROVIDED "AS IS" AND WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED. OTHER THAN THOSE WARRANTIES WHICH, UNDER THE UNITED KINGDOM LAWS APPLICABLE TO THESE TERMS, ARE IMPLIED BY LAW AND ARE INCAPABLE OF EXCLUSION, RESTRICTION, OR MODIFICATION, INHERENT RISKS DISCLAIMS ANY AND ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE.

NEITHER INHERENT RISKS, ITS AFFILIATED OR RELATED ENTITIES, NOR THE THIRD PARTIES, NOR ANY PERSON INVOLVED IN THE CREATION, PRODUCTION, HOSTING AND/OR DISTRIBUTION OF THIS WEBSITE, WARRANT THAT THE FUNCTIONS, FEATURES OR SERVICES CONTAINED IN THIS WEBSITE WILL BE UNINTERRUPTED OR ERROR-FREE, THAT DEFECTS WILL BE CORRECTED, OR THAT THE SERVER THAT MAKES THE CONTENT AVAILABLE WILL BE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. THE CONTENT THAT YOU ACCESS ON THIS WEBSITE IS PROVIDED SOLELY FOR YOUR CONVENIENCE AND INFORMATION. INHERENT RISKS DOES NOT WARRANT OR MAKE ANY REPRESENTATIONS REGARDING THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THIS WEBSITE, OR AS TO THE RELIABILITY, ACCURACY OR CURRENCY OF ANY CONTENT, SERVICE, AND/OR MERCHANDISE PROVIDED OR ACQUIRED PURSUANT TO YOUR USE OF THIS WEBSITE.

YOUR USE OF THIS WEBSITE IS AT YOUR OWN RISK. YOU (AND NOT INHERENT RISKS) ASSUME THE ENTIRE COST OF ALL NECESSARY SERVICING (INCLUDING, WITHOUT LIMITATION, YOUR INTERNET CONNECTION) AND REPAIR OR CORRECTION OF YOUR COMPUTER, NETWORK AND/OR SYSTEM.

IN NO EVENT SHALL INHERENT RISKS, ITS AFFILIATED OR RELATED ENTITIES OR THIRD PARTIES, NOR ANY OF ITS OR THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES OR AGENTS, OR ANY PERSON OR ENTITY INVOLVED IN THE CREATION, PRODUCTION, DISTRIBUTION AND HOSTING OF THIS WEBSITE, BE LIABLE FOR ANY DIRECT, ACTUAL, INDIRECT, CONSEQUENTIAL, INCIDENTAL, SPECIAL, PUNITIVE OR EXEMPLARY DAMAGES, OF ANY KIND, WHETHER ARISING UNDER CONTRACT, WARRANTY, OR TORT (INCLUDING NEGLIGENCE) OR ANY OTHER THEORY OF LIABILITY, REGARDLESS OF WHETHER INHERENT RISKS (OR ITS AFFILIATED OR RELATED ENTITIES OR PROVIDERS) KNEW OR SHOULD HAVE KNOWN OF THE POSSIBILITY OF SUCH DAMAGES, INCLUDING, WITHOUT LIMITATION, FROM THE USE OR ATTEMPTED USE OF THIS WEBSITE OR ANY OTHER LINKED SITE.

By accessing this Website, you agree that this Agreement and your use of the Website shall be governed in all respect by the laws of the United Kingdom, without regard to any conflict of laws provisions, and shall not be governed by the United Nations Convention on the International Sale of Goods. You further agree to submit to the exclusive jurisdiction and venue in the United Kingdom for all disputes, cases and controversies regarding this Website, your use of this Website, and any matter arising out of or related to this Agreement.

Inherent Risks reserves the right to report any wrongdoing, if and when it becomes aware of it, to any applicable government or law enforcement agencies. You agree to indemnify, defend and hold Inherent Risks, its and their officers, directors, employees, affiliated or related entities, Third Parties, agents, licensors, and suppliers, harmless from and against any and all claims, demands, actions, costs, liabilities, losses and damages of any kind (including attorneys' fees) resulting from your use of this Website, your breach of any provision of this Agreement and/or any negligent acts, omissions or intentional wrongdoing by you relating to or arising from your use of this Website.

