Privacy Policy

Please review the document before using the application.

Definitions

"Law" means the legislation of any country, including all amendments and additions, as well as other legislative acts, including those of international law.

"Application" refers to the software (with all existing updates and improvements) designed to operate on smartphones, tablets, watches, and other devices, developed for a specific platform (iOS, Android, Windows Phone, etc.). For the purposes of this Policy, the application refers to any software developed by the developer.

"Personal Data" means a collection of personal and/or non-personalized information about the User, provided by the User to the Rights Holder and/or automatically collected by the Rights Holder and/or third parties.

"Policy" refers to this Privacy Policy of the application (including all existing updates and amendments).

"User" means any legal or natural person who has downloaded the application to a smartphone, tablet, watch, or any other device and/or activated the application on one of these devices.

"User Agreement" refers to the agreement between the Rights Holder and the User regarding the terms, rules, and specifics of the User's use of the application. The User joins this agreement and has no right to make or demand any changes or additions to it.

"Rights Holder" refers to the following entity, which holds the exclusive rights to the application: sole proprietor Mikhail Malyshev.

Relationships Governed by the Policy

General Provisions

This Policy is applicable exclusively to the Personal Data obtained from the User in connection with their use of the application. The provisions of this Policy are aimed at:

  • defining the types of Personal Data collected, their purposes and sources;
  • defining the User’s rights regarding the protection of their transmitted Personal Data;
  • identifying the parties responsible for processing and storing Personal Data, and third parties to whom such data is disclosed (in whole or in part).

The rules of this Policy do not apply to Personal Data processed by third parties voluntarily provided by the User.

By installing and/or activating the application on a smartphone, tablet, watch, or other device, the User agrees to the terms of this Policy and gives their consent to the Rights Holder to collect, process, retain, and store Personal Data in accordance with this Policy.

If the User disagrees with the Policy’s terms or does not understand them, the User must immediately stop using the application.

User Rights for Personal Data Protection

By providing Personal Data, the User automatically gains the following rights:

  • to access data concerning its processing (the grounds and purposes of such processing, the methods used, and information about those with access to it or to whom it may be disclosed under contract or law);
  • to receive data on the location and identification details of entities processing the Personal Data;
  • to receive information on the retention periods of the Personal Data;
  • to receive information on any cross-border transfer of Personal Data;
  • to challenge the Rights Holder’s actions or inaction with a competent authority or through legal proceedings;
  • to claim compensation for damages and/or moral harm caused by Rights Holder or third-party violations of the User's Personal Data protection rights;
  • to exercise other rights in the field of Personal Data protection as stipulated by law or this Policy.

List of Personal Data Collected

Non-Personalized Information About Users

In connection with the use of the application, the Rights Holder may automatically collect and process the following non-personalized information about the User:

  • information about traffic, the possible number of clicks made, logs, and other data;
  • information about the device (identification number, mobile network operator), operating system, platform, browser type, and other browser information, IP address.
Personal Data About Users

The Rights Holder does not collect any Personal Data about Users that would allow for their identification.

Purposes of Collecting and Processing Personal Data

Defining Processing Purposes

The collection and processing of Personal Data is carried out for the following purposes:

  • to analyze User behavior and preferences for certain types of content;
  • to ensure the correct and efficient operation of the application, improve its functionality and content, and enhance its internal architecture and features;
  • to identify the User;
  • to comply with legal requirements;
  • to provide technical support, identify, and resolve issues in the application;
  • to communicate with the User;
  • to fulfill other obligations of the Rights Holder towards the User;
  • for any other purposes, with the User's explicit consent.

Processing of Personal Data is based on principles of:

  • legality in processing methods and purposes;
  • good faith;
  • consistency of Personal Data processing with predefined and declared purposes;
  • proportionality of the volume and nature of processed Personal Data with the declared purposes of its processing.
Conditions for Processing Personal Data

Personal Data is processed in the following cases:

  • with the User's consent;
  • to achieve objectives prescribed by international treaties or law;
  • when the User provides their Personal Data to an unlimited group of people;
  • to fulfill other obligations of the Rights Holder to the User;
  • to protect the User’s life or health when consent cannot be obtained in advance.

