Privacy policy of the services
1. General provisions
1.1. The subject of regulation of this Privacy Policy (hereinafter referred to as the "Policy") is the relationship between the Limited Liability Company "Euclid Technologies" (OGRN 1217700483110, 25480, Moscow, Planernaya ul., 3 K. 1, room. II floor 1 room. 8), hereinafter referred to as "ET" or "Company", which is the copyright holder of websites, services, programs and/or other products, including information, communication, advertising, educational, entertainment and other nature (hereinafter referred to as "Services", and separately as "Service") located on the network Internet at https://projectoola.com/ (next – The "Site"), as well as on other domains administered by ET, and by you (an individual Internet user), hereinafter referred to as the "User", regarding the processing of User information, including personal data, in the process of using ET Services by such a person (hereinafter referred to as "Information"). This Policy is available at: https://projectoola.com/pks .
1.2. Relations related to the processing of information, including, but not limited to the collection, use, storage, dissemination and protection of information about Users of the ET Services, are governed by this Policy, the privacy policies of individual Services (which specify in relation to a particular Service the list of processed data, including personal data, purposes, legal grounds for processing and other conditions) and other rules posted within the ET Services (hereinafter collectively referred to as — "Policies", and separately "Policy"), as well as the current legislation of the Russian Federation. Before using the Company's Services, the User is obliged to familiarize himself with this Policy, as well as with all applicable Rules.
1.3. Upon registration, each access and/or actual use of any of the Services, the User agrees to the terms of this Policy, the privacy policies of individual Services, as well as the terms of agreements, regulations and rules of the Services used by him, which are posted on the pages (sections) of the relevant Services, in the editions that were in effect at the time of the actual use of such services.
2. Composition of Information
2.1. The Information processed by the Company includes:
2.1.1. Credentials, which are understood as:
(a) user data provided by the User to create an account during the registration process in the Service;
(b) additional information filled in by the User when editing his account during the use of the Service;
(c) data additionally provided by the User at the request of the Company in order for the Company to fulfill its obligations to the User arising from the agreement on the provision of the relevant Service, for example, first name, last name, date of birth, gender, mobile phone number, etc.;
2.1.2. Other data necessary for the operation of a particular Service, namely:
(a) data on technical means (devices), technological interaction with the Service (including the IP address of the host, the type of User's operating system, browser type, geographical location, Internet service provider);
(b) information automatically obtained when accessing the Service using cookies;
(c) information obtained as a result of User actions in the Service, in particular, information about the addition of any content (if applicable);
(d) information obtained as a result of actions of other Users in the Service (if applicable);
(e) generalized analytical information about the use of Internet services.
The Accounting and Other data processed by the Company to the extent necessary and sufficient to classify them as personal data in accordance with the current legislation of the Russian Federation are processed by the Company as personal data under the terms of this Policy and the privacy policies of individual Services.
A detailed list of processed Credentials and Other data in relation to a particular Service is provided in the privacy policy of the relevant Service. If any ET Service does not contain a special privacy policy of the corresponding Service, then the terms of this Policy apply.
For the full use of some ET Services, the User must be authorized (enter a username and password) through an account. In this case, the Service can receive the following User data from the account: first name, last name, date of birth, gender, e-mail. At the same time, the amount of data received about the User in each specific ET Service depends on the functional necessity of such a Service for the purposes of fulfilling the agreement with the User (the purpose of processing).
2.2. By the functionality and rules of use of individual Services, the User may be given the opportunity to post any other information in the Services (if applicable), in addition to the information specified in paragraph 2.1. of this Policy, if it does not contradict the requirements of current legislation. The Company has no purpose to process such information, as well as biometric and special categories of personal data. By posting information, the User understands that it may be available to an indefinite circle of Internet users, taking into account the settings of the desired level of privacy.
2.3. If the functionality of the Service used allows you to reflect information about the User in his Account, which is available for viewing by other Users of such a Service or Internet users, then the User agrees to reflect information about him in his Account. The User agrees that the Information, including Credentials and Other data, as well as other information may be available to other Users of the relevant Service and/or other Internet users, taking into account the existing functionality of the Service (which may be changed from time to time by the Company).