Inherent Risks' failure to act with respect to a breach by you or others does not waive Inherent Risks’ right to act with respect to subsequent or similar breaches. If any provision of this Agreement is held to be invalid or unenforceable, such provision will be struck and the remaining provisions enforced. Headings are for reference purposes only. You and Inherent Risks are dealing at arms' length, creating a commercial relationship. Inherent Risks is not your agent, representative or fiduciary. The provisions and conditions of this Agreement, and each obligation referenced herein, represent the entire Agreement between Inherent Risks (including the Third Parties), its affiliated or related entities, and you, and supersede any prior agreements or understandings not incorporated herein. In the event that any inconsistencies exist between this Agreement and any future published terms of use or understanding, the last published Agreement shall prevail.

INHERENT RISKS RESERVES ANY RIGHTS NOT EXPRESSLY GRANTED OR STATED IN THESE TERMS.

This privacy notice is provided in accordance with the General Data Protection Regulation 2016/679 (“GDPR”), including any EU national laws implementing or supplementing the same, and any other applicable data protection laws (the “Data Privacy Laws”).

Inherent Risks operates globally and as such we are committed to complying with the applicable data privacy and security requirements in the jurisdictions in which we operate. Inherent Risks complies with internationally recognized standards of privacy protection, and with various privacy laws globally including, but not limited to, the GDPR..

To the extent that Inherent Risks is deemed to be a data controller under Data Privacy Laws, this notice fulfils our obligation to provide certain information to third parties whose personal data we process in this capacity as required by Article 14 of the GDPR and the notice requirements set out in any other Data Privacy Laws for processing personal data which has been obtained indirectly.

Data will be collected by Inherent Risks.

Inherent Risks collects the following categories of personal data:

Contact data: We may collect information about data subjects such as name and contact details (email, phone number, etc.) in order to communicate and facilitate the provision of our services with our clients' or potential clients. For example, contact details of individuals who work for or on behalf of the clients, in order to carry out the client’s engagement with Inherent Risks.

Services data: Personal data may be provided to us by clients to the extent required to perform the services. Inherent Risks may also acquire personal data from a third party as required to perform services requested by our client(s).

Marketing information: We may collect information to respond to inquiries regarding our products and services or to provide you with information, reports, or updates.

Website visitor information: when you visit our website, we may collect information such as your IP address and the pages you visited and when you use our services we may collect information on how you use those services.

Clients and other third parties who provide personal information to Inherent Risks must do so in compliance with applicable data privacy regulations.

We collect personal data to offer and administer our services.

The data you provide to us will be processed in accordance with the purposes specified in this notice, namely:

a. To provide the products or perform the services requested by clients and individuals pursuant to a letter of engagement, service level agreement, statement of work, or similar (where the processing is necessary for our legitimate business interests in conducting and managing our business).

b. To provide the products or perform the services requested by clients and individuals using our website or web applications (where the processing is necessary for our legitimate business interests in conducting and managing our business).

c. For complying with obligations provided by laws, current regulations and European legislation (e.g. tax regulations) (where processing is based on a legal obligation) or legislation in other jurisdictions that may be applicable.

d. For legitimate business purposes to advise you through email, phone call, or post, in the framework of our ordinary commercial relationship, about other products or services similar to the products or services we have provided to you and that we think will be of interest to you (where the processing is necessary for our legitimate business interests).

e. For marketing purposes. For example, we may use your information to further discuss your interest in the services and to send you information regarding Inherent Risks' such as information about promotions, events, products or services. You can withdraw your consent or opt out of receiving our marketing communications at any time. If you are not located in the EU, you may opt-out of receiving marketing communications and updates at any time. You can manage your receipt of marketing and non-transactional communications by clicking on the «unsubscribe» link located on the bottom of Inherent Risks marketing emails.

f. For improving Inherent Risks communications with you. Emails sent to you by us may include standard tracking, including open and click activities. We may collect information about your activity as you interact with our email messages and related content.

g. For operating and improving Inherent Risks website and your customer experience. For example, we may collect and analyse data on your use of our website and process it for the purpose of improving our online experience.

h. For security purposes. For example, we may use your data to protect Inherent Risks and its third parties against security breaches and to prevent fraud and violation of Inherent Risks applicable agreements (where the processing is necessary for our legitimate business interests).