In case of anonymization, where Personal Data no longer directly or indirectly identifies the User, further use and disclosure of such data to third parties is allowed, and the rules of this Policy no longer apply.

The Rights Holder takes all possible measures to protect the confidentiality of collected Personal Data, except when the User has made such data publicly available.

Personal Data is processed with or without automated means.

Third-Party Access to Personal Data

Use of Analytical Platforms

The Rights Holder uses analytical platforms for:

  • tracking website traffic frequency;
  • monitoring how the User uses the application and/or its content;
  • identifying popular content among Users;
  • determining the User’s location.

The User also consents to the Rights Holder’s use of information collected from analytical platforms.

For these purposes, analytical platforms may collect information on the IP address, geolocation, behavior, and content preferences of the User.

Analytical platforms gain access to Personal Data to provide the Rights Holder with insights on the effectiveness of the application, popular content, ad placement, and to develop or enhance the marketing strategy.

By installing the application, the User agrees to this Privacy Policy and the automatic installation of the corresponding analytics tools.

Disclosure of Personal Data to Third Parties

The Rights Holder has the right to disclose Personal Data to:

  • affiliates, branches, and representative offices located both within and outside the Rights Holder’s country of operation;
  • successors resulting from the Rights Holder’s liquidation, reorganization, or bankruptcy;
  • third parties solely for the purpose of providing the User with specific content or access to it;
  • third parties where the User has consented to such disclosure or as explicitly provided for by law or this Policy.

The Rights Holder discloses Personal Data only when:

  • they are confident third parties will comply with this Policy and adopt equivalent privacy protection measures;
  • the User’s consent or legal permission has been obtained.

Advertising

Advertising in the Application

The Rights Holder reserves the right to place advertisements in their application without the User's consent or notification.

Submitting Complaints and Requests to the Rights Holder

Request to Stop Processing Personal Data

Each User has the right to express an objection to the Rights Holder regarding the processing and/or storage of their Personal Data. Such an objection may be expressed by:

  • sending a request to the email address [email protected];
  • via public profiles on the Rights Holder’s social networks.
Request for Information About Personal Data

If the User has any questions regarding the application or enforcement of this Policy, or the method of processing Personal Data, the User may contact the Rights Holder by:

  • sending a request to the email address [email protected];
  • via public profiles on the Rights Holder’s social networks.
Changes or Deletion of Personal Data

The User has the right at any time to change or delete Personal Data by sending a special request to the Rights Holder via the following email address: [email protected].

The Rights Holder may refuse to modify or delete Personal Data if such actions would:

  • violate this Policy;
  • violate the law;
  • constitute evidence in any legal proceedings between the Rights Holder and the User.

Personal Data Retention Period

Data is stored by the Rights Holder for the entire duration of the User’s use of the application.

The Rights Holder undertakes to destroy or anonymize the User's Personal Data immediately upon termination of application use.

Minors' Access to the Application

This right is regulated by the age restrictions of the app store.

Personal Data Protection Measures

The Rights Holder adheres to all required international standards, rules, and recommendations on Personal Data protection.

The Rights Holder has implemented several technical and organizational methods to protect Personal Data from disclosure or unauthorized access by third parties.

Final Provisions

Availability of the Policy Text

Users can review the terms of this Policy in this document.

This edition of the Policy is effective from "01" September 2024.

Amendments to the Policy

This Policy may be amended from time to time. The Rights Holder is not responsible for changing the terms of this Policy without the User’s permission or consent.

Users are obligated to regularly check this Policy for any updates or amendments.

Governing Law

This Policy is drafted in accordance with current international law.

Risk of Disclosure

Despite the Rights Holder's measures to protect the confidentiality of collected Personal Data, Users are hereby informed that any transfer of Personal Data over the Internet cannot be guaranteed as completely secure, and therefore the User transfers such data at their own risk.