Privacy Policy

1. This Public Offer (hereinafter referred to as the “Offer”) is an official public offer of the Company, hereinafter referred to as the “Contractor”, to conclude with a natural person, hereinafter referred to as the “Customer”, the Agreement for providing training courses under the conditions set forth in this Offer and selected by the Customer.
For services rendered via the Internet the Company means Anna Palevich (NIF: 309753945), Portugal. For the services rendered in the territory of the Russian Federation – “VAVES” LLC (INN/KPP: 7203532998/720301001).

2. This offer is addressed to an unlimited number of individuals having the corresponding legal capacity in accordance with the legislation of their country of residence and location, which allows them to enter into civil legal relations for services with the Contractor on the terms specified in the Offer.

3 The Customer hereby presumes and confirms that he has sufficient legal capacity and capacity to conclude the agreement with the Contractor for providing training services under the conditions determined in the present Offer and chosen by the Customer.

The acceptance of the present offer is realized by means of conclusive (factual) actions of the Customer, showing his intention, expression of will and desire to enter the legal relationship with the Contractor and to receive services rendered by him. In particular, to the above-mentioned conclusive actions include fulfillment by the Customer of the payment for the services provided by the Provider in the order established by the Offer, registration for free course.

5. The acceptance of the Offer means reading, understanding all together and individually the terms of the Offer, the full, unconditional and unconditional consent of the Customer to the terms and conditions defined in the Offer.

6. From the moment of acceptance of the Offer the Agreement on providing training services / courses between the Contractor and the Customer is recognized as concluded and agreed, and its terms and conditions are subject to mandatory execution by the Parties.

Translated with (free version)


For the purposes of this Offer the following terms are used in the following meaning:

Site – Contractor’s websites located on the Internet under the domain names (address, domain) –, as well as their constituent subdomain pages.

Executor – the Company Anna Palevich (NIF: 309753945), Portugal; LLC “VAVES” (INN / KPP: 7203532998/720301001), providing and/or organizing training / courses set forth in this Offer.

Customer – any natural person having the necessary legal capacity in accordance with the laws of the country of his residence and location, who intends to enter into a legal relationship with the Contractor to provide services for the training / courses under the conditions set forth in this Offer.

Apprentice – a natural person in whose favor training services are provided. The student can be a customer.

Exercise – a lesson in a training course in accordance with the program of the course, chosen by the Customer.

Electronic Mail (E-mail) – a special technology that provides forwarding and receipt of electronic messages, letters, files, documents, etc. through the use of the Internet.

The Offer may use terms not defined in clause 7 of this Offer. In such cases terms are interpreted in accordance with the text and meaning of this Offer.

In case this Offer is accepted, the Parties shall conclude the Agreement on providing training/training services under the following terms and conditions:

8. Subject matter of the Agreement
8.1 The Customer commissions and the Contractor undertakes for a fee, and in cases provided on the Contractor’s site – free of charge rendering of training/training services.
8.2 Provision of services is carried out in the following form:
8.2.1 Free course “Beginner Trader”. Registration for the free course is performed by providing the necessary information on the Executor’s website. In case the Customer has provided incorrect information, the Executor is not responsible for the impossibility to provide access to the free course. The access to the course is 14 days. After 14 days the access is closed.
8.2.2 Course “Trading System” – is access to a closed channel in Telegram with daily analytics and a mini-course on the rules of trading basic patterns in Wave Analysis. There are two payment options:
Monthly payment. There is a possibility of the subscription payment system. In case the Customer chooses this payment system, the Customer grants the Executor the right to charge the funds from the Customer’s card which is indicated in the payment details on a monthly basis without additional approval. The Customer has the right to cancel the subscription through the technical support service by contacting the e-mail: All payments received before the cancellation of the subscription are non-refundable.
Term of consideration of cancellation and refund is 10 working days from the date of receipt of the cancellation of subscription.
In the case of changes in the cost of the program, the Parties will consider the prices indicated on the Executor’s website as the actual prices.
8.2.3 The course “Independent trader” – the basic annual program.
The following payment options are available:
Subscription-based payment system. Payment is made on a monthly basis. In case of this payment system the Customer grants the Executor the right to charge the funds from the Customer’s card which is specified in the payment details every month without additional coordination. The Customer has the right to cancel the subscription through the technical support service by contacting the e-mail: All payments received before the subscription cancellation are non-refundable.
Annual payment. Payment is made at the expense of the Customer or by bank installments. In case of cancellation of subscription, no refunds will be provided.
The cost of the program is set on the Executor’s website.
8.3. The actual name of the course\training, the course\training program, the order of the course\training, the cost of courses are set out on the website, and are an integral part of this offer.

9. Rights and obligations of the parties
9.1. the CONTRACTOR shall:
9.1.1. Organize online lessons on the platform specified on the Contractor’s website and provide the Customer with access to a personal account / chat in Telegram or video recordings of the lessons.
9.1.2 Make arrangements to notify the Customer of the beginning of the event (by letter to the email address specified during registration).
9.1.3 Provide the Customer with the materials according to the tariff after the end of the online event. The period during which the materials are available is indicated on the Provider’s website.