Whenever we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you and your rights under data protection laws. Our legitimate business interests do not automatically override your interests – we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You have the right to object to this processing if you wish.

Personal data is processed both manually and electronically in accordance with the above- mentioned purposes and in compliance with current regulations. We permit only authorised Inherent Risks employees to have access to your information. Such employees are appropriately designated and trained to process data only according to the instructions we provide them.

Inherent Risks will retain personal data for a reasonable period, taking into account legitimate business needs to capture and retain such information. Information will also be retained for a period necessary to comply with state, local, federal regulations, or country specific regulations and requirements, and in accordance with Inherent Risks policies.

We only share your personal data with your consent or in accordance with this notice. We will not otherwise share, sell or distribute any of the information you provide to us except as described in this notice.

We share personal data among Inherent Risks-controlled affiliates and subsidiaries who act for Inherent Risks for the purposes set out in this notice.

Inherent Risks may share your information with external third parties, such as vendors, consultants, legal advisors, auditors and other service providers who are performing, advising or assisting with certain services on behalf of our company. Such third parties have access to personal data solely for the purposes of performing the services specified in the applicable contract, and not for any other purpose. Inherent Risks requires these third parties to undertake security measures consistent with the protections specified in this notice.

Inherent Risks may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

If Inherent Risks business enters into a joint venture with or is merged with another business entity, your information may be disclosed to our new business partners.

Personal information may be transferred, accessed and stored globally as necessary for the uses stated above in accordance with this notice, and in compliance with local law and regulations.

Data concerning EU data subjects may be transferred to or processed in locations outside of the EU only where one of the following safeguards is in effect:

Transfers to the US, pursuant to D&P’s participation in the EU-U.S. Privacy Shield

Transfers to certain countries which the EU Commission has determined ensures an adequate level of protection

Where required, Inherent Risks entities have entered into European Union Model Clause Agreements which allows for the processing of your personal information and for transfers of your personal information.

You have the following rights concerning your data processed by Inherent Risks:

Access: You have the right to access personal information that Inherent Risks holds about you.

Rectification: You have the right to ask us to rectify information Inherent Risks holds about you if it is inaccurate or not complete.

Erasure: You can request that Inherent Risks erase your personal data. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

Restrict Processing: You have the right to ask Inherent Risks to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future.

Object to processing: Where processing is based on legitimate interests, you have the right to object to Inherent Risks processing your data. We will discontinue processing your data, unless we can demonstrate compelling legitimate grounds for the processing. We will keep basic data to identify you and retain it solely for preventing further unwanted processing.

Portability: Where processing is based on consent or performance of a contract, you have the right to data portability. Inherent Risks must allow you to obtain and reuse your personal data for your own purposes in a safe and secure way without this affecting the usability of your data.

Automated decisions are defined as decisions about individuals that are based solely on the automated processing of data and that produce legal effects that significantly affect the individuals involved.

Inherent Risks does not make automated decisions using personal data. If automated decisions are to be made, affected persons will be given an opportunity to express their views on the automated decision in question and object to it.

If you choose not to provide certain personal information, it may be an impediment to the exchange of information necessary for the execution of the contract or provision of services, and we may not be able to provide you with some services and you may not be able to participate in some of the activities on our website(s).

We are not responsible for the privacy practices of any non-Inherent Risks operated websites, mobile apps or other digital services, including those that may be linked through Inherent Risks websites or services, and we encourage you to review the privacy policies or notices published thereon.

Please contact us with questions, concerns, or complaints:

For data subjects located in the EU: if we are not able to satisfactorily resolve your questions, concerns, or complaints, or if you believe that the processing of your personal data infringes on your rights under applicable data protection laws, you have the right, without prejudice to any other administrative or judicial remedies, to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement. Contact information for the supervisory authorities may be found here:

http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm