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skaz2 edited this page Feb 15, 2023 · 2 revisions

"Privacy Policy for 'Psy' Mobile Application"

  1. DEFINITIONS: "Law" means the Federal Law of the Russian Federation "On Personal Data" with all amendments and additions, as well as other legislative acts of the Russian Federation. "Controller" means the person responsible for the processing and protection of personal data of users located in the EU under the General Data Protection Regulation of April 27, 2016 (hereinafter "GDPR"). "Mobile application" is software (with all existing add-ons and enhancements) designed to run on smartphones, tablets, watches, and other mobile devices and developed for a specific platform (iOS, Android, Windows Phone, etc.). For the purposes of this Policy, the following software is referred to as the Mobile Application: PSY & AVOCADO. "Personal data" means a combination of personal data and/or non-personal information about the user provided by the user to the right holder and/or automatically collected by the right holder and/or third parties. "Policy" means this Privacy Policy of the Mobile Application (with all existing add-ons and changes). "User" means a legal or natural person who has downloaded the Mobile Application to a smartphone, tablet, watch or any other mobile device and/or activated such Mobile Application on any of the mentioned devices. "User Agreement" means an agreement concluded between the right holder and the user regarding the procedure, rules and features of the use of the Mobile Application by the user. The user agrees to this agreement and has no right to make any changes or additions to it. "Right holder" means the person who holds exclusive rights to the PSY & AVOCADO Mobile Application. "Processor" means a person who, in accordance with the GDPR, on behalf of the Controller, performs storage and/or processing of personal data received from users. "Cookies" means small files sent by any mobile application or website and placed on the user's smartphone, tablet, watch, and other mobile devices to improve the performance of such applications or websites, as well as the quality of content posted on them.

  2. RELATIONSHIPS TO WHICH THE POLICY APPLIES General Provisions This Policy is used and applicable exclusively to Personal data obtained from the User in connection with the use of the Mobile application. The provisions of this Policy are aimed at: (1) identifying the types and types of Personal data obtained, directions and purposes of use (processing) of Personal data, as well as sources of obtaining such Personal data; and (2) defining the User's rights with regard to the protection of the confidentiality of the Personal data transmitted by him; and (3) identifying the persons responsible for processing and storing Personal data, as well as third parties to whom such data are disclosed (in full or in part). The rules of this Policy do not apply to the processing by third parties of Personal data voluntarily provided by the User. By installing and/or activating the Mobile application on a smartphone, tablet, watch or other mobile device, the User agrees to the terms of this Policy and gives his consent to the Rights holder to collect, process, retain and store Personal data in the manner and on the conditions provided for by this Policy. If the User does not agree with the terms of the Policy and/or some terms of the Policy are unclear to him, in this case, the User must immediately stop using the Mobile application. User rights to personal data protection In connection with the provision of Personal data, the User automatically receives the following rights: (1) to receive data related to their processing (grounds and purposes of such processing, methods of processing, information about persons who have access to them or to whom they may be disclosed on the basis of a contract or law). (2) to receive data on the location and identification data of persons processing Personal data. (3) to receive data on the terms of storage of Personal data. (4) to receive data on the implemented or assumed cross-border transfer of Personal data. (5) to appeal the actions or inaction of the Rights holder to the authorized body for the protection of the rights of personal data subjects or in court. (6) to receive compensation for damages and/or compensation for moral damage in court as a result of violations of the User's rights to the protection and defense of his Personal data committed by the Rights holder and/or third parties. (7) to exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.

  3. LIST OF COLLECTED PERSONAL DATA Non-personal information about users: The Rights Holder may automatically collect and process the following non-personal information about the User in connection with the use of the Mobile Application: (1) traffic information, possible number of clicks, logs, and other data; (2) device information (identification number, mobile operator network), from which the User logs in, operating system, platform, browser type, and other browser information, IP address. The Rights Holder does not collect any personal data about the Users that would allow for their identification. Information about transactions: A User may make payments for goods or services through the Mobile Application by entering information about their payment card and the identification data of the cardholder into a special field. The User can make payment through the Mobile Application using a bank card or the Google Pay payment system. Data collection and processing about the User in this case is carried out solely for the purposes of payment, prevention of fraud, and compliance with other legal requirements. The User gives their consent to the Rights Holder and the corresponding payment system or bank that handles the payment to access and collect such personal data and agrees with the privacy policy of the corresponding payment system or bank. Use of cookies: This Mobile Application applies certain Cookies to store the IP address, User preferences or type of device used in order to (1) conduct statistics of website visits and traffic, (2) personalize the displayed User data, (3) store data required for User identification, including when accessed from different devices, and (4) show advertisements according to User interests and preferences. The mobile application can use both its own cookie files owned by the Rights Holder and third-party cookie files. The mobile application uses the following cookie files: (1) Technical (functional) cookie files that are necessary for traffic control and data transfer, identifying Users and providing User access to Mobile Application content, and without which the use of the Mobile Application is functionally limited, as well as preventing recommendations that do not correspond to the User's interests. (2) Advertising (marketing) cookie files that are necessary for placing advertising and/or marketing announcements in the Mobile Application that correspond to the User's preferences and interests. (3) Third-party cookie files that are set by third parties with the User's permission and are intended for conducting statistical research on the User's behavior on the Internet and/or directing personalized advertising or marketing materials to the User and/or providing goods or services. The User has the right to disable cookie files in the Mobile Application at any time by changing certain settings in their smartphone, tablet, watch, or other mobile device. Such disabling does not restrict or change the User's access to the functional capabilities of the Mobile Application and/or content. To disable cookie files, the following actions must be taken:

  4. GOALS OF PERSONAL DATA COLLECTION AND PROCESSING The purposes of collecting and processing personal data include: (1) analyzing user behavior and preferences, (2) improving the mobile application's functionality and content, (3) identifying users, (4) providing personalized advertising and marketing materials, (5) complying with the law, (6) tracking user orders/purchases, (7) providing technical support, (8) maintaining communication with users, (9) fulfilling the rights holder's obligations, and (10) other purposes with separate user consent. Personal data processing is based on the principles of legality, fairness, transparency, and proportionality. Personal data processing is performed with or without automation tools.