9.2 CUSTOMER shall:
9.2.1. if agreeing to the terms of this Offer, to pay the cost of training courses / trainings before the start of training. In case other conditions are provided for the training courses on the site, pay according to the conditions set out on the site.
9.2.2 The Customer must comply with the Executor’s copyright. Recordings of the lessons can be used by the Customer only for personal viewing and can not be distributed without the Provider’s consent. In case of the unauthorized distribution of the lessons recordings and other course materials to the third parties the fine of 500 000 rubles is provided.
9.2.3 The Customer is obliged to use the account/chat/personal account only for personal viewing of the lessons. The use of the account/chat/personal account of the participant by several persons leads to the blocking of the account.

10. Payments for the contract
10.1 By making the payment, the Customer confirms his consent to all clauses of this Agreement.
10.2 Executor’s expenses are included in the cost of services and are not additionally paid.
10.3 All actual prices for the packages are given on the Executor’s website.

11. Terms and procedure of refund
11.1. The Customer has the right to refuse the paid services and demand refund in accordance with paragraph 8 of this offer.
11.2 Requests are accepted at the support service e-mail:

12. Responsibility of the Parties
12.1 For default or improper performance of obligations under this Agreement the parties shall be liable in accordance with applicable law.
12.2 Any disputes arising during the execution of this Agreement shall be resolved in the pretrial order by filing claims.

13. Claims
13.1 The Parties shall establish a claim procedure for disputes relating to the performance of this Contract. The term of consideration of the claim is 30 days from the date of receipt of the claim. Claims for breach of obligations by the Party shall be issued by the other Party in writing with attachment of the documents confirming the claim and sent to the address specified in this offer.
13.2 The date of receipt of the claim shall be the date of receipt of the recipient’s representative’s receipt of the document. The date of response to the claim shall be the date of registration of the mail with the response.

14. Circumstances of insuperable force
14.1 The Parties shall not be held liable for failure to perform their obligations hereunder in part or in full, if that failure resulted from force majeure events that occurred after the conclusion of this Contract and which the Party could neither foresee nor prevent by reasonable measures.
14.2 The above circumstances in the context of this Agreement, in particular, include: natural disasters, war or military actions, strike in the industry or region, as well as their consequences; adoption of a regulatory act by public authorities, resulting in impossibility of performance of this Agreement by any of the Parties. This list of force majeure circumstances is not exhaustive and may include all other circumstances falling under the notion of force majeure in accordance with the applicable laws of the Russian Federation.
14.3 The occurrence of force majeure circumstances shall extend the term of performance of this Agreement for the period of the specified circumstances, unless the Parties decide to terminate it.
14.4 The Parties shall immediately inform each other about the occurrence of the force majeure circumstances.
14.5 The confirmation of the fact of occurrence of the force majeure circumstances are the documents, issued by the authorized body.

15. Final Provisions
15.1 The offer is valid from the moment of its acceptance by the Customer by paying for the free course and until the Parties fulfill their obligations.
15.2 Disputes arising from the relationship arising from this offer are considered under the law of registration of the Company at the location of the defendant.

16. Artist

Anna Palevich (NIF: 309753945)
Rua Manuel Marques, 10, 12D
1750-171, Lisboa, Portugal

OOO VAVES (NIF: 7203532998/720301001)
112 Deputatskaya St., bldg. 116, Tyumen, 625007, Russia

Privacy Policy

Making registration on the site or purchasing services of the site 89WAVES.COM, as well as answering the necessary questions in the questionnaire at the registration and making a purchase, the user confirms that he/she gives consent to the Company and its authorized persons to process personal data.
The Company means Anna Palevich (NIF: 309753945), Portugal. For services rendered in the territory of the Russian Federation, VAVS LLC (INN/KPP: 7203532998/720301001).
The Company protects the data of its customers, the privacy of users of its services and complies with the requirements of the federal law of the Russian Federation “On Personal Data”, the General European Data Protection Regulation (“GDPR”) and the framework agreements of Privacy Shield.


Personal Data – any data from which you can be identified.
Processing of personal data – any action (e.g. collection, recording, systematization, accumulation, storage, updating, modification, extraction, use, transfer, dissemination, provision, access, anonymization, blocking, deletion, destruction) performed on personal data.
Privacy of personal data – based on the law not to disclose personal data without the consent of the subject of personal data or the presence of other legal grounds.
Website User, User Services – you, that is, a person who has access to the Site, via the Internet and / or use the services of the Company
Cookies – is a small fragment of data sent by a Web server and stored on the user’s computer. It is used to store data on the user side.
IP-address – unique network address of a node in a computer network based on the IP protocol.

2. Why do we collect your personal data?

The Company processes and collects your personal data for the following reasons:
a) it is necessary to fulfill our agreements with you, to arrange access to the Company Services;
b) we are obliged to keep your information in accordance with the laws of Russia, for example, to comply with tax laws;
c) it makes our Service convenient and efficient so that we can better and faster solve your tasks.
If you do not want your data to be used further – you may withdraw your consent to the processing of personal data by sending a notice of withdrawal to the email address in this Privacy Policy. The data will be deleted or blocked at your request.

