1. DEFINITION OF TERMS
"Law" means the Federal Law of the Russian Federation "On Personal Data" with all amendments and supplements, and other legislative acts of the Russian Federation.
"Mobile Application" is software (with all existing additions and enhancements) designed to run on smartphones, tablets, watches and other mobile devices, and designed for a specific platform (iOS, Android, Windows Phone etc.). For the purposes of this Policy, Mobile Application means the following software: SENSES.
"Personal Data" means the aggregate of personal data and/or non-personally identifiable information about the User provided by him/herself to the Right Holder and/or automatically collected by the Right Holder and/or third parties.
"User" means the entity or individual who has downloaded the Mobile Application to a smartphone, tablet, watch or any other mobile device and/or has activated such Mobile Application on one of the said devices.
"User Agreement" means the agreement entered into between the Rights Holder and the User in relation to the manner, rules and features of the User's use of the Mobile Application. The User accedes to such agreement and shall not have the right to make and/or demand any changes or additions to it.
"Copyright holder" means the following person who owns the exclusive rights of ownership of the Mobile ApplicationArtem Gennadyevich Krivich, INN 470322686728
"Cookies" means small files sent to any mobile application or website and placed on the User's smartphones, tablets, watches and other mobile devices to improve the performance of such applications or websites as well as the quality of the content placed in them.
2. RELATIONSHIP TO WHICH THE POLICY APPLIESGeneral Provisions
This Policy applies and applies solely to Personal Data collected from a User in connection with his or her use of the Mobile Application. The provisions of this Policy are intended to:
- determine the types and types of Personal Data received, the uses (processing) of Personal Data, and the sources of such Personal Data; and
- definition of the User's rights regarding the protection of confidentiality of Personal Data transferred to them; and
- definition of persons responsible for the processing and storage of Personal Data, as well as of third parties to whom such data is disclosed (in full or in part). The rules of this Policy shall not apply to the processing by third parties of Personal Data that is voluntarily provided by the User.
The rules of this Policy shall not apply to the processing by third parties of Personal Data that is voluntarily provided by the User.
By installing and/or activating the Mobile App on a smartphone, tablet, watch or other mobile device, the User agrees to the terms of this Policy and gives its consent to the Right Holder to collect, process, retain and store Personal Data in the manner and on the terms set out in this Policy.
If the User does not agree to the terms of this Policy and/or certain terms of this Policy are not clear to him/her, in such case the User shall immediately stop using the Mobile Application.Rights of the User regarding the protection of Personal Data
In connection with the submission of Personal Data, the User shall automatically have the following rights:
- to receive data relating to their processing (the grounds and purposes of such processing, the methods of processing used, details of persons who have access to them or to whom they may be disclosed on the basis of a contract or the Act).
- Receive data on the location and identification data of the persons who carry out the processing of Personal Data.
- to obtain data on the retention period of Personal Data.
- To appeal against actions or omissions of the Rights Holder to the authorised body for the protection of the rights of subjects of personal data or in court.
- Receive reimbursement of losses and / or compensation for moral damages in court as a result of violations of the rights of the User for the protection and defence of their Personal Data by the Rights Holder and / or third parties.
- Exercise other rights in the area of personal data protection, as provided by the Act or provisions of this Policy.
3. LIST OF PERSONAL DATA COLLECTEDNon-personal information about users
In connection with the use of the Mobile Application, the Rights Holder may automatically collect and process the following non-personalised information about the User
Personal user data
- information about traffic, possible number of clicks, logs and other data.
- Information about the device (identification number, mobile network) from which you are logging in, operating system, platform, browser type and other browser information, IP address.
The user provides the Right Holder the following personal data about him/her:
- email address.
- mobile phone number.
- sex of the User.
- photo of the User.
- all photos, video clips, audio files and other types of media stored on the device from which the User logs in to the Mobile application.
- data contained in the User's personal account (profile), all internal correspondence of the User (if any), as well as other activity of the User's personal account (profile).
- the data about all User's publications in the Mobile App, including, but not limited to, comments, rating, reviews, publishing reports, videos and photos, likes, ratings and/or any other forms of activity available to the User in the Mobile App, and/or content created.
- The following data:
- The User's physical data, height, size and body type
- data and information obtained as a result of combining certain Personal Data of a particular User as well as data and information obtained about the User from third parties (partners, marketers, researchers).
