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PRIVACY POLICY

05-07-2021

 

1. GENERAL PROVISIONS

This privacy policy (the “Policy”) sets out the basic rules for the processing of Personal Data by Privyet Limited Liability Company (Main State Registration Number (OGRN) 1217700070103, Taxpayer Identification Number (INN) 7734440625, address: 123308, Moscow, an external territory of city Khoroshevo-Mnevniki municipal district, ul. Mnyovniki 6, Unit IV, Office 5) (“privyet”) when you use the Service provided by privyet in accordance with the Terms of Service (the “Terms”). The purpose of this Policy is to inform you about how we process your Personal Data and protect the data of individuals who use the services provided by privyet. Privyet acts as a Personal Data operator for any processing of Personal Data described in this Policy.

Relationships related to the collection, storage, distribution, and protection of the data of individuals who use the Services provided by privyet are regulated by this Policy, other official documents drawn up by privyet and applicable laws of the Russian Federation, including Federal Law No. 152-FZ On Personal Data dated July 27, 2006 (the “Law On Personal Data”), Federal Law No. 149-FZ On Information, Information Technology and Data Protection dated July 27, 2006 (the “Law On Information”).

The purpose of this Policy is to ensure that information about individuals, including their Personal Data are duly protected from unauthorized access and disclosure, as well as to inform about the methods used for Personal Data processing.

This Policy has been developed and is applied in accordance with privyet Terms, among others, posted on the website. In case of inconsistencies between this Policy and other official documents drawn up by privyet, this Policy shall prevail. The terms used in this Policy (e. g. User, Website, Content) have the meaning that is set out in the Terms unless otherwise specified.

This Policy is a public document and is available on the Website.

privyet is entitled to make changes to this Policy. privyet will notify any changes made to the Policy by posting the Policy as amended on privyet Website within 15 (calendar) days of the entry into force of the relevant changes. The previous versions of the Policy can be requested by using support@privyet.ru.

By registering and/or using privyet Website, you agree with the terms of this Policy. If you do not want your Personal Data to be processed by privyet, you will not be able to use the Service provided by privyet. If you do not agree with the terms of this Policy, you should stop using the Website and its Services immediately.

Personal Data means any information relating directly or indirectly to a specific or identifiable individual or data subject (“Personal Data”).

Data subjects under this Policy refer to Website Users and Creators.

 

2. WHY DOES PRIVYET USE YOUR PERSONAL DATA OR INFORMATION ABOUT YOU?

privyet processes (collects, records, classifies, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, destroys Personal Data) information about individuals who use the Services provided by privyet, including their Personal Data to:

  • Provide Website Users with technical and other opportunities to place offers, request and provide short, personalized or non-personalized text, audio and video messages from well-known actors, musicians, athletes, influencers, experts, public figures and other well-known personalities registered on privyet.ru Website as well as offer to Creators the Service’s opportunity for different potential interaction.

 

3. WHAT PERSONAL DATA DO WE PROCESS?

Personal Data of Users

privyet processes the following Personal Data of Users:

  • Data necessary for the User to request Content on the Website: (а) name; (b) email address and/or (c) mobile phone number; (d) payment details (bank card/account, e-wallet details); (e) description and instructions as requested by the User; (f) social media accounts that the User chooses to share (optional).

privyet is entitled to request from Users a copy of an identity document or other document with their name, surname, and photo, as well as other additional information which at privyet’s discretion is necessary and sufficient to identify a particular User and allows excluding any abuse and violation of third parties’ rights.

Personal Data of Creators

privyet processes the following Personal Data of Creators:

  • Data necessary to fulfill the obligations to Users (а) name; (b) email address; (c) mobile phone number; (d) details of company (legal entity) to make payments; (d) city of residence; (f) country; (g) personal description; (h) Creator category; (i) agent (representative) number (if applicable); (j) agent (representative) email address (if applicable); (k) social media account details (link).

privyet is also entitled to request a copy of an identify document or other document with the name, surname, and photo of the Creator or agent (representative) (if applicable), as well as other additional information which at privyet’s discretion is necessary and sufficient to identify a particular Creator allows excluding any abuse and violation of third parties’ rights.

Other information about Data Subjects processed by privyet

  • Data received when accessing privyet website, including data on technical means (devices), technological interaction with the Website (including host IP address, type of user’s operating system, type of browser, geographic location, internet service provider);
  • Information automatically obtained when accessing the Website using bookmarks (cookies).

 

4. BASED ON WHAT PRINCIPLES DOES PRIVYET PROCESS PERSONAL DATA?

  • Validity of the purposes and methods for Personal Data processing;
  • Good faith;
  • Compliance of Personal Data processing purposes with the purposes determined and declared when collecting Personal Data as well as with the powers and authority of privyet Website;
  • Compliance of the scope and nature of processed Personal Data, Personal Data processing methods with Personal Data processing purposes;
  • Combining Personal Data databases created for purposes that are not compatible with each other is not permitted.

 

5. CONDITIONS AND PURPOSES FOR PERSONAL DATA PROCESSING

privyet Website processes Personal Data for the purposes specified in section 2 of this Policy. Requesting access to the Website Services (as well as creating an account on the Website), performing other actions aimed at using the Services means consenting to the processing of Personal Data.

 

6. COLLECTION OF PERSONAL DATA

Personal Data are collected on privyet Website upon request of Content or access to the Service as well as later when Data subjects make changes and/or provide additional information about themselves.

