Placement date: 31.10.2022
PRIVACY POLICY
- This Privacy Policy (the Policy) shall apply to all information published on the Website located at https://my.appbooster.com (the Website), which self-employed Limited Liability Company Dzhusisoft (the Website Administration) can receive from the Website visitors (the Users) during their use of the Website, its services, programs, and products.
- Use of the Website services shall mean the User's unconditional agreement to this Privacy Policy and its provisions regarding processing of personal data. If the User does not agree to this Privacy Policy, they should not use the Website services.
01.GENERAL PROVISIONS
- 1.1. For the purposes of this Policy, personal data shall mean the following:
- 1.1.1. Personal information the User provides when signing up (creating a profile) or using the Services. Such information includes the User's email, full name, phone number, occupation and title; bank card number, CVC code, and expiry date; username and password they use to access the Website. Other information is provided—or not provided—by the User at their own discretion.
- 1.1.2. Information automatically passed to the Website services through software installed on the User's device. Such information includes the IP address, cookies, browser info (or information about another software through which the User accesses the services), equipment and software specifications, date and time of access to the services, URLs of requested pages, location; operating system type and version; browser type and version; device type and screen resolution; where the User came from (a website or ad); operating system language; browser language; which pages the User opens and which buttons the User clicks; other related information.
- 1.1.3. Other User information, processing of which is prescribed by the User Agreement.
- 1.2. This Privacy shall only apply to the Website https://my.appbooster.com. The Website https://my.appbooster.com shall not control or be responsible for third-party websites the User can visit by following the links available on the Website https://my.appbooster.com.
- 1.3. By clicking the "OK" button in the electronic notice on the use of cookie files and continuing to use the Website, the User agrees to processing of personal data specified in Clause 1.1.2 of the Privacy Policy. The User has the right not to consent to the processing of the said personal data. In this case, they should either leave the Website or disable cookies on the Website in settings.
- 1.4. Personal data specified in Clause 1.1.1 of the Privacy Policy can be provided either on paper or by filling out the corresponding electronic form on the Website, or with the use of other means of electronic communication.
- 1.5. The Website Administration does not store such personal data as the bank card number, CVC code, and expiry date but discloses them to third parties for payments.
02.PURPOSES OF PERSONAL DATA PROCESSING
- 2.1. The Website Administration shall only collect and store personal data it needs to provide the services and fulfill agreements with the User, unless the law prescribes mandatory storage of personal data for the specific period as set by the law.
- 2.2. The Website Administration shall process the User's personal data for the following purposes:
- 2.2.1. Creating the profile of, and identifying, the User who has signed up on the Website; creating the User's account; granting the User access to the Website services.
- 2.2.2. Granting the User access to the personalized resources of the Website.
- 2.2.3. Allowing the User to make payments (as well as wire transfers) on the Website.
- 2.2.4. Establishing communication with the User, including sending notifications and requests related to the use of the Website, rendering of services, processing of the User's requests.
- 2.2.5. Providing the necessary information related to the activity of the Website or the Website Administration. Sending notifications, requests, or information related to the use of the Website, availability of new functions, Website updates, and function setting recommendations. The Website Administration has the right to use the email specified by the User to communicate with the User.
- 2.2.6. Identifying the User's location to ensure security and prevent fraud.
- 2.2.7. Verifying the accuracy and completeness of personal data provided by the User.
- 2.2.8. Informing the User of the changes made, if necessary, to this Policy and/or the User Agreement.
- 2.2.9. Providing the User with efficient customer and technical support in case of problems related to the use of the Website.
- 2.2.10. Analyzing the User's activity on the Website; analyzing the Website operation.
- 2.2.11. Carrying out, upon the User's consent, advertising activities and sending newsletters.
- 2.2.12. Carrying out statistical and other studies based on anonymized data to investigate satisfaction with the Website and its functionality. Such data are used to improve the Website quality and carry out studies of any categories.
- 2.2.13. Protecting confidentiality of Personal data, maintaining Website performance and security, verifying the User's activity, preventing fraud, cyber attacks, and other abuse, investigating such cases.
03.TERMS AND CONDITIONS OF PERSONAL DATA PROCESSING AND DISCLOSURE THEREOF TO THIRD PARTIES
- 3.1. The Website Administration shall store personal data of the Users in compliance with the internal regulations of specific services.
- 3.2. Personal data of the User shall remain confidential, unless the User voluntarily discloses their personal information to the general public.
- 3.3. The Website Administration has the right to disclose personal data of the User to third parties in the following cases:
- 3.3.1. The User has consented to such disclosure.
- 3.3.2. Such disclosure is required to grant the User access to a specific service, fulfill a specific agreement with the User, or to enable a payment.
- 3.3.3. Such disclosure is prescribed by Russian law and other applicable legislation, and should be performed in the manner prescribed by law.
- 3.4. In case of the sale of the Website, the purchaser shall assume all the obligations to observe this Policy in regard to personal data they receive after such a sale.