2.4. The Company does not verify the Credentials provided by the User and cannot judge their reliability, as well as whether the User has sufficient legal capacity to provide Scientific Data. Nevertheless, the Company assumes that the User provides reliable and sufficient Credentials, as well as updates them in a timely manner. By registering in the relevant Service or accessing it without registration, the User confirms that he has reached the acceptable age of using such a Service in accordance with applicable law.
2.5. Processing cookies
Cookies are small pieces of data that websites request from the browser used on the User's computer or mobile device. Cookies are stored locally on the computer or mobile device of the Internet user. The Company collects and processes cookies in relation to Users visiting the Company's Services.
The Company's Services use the following types of cookies:
strictly necessary cookies / technical cookies: these cookies are necessary for the operation of the site and the provision of Services to the User; among other things, they allow the Company to identify the User's hardware and software, including the browser type;
statistical/analytical cookies: these cookies allow you to recognize users, count their number and collect information, such as operations performed on websites, including information about the web pages visited and the content that the User receives;
technical cookies: these cookies collect information about how users interact with the site, which allows you to identify errors and test new features to improve the performance of the Services;
functional cookies: these cookies allow you to provide certain functions to facilitate the use of the sites, for example, by saving preferences (such as language and location);
(third-party) tracking files / advertising cookies: These cookies collect information about traffic sources, pages visited and advertisements displayed by the User. They allow you to display ads that may be of interest to the User, based on the analysis of information collected about the User. They are also used for statistical and research purposes.
Cookies are processed by the Company solely for the purpose specified in clause 3.2 of this Policy, on the terms and in the manner defined by this Policy, in particular on the basis of data obtained using cookies, the Company develops the most useful functionality for the Services available to the User, conducts statistical research, corrects errors in the Services and tests new functions to improve the performance of Services, it personalizes them and shows the most relevant information for the User.
The information collected using cookies placed on the User's device may be transferred and made available to the Company and/or third parties specified in clause 3.4 of this Policy, as well as to companies that own web analytics services. Mail.ru , Yandex.Metrica, Google Analytics and/or other similar services, if this is indicated in the privacy policy of the Company's respective service. The use of information outside the Services collected using cookies for advertising purposes, if any, may be subject to separate user agreements available on the Company's or third-party websites. The Company and/or third parties may also provide the User with the opportunity to opt out of the personalization of advertising, which may be subject to the regulation of legislation and rules applicable to such products and offers.
The user can refuse the processing of cookies in the settings of his browser. In this case, the Company's services will use only those cookies that are strictly necessary for the functioning of such a service and the provision of its functionality.
2.6. Processing of Other data when using mobile applications
The Company may receive and process Other data about Users who use the Company's mobile applications by embedding the SDK in mobile applications, which is specified in the privacy policy of the Company's respective service. Such Other Data is processed exclusively for the purpose specified in paragraph 3.2 of this Policy, on the terms and in the manner specified by this Policy.
2.7. Processing of information about the User's location (geo-location).
The Company may receive and process information about the User's location (geo-location) as part of Other data in compliance with the Purpose specified in clause 3.2 of this Policy, namely, to continuously improve the content of the Services, prevent and prevent any errors that may occur when using the Services, to personalize the information (including advertising) available To the User in the Services, to provide the User with relevant recommendations, as well as to conduct statistical research.
The Company can receive and process information about the User's location (geo-location) of varying accuracy, which depends on the functionality of the Service used, the settings selected by the User, the source of receiving data about the User's location, as well as the need to process location data to provide the functionality of a particular Service to the User and improve the user experience.
At the same time, the Company bases its assumptions about the User's location depending on the settings selected by the User in the browser or on a mobile device based on the User's IP address; information about the location of the device; and/or other information about the User's use of a particular Company Service.
The user can restrict the transmission of information about his location by changing the settings of his browser and/or mobile device.