The user is solely responsible for the completeness of the provided personal data and is obliged to carry out timely changes (updates, checks, corrections) on a regular basis.
This Mobile Application uses certain Cookies to store the IP address, User preferences or the type of device used in order to (1) keep statistics on visits and traffic to the Site and (2) personalise the data displayed on the User and (3) store data needed to identify the User, including when accessed from different devices, and (4) display advertisements according to the User's interests and preferences. The Mobile App may use both its own Cookies owned by the Rights Holder and Cookies of third parties.
4. PURPOSES OF THE COLLECTION AND PROCESSING OF PERSONAL DATADefinition of processing purposes
Personal Data shall be collected and processed for the following purposes:
- to analyse the User's behaviour and to identify the User's preferences for a particular type of content.
- for the prompt and correct operation of the Mobile Application, to improve the functioning of the Mobile Application, to improve the content of the Mobile Application, to improve the internal architecture and functionality of the Mobile Application.
- to identify the User.
- to provide personalised advertising and marketing materials.
- to comply with the requirements of the Act.
- to provide technical support for the Mobile Application, to identify and correct problems with the Mobile Application.
- To communicate with the User (communication).
- to perform other obligations of the Rights Holder that arise to the User.
- For conducting statistical research.
- for any other purposes, subject to the separate consent of the User.
Processing of Personal Data is based on the principles of: (1) legitimacy of the purposes and methods of processing; and (2) good faith; and (3) consistency of the purposes of Personal Data processing with the purposes specified and stated in advance when collecting such Personal Data; and (4) consistency of the amount and nature of Personal Data processed with the stated purposes of processing.Conditions for processing of Personal Data
Personal Data shall be processed when: (1) obtaining consent from the User; or (2) achieving the Right Holder's goals as stipulated by an international treaty or the Law; or (3) providing the User's Personal Data to an unlimited number of people; or (4) performing other obligations of the Right Holder to the User, including but not limited to providing certain content to the User; or (5) saving the User's life or health, when consent to processing of their Personal Data cannot be obtained in advance.
If Personal Data is anonymised, which makes it impossible to identify the User directly or indirectly, subsequent use and disclosure of such data to third parties is permitted and the rules of this Policy no longer apply.
The data controller shall take all possible measures to protect the confidentiality of the Personal Data received, unless the User has made such data publicly available.
Personal Data is processed with and without the use of automated means.
5. THIRD-PARTY ACCESS TO PERSONAL DATAUse of analytical platforms
The Rights Holder shall use the following analytical platform: Amplitude to (1) track the frequency of visits to the Website by Users; and (2) track the ways in which the User uses the Mobile Application and/or its content; and (3) identify the type and type of content that is popular among Users; and (4) determine the User's location. The User also consents to the Right Holder's use of information obtained about the User from another option.
For these purposes, the following analytics platform: Amplitude may collect data on the User's IP address, geolocation, behavior, as well as their preferences and interest with respect to certain content.
The following analytics platform: Amplitude accesses Personal Data in order to provide the Rights Holder with an understanding of how effective its Mobile App is, which content is popular, how effective it is in placing certain advertisements, and for the purpose of developing and/or improving the Rights Holder's existing marketing strategy.
The Rights Holder may disclose Personal Data (1) to its affiliates, branches and representative offices opened both in the Russian Federation and in other countries; (2) to legal successors of the Rights Holder, which emerged as a result of its liquidation, reorganisation or bankruptcy, and which have acquired exclusive rights to possess the Mobile application; (3) to third parties solely for the purpose of providing certain content or access to it; (4) to third parties when the User would receive certain content from the Mobile application.
The Rights Holder shall disclose Personal Data only if (1) it is confident that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data as the Rights Holder itself, and (2) consent to such disclosure has been previously expressed by the User and/or is permitted under the Act.Advertisements from third parties
The content of the Mobile Application may contain advertising banners and/or links to third party websites. The User's use of such websites (by clicking on the link or by any other means) may entail the collection, processing and use of Personal Data as well as the possible automatic transfer of Cookies to the User's device from which the User connects to third parties' websites. The Rights Holder is not responsible for the ways, methods and procedure of processing Personal Data by third party websites. Consequently, the Rights Holder shall also not be liable in the event of disclosure of Personal Data to the public in connection with the User's use of such websites.