- 3.5. Processing of the User's personal data shall be carried out without any time limitation, in any lawful way. Such processing may be performed in the data systems with our without the use of automation technology. Personal data of the Users shall be processed in compliance with Federal Law of Russia No. 152-FZ dated July 27, 2006, "On personal data."
- 3.6. If personal data are lost or disclosed, the Website Administration shall inform the User of such loss or disclosure.
- 3.7. The Website Administration shall take the necessary organizational and technical measures to protect the User's personal data from unauthorized or accidental access, destruction, change, blocking, copying, distribution, or other unlawful activity of third parties.
- 3.8. The Website Administration, in cooperation with the User, shall take all the necessary measures to prevent loss or other negative repercussions entailed by loss or disclosure of the User's personal data.
04.OBLIGATIONS OF THE PARTIES
- 4.1. The User is obliged to:
- 4.1.1. Provide accurate personal data necessary for the use of the Website. The Website Administration shall not verify the accuracy of personal data the User provides.
- 4.1.2. Update and supplement personal data in case of any change thereof.
- 4.2. The Website Administration is obliged to:
- 4.2.1. Use the received personal data only for the purposes specified in this Privacy Policy.
- 4.2.2. Ensure confidential storage of sensitive data; not, without prior written permission of the User, sell, exchange, publish, or otherwise disclose personal data provided by the User, except for the cases prescribed by this Privacy Policy.
- 4.2.3. Take the relevant precautionary measures to protect confidentiality of the User's personal data following the common business practices in the field of protecting such data.
- 4.2.4. In case of identifying inaccurate personal data or unlawful use thereof, block personal data related to a respective User, after receiving a claim from such a User, their authorized representative, or personal data protection authority.
05.RIGHTS OF THE USER
- 5.1. The User has the right to receive information regarding processing of their personal data, which includes the following:
- 5.1.1. Confirming processing of the User's personal data by the Website
- 5.1.2. Legal grounds and purposes for processing personal data
- 5.1.3. Methods of personal data processing
- 5.1.4. Name and location of the Website Administration, information about the persons that have access to personal data or which may be granted access to personal data under an appropriate agreement or per an applicable federal law.
- 5.1.5. Personal data of a specific User, which are subject to processing.
- 5.1.6. Time frames for processing and storing personal data.
- 5.1.7. Full name (legal name) and address of the party processing personal data on behalf of the Website Administration, if processing is or will be assigned to such a party.
- 5.1.8. Other information prescribed by applicable federal laws.
- 5.2. The User has the right to request the Website Administration to update their personal data, or block or destruct them if such personal data are out of date, inaccurate, unlawfully obtained. The User also has the right to request the Website Administration to take the necessary measures to protect the User's rights.
06.CESSATION OF PERSONAL DATA PROCESSING
- 6.1. The Website Administration shall cease to process personal data in the following cases:
- 6.1.1. Occurrence of the conditions of cessation of personal data processing or end of the processing period.
- 6.1.2. Fulfillment of the purposes of personal data processing or no further need to fulfill such purposes.
- 6.1.3. Upon the User's request, if personal data processed are incomplete, out of date, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing.
- 6.1.4. Withdrawal by the User of their consent to personal data processing or expiry of such consent. This condition only applies if the User's personal data are only processed on the basis of the User's consent.
- 6.1.5. Cessation of the Website Administration's activity.
- 6.2. The User has the right to withdraw their consent to personal data processing by sending a written application to self-employed Limited Liability Company Dzhusisoft by (to 265A Novo-Sadovaya Street, Samara, Russia) or to [email protected]. In case of the consent withdrawal, the Website Administration shall cease to process the User's personal data within 30 calendar days after receiving such a withdrawal.
07.PERSONAL DATA PRIVACY MEASURES
- 7.1. Both personal data provided on paper and personal data provided on electronic media shall be subject to protection.
- 7.2. For the purposes of personal data protection, the Website Administration shall take the measures prescribed by Federal Law of Russia No. 152-FZ dated July 27, 2006, "On personal data", other personal data protection regulatory acts, and this Privacy Policy.
- 7.3. The Website Administration shall take the following measures to fulfill the obligations prescribed by Federal Law of Russia No. 152-FZ dated July 27, 2006, "On personal data":
- 7.3.1. A person responsible for observing the personal data legislation has been assigned.
- 7.3.2. Local regulatory acts pertaining to processing and ensuring confidentiality of personal data, including this Privacy Policy, have been issued.
- 7.3.3. Organizational and technical measures are taken to ensure the integrity of personal data during processing thereof in data systems. These measures are necessary for fulfilling the personal data protection obligations, fulfillment of which ensures achievement of the personal data protection levels set forth by the Government of the Russian Federation.
- 7.3.4. The employees have been familiarized against signature with this Policy, other local regulations pertaining to personal data protection, and requirements stipulated in the personal data legislation.
