This document “Privacy Policy” (hereinafter referred to as “Policy”) is the terms and conditions for collection and use of thePersonal information of the User (hereinafter referred to also as “You”) by AO“VIEWEVO” (JSC) (hereinafter referred to as “ Rightholder”) during download,installation and use of the mobile application “ViewEvo” (hereinafter referredto as “Mobile application”).
USER’S CONSENT:
By downloading,installation and use of the Mobile application you (hereinafter also referredto as “User”) with your own free will and for your benefit give your consent tothe processing of User’s Personal Information for the purposes and under theterms and conditions stipulated by this Policy.t inside of a div block.
1. General Provisions
1.1. ThisPolicy is an integral part of the End User License Agreement for the Mobileapplication (hereinafter referred to as the “EULA”). Therefore, when executing the above said EULA by methods defined thereinincluding by downloading, installation and using the Mobile application youfully accept the terms of this Policy.
1.2. Methods of processing of Personal Information include any action (operation) or acombination of actions (operations) with Personal Information includingcollection, recording, systematization, storage, updating (refreshment, modification),extraction, use, transfer (provision, access), depersonalization, blocking,deletion, destruction in the purposes established by this Policy with/without the use of automated facilities.
1.3. The terms and definitions provided for by the EULA are used herein, as well as other agreements entered into with the User, unless otherwise provided for bythis Policy or follows from the merits there of. In other cases, the terms used in the Policy shall be interpreted in accordance with the applicable laws, business practice, or scientific doctrine.
2. Personal Information
2.1. Personal information in this Policy means as follows:
2.1.1. Information that the User provides about him/her on registration or authorization with the Service via Mobile application, as well as during further use of the Mobile application and the Service based thereon, including personal data of the User.
2.1.2. Data transmitted in automatic mode, depending on the settings of the User’s software.
2.2. Rightholder is entitled to establish requirements for the composition of the User’s Personal Information, which are mandatory for the use of the Mobile application and/or the Service based thereon. If certain information is not marked by the Rightholder as mandatory, it is provided or disclosed by the User at his/her discretion.
2.3. When being registered, the User shall provide in the mandatory manner either email or phone number. In order to fill out an Account in the Service, the User can also provide the following personal data about himself/herself: name, last name, email or phone number.
Registration and/or authorization with the Service can be performed using authentication service of social networks (Facebook, Vkontakte, etc.). In that case, User provides personal information to Rightholder through use of such authentication service, and that personal information includes items that can be stored in User’s Account as well as the User’s ID in such social network.
When User uses the Mobile application’s function of identification and search of goods depicted on TV Rightholder can collect audio records.
Rightholder stores information about objects (goods, images) that are added by User to “Favorites” category.
2.4. When User uses the Mobile application and/or the Service Righholder can automatically collect data as follows:
· Data of system registration files or similar information on interaction of User with Service including such data as IP-address, language of browser, data and time of access, type of browser and domain of incoming request, web-pages that You visit, search words that You use, functionality that You use for visiting, and information of cookie files;
· User’s device data, including unique identifiers of User’s device, its location, operating system data (type, version, screen resolution) and so on;
· other information about User’s activity in the Mobile application.
2.5. User acknowledges and accepts the possibility of using third party software in the Mobile application and/or the Service; as a result, such third parties can receive and transmit the data indicated in clause 2.4. in a depersonalized form.
Specifically, Rightholder uses Google Analytics, Demographics и Interest Reporting, Crashlytics, that collects and processes data according to privacy policy available at:
https://www.google.com/policies/privacy/partners/ ;
The scope and conditions for collection and use of impersonal data by such software’s titleholders are determined directly by its titleholders and governed by documents available at their websites.
Accepting this Policy as well applying certain setting in his/her software including device’s operating system, the User agrees with conditions for collection and use of data by the titleholders of above listed software.
2.6. Rightholder will not verify the reliability of the provided Personal Information and whether the User has the necessary consent for the processing thereof in accordance with this Policy, believing that the User acts in good faith, carefully and makes every effort to keep such information up to date and obtain all necessary agreements of the subjects of personal data.
