This Privacy and personal data processing policy (hereinafter referred to as the “Policy”) defines the procedure for processing and protecting personal data of Users that “Fless” limited liability company, OGRN 1197746139315, TIN / KPP 9725003319/772701001, address: 133, 7, Venevskaya str., Moscow, 117042 (hereinafter referred to as the “Administrator”) may receive while using the site with a network address https://fless.pro and its subdomains (hereinafter referred to as the “Site”).
Before using the Site, please read the terms of this Policy.
1. GENERAL PROVISIONS
1.1. By using the Site, You (the User) agree that:
You have read the terms of this Policy in full before using the Site;
the beginning of your use of the Site in any form means that You accept all the terms of this Policy in full without any exceptions and restrictions on Your part;
if You do not agree to the terms of this Policy, you should immediately stop any use of the Site;
1.2. By accepting the terms of this Policy, the User agrees to the processing of the User information by the Administrator for the purposes of this Policy, and to transferring of the User data to third parties in the cases listed in this Policy. Using the Site using a web browser that accepts data from cookies means that the User agrees that the Administrator can collect and process data from cookies for the purposes provided for in this Policy, as well as agrees to the data transfer from cookies to third parties in the cases listed in this Policy. Disabling and/or blocking the web browser option for accepting data from cookies by the User means that the Administrator is prohibited from collecting and processing data from cookies in accordance with the terms of this Policy.
1.3. As a general rule, the Administrator does not verify the accuracy of personal information provided by Users. However, in cases stipulated by the agreements on the use of sections of the Site, the User must provide confirmation of the authenticity of the personal information provided by them about themselves.
2. USER INFORMATION THAT THE ADMINISTRATOR RECEIVES AND PROCESSES
2.1. This Policy applies to the following types of personal information:
2.1.1. the personal information posted by Users, including information about themselves during registration, other personal information that the User provides to the Administrator through third-party websites or services, or personal information posted by Users during the use of the Site. The personal information obtained in this way includes the User’s first and last name, phone number, and email address. The information that is mandatory for using the Site or its individual functionality is marked in a special way. Other information is provided by the User at their discretion. It is prohibited for the User to provide personal data of third parties without permission from the third parties for such distribution, or unless such personal data of third parties were obtained by the User from publicly available sources of information;
2.1.2. the data automatically transmitted by the Site in the course of their use using software installed on the User’s device, including IP address, individual network number of the device (MAC address, device ID), electronic serial number (IMEI, MEID), Android advertising ID (Google AID), data from cookies, information about the browser, operating system, access time, search queries, information about the location and movement of the User’s device;
2.1.3. the data additionally provided by Users at the request of the Administrator in order to fulfill the Administrator’s obligations to Users in relation to the use of the Site; and
2.1.4. other information about Users, the collection and/or processing of which is established by the User agreement located at the network address https://fless.pro/legal/user-agreement-en and/or agreements for the provision of services using the Site.
3. PURPOSES OF COLLECTING AND PROCESSING USER INFORMATION
3.1. the Administrator collects and processes only the information about Users, including their personal data, that is necessary to fulfill the Administrator’s obligations to provide services on the Site.
3.2. the Administrator may use Users’ personal information for the following purposes:
3.2.1. identifying the party within the agreements between the User and the Administrator;
3.2.2. providing services to Users using the Site;
3.2.3. responding to User requests to the support service, informing Users about the Site’s capabilities, sending requests regarding the use of the Site;
3.2.4. performing marketing tasks (including marketing emails), conducting statistical and other research based on depersonalized data; and
3.2.5. implementing the relations for the provision of data from cookies to third parties by the Administrator for the implementation by third parties of activities to display targeted advertising and information materials to Users on the Internet and/or for the purpose of providing other services to Users by third parties in accordance with the procedure established by law.
3.3. if it is necessary to use the User’s personal information for purposes not provided for in this Policy, the Administrator requests the User’s consent to such actions.
3.4. when processing personal data of Users, the Administrator is guided by the Federal law “On personal data” dated 27.07.2006 No. 152-FZ (as amended).
4. REQUIREMENTS FOR THE PROTECTION OF PERSONAL INFORMATION
4.1. The Administrator stores personal information about the User and ensures its protection from unauthorized access and distribution in accordance with the internal rules and regulations.
4.2. Personal information about the User is kept confidential, except in cases when the technology of the Site or the services provided on its basis or the settings of the software used by the User provide for an open exchange of information with other Users of the Site or with any Internet users.
4.2. Personal information about Users is not transferred to third parties, except for the following cases:
4.2.1. the User has agreed to such actions;
4.2.2. the transfer is necessary in order to ensure the functioning of the Site, the implementation of partner and other programs of the Site.
4.2.3. the transfer is provided for by applicable law;
4.2.4. in order to ensure the possibility of protecting the rights and legitimate interests of the Administrator and/or third parties in cases where the User violates the terms of the Site use agreements;
4.2.5. if the Administrator participates in a merger, acquisition or any other form of sale of part or all of its assets. In this case all obligations to comply with the terms of this Policy will pass to the acquirer of the Administrator’s assets;
4.3. The User hereby acknowledges and agrees that the Administrator may receive personal information of third parties provided by the User during use, and use them to implement certain functions of the Site, under the condition that the User guarantees the existence of consent of third parties, the details of which are provided by the User when using the Site, for processing by the Administrator for the purposes specified in this Policy and for the transfer of such data in the cases listed in this Policy.
4.4. In addition, the User is hereby notified and agrees that the Administrator can receive statistical depersonalized (without linking to the User) data about the User’s actions when using the Site and about the settings set by the User.
4.5. The databases of information containing personal data of Users who are citizens of the Russian Federation are located on the territory of the Russian Federation.
5. USERS’ RIGHTS
5.1. Users have the right to:
5.1.1. independently make changes and additions to the information about themselves in their Personal account on the Site;
5.1.2. request the deletion of information about themselves by sending a request to firstname.lastname@example.org, provided as part of their Personal account on the Site. However, deleting the profile may make it impossible to use certain sections of the Site, including the User’s Personal account;
5.1.3. upon request, receive information regarding the processing of their personal data from the Administrator.
6. MEASURES TO PROTECT USER INFORMATION
6.1. The Administrator takes all necessary and sufficient organizational and technical measures to protect personal information about Users from unauthorized or accidental access to them, destruction, modification, blocking, dissemination of personal information, as well as from other illegal actions with it. These measures include, in particular, internal verification of data collection, storage and processing processes and security measures, including appropriate encryption and physical security measures to prevent unauthorized access to systems where personal information is stored.
7. FINAL PROVISIONS
7.1. This Policy, the relationship between the User and the Administrator arising in connection with the application of this Policy, as well as issues not regulated by this Policy, are governed by the current legislation of the Russian Federation.
7.2. Users have the right to send requests, suggestions or questions related to this Policy to the Administrator by e-mail: email@example.com.
7.3. The current version of this Policy is posted on the Administrator’s website and is available on the Internet at the following address: https://fless.pro/legal/privacy-policy-en.