3. Information Processing Conditions
3.1. The processing of User Information is carried out by the Company in accordance with the following principles:
3.1.1. legality of the purposes and methods of information processing;
3.1.2. integrity of the Company;
3.1.3. compliance of the purposes of information processing with the purposes previously defined and declared during its collection, as well as with the Company's powers;
3.1.4. compliance of the volume and nature of the processed Information, methods of its processing with the purposes of information processing;
3.1.5. the inadmissibility of combining databases containing User Information created for incompatible purposes.
3.2. Purposes of information processing
The Company processes the Credentials and Other data of the Users of the Services in order to fulfill the agreements concluded with the Users on the use of the relevant Services.
3.3. Collecting Information
The User's Credentials are collected during his registration in the relevant Service by filling out the registration form by the User, as well as later when the User edits previously provided information or when adding Credentials on his own initiative (if applicable) using the tools of the relevant Service.
Other data is collected by the Company independently during the User's use of the Service. In some cases, the collection of Other User data begins from the moment the User receives access to the Service (for example, when loading an Internet page or launching an application) until the moment of his registration in the corresponding Service.
3.4. Processing and Transmission of Information
User credentials and Other data are not transferred to any third parties, except as expressly provided for in this Policy, the policies of individual Services, other applicable rules, as well as applicable legislation.
The Company may transfer User Credentials and Other Data to third parties, in compliance with the purposes and if there are grounds specified in this Policy. Such third parties may include:
- persons who participate in the provision of services related to the placement and display of information to users (including offers relevant to the interests of users) about the Company's services and services in programs, products or services owned or controlled by such persons (for example, owners of websites and applications, advertising networks and other persons, etc.);
- persons who have legitimate grounds to process Credentials and Other data, for example, if the transfer of Credentials and Other data to such persons is carried out with the consent of the User, including if Credentials and Other data are necessary to provide the User with the appropriate service or to fulfill a certain agreement or contract concluded with the User, in particular, mobile operators and/or technological partners operating between the Company and mobile operators, pursuant to clauses 3.3 and 6.3.6 of the User Agreement of the ET Services.
- third parties in respect of whom the assignment of rights or obligations has been made, or novation under the relevant agreement;
- any state or local government body to which the Company is obliged to provide information in accordance with applicable law upon request.
In order to provide high-quality, multifunctional, user-friendly and focused on the personal needs and interests of Users of Services, the Company develops, improves, optimizes the current and introduces new functionality of Services (informational, communication, advertising, educational, entertainment and other nature), including with the participation of partners and / or affiliated persons.
Taking into account the above, as well as taking into account the Company's compliance with the processing purposes specified in clause 3.2 of this Policy, the User agrees and instructs the Company to perform the following actions:
- processing, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), comparison, extraction, use, blocking, deletion/destruction of User Credentials and Other data;
- transfer of Accounting and Other data to partners and affiliates, and their processing by partners and affiliates, on the basis of an order from the Company (by the methods specified in this paragraph), as well as joint processing by partners and affiliates of Accounting and Other data with data available to partners and affiliates;
- collecting (receiving) from partners and/or affiliated persons the results of processing Accounting and Other data together with the data at the disposal of partners and affiliated persons, including in the form of integer and/or text values and identifiers.
In some cases, certain functionality of the Services may be provided not by the Company, but by third parties who act independently of the Company and do not act on behalf of or on behalf of the Company. In this case, Users are obliged to familiarize themselves with the rules for the provision of services and the information/personal data protection policy of such third parties before using the relevant functionality of the Services.
In cases stipulated by the privacy policies of the relevant Services, the Company may transfer Information across borders to the minimum extent necessary for the purposes specified in this Policy or the policies of the relevant Services to third parties.
It is not allowed to extract and use User Credentials and Other Data, including for commercial purposes, without the Company's permission.
3.5. Information Storage
Accounting and Other user data are stored on the territory of the Russian Federation, while storage is carried out exclusively on electronic media, and processing is carried out using automated systems, except in cases when non-automated processing of Accounting and Other data is necessary in connection with compliance with the requirements of applicable legislation.
