Effective since September 7, 2020
Kristina А. Kushner acting as a private entrepreneur (”Company”, ”we”, ”us”, ”our”) is the controller of your Personal information.
PURPOSE AND WHO WE ARE
”Personal information” means information that can be used in order to identify you (it may also be called ”personal data” or ”Personal information”). Personal information may include such information as your name, email address, IP address, device ID, and other data. You are responsible for ensuring the accuracy of the Personal information that you provide to the Company. Inaccurate information may affect your ability to use the Website or your ability to receive our Services, as well as our ability to contact you. For example, your email address must be correct because this is one of the main ways for us to communicate with you.
WHAT YOU AGREE TO BY USING OUR WEBSITE
- our use of your Personal information is necessary to fulfill our obligations under any agreement with you (for example, to comply with the conditions of use of our Website that you accept when browsing our Website, and/or to fulfill our contract for the provision of Services for you); or
- our use of your Personal information is necessary to comply with our legal obligations; or
- use of your Personal information is necessary for our legitimate interests or the legitimate interests of others. Our legitimate interests are:
- to manage our business as well as develop it;
- to manage our Website and provide our Services;
- to select the appropriate, experienced and qualified partners;
- to build relationships with partners;
- to conduct research and statistical analysis;
- to perform marketing and business development; and
- internal administrative and audit objectives.
- use of your Personal information is necessary in order to send you certain messages or to receive certain information from you.
What legal framework applies to a particular processing activity will depend on the type of Personal information being processed and the context in which it is processed.
If we rely on our legitimate interests (or such of other persons) regarding the use of your Personal information, we will take a balance to ensure that our legitimate interests (or such of other persons) are not outweighed by your interests or fundamental rights and freedoms that require the protection of Personal information.
In some cases, we may process your Personal information for marketing purposes based on your consent (which you can withdraw at any time, as described below).
If we rely on your consent for us to use your Personal Information in a particular way, but later change your mind, you can withdraw your consent by visiting your profile page on the website of our partner and clicking the box to remove consent or deleting your account, and we will stop using your Personal Information. You can also revoke your consent by emailing us аt firstname.lastname@example.org. However, if you withdraw your consent, this may affect your ability to use our Website and/or our ability to provide you with our Services.
WHAT PERSONAL INFORMATION WE COLLECT
We collect two types of Personal information about users through the Website:
- Personal information provided directly by you or through third parties. We collect Personal Information that you provide to us when you fill out an application on our Website or register an account on the website of our partner, update or change information for your account, purchase our paid Services, subscribe to email updates, send us email messages and/or receive any other Services on our Website. We may use your Personal Information to answer your questions, provide you with feedback or suggestions, provide the Services, and send you e-mail messages about maintenance or updates to the Website.
- Account registration. If you register an account on the website our Partner, you may be required to provide us with Personal Information such as your name and the email address you provided upon registration.
- Updates. The company may offer you the opportunity to receive updates either by e-mail or by posting in those sections of the Website that are available only to registered users. In order to be able to do so, you may need to provide us with Personal information, such as your name and email address.
- Identity authentication. The Company may offer you the opportunity to verify your identity in order to receive certain Services. In order to start receiving such Services, you may need to provide us or our third-party identity verification provider with Personal information such as but not limited to your name, address, date of birth, photo of a person taken with a webcam, and an identity document with your photo.
- Communication with the Company. We may receive Personal information when you email us or contact us in any other way.
- Third-party websites. We may receive Personal information when you visit our Website or visit third party websites, for example, Facebook, Google, Bing. Such information may include text and/or image containing your Personal information available on a third-party site.
- Affiliate sites. Partner sites providing functions related to the Company users receiving Services may collect non-financial Personal information regarding the use of such an affiliate site. Partner sites may share such Personal information with the Company in order to improve the quality of the Services provided by the Company and the partner. This information includes Personal information such as the amount of time spent on the affiliate site and information about the pages viewed.
- Credit card processing by third parties. The Company gives you the opportunity to pay for the Services with a credit card through a third-party payment processing service provider. Be aware that it is our service provider, not the Company, that collects and processes information about your credit card.
HOW WE USE THE INFORMATION
- Information regarding your use of our Website. We use information relating to your use of the Website to improve the operation of the Website and create better Services by conducting statistical analysis of the collective characteristics and behavior of our users, as well as by measuring demographics and interests on specific pages of our Website. We may also use this information to ensure the security of our Website.