THIRD-PARTY ACCESS TO PERSONAL DATA: The content User of the Mobile Application may be advertised on other websites through remarketing services provided to the Owner through the Google Ads platform. Google Ads collects and processes non-personal data such as viewed content, date and time of viewing, and location information to provide targeted advertising content. By installing the Mobile Application, the User agrees to the Privacy Policy and Terms of Use for Google Ads and the automatic installation of relevant cookies. The User may opt-out of this advertising at any time by changing browser and device settings. The Owner may disclose Personal Data to affiliated entities, successors, payment providers, or with User consent or as required by law.

The copyright owner discloses Personal data only if (1) they are confident that third parties will comply with the conditions of this Policy and take the same measures to protect the confidentiality of Personal data as the copyright owner does, and (2) the consent to such disclosure was previously expressed by the User and/or is permitted by law. Third-party advertising The Content of the Mobile Application may contain advertising banners and/or links to third-party websites. The use of such websites by the User (by clicking on a link or in any other way) may result in the collection, processing, and use of Personal data, as well as the possible automatic transfer of cookie files to the User's device from which the transition to third-party websites was made. The copyright owner is not responsible for the methods, methods, and procedures for processing Personal data by third-party websites. As a result, the copyright owner is also not responsible for the disclosure of Personal data to an unlimited circle of persons in connection with the use of such websites by the User. The copyright owner strongly recommends that each User carefully review the privacy policies of the websites used. The User has the right to disable such advertising banners and/or links at any time by performing the following actions:

  1. ADVERTISING PLACEMENT The Right holder places various advertising and marketing materials in the mobile application along with the content, taking into account the User's preferences for certain content. Placing advertising in the mobile application involves installing certain cookie files on the Right holder's device. The User has the right to opt-out of such advertising at any time by taking the following actions:

  2. COMPLAINTS AND REQUESTS TO THE RIGHTHOLDER Request to cease personal data processing Each User has the right to object to the processing and/or storage of their Personal Data by the Rightsholder. Such objection can be expressed in the following way:

Request for personal data information If the User has any questions related to the application or use of this Policy, the procedures and/or methods of processing Personal Data, the User may ask such a question in the following way:

Modification (updating, addition, correction) or deletion of personal data The user has the right to independently modify or delete their personal data at any time, except in cases where such modification or deletion may lead to (1) a violation of the rules of this Policy; or (2) a violation of the Law; (3) the nature of such Personal data is evidence in any legal proceedings arising between the Rights holder and the User. To do this, the user needs to delete their personal account (profile) in the Mobile application. The Rights holder has the right to delete the user's personal account/profile and all personal data about the user at any time if the user violates the terms of this Policy and/or the User agreement.

  1. TERMS AND PROCEDURE FOR STORING PERSONAL DATA. Storage of personal data is carried out by the Data Controller themselves. Storage is carried out for the entire period necessary to achieve the stated purposes of processing personal data. The Data Controller undertakes to immediately destroy or depersonalize the data after the purposes of processing personal data have been achieved.

  2. ACCESS OF MINORS TO THE MOBILE APPLICATION. Users in the territory of the Russian Federation. The use of the Mobile Application is intended for persons over 18 years of age. If the User is a minor, they must immediately stop using this Mobile Application. Users in the territory of the European Union. The use of the Mobile Application is intended for persons aged 16 and over. If the Data Controller becomes aware that the User's age does not correspond to the permissible age for using the Mobile Application, the Data Controller undertakes to immediately block such User's access to the Mobile Application.

  3. PROCEDURE FOR PROTECTING PERSONAL DATA. Protecting the confidentiality of personal data is a top priority and important task for the Data Controller. The Data Controller adheres to all required international standards, rules, and recommendations for the protection of personal data. The Data Controller has implemented a number of technical and organizational methods aimed at protecting personal data from disclosure or unauthorized access by third parties.

  4. USERS LOCATED IN THE EUROPEAN UNION General Provisions Since the Mobile Application is available to users from the European Union, the Owner undertakes to additionally comply with the provisions of GDPR. The Controller, as understood in this Policy, is the Owner. The Owner stores Personal Data for a reasonable period of time necessary to achieve the processing purposes, but not less than the period established by the local legislation of the European Union member state where the Mobile Application is available for storing certain types of Personal Data. Upon expiration of the storage period, the Owner undertakes to immediately destroy or anonymize such data. Official Representative Since the Controller is located outside the European Union, the following person is appointed as its official representative for the protection of Users' Personal Data in the European Union: Kharlamova Yana Aleksandrovna, address: St. Petersburg, contact details: lev.dev.apps@gmail.com. Users' Rights in the Field of Personal Data Protection According to Chapter 3 of GDPR, Users located in the European Union have the following rights in the field of Personal Data protection: (1) the right to be informed about their Personal Data ("the right to be informed"); (2) the right to access their Personal Data ("the right of access"); (3) the right to rectify Personal Data ("the right to rectification"); (4) the right to erasure of Personal Data ("the right to erasure"); (5) the right to restrict the processing of Personal Data ("the right to restrict processing"); (6) the right to data portability ("the right to data portability"); (7) the right to object ("the right to object").

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