- 7.3.5. Internal control in the field of personal data protection is being exercised.
- 7.3.6. The Privacy Policy has been published on the Website, available to the general public.
- 7.4. The following are the measures to ensure the integrity and security of personal data during processing thereof:
- 7.4.1. Threats to the integrity and security of personal data during processing thereof in the data system have been identified.
- 7.4.2. Measures have been taken to store personal data in a way making impossible any unauthorized access thereto.
- 7.4.3. Written undertakings have been received from the employees on (1) observing confidentiality of personal data disclosed to them for the purposes of their respective duties and (2) observing the rules of personal data processing.
- 7.4.4. The observance of the Privacy Policy by the employees is being supervised.
- 7.4.5. The list of persons authorized to access the premises where personal data are stored has been approved.
- 7.4.6. Personal data can only be accessed by the employees which need such personal data to perform their respective duties. An employee's access to personal data is granted by order of the sole executive body.
- 7.5. The employees having access to personal data for the purposes of their respective duties are obliged to:
- 7.5.1. Make it impossible for any unauthorized persons to access personal data.
- 7.5.2. Prevent any situations where, while the authorized employee is absent, personal data—including login credentials—stored at their work station or in their personal computer become available to third parties.
- 7.6. In the event when an employee having access to personal data is dismissed, the documents and other media containing personal data shall be handed over to another employee by order of the sole executive body.
- 7.7. The documents and other media containing personal data shall be kept in locked cabinets or safes preventing any unauthorized access. A cabinet or safe shall be only accessible to the employees having access to personal data by order of the sole executive body.
- 7.8. At the end of the business day, all paper media containing personal data shall be placed into cabinets or safes preventing any unauthorized access to such personal data.
- 7.9. Access to the electronic media containing personal data is protected as follows:
- 7.9.1. Ensuring accessibility of the premises where electronic media with personal data are kept in a way that prevents any unauthorized access thereto.
- 7.9.2. Using licensed antivirus software preventing any unauthorized access to personal data.
- 7.9.3. Assigning access to the files containing personal data by means of a special account only available to the employees authorized to use personal data.
- 7.9.4. Setting passwords on desktops.
- 7.10. Personal data are stored in a way that allows to identify a specific User no longer than required by the respective purposes of personal data processing, unless the storage period is prescribed by a federal law or agreement to which the User is a party or beneficiary. Processed personal data are subject to destruction in case the purposes of personal data processing have been fulfilled or there is no more need to fulfill such purposes, unless otherwise prescribed by applicable law.
08.LIABILITIES OF THE PARTIES
- 8.1. If the Website Administration has failed to perform its obligations, it should be held liable, in accordance with applicable Russian law, for any losses incurred by the User due to unauthorized use of their personal data.
- 8.2. In case of loss or disclosure of confidential information, the Website Administration shall not be held liable if such confidential information:
- 8.2.1. Had become available to the general public before such loss or disclosure.
- 8.2.2. Had been received from a third party before it has been received by the Website Administration.
- 8.2.3. Had been disclosed upon the User's consent.
09.DISPUTE RESOLUTION
- 9.1. A claim, which is a written proposal to resolve a dispute, shall be submitted before applying to court on any dispute arising from the relations between the User and the Website Administration.
- 9.2. The claimee shall, within 10 (ten) calendar days from the receipt of the claim, make the claimant aware of the claim consideration results.
- 9.3. If no agreement is reached, the dispute shall be submitted to the court as prescribed by applicable Russian law.
- 9.4. This Privacy Policy, as well as the relations between the User and the Website Administration, are subject to applicable Russian law.
10.ADDITIONAL TERMS AND CONDITIONS
- 10.1. The Website Administration has the right to update this Privacy Policy without the User's consent.
- 10.2. The updated Privacy Policy shall come into effect when published on the Website, unless otherwise prescribed by the new edition of the Privacy Policy.
- 10.3. All suggestions and questions related to this Privacy Policy shall be sent to [email protected].
- 10.4. The User, or their authorized representative, has the right to send the Website Administration their requests, including those related to personal data processing, or withdraw their consent to personal data processing:
- 10.4.1. In writing, sending the letter to the following address: 3rd Floor, 265A Novo-Sadovaya Street, Samara, Samara Oblast, Russia 443011.
- 10.4.2. As en electronic document sent to [email protected].
- 10.5. A request shall contain the following information:
- 10.5.1. Details of the User's identity document.
- 10.5.2. Details confirming the User's relations with the Website Administration (e.g., phone number and email the User has specified when signing up on the Website).
- 10.5.3. Details of the User's representative and verification of their authority (if the request is sent by the User's representative).
- 10.5.4. The User's (the User representative's) signature.
- 10.6. The Website Administration undertakes to review and respond to the request within 30 (thirty) calendar days from receipt of such a request.
- 10.7. All the electronic messages and written letters received by the Website Administration shall be considered confidential information and may not be disclosed without the User's written consent.