2.7. Following the links available in the Mobile application User can further browse electronic premises of the third parties. Processing of information provided by User at such third partу premises is performed by the titleholders thereof and according to the rules set forth by them. Rightholder does not process the information the User provides to such third parties at their electronic premises and shall not be liable for use of provided information by such third parties.
3. User’s options
3.1. User can turn off Google Analytics by downloading official blocking software available at
https://tools.google.com/dlpage/gaoptout.
3.2. User can turn off provision information of his/her device’s location by changing relevant settings in the Mobile application or by turning off such function in user’s device.
3.3. All Rightholder’s marketing electronic messages will contain instructions on how to unsubscribe from such messages. Please, note, that even if User unsubscribed from marketing messages Rightholder has the right to send messages of administrative nature, for example, about malfunction of the Service.
3.4. The functionality of the Service and the Mobile application that uses certain Personal information may work not as intended due to lack of such information.
4. Legal basis of processing of Personal information
The legal basis on which Rightholder relies for the use of Personal information includes:
4.1. Processing of Personal information where User has given consent for one or more specific purposes;
4.2. Processing of Personal information that is necessary for performing a contract to which User is a party;
4.3. Processing of Personal information that is necessary for pursuing legitimate interests of the Rightholder. Specifically, the Rightholder’s legitimate interests consist of ensuring safety and improving functionality of the Mobile application and the Service; of data analysis; of protection of the Rightholder and its partners from fraud.
5. Policy with regard to children
5.1. Rightholder does not intentionally collect personal data from children younger than 16, it does not request it and does not allow them to use the Mobile application and/or the Service. Persons under 16 are not allowed to provide personal information including name, address, telephone number and e-mail. If Rightholder gets to know that the information was collected from a child under 16, Rightholder shall immediately delete such information. If you think we could have obtained any information from a child or about a child under 16, please, contact us through e-mail indicated below.
6. Purposes for Personal Information Processing
6.1. Rightholder is entitled to use the Personal Information for the following purposes:
6.1.1. Identification of the User for access to Account within the fulfillment of the obligations under the EULA. The User is identified by the email or phone number.
6.1.2. Fulfillment of obligations under the EULA, including provision the User with access to the functionality of the Mobile application and/or the Service. Within relevant functionality of the Service Rightholder stores, organizes and displays in the Mobile application the information of the User’s Account.
6.1.3. Provision communication with the User for the purpose of technical support and improving the quality of the Mobile application and/or the Service;
6.1.4. Marketing, statistical and other research based on depersonalized data from the analytics systems stipulated in the paragraph 2.4. hereof for the purpose of improvement of the Mobile application and/or the Service.
6.1.5. Targeting of advertising and/or informational materials based on depersonalized data from the analytics systems stipulated in the paragraph 2.5. hereof.
7. User’s Rights to User’s Personal Information
7.1. Subject to specific provisions of applicable law, the User has the right:
7.1.1. to be informed about the collection and use of his/her personal data.
7.1.2. to access his/her personal data and have it corrected if it is wrong or incomplete.
7.1.3. to restrict the processing of his/her personal data where the accuracy of the personal data is contested, where the processing is unlawful, and where Rightholder no longer needs the personal data for the purposes for which Rightholder has processed it.
7.1.4. to object to the processing of his/her personal data and also restrict its processing in those instances where Rightholder undertook processing of it in carrying out a task in the public interest or where necessary for our legitimate interest where there is no compelling reason for its continued processing.
7.1.5. to withdraw consent that User had given to the collection and processing of his/her personal data at any time. If User does withdraw his/her consent to the collection and processing of personal data, that withdrawal shall not affect the lawfulness of any processing by Rightholder that is based on the consent User had given before he/she withdrew it.
7.1.6. to obtain the deletion of his/her personal data when it is no longer relevant to the purposes for which it was collected or processed, when User has withdrawn consent and there is no basis for us to continue processing, when User has objected to further processing and there is no compelling interest for continued processing, and when the data was unlawfully processed.