- Use of the Website and our Services. We use the Personal information that you provide to us so that you can access and use the Website, as well as to provide any information about the Content and Services that you request from us.
- Technical support and security. We may use Personal information to provide you with technical support, where necessary, and to ensure the security of our Website.
- Updates. We use the Personal information collected during completing an application on our Website or registration on the website of our partner to send you emails in connection with updates to the Website or Services. We may also archive this information and/or use it for further communication with you if we have the legal right to do so. Identity authentication. To provide Services that require an identity check, we may use the Personal information we collect to verify your identity.
- Identity verification may be conducted by a third-party identity verification service provider. Your identity document will be deleted after successfully verifying your information.
- Communication with partners of the Company. We may transfer your Personal information to the partners of the Company so that they can share information about their products and services that may be of interest to you if they have a legal right to do so.
- Research. We may use the information about your activities on our Website in order to use it for research related to the use of the Website and the receipt of our Services.
- Disclosure of information to the Company’s operation and maintenance contractors. We use a variety of service providers, suppliers, and contractors (collectively referred to as ”Contractors”) to help us provide our Services to you. Our Contractors may have limited access to your Personal information when providing us with our products or services, so that we, in turn, can provide you with our Services. These Contractors may include suppliers who provide us with technology, services, and/or content related to the operation and maintenance of the Website. The access of these contractors to your Personal information is limited to the information reasonably necessary for the Contractor to perform its limited functions for us.
- Disclosure for purchasers. The Company may disclose and/or transfer your Personal information to the acquirer, assignee, or other legal successors in connection with the sale, merge or reorganization of all or part of the business or assets of the Company to which your Personal information relates.
STORAGE OF PERSONAL INFORMATION
We do not store your Personal information for longer than necessary for the purposes for which Personal information is collected and processed. The time during which we store your Personal information depends on the purposes for which we collect and use it, and/or on how long it is required to store it in order to comply with applicable laws, as well as to establish, exercise or protect our legal rights.
CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION
UPDATING OR DELETING OF YOUR PERSONAL INFORMATION
You have certain rights with respect to your Personal information. You can access your Personal information and confirm that it remains true and up to date, choose whether you want to receive materials from us or our partners, and require that we delete or provide you with a copy of your Personal information by going to the site and visiting your account page on the website of our partner. If you need additional information about your rights or want to exercise any of your rights, you can also contact us by e-mail at email@example.com. If you reside or are located in the United States or the EEA, you have the right to demand that we:
- provide access to any Personal information about you that we store;
- stop processing your Personal information for direct marketing purposes;
- update any Personal information that is outdated or incorrect;
- delete any Personal information we hold about you;
- limit ways of processing your Personal information;
- provide your Personal information to a third-party service provider, or
- provide you with a copy of any Personal information we hold about you.
We try to respond to each email as soon as possible and provide our answer within the time period established by applicable law. Keep in mind that in our databases, access logs, and other entries there will be residual information that may or may not contain your Personal information. Also, please, be aware that certain Personal information may be exempted from such requests in certain circumstances, which may include the need to continue processing your Personal information to fulfill a legal obligation. When you email us a request, we may ask you to provide us with the information necessary to confirm your identity.
QUESTIONS, SUGGESTIONS, AND COMPLAINTS
If you have any questions, suggestions, unresolved problems, or complaints related to confidentiality, you can contact us by e-mail at firstname.lastname@example.org. If you reside or are located in the United States or the EEA, our data protection officer and privacy department can help with all questions regarding the processing of an identifiable identity by email email@example.com. If you live or are residing in the EEA, you can also file a complaint with our data protection supervisor (namely, the Federal Service for Supervision of Communications, Information Technology, and Mass Media) or seek help from local courts if you think your rights have been violated.
CALIFORNIA PRIVACY RIGHTS
SHINE THE LIGHT
According to the Californian ”Shine the Light” law California residents who provide Personal information when they receive products or services for personal, family, or home use have the right to request and once a calendar year receive from us information about the partners with whom we shared Personal information, if any, for their own direct marketing. If applicable, this information will include various categories of information about partners, as well as the names and addresses of those partners with whom we directly shared customer information for the previous calendar year (for example, requests made in 2020 will receive information regarding exchange activities 2019).
In order to receive this information, email us at firstname.lastname@example.org with the text ”California Privacy Information Request” in the subject line and in the text of your message. In response to that, we will provide you with the requested information to your email address. Be aware that not all information exchange is subject to the requirements of the Shine the Light law, and only information on a hidden information exchange will be included in our response.