The Rights Holder strongly advises each User to read in detail the personal data protection policies of the used websites.
6. ADVERTISEMENT PLACEMENTAdvertising in the Mobile App
The Rights Holder shall place various advertising and marketing materials in the Mobile Application along with the content, taking into account the User's identified preferences for one or another content. The placement of advertisements in the Mobile App shall involve the installation of certain Cookies on the Rights Holder's device.
7. SUBMITTING COMPLAINTS AND REQUESTS TO THE RIGHTS HOLDERDemanding the termination of the processing of personal data
Each User shall have the right to express their objection to the Right Holder against the processing and/or storage of their Personal Data. Such objection may be expressed as follows:Write an email to firstname.lastname@example.org from the email address to which the account is registered.Request for information on personal data
If the User has any questions relating to the manner of application or use of this Policy, the manner and/or method of processing of Personal Data, the User may ask such question as follows:The question should be sent to team@senses@team.Modification (update, amendment, correction) or deletion of personal data
The User may at any time amend or delete their Personal Data on their own unless such amendment or deletion would result (1) in a breach of the rules of this Policy; or (2) in a breach of the Law; (3) the nature of such Personal Data is evidence in any legal proceedings arising between the Rights Holder and the User. This requires the User to delete their personal account (profile) in the Mobile Application.
The Rights Holder shall have the right to delete the User's personal account/profile as well as all Personal Data about the User at any time, if the User has violated the terms of this Policy and/or the User Agreement.
If Personal Data on the User is deleted, all publications made by such User (comments, ratings, reviews, publication of reports, videos and photos, likes, ratings) and/or any other forms of activity available to the User in the Mobile application shall also be automatically deleted.
8. TERMS AND PROCEDURE FOR RETENTION OF PERSONAL DATA
Storage shall be carried out independently by the Rights Holder.
The storage shall be carried out for the duration of the User's use of this Mobile Application.
The Rights Holder shall be obliged to destroy or anonymise the User's Personal Data immediately after the User stops using the Mobile Application.
9. ACCESS OF MINORS TO THE MOBILE APPLICATION
The Mobile App may be used by persons under the age of 18 years.
The Mobile application collects personal data about Users, therefore the use of this application by underage Users shall only be allowed subject to the prior consent of the legal representative (guardian) to the processing of Personal Data. This consent must be given as follows:Sending a scan of the passport of the legal representative to the following email address team@senses@team
If a minor User is unable to obtain consent to the processing of their Personal Data from their legal representative (guardian), the User shall immediately stop using the Mobile application.
10. PROCEDURE FOR PROTECTION OF PERSONAL DATA.
Protecting the confidentiality of Personal Data is of primary and important concern to the Rights Holder. The Rights Holder adheres to all required international standards, rules and recommendations for the protection of Personal Data.
The Licensor has implemented a number of technical and organisational methods to protect Personal Data from disclosure or unauthorised access to it by third parties.
11. FINAL PROVISIONSAccessibility of the text of this policy
Users may read the terms and conditions of this Policy at the following link: https://promo.senses.team/en/privacy.
This revision of the Policy is effective as of 25 September 2021.Changes and additions to this policy
This Policy may be changed from time to time. The Rights Holder shall not be liable to the User for changing the terms of this Policy without the permission and/or consent of the User.
It is the User's responsibility to check the terms of this Policy for possible amendments or additions on a regular basis.Applicable law
This Policy is developed in accordance with the current legislation on personal data protection of the Russian Federation, in particular the provisions of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (as amended), the Federal Law of July 21, 2014 No. 242-FZ "On Amendments to Certain Legislative Acts of the Russian Federation in terms of clarifying the processing of personal data in information and telecommunications networks" (as amended).Risk of disclosure
Regardless of the measures taken by the Rights Holder to protect the confidentiality of personal data received, the User is hereby considered to be duly informed that any transfer of Personal Data on the Internet cannot be guaranteed secure, and therefore the User makes such transfer at its own risk.Public information
Within the Mobile App, the User shall be entitled to publish and post any content at their own discretion and in any of the forms available (photo, video, comment, article, rating, blog, etc.). Such publications and content shall be made publicly available to other users of the Mobile application and the Rights Holder shall not be under any obligation to protect any Personal Data that may be disclosed or published as part of such publication and/or content.