Credentials and Other data are stored until the purposes of their processing are achieved, unless otherwise specified in the privacy policy of the relevant service.
3.6. Information retention Periods
Accounting and Other data are stored by the Company during the term of the agreement between the User and the Company on the use of the relevant Service, and after the termination of such agreement – for the period necessary and established by the current legislation of the Russian Federation.
3.7. Termination of Information processing
Upon achieving the purposes of information processing, the Company stops processing Accounting and Other data in one of the ways provided for by the Federal Law "On Personal Data".
4. Rights and obligations of Users when processing their Information
Users have the right to:
4.1. get free access to information about yourself by viewing the User Account in the corresponding Service;
4.2. using the tools of the Service, establish the desired level of confidentiality with respect to information about yourself (conditions of access to information), taking into account the functionality of the relevant Service (if applicable);
4.3. independently make changes and corrections to the information about yourself by editing the information in the User Account, provided that such changes and corrections contain up-to-date and reliable information;
4.4. delete information about yourself by editing information in the Account of the relevant Service (if applicable); at the same time, the User's deletion of certain information about himself from the User's Account in some Services may lead to the inability to provide the User with access to these Services.
4.5. require the Company to clarify information about the User, block or destroy it if such information is incomplete, outdated, unreliable, unreasonably obtained or is not necessary for the stated purpose of processing and if the functionality of the Service does not allow the User to delete such information independently;
4.6. on the basis of a request to receive information from the Company concerning the processing of User information.
4.7. refuse to process personal data by sending a corresponding request to the Company in accordance with the procedure provided for in Section 7 of this Policy.
5. Information protection measures
5.1. The Company takes technical and organizational and legal measures to ensure the protection of User information from unauthorized or accidental access to them, destruction, modification, blocking, copying, distribution, as well as from other illegal actions.
5.2. Technical security measures are implemented by the Company taking into account the requirements of applicable legislation, the state-of-the-art technology, the nature of the processed information and the risks associated with its processing.
The information is processed mainly automatically without access to it by employees and/or contractors of the Company. If such access is provided to employees or contractors of the Company, then only to the extent necessary for such persons to perform their official duties or obligations under a contract with the Company, while such persons are obliged to comply with security requirements when accessing Information. To protect and ensure the confidentiality of data, all employees/contractors comply with internal rules and procedures regarding the processing of information. These persons also comply with all technical and organizational security measures provided for by applicable law and necessary to protect User information.
6. Limitation of liability of the Company
6.1. The Company is not responsible for the disclosure and dissemination of information about the User by other Users of the Services or other Internet users if such persons have gained access to the specified information in accordance with the privacy settings of the corresponding Service chosen by the User, or in case of violation by the User of the security of his login and / or password or other necessary for authorization data.
7. User Requests
7.1. Information about the data processed by the Company, including the User's personal data, in connection with the use of the relevant Service is provided to the User or his representative when contacting (requesting).
7.2. Requests are sent in writing to the address of the Company's location or in another form provided for by the current legislation of the Russian Federation.
7.3. The User has the right to withdraw consent to the processing of his personal data by sending a written application to the Company at the location of the Company in accordance with the requirements of current legislation.
8. Amendments and additions to this Policy
8.1. This Policy and the policies of individual Services may be changed by the Company with the notification of the User, including by posting a new version of the amended policy on the Website. Changes to the Policy made by the Company come into force on the day following the day of its posting on the Website of the new version of the Policy. The User undertakes to independently check this Policy and the Policies of individual Services for changes made. The User's failure to perform familiarization actions cannot serve as a basis for the User's failure to fulfill his obligations and the User's failure to comply with the restrictions established by this Agreement and the Agreements of individual Services.
8.2. The User has the right to refuse to accept changes and additions to this Policy and/or the policies of individual Services, which means that the User refuses to use all and/ or individual ET Services and all rights previously granted to him.
8.3. This Policy is regulated and interpreted in accordance with the legislation of the Russian Federation. Issues not regulated by this Policy are subject to resolution in accordance with the legislation of the Russian Federation.
