Last updated: September 18, 2019
The User guarantees that in accordance with the jurisdiction of the User, he has reached the age of legal capacity allowing him to independently dispose of his personal information (but not less than 16 years) or the User can confirm in the prescribed manner and form the appropriate permission to dispose of his personal information from his legal representatives.
Please note that you are not required by law to provide us with any personal information, but providing such information is a prerequisite for using our Service. You hereby represent, warrant and agree that any information you provide to us is provided of your own free will, is specific, unambiguous, and corresponds to a genuine desire to use your data for the purposes described in the Policy.
You can withdraw consent to the processing of your personal information at any time, so we guarantee that the procedure for withdrawing consent is as simple as giving it. Withdrawal of consent does not affect the lawfulness of the processing of Personal Information based on consent prior to its withdrawal.
1.1. In our activities, we are guided by the current legislation of the Russian Federation in the field of personal data processing, as well as the standards established by the Council of Europe Directives on the collection and storage of personal data (GDPR).
1.2. In accordance with the principle of “data minimization”, we collect Personal Information only to the extent necessary to use the Service and achieve the goals of its collection.
1.3. In the process of using the Service by the User, we collect two types of Personal Information: Personal Information and Anonymous Information.
1.3.1. Personal information. Such information includes individual information that identifies a particular User, and which the User provides to us during the Registration process.
Personal information is collected by the Service when you attach an account from a social network available for login. The service receives the following types of information from the social network account:
If any of the above types of information is missing in the social account, this information is not received by the Service.
1.3.2. Anonymous information. Anonymous information is information that does not identify a specific User, and is collected automatically when registering and using the Service.
Anonymous information may include:
1.4. The User accepts and agrees that in some cases we have the right to request additional information about the User, as well as copies of documents to confirm the specified information and make any other requests when necessary, based on reasonable assumptions and legitimate interests.
2.1. The legal basis for the collection of Personal Information is the User's consent to the collection of information.
2.2. Personal information is collected by us at the time of User Registration in the Service. Registration in the Service takes place through a social media account that is available to enter the Service, while Personal Information is automatically transferred from the social media account.
2.3. Anonymous information is collected by us in the course of your use of the Service.
3.1. We use Personal Information for the following purposes:
3.1.1. Providing access to the Service for its further operation.
3.1.2. Improving the Service, improving the convenience of its use and setting the necessary parameters, based on the general or individual preferences, experience of use or the difficulties encountered by the Users.
3.1.3. Providing technical support, feedback, including sending notifications, requests and information related to the use of the Service (notifications about updates, information on security issues, changes to our rules and conditions for using the Service).
3.1.4. Creation of summary statistical information, including analytics and monitoring of trends in the use of the Service and the actions of Users in the Service.
3.1.5. Sending promotional mailings to your email address and displaying advertising materials within the Service about products, services, promotions, events and other news and information that, in our opinion, will be of interest to the User. You can opt out of receiving promotional emails by using the “unsubscribe” option we offer in these emails.
3.1.6. Prevent fraud or violate applicable laws, in particular to detect, investigate and prevent fraudulent transactions and other illegal activities and protect our rights and property, as well as the rights and property of other users and third parties.
3.1.7. To comply with any applicable law.
3.2. The User's personal information will not be used for purposes other than the above.
3.3. The User confirms that the purposes of using his Personal Information correspond to his interests, and the consent to the processing of Personal Information by us, expressed by the User when using the Service, is given for each purpose of processing specified in clause 3.1 of the Agreement.
4.1. We undertake not to disclose the User's Personal Information to third parties, except when:
4.1.1. The User has expressly and specifically agreed to the disclosure of his Personal Information.
4.1.2. Such transfer of information is necessary for the User to use the Service, or for the execution of the User Agreement or other binding documents governing the relationship between us and the User.
4.1.3. When such transfer of information is necessary for the operation of the Service and its functionality (transfer of information to hosting, communications and content delivery (distribution) networks, data protection and cybersecurity services, billing and payment processing services, fraud detection and prevention services, web analytics, electronic distribution mail and monitoring the status of the Service, including measuring performance and optimizing data, marketing and advertising services), third parties (recipients of Personal Information) may receive or otherwise have access to the User's Personal Information, in full or in part - depending on the role and the goals of each such person in maintaining the Service or improving it; in addition, they may use the information received only for the purposes specified in this Policy.
4.1.4. Transfers of Personal Information are made in accordance with applicable law at the request of authorized recipients of such information (judicial and law enforcement requests), where we are under an obligation to disclose such information, if we believe in good faith that the law requires us to do in this way.
4.1.5. There is a transfer of ownership or control over all or part of the Service to the new owner.
4.2. We will never sell Users' Personal Information to third parties.
5.3. We strive to protect and preserve Users' Personal Information in accordance with international industry standards and do not take into account any lesser legal requirements than the User's jurisdiction.