  • User’s Personal Data namely, name, email address and/or mobile phone number, payment details (bank card/account, e-wallet details details), description and instruction as requested by the User, social media accounts that the User chooses to share are the minimum required to use the Services offered by privyet
  • Creator’s Personal Data (namely, name, email address and/or mobile phone number, details of company (legal entity) to make payments, city of residence, country, personal description, Creator category, number of agent (representative) (if applicable), email address of agent (representative) (if applicable), social media account details (link) are the minimum required to register on the Website and use the Services offered by privyet.

Data subjects are entitled at their own discretion to provide privyet with additional Personal Data which are not necessary using the tools on privyet Website.

 

7. STORAGE AND USE OF PERSONAL DATA

Personal Data is stored exclusively on electronic media and processed using automated systems, except in cases where Personal Data are to be processed manually as prescribed by law.

 

8. TRANSFER OF PERSONAL DATA

Personal Data are not transferred to any other third parties except in cases specified in this Policy. Personal Data may be transferred to third parties/counterparties of privyet Website only at the request of Data subjects or with their consent. When Personal Data are transferred to privyet Website’s counterparties, its parent company, the counterparties, and privyet’s parent company (STAREO TECHNOLOGIES AB, 559275-7685, Sweden) are to assume and fulfill the obligations to keep the data received confidential. privyet guarantees Data subjects that in case of transfer of Personal Data to its parent company, privyet will comply with the regulations on cross-border transfer of Personal Data. Personal Data and other information are in any case transferred with the consent of Data subjects, expressed implicitly through actions such as, for example, pressing a specific button as well as by using the Website (Services).

By accepting the terms for Personal Data processing, the User agrees to the transfer of the following Personal Data and for the following purposes in any cases:

  • The Username is transferred to the Creator to inform of the User’s request for Content from the Creator;
  • Payment details (bank account/card, e-wallet details) are transferred to the payment provider to hold funds as defined in the Terms to fulfill Content request and/or pay for delivered Content;
  • The name, email address, mobile phone number are transferred to service providers that contact the Users by email or phone to liaise with them on their Content requests/services.

The Data subject also agrees to the transfer of information (including as it is defined in section “Other Information about Personal Data Subjects Processed by privyet”) for privyet’s marketing purposes.  

Personal Data are to be provided at the request of state authorities (local authorities) in the manner prescribed by law. To provide Data Subjects with access to services on privyet Website, privyet Website develops, improves, and optimizes the products on the Website. For these purposes, Data Subjects agree to privyet Website’s mailing (including surveys) in compliance with applicable laws to get some feedback through the Website Administration services and/or third parties’ services: electronic messages, SMS and other types of mailings, as well as collection, storage, accumulation, classification, retrieval, comparison, use, data filling (clarification), as well as receipt and transfer of the results of the automated processing of such data to affiliates and partners using various information assessment models in the form of integer and/or text values and identifiers consistent with the evaluation criteria in the requests for data processing by the Website Administration and/or the entities specified in this paragraph.

 

9. DESTRUCTION OF PERSONAL DATA

Personal Data is destroyed upon deletion by Data Subjects, upon deletion of account (if applicable) by Data subjects, upon deletion by the Website of information that is posted in violation of the Terms.

privyet will store on its electronic media Personal and other necessary data for the necessary period as set out by Russian law.

By posting information, using an account, including their Personal Data, Creators acknowledge and agree that this information may be available to other Internet users given the particularities of the Website architecture and functions.

 

10. RIGHTS AND OBLIGATIONS OF DATA SUBJECTS

Data Subjects are entitled to:

  • Easy and free access to information about themselves by uploading their data on the Website (if it is applicable);
  • Change and correct the information about themselves provided such changes and corrections are relevant and accurate;
  • Delete information about themselves (this right applies subject to the provisions of section 9 on the storage of Personal Data);
  • Request privyet to update, block, or destroy their Personal Data if such data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose for data processing, and if these actions may not be performed by Data subjects;
  • Upon request obtain from privyet information about the processing of their Personal Data.

Data Subjects must:

  • Provide up-to-date and accurate data about themselves. If the data provided is irrelevant and/or inaccurate, the Website shall not be liable for the inability to use the Services offered on the Website.

 

11. WHAT MEASURES DO WE TAKE TO PROTECT USER DATA?

The Website takes technical, organizational, and legal measures to ensure the protection of Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other wrongful acts.

Data subjects are responsible for keeping information safe that allows Data subjects to use the Site (Services). Data subjects are not entitled to pass on their data related to the use of the Website (Services) to third parties and must take measures to ensure that they remain confidential.

 

12. RESTRICTIONS

This Policy does not apply to the actions and internet resources of third parties.

 

13. REQUESTS FROM DATA SUBJECTS

Data Subjects are entitled to send their requests to the Website Administration, including requests regarding the use of their Personal Data. Requests must be sent in writing to the following address: 123308, Moscow, external territory of city Khoroshevo-Mnevniki municipal district, ul/ Mnyovniki 6, Unit IV, Office 5 or electronically to the following email address as a document signed with a qualified electronic signature in compliance with Russian law support@privyet.ru.

The following information must be specified in any request sent by Data subjects:

  • Number of main identity document for the user or his/her representative;
  • Date of issuance of this document and name of issuing authority;
  • Information confirming the Data subj’s participation in the relationship with the operator;
  • Signature of the user or his/her representative. 

The Website Administration undertakes to consider and send a response to any user’s request within 30 days of the request receipt date.

All correspondence received by the Website Administration from users (requests in writing or electronic form) constitutes information with restricted access and is not disclosed without the user’s written consent. Personal Data and other information about Data subjects who have sent a request cannot be used without the Data Subject’s special consent for anything other than to respond to the topic of the request or in cases expressly provided by law.