Edition of 14.07.2022
1.1. The subject of regulation of this Privacy Policy (hereinafter referred to as the "Policy") is the relationship between the Limited Liability Company "Euclid Technologies" (OGRN 1217700483110, 25480, Moscow, Planernaya ul., 3 K. 1, room. II floor 1 room. 8), hereinafter referred to as "ET" or "Company", which is the copyright holder of websites, services, programs and/or other products, including information, communication, advertising, educational, entertainment and other nature (hereinafter referred to as "Services", and separately as "Service") located on the network Internet at https://projectoola.com/ (next – The "Site"), as well as on other domains administered by ET, and by you (an individual Internet user), hereinafter referred to as the "User", regarding the processing of User information, including personal data, in the process of using ET Services by such a person (hereinafter referred to as "Information"). This Policy is available at: https://projectoola.com/pks .
1.2. Relations related to the processing of information, including, but not limited to the collection, use, storage, dissemination and protection of information about Users of the ET Services, are governed by this Policy, the privacy policies of individual Services (which specify in relation to a particular Service the list of processed data, including personal data, purposes, legal grounds for processing and other conditions) and other rules posted within the ET Services (hereinafter collectively referred to as — "Policies", and separately "Policy"), as well as the current legislation of the Russian Federation. Before using the Company's Services, the User is obliged to familiarize himself with this Policy, as well as with all applicable Rules.
1.3. Upon registration, each access and/or actual use of any of the Services, the User agrees to the terms of this Policy, the privacy policies of individual Services, as well as the terms of agreements, regulations and rules of the Services used by him, which are posted on the pages (sections) of the relevant Services, in the editions that were in effect at the time of the actual use of such services.
2. Composition of Information
2.1. The Information processed by the Company includes:
2.1.1. Credentials, which are understood as:
(a) user data provided by the User to create an account during the registration process in the Service;
(b) additional information filled in by the User when editing his account during the use of the Service;
(c) data additionally provided by the User at the request of the Company in order for the Company to fulfill its obligations to the User arising from the agreement on the provision of the relevant Service, for example, first name, last name, date of birth, gender, mobile phone number, etc.;
2.1.2. Other data necessary for the operation of a particular Service, namely:
(a) data on technical means (devices), technological interaction with the Service (including the IP address of the host, the type of User's operating system, browser type, geographical location, Internet service provider);
(b) information automatically obtained when accessing the Service using cookies;
(c) information obtained as a result of User actions in the Service, in particular, information about the addition of any content (if applicable);
(d) information obtained as a result of actions of other Users in the Service (if applicable);
(e) generalized analytical information about the use of Internet services.
The Accounting and Other data processed by the Company to the extent necessary and sufficient to classify them as personal data in accordance with the current legislation of the Russian Federation are processed by the Company as personal data under the terms of this Policy and the privacy policies of individual Services.
A detailed list of processed Credentials and Other data in relation to a particular Service is provided in the privacy policy of the relevant Service. If any ET Service does not contain a special privacy policy of the corresponding Service, then the terms of this Policy apply.
For the full use of some ET Services, the User must be authorized (enter a username and password) through an account. In this case, the Service can receive the following User data from the account: first name, last name, date of birth, gender, e-mail. At the same time, the amount of data received about the User in each specific ET Service depends on the functional necessity of such a Service for the purposes of fulfilling the agreement with the User (the purpose of processing).
2.2. By the functionality and rules of use of individual Services, the User may be given the opportunity to post any other information in the Services (if applicable), in addition to the information specified in paragraph 2.1. of this Policy, if it does not contradict the requirements of current legislation. The Company has no purpose to process such information, as well as biometric and special categories of personal data. By posting information, the User understands that it may be available to an indefinite circle of Internet users, taking into account the settings of the desired level of privacy.
2.3. If the functionality of the Service used allows you to reflect information about the User in his Account, which is available for viewing by other Users of such a Service or Internet users, then the User agrees to reflect information about him in his Account. The User agrees that the Information, including Credentials and Other data, as well as other information may be available to other Users of the relevant Service and/or other Internet users, taking into account the existing functionality of the Service (which may be changed from time to time by the Company).