3. For what purposes does the Company collect and process your personal data?

We collect and process personal data and other information that you submit to us in order to be able to fulfill the User Agreement. By accessing our website, you also accept the User Agreement and agree to abide by it by remaining on our website (even reading this document) and using its resources.
We need your data to conclude an agreement, and in order to know exactly what you have accepted the terms of our public offer (start to work with us and we will tell you more about the terms), and to bill for services rendered, to keep accounting and reporting to you.
We need information about you in order to answer your questions about the activities of our site and the services we offer.

4. What information do we collect?

4.1 Basic credentials
In order to create and activate an account, we ask for your name, organization name or details of your sole proprietorship, e-mail (to which you plan to connect the system) and Telegram Username (if any).

4.2 Transactions and payment details
For convenient payment of the Company’s services you can provide us with your payment data. This data might contain information about current accounts, e-wallets, or bank cards. The company processes this information and passes it to the operator of a payment system of your choice, or to the bank or the company in which your e-wallet is registered (to carry out a transaction and to check for fraud). Similarly, the Company will receive data from your payment system operator (bank, etc.) for the same reasons.

4.3 The data you give us intentionally, in the process of using the Site and Services of the Company.
When you contact us with a question or write through web forms to our support service, contact messengers with suggestions, we receive your messages and accompanying information (sometimes your phone number, ip address, e-mail, cookies), then we process this to provide assistance or give advice.

4.4 Data that you transmit indirectly, in the process of using the Site and Services of the Company.
We would like to draw your attention to the fact that in the process of using our services, you transmit information to us.
This information is naturally used to fulfill a contract between us, the Company, and you, our customers. It is this information that allows you to use the functionality of our system.
Also we get information about your location, which allows us to take care of the safety of your transactions (for example, it is unlikely that you can move in two seconds from Vladivostok to Kaliningrad, so for financial security reasons we need to make sure that at this time it is you and no one else in the system).
We don’t take, request or use any data from you that isn’t necessary to perform the tasks you’ve set us by entering into a contract with us.

4.5 Data tracking and cookies
We use cookies to recognize you and your devices. This gives us insight into how you use our services and similar technologies, which allows us to improve our product. This is standard practice on the Internet (but we do it responsibly and don’t hide it from you).
You can set your browser so that we do not have access to these files, or remove them, or prohibit their use, but this will certainly make using the Internet more inconvenient and make it harder for us to effectively help you and fulfill your requests.

4.6 Information We Are Obliged to Keep by Russian Law
We collect and maintain information we are required by law to keep. This is necessary to prevent fraud, to comply with regulatory requests and to resolve any disputes with you about the performance of agreements between the Company and you.

4.7 How long will we retain your information?
We retain your information for the period necessary to fulfill the purposes for which it is collected and processed, or if applicable law requires a longer retention period, for the period required by law. After this period, your Personal Information will be deleted, blocked, or anonymized as required by applicable law.

5. Who has access to your data (personal and confidential)?

We fully comply with the requirements of Russian legislation, international treaties and legislation of countries where our clients live in relation to personal data. Only those specialists of the Company who need it to fulfill their job functions to fulfill contractual agreements and legal requirements have access to it.

6. How is your data (personal and confidential) stored?

Your data is stored, processed and used in accordance with the provisions of Federal Law of 27.07.2006 N 152-FZ “On Personal Data”, recommendations of Roskomnadzor and the requirements of other regulations, including international and some jurisdictions of our users, i.e. in compliance with information, hardware and documentary security.

7. To whom can your data be transferred?

Your data can be given to state and law enforcement bodies at their request in accordance with the laws of the Russian Federation, to the courts and to other persons in the case provided by law. In some situations where this is necessary for the execution of a contract (such as banking transactions), we will transfer your data to third parties. By continuing to use our Site and Services, you agree to this.

8. How do I protect my rights regarding personal data?

First, if you have any questions, please email us. Second, remember: when you click on external links on the Internet, you should assess for yourself the risks of disclosure of your personal information on third-party sites. Do not disclose your login and password to anyone, and carefully read the documents of the Site and the Service.

9. What obligations do I have?

By accepting this Privacy Policy you commit yourself to honestly, fully and timely reporting of information that is required to fulfill the agreements between the Company and you.
You must be of legal age and legal capacity to use the Site and the Service.

10. What if I want to complain?

You have the full right to object, complain and make requests in accordance with this Policy and the laws of your country.

11. The current Privacy Policy is available at :

12. Company Contact Information:
Anna Palevich (NIF: 309753945)
Rua Manuel Marques, 10, 12D
1750-171, Lisboa, Portugal

112 Deputatskaya St., 112 Sq. 116, Tyumen, 625007
INN 7203532998
KPP 720301001
account 40702810301240003464
BIK 047162812
credit card 301018104657100812

We value your privacy

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