6.1. We use certain control and tracking technologies in order to maintain, provide and improve the operation of our Service on an ongoing basis, and in order to provide the User with a comfortable use of the Service. By default, we use several of these technologies for the purposes of session and User authentication, security, to preserve User preferences (for example, in relation to the default language and settings), connection stability, monitoring the performance of our Service and marketing campaigns, and to provide and improve our Services.
7.1.1. The right to access your Personal Information. To ensure this right, the Service provides a special section where all the User's Personal Information received by us is indicated. The user can go to the section with Personal Information and get acquainted with the Personal Information that we currently have in our possession. At the request of the User, we provide a complete list of Personal Information that we have collected about the User, the legal basis and purposes of processing, categories of Personal Information, a list of third parties to whom Personal Information has been or will be disclosed, for how long Personal Information will be stored, as well as protection measures personal information. A response will be given within a reasonable time in accordance with applicable law.
7.1.2. Right to Correction. The user at any time has the right to send a corresponding request to us, we will make corrections within a reasonable period of time. Taking into account the purposes of processing, the Data Subject has the right to incomplete Personal Information, indicating only the mandatory types of Personal Information necessary to access the Service.
7.1.3. The right to withdraw consent to the processing of Personal Information. The user has the right to withdraw his consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal. The Service provides the ability to withdraw consent as easily as it is given. Thus, the User has the opportunity at any time to send us a request to delete the account - we will delete the account within a reasonable time after receiving the appropriate request.
Please note that you can correct, update or delete certain pieces of Personal Information yourself.
When making corrections to Personal Information or withdrawing consent by the User, we will notify all third parties with access to the User's Personal Information.
7.1.4. The right to be erased ("the right to be forgotten"). The User has the right to demand and we are obliged to delete the User's Personal Information without undue delay if:
7.1.5. Right to data portability. The User has the right to receive his Personal Information in a structured, commonly used and machine-readable format. To receive in a structured form all the Personal Information ever received by us, the User can send a corresponding request to the technical support service. The User has the right to transfer his Personal Information directly from one controller to another, if this is technically feasible.
8.1. We store your Personal Information for as long as you use the Service (your account activity) or until we no longer need this data to provide the Service, or when a longer period is set for this (if we are required to store it longer in applicable law, or to resolve disputes with our Users, prevent fraud and abuse, and/or protect our legitimate interests).
9.1. We hereby give a guarantee that we take all necessary and sufficient, in accordance with applicable law, organizational and technical measures to protect the User's Personal Information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions with her third parties. In our activities, we use generally accepted industry standards to protect the User's Personal Information and strive to protect and ensure the confidentiality of Personal Information as much as possible. The protection of Personal Information is implemented by default at the constructive level of the Service during its development. Security measures include firewalling, pseudonymization, data encryption, data minimization, resilience of processing systems to failures, the ability to restore availability and access to Personal Information in a timely manner in the event of a physical or technical incident, control of physical access to data centers, and as well as control of data access permissions. We regularly monitor our systems for possible vulnerabilities and attacks, evaluate the effectiveness of technical and organizational measures to ensure the security of Personal Information, and are constantly looking for new ways and service providers to further improve the security of our Service and protect the privacy of our Users. All third parties gaining access to Personal Information and participating in the process of providing access to the Service for the User adhere to no less stringent measures to ensure the security of Personal Information.
9.2. However, we cannot guarantee absolute security, and therefore we urge you to exercise caution, set a strong password for your account, and avoid providing any sensitive information, the disclosure of which could cause you significant harm.
9.3. In the event of any violation of the confidentiality of Personal Information, we take all measures within our power to eliminate or minimize possible negative consequences, and also ensure that the authorized supervisory authorities and the User are immediately notified of this incident, indicating all available information about the violation of confidentiality. The facts of such incidents are recorded in a special register of incidents, which we are required to maintain in accordance with applicable law.
9.4. A breach of the confidentiality of Personal Information in this Policy refers to a breach of security resulting in accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access to transferred or processed Personal Information.
10.2. You hereby agree that any disputes that may arise shall be resolved exclusively by the courts in the Russian Federation at our location.
11.2. We will respond to your request within a reasonable period of time or as required by applicable law.
11.3. In cases where this Policy or applicable law establishes our obligation to provide you with copies of information or any documents, we provide them in a single copy, subject to reimbursement by you for the costs of producing and sending such documents. If you make a request by electronic means, and unless otherwise requested by you, we will provide a response in a commonly used electronic format at our sole discretion.
11.5. If the User's requests are manifestly unfounded or excessive, in particular due to their repetitive nature, we have the right to refuse to act on the request.
11.6. In the event that we have reasonable doubts about the identity of the person making the request, we may request the provision of additional information necessary to confirm the identity of the User.