2.4. The Company does not verify the Credentials provided by the User and cannot judge their reliability, as well as whether the User has sufficient legal capacity to provide Scientific Data. Nevertheless, the Company assumes that the User provides reliable and sufficient Credentials, as well as updates them in a timely manner. By registering in the relevant Service or accessing it without registration, the User confirms that he has reached the acceptable age of using such a Service in accordance with applicable law.
2.5. Processing cookies
Cookies are small pieces of data that websites request from the browser used on the User's computer or mobile device. Cookies are stored locally on the computer or mobile device of the Internet user. The Company collects and processes cookies in relation to Users visiting the Company's Services.
The Company's Services use the following types of cookies:
strictly necessary cookies / technical cookies: these cookies are necessary for the operation of the site and the provision of Services to the User; among other things, they allow the Company to identify the User's hardware and software, including the browser type;
statistical/analytical cookies: these cookies allow you to recognize users, count their number and collect information, such as operations performed on websites, including information about the web pages visited and the content that the User receives;
technical cookies: these cookies collect information about how users interact with the site, which allows you to identify errors and test new features to improve the performance of the Services;
functional cookies: these cookies allow you to provide certain functions to facilitate the use of the sites, for example, by saving preferences (such as language and location);
(third-party) tracking files / advertising cookies: These cookies collect information about traffic sources, pages visited and advertisements displayed by the User. They allow you to display ads that may be of interest to the User, based on the analysis of information collected about the User. They are also used for statistical and research purposes.
Cookies are processed by the Company solely for the purpose specified in clause 3.2 of this Policy, on the terms and in the manner defined by this Policy, in particular on the basis of data obtained using cookies, the Company develops the most useful functionality for the Services available to the User, conducts statistical research, corrects errors in the Services and tests new functions to improve the performance of Services, it personalizes them and shows the most relevant information for the User.
The information collected using cookies placed on the User's device may be transferred and made available to the Company and/or third parties specified in clause 3.4 of this Policy, as well as to companies that own web analytics services. Mail.ru , Yandex.Metrica, Google Analytics and/or other similar services, if this is indicated in the privacy policy of the Company's respective service. The use of information outside the Services collected using cookies for advertising purposes, if any, may be subject to separate user agreements available on the Company's or third-party websites. The Company and/or third parties may also provide the User with the opportunity to opt out of the personalization of advertising, which may be subject to the regulation of legislation and rules applicable to such products and offers.
The user can refuse the processing of cookies in the settings of his browser. In this case, the Company's services will use only those cookies that are strictly necessary for the functioning of such a service and the provision of its functionality.
2.6. Processing of Other data when using mobile applications
The Company may receive and process Other data about Users who use the Company's mobile applications by embedding the SDK in mobile applications, which is specified in the privacy policy of the Company's respective service. Such Other Data is processed exclusively for the purpose specified in paragraph 3.2 of this Policy, on the terms and in the manner specified by this Policy.
2.7. Processing of information about the User's location (geo-location).
The Company may receive and process information about the User's location (geo-location) as part of Other data in compliance with the Purpose specified in clause 3.2 of this Policy, namely, to continuously improve the content of the Services, prevent and prevent any errors that may occur when using the Services, to personalize the information (including advertising) available To the User in the Services, to provide the User with relevant recommendations, as well as to conduct statistical research.
The Company can receive and process information about the User's location (geo-location) of varying accuracy, which depends on the functionality of the Service used, the settings selected by the User, the source of receiving data about the User's location, as well as the need to process location data to provide the functionality of a particular Service to the User and improve the user experience.
At the same time, the Company bases its assumptions about the User's location depending on the settings selected by the User in the browser or on a mobile device based on the User's IP address; information about the location of the device; and/or other information about the User's use of a particular Company Service.
The user can restrict the transmission of information about his location by changing the settings of his browser and/or mobile device.