7.1.7. not to be a subject to a decision based solely on automated processing, including profiling, which produces legal affects concerning User or similarly affecting User, except where there is a lawful basis for continued processing.7.1.8. to receive personal data in a structured, commonly used, and machine readable form for the purpose of data portability in those instances where Rightholder processes by automated means personal data that User has provided.
7.2. These rights may be exercised by contacting Rightholder with specific request through the methods described below. Rightholder will address any such requests in a timely manner and according to applicable law. In certain cases, Rightholder may ask User to verify identity before acting on User’s request. If User is unsatisfied with Rightholder’s response, User may refer his/her complaint to the relevant supervisory authority in User’s jurisdiction.
8. Personal Information Storage Retention
8.1. All Personal Information that is collected will be stored only as long as is necessary to accomplish the purpose for which it is collected, or as long as is permitted or required by applicable law. Periodically, Rightholder will review its data processing systems to determine whether or not the purposes for the collection and processing of User’s personal data remain valid. That determination will be based on factors that include, but are not limited to, whether or not you are still in contact with Rightholder, whether or not any requests made by User from Rightholder have been fulfilled (including any follow-up tasks), whether or not there is a contractual relationship between User and Rightholder, and whether or not there is a contractual or legal basis for continuing to retain User’s personal data. Based on that review and any notifications received from data subjects, Rightholder will update its systems.
9. Requirements for the Personal Information Protection
9.1. Rightholder stores the Personal Information and provides its protection against unauthorized access and distribution in accordance with internal terms and regulations.
9.2. With regard to the User’s Personal Information, its confidentiality is protected, except for the cases when the technology of the Mobile application or the configuration of the User’s software provides for an open exchange of information with other Users of the Mobile application or third parties via Internet.
10. Transfer of the Personal Information10.1. Rightholder is entitled to transfer Personal Information to third parties in the following cases:
10.1.1. The User expressed his/her consent to such actions, including when the User applies the settings of the used software that specifically allow or do not limit the provision of certain information;
10.1.2. The transfer is performed as relevant function of the Mobile application and/or the Service;
10.1.3. In connection with use in the Mobile application and/or the Service of third party software for collection and processing of User’s data. Specifically, Rightholder may use the third party software for collection and processing of User’s data according to clause 2.5. of this Policy.
10.1.4. In connection with use of the services of third party providers by the Rightholder. Such third party providers receive Personal Information solely for the purposes of rendering services for the Rightholder. Specifically, Rightholder may transfer emails and phone numbers to providers of electronic mail-out services;
10.1.5. Due to the transfer of the Mobile application and/or the Service to the possession, use or property of a third party, including the assignment of rights under contracts concluded with the User in benefit of such third party;
10.1.6. Upon request of a court or other state authority within the procedure established by law;
10.1.7. To protect the rights and legitimate interests of Rightholder in connection with failure to comply with the agreements entered into with the User.
11. Amendments to and deletion of the Personal Information
11.1. The User is entitled at any time to independently edit the Personal Information in his/her Account except for email or phone number that is used for identification of the User.
11.2. The User is entitled to delete his/her own Account or to exercise other rights related to the processing of his/her personal data by sending to Rightholder a request at the address indicated below.
12. Amendments to the Privacy Policy
12.1. This Policy may be amended or terminated unilaterally by Rightholder without prior notice to the User. The User is recommended to read this Policy in the current version regularly.
12.2. The new version of the Policy becomes effective upon its placement, unless otherwise provided for by the new version of the Policy.
12.3. The current version of the Policy is available at:
https://viewevo.com/app-privacy-policy
13. The Rightholder’s details:
Name: AO “VIEWEVO”
Address: 123100, Moscow, Presnenskaya emb. 10, building 2, floor 11, room. 97, room 2, office. 98
Email: complaints@viewevo.com
The current version of the Policy of 24.05.2021.