CALIFORNIA CONSUMER PRIVACY ACT
Under the California Consumer Privacy Act (”CCPA”), California residents have the right to know what Personal information about them is collected, request the deletion of their personal data, refuse to sell their personal data and not be discriminated against if they decide to use any of these rights. The Company does not sell any data that we collect about you. If you want to exercise any other rights granted to you, please contact us by e-mail at email@example.com.
COLLECTION OF PERSONAL INFORMATION AND ITS PURPOSE
We collect and use California Personal information for the purposes described below, including:
- manage and develop our business;
- manage our Website and provide our Services;
- select the appropriate experienced and qualified partners;
- build relationships with partners;
- conduct research and statistical analysis;
- perform marketing and business development; and
- for internal administrative and audit purposes.
We may share Personal information with service providers, as defined in the CCPA, so that they can provide the services specified in a written contract, or with others for purposes permitted by the CCPA, such as responding to a law enforcement request.
We may share Personal information with partners and service providers to verify interactions and transactions.
We may transfer Personal information to our partners and service providers in order to improve our Website and Services, for example, to identify errors, correct errors, or ensure that the services function in accordance with our intentions, as well as to conduct internal research and analysis to improve our technologies.
CATEGORIES OF PERSONAL INFORMATION
Personal information is described in California Civil Code § 1798.80 (e) (e.g. name, address, phone number, education, employment history, credit or debit card number) Identifiers (e.g., real name, alias, mailing address, unique personal identifier, network identifier, Internet protocol address, email address, account name on our partner’s website, or other similar identifiers)
Specifications of protected classes according to California or Federal Law (such as your gender or age) (”Specifications of protected classes”)
Information that you provide to us directly
Commercial information (e.g. information about goods or services purchased, received, or reviewed)
Information that you provide to us directly, for example, when purchasing a subscription. Your interaction with our Website and Services. Information from our partners and service providers.
Information about activity on the Internet (for example, your browsing history, search history and information about your interactions with our Website)
Your interaction with our Website
Information that you provide to us directly or through your interaction with our Website
Professional or employment information
Information that you provide to us directly. Information from our partners, service providers, or your employer.
Information that you provide to us directly or through your interaction with our Website. Information from our partners and service providers.
Audio, electronic, visual or similar information
Information that you provide directly or through your interaction with our Website.
CALIFORNIA CITIZENS' PRIVACY RIGHTS
California’s residents have the right to request access to or deletion of their Personal information and cannot be discriminated against because they exercise any of their rights under the CCPA in violation of the California Civil Code § 1798.125. They can send requests as follows: (1) use our self-service tools for access and deletion, available on the Website, or (2) send an email firstname.lastname@example.org with the details of a specific request. California’s residents also have the right to refuse to sell their Personal information, but the Company does not provide this option since we do not sell your Personal information. The Company will not collect new categories of Personal information or use the previously collected Personal information for substantially different purposes without your prior notice.
GLOBAL PRIVACY PRACTICES
The Company’s website is mainly maintained and operated on servers located and operated in the Russian Federation, USA, and EEA. In order to provide you with our Services, we may send and store your Personal information outside the country in which you reside or are located, including the Russian Federation. Accordingly, if you reside or are located within the United States or EEA, your Personal information may be transferred outside the United States or EEA, including to the Russian Federation or other countries that may or may not provide the same level of protection for your Personal information. We are committed to protecting the confidentiality of Personal information when transmitting it. If you reside or are located in the United States or the EEA, and such transfers occur, we take appropriate steps to provide the same level of protection for processing carried out in any such countries as you would have in the United States or EEA, as far as possible in accordance with the applicable legislation. We participate and are committed to adhering to the privacy protection mechanism adopted in the USA and the EEA when transferring data from the EEA and from the USA.
BAN ON THE PROCESSING OF PERSONAL INFORMATION BELONGING TO CHILDREN UNDER 13 YEARS
The Company strongly believes in protecting children’s privacy. Any access to the Website or use of the Services by anyone under the age of 13 is prohibited, and in some regions, there may be additional requirements and/or restrictions. In accordance with this belief, we do not collect or store Personal information from persons under 13 years of age, and no part of our Website and our Services is intended for persons under 13 years of age. If you are under the age of 13, please do not use or access this Website. We will take appropriate steps to delete any Personal information of persons under the age of 13 that was collected on our Website without the confirmed consent of the parents when receiving information about the existence of such Personal information.