3. Information Processing Conditions
3.1. The processing of User Information is carried out by the Company in accordance with the following principles:
3.1.1. legality of the purposes and methods of information processing;
3.1.2. integrity of the Company;
3.1.3. compliance of the purposes of information processing with the purposes previously defined and declared during its collection, as well as with the Company's powers;
3.1.4. compliance of the volume and nature of the processed Information, methods of its processing with the purposes of information processing;
3.1.5. the inadmissibility of combining databases containing User Information created for incompatible purposes.
3.2. Purposes of information processing
The Company processes the Credentials and Other data of the Users of the Services in order to fulfill the agreements concluded with the Users on the use of the relevant Services.
3.3. Collecting Information
The User's Credentials are collected during his registration in the relevant Service by filling out the registration form by the User, as well as later when the User edits previously provided information or when adding Credentials on his own initiative (if applicable) using the tools of the relevant Service.
Other data is collected by the Company independently during the User's use of the Service. In some cases, the collection of Other User data begins from the moment the User receives access to the Service (for example, when loading an Internet page or launching an application) until the moment of his registration in the corresponding Service.
3.4. Processing and Transmission of Information
User credentials and Other data are not transferred to any third parties, except as expressly provided for in this Policy, the policies of individual Services, other applicable rules, as well as applicable legislation.
The Company may transfer User Credentials and Other Data to third parties, in compliance with the purposes and if there are grounds specified in this Policy. Such third parties may include:
- persons who participate in the provision of services related to the placement and display of information to users (including offers relevant to the interests of users) about the Company's services and services in programs, products or services owned or controlled by such persons (for example, owners of websites and applications, advertising networks and other persons, etc.);
- persons who have legitimate grounds to process Credentials and Other data, for example, if the transfer of Credentials and Other data to such persons is carried out with the consent of the User, including if Credentials and Other data are necessary to provide the User with the appropriate service or to fulfill a certain agreement or contract concluded with the User, in particular, mobile operators and/or technological partners operating between the Company and mobile operators, pursuant to clauses 3.3 and 6.3.6 of the User Agreement of the ET Services.
- third parties in respect of whom the assignment of rights or obligations has been made, or novation under the relevant agreement;
- any state or local government body to which the Company is obliged to provide information in accordance with applicable law upon request.
In order to provide high-quality, multifunctional, user-friendly and focused on the personal needs and interests of Users of Services, the Company develops, improves, optimizes the current and introduces new functionality of Services (informational, communication, advertising, educational, entertainment and other nature), including with the participation of partners and / or affiliated persons.
Taking into account the above, as well as taking into account the Company's compliance with the processing purposes specified in clause 3.2 of this Policy, the User agrees and instructs the Company to perform the following actions:
- processing, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), comparison, extraction, use, blocking, deletion/destruction of User Credentials and Other data;
- transfer of Accounting and Other data to partners and affiliates, and their processing by partners and affiliates, on the basis of an order from the Company (by the methods specified in this paragraph), as well as joint processing by partners and affiliates of Accounting and Other data with data available to partners and affiliates;
- collecting (receiving) from partners and/or affiliated persons the results of processing Accounting and Other data together with the data at the disposal of partners and affiliated persons, including in the form of integer and/or text values and identifiers.
In some cases, certain functionality of the Services may be provided not by the Company, but by third parties who act independently of the Company and do not act on behalf of or on behalf of the Company. In this case, Users are obliged to familiarize themselves with the rules for the provision of services and the information/personal data protection policy of such third parties before using the relevant functionality of the Services.
In cases stipulated by the privacy policies of the relevant Services, the Company may transfer Information across borders to the minimum extent necessary for the purposes specified in this Policy or the policies of the relevant Services to third parties.
It is not allowed to extract and use User Credentials and Other Data, including for commercial purposes, without the Company's permission.
3.5. Information Storage
Accounting and Other user data are stored on the territory of the Russian Federation, while storage is carried out exclusively on electronic media, and processing is carried out using automated systems, except in cases when non-automated processing of Accounting and Other data is necessary in connection with compliance with the requirements of applicable legislation.
Credentials and Other data are stored until the purposes of their processing are achieved, unless otherwise specified in the privacy policy of the relevant service.
3.6. Information retention Periods
Accounting and Other data are stored by the Company during the term of the agreement between the User and the Company on the use of the relevant Service, and after the termination of such agreement – for the period necessary and established by the current legislation of the Russian Federation.
3.7. Termination of Information processing
Upon achieving the purposes of information processing, the Company stops processing Accounting and Other data in one of the ways provided for by the Federal Law "On Personal Data".
4. Rights and obligations of Users when processing their Information
Users have the right to:
4.1. get free access to information about yourself by viewing the User Account in the corresponding Service;
4.2. using the tools of the Service, establish the desired level of confidentiality with respect to information about yourself (conditions of access to information), taking into account the functionality of the relevant Service (if applicable);
4.3. independently make changes and corrections to the information about yourself by editing the information in the User Account, provided that such changes and corrections contain up-to-date and reliable information;
4.4. delete information about yourself by editing information in the Account of the relevant Service (if applicable); at the same time, the User's deletion of certain information about himself from the User's Account in some Services may lead to the inability to provide the User with access to these Services.
4.5. require the Company to clarify information about the User, block or destroy it if such information is incomplete, outdated, unreliable, unreasonably obtained or is not necessary for the stated purpose of processing and if the functionality of the Service does not allow the User to delete such information independently;
4.6. on the basis of a request to receive information from the Company concerning the processing of User information.
4.7. refuse to process personal data by sending a corresponding request to the Company in accordance with the procedure provided for in Section 7 of this Policy.
5. Information protection measures
5.1. The Company takes technical and organizational and legal measures to ensure the protection of User information from unauthorized or accidental access to them, destruction, modification, blocking, copying, distribution, as well as from other illegal actions.
5.2. Technical security measures are implemented by the Company taking into account the requirements of applicable legislation, the state-of-the-art technology, the nature of the processed information and the risks associated with its processing.
The information is processed mainly automatically without access to it by employees and/or contractors of the Company. If such access is provided to employees or contractors of the Company, then only to the extent necessary for such persons to perform their official duties or obligations under a contract with the Company, while such persons are obliged to comply with security requirements when accessing Information. To protect and ensure the confidentiality of data, all employees/contractors comply with internal rules and procedures regarding the processing of information. These persons also comply with all technical and organizational security measures provided for by applicable law and necessary to protect User information.
6. Limitation of liability of the Company
6.1. The Company is not responsible for the disclosure and dissemination of information about the User by other Users of the Services or other Internet users if such persons have gained access to the specified information in accordance with the privacy settings of the corresponding Service chosen by the User, or in case of violation by the User of the security of his login and / or password or other necessary for authorization data.
7. User Requests
7.1. Information about the data processed by the Company, including the User's personal data, in connection with the use of the relevant Service is provided to the User or his representative when contacting (requesting).
7.2. Requests are sent in writing to the address of the Company's location or in another form provided for by the current legislation of the Russian Federation.
7.3. The User has the right to withdraw consent to the processing of his personal data by sending a written application to the Company at the location of the Company in accordance with the requirements of current legislation.
8. Amendments and additions to this Policy
8.1. This Policy and the policies of individual Services may be changed by the Company with the notification of the User, including by posting a new version of the amended policy on the Website. Changes to the Policy made by the Company come into force on the day following the day of its posting on the Website of the new version of the Policy. The User undertakes to independently check this Policy and the Policies of individual Services for changes made. The User's failure to perform familiarization actions cannot serve as a basis for the User's failure to fulfill his obligations and the User's failure to comply with the restrictions established by this Agreement and the Agreements of individual Services.
8.2. The User has the right to refuse to accept changes and additions to this Policy and/or the policies of individual Services, which means that the User refuses to use all and/ or individual ET Services and all rights previously granted to him.
8.3. This Policy is regulated and interpreted in accordance with the legislation of the Russian Federation. Issues not regulated by this Policy are subject to resolution in accordance with the legislation of the Russian Federation.
Edition of 14.07.2022
