PRIVACY POLICY FOR THE MOBILE APP AFFITODAY


1. DEFINITION OF CONCEPTS
"Controller" means a person who is responsible for the processing and protection of Personal Data of Users located on the territory of the EU within the meaning of the General Data Protection Regulation of April 27, 2016 (hereinafter "GDPR").

"Mobile Application" is software (with all existing additions and improvements) designed to work on smartphones, tablets, watches and other mobile devices, and developed for a specific platform (iOS, Android, Windows Phone, etc.). For the purposes of this Policy, a Mobile Application means the following software: AffiToday.

"Personal Data" means a set of personal data and/or non-personalized information about the User provided by him to the Copyright Holder and/or automatically collected by the Copyright Holder and/or third parties.

"Policy" means the present Privacy Policy of the mobile application (with all existing additions and changes).

"User" means a legal entity or an individual who has downloaded a Mobile Application to a smartphone, tablet, watch or any other mobile device and/or has activated such a Mobile Application on one of these devices.

"User Agreement" means an agreement concluded between the Copyright Holder and the User regarding the procedure, rules and features of the User's use of the Mobile Application. The User joins such an agreement and has no right to make and/or require any changes or additions to it. The User can read the terms of the User Agreement at the following link: http://affi.today/termsofuse .

"Copyright Holder" means the following person who owns the exclusive rights of ownership of the Mobile Application
Sole proprietor Shamil Kuramshin., location address: 143582, Moscow region, Istra district, Konyukhov S. str., 6-20, contact via sh@affi.today
"Processor" means a person who, in the understanding of GDPR, on behalf of the Controller, performs the storage and/or processing of Personal Data received from Users.

"Cookies" means small files sent to any mobile applications or website and placed on the User's smartphones, tablets, watches and other mobile devices to improve the operation of such applications or websites, as well as the quality of the content posted in them.

2. RELATIONS COVERED BY THE POLICY
General provisions
This Policy is used and applies exclusively to Personal Data received from the User in connection with the use of the Mobile Application. The provisions of this Policy are aimed at:
(1) determination of the types and types of Personal Data received, directions and purposes of use (processing) Personal Data, as well as the sources of obtaining such Personal Data; and
(2) determining the User's rights with respect to protecting the confidentiality of the Personal Data transmitted to them; and
(3) identification of persons responsible for the processing and storage of Personal Data, as well as third parties to whom such data is disclosed (in whole or in part).
The rules of this Policy do not apply in the case of processing by third parties of Personal Data that are voluntarily provided by the User.
By installing and/or activating a Mobile Application on a smartphone, tablet, watch or other mobile device, the User agrees to the terms of this Policy and gives his consent to the Copyright Holder to collect, process, retain and store Personal Data in the manner and on the terms provided for in this Policy.
If the User does not agree with the terms of the Policy and /or does not understand the individual terms of the Policy, in this case the User is obliged to immediately stop using the Mobile Application.
User rights to protect personal data
In connection with the provision of Personal Data, the User automatically receives the following rights:
(1) to receive data concerning their processing (the grounds and purposes of such processing, the processing methods used, information about persons who have access to them or to whom they may be disclosed on the basis of a contract or Law).
(2) to receive data on the location and identification data of persons who process Personal Data.
(3) to receive data on the terms of storage of Personal Data.
(4) receive data on the trans-border transfer of Personal Data that has been carried out or is expected to be carried out.
(5) to receive information about the location and identification data of persons who store Personal Data.
(6) appeal the actions or omissions of the Copyright Holder to the authorized body for the protection of the rights of personal data subjects or in court.
(7) receive damages and/or compensation for moral damage in court as a result of violations of the User's rights to the protection and protection of his Personal Data committed by the Copyright Holder and/or third parties.
(8) exercise other rights in the field of personal data protection provided for by Law or the provisions of this Policy.

3. LIST OF PERSONAL DATA COLLECTED
Non-personalized user information
In connection with the use of the Mobile Application, the Copyright Holder can automatically collect and process the following non-personalized information about the User:
(1) traffic information, the possible number of clicks made, logs and other data.
(2) information about the device (identification number, mobile operator network) from which the login is performed, operating system, platform, browser type and other browser information, IP address.
Personal data about users
The User provides the Copyright Holder with the following personal data about himself:
(1) full surname, first name and patronymic.
(2) date of birth and age.
(3) email address.
(4) mobile phone number.
(5) the gender of the User.
(6) the User's nationality.
(7) a photo with the User's image.
(8) data contained in the personal account (profile) The User, all internal correspondence of the User (if any), as well as other activity of the User's personal account (profile).
(9) data on orders made to Users/purchases and/or services received/paid for via the Mobile App.
(10) data and information obtained as a result of combining certain Personal Data of a particular User, as well as data and information received about the User received from third parties (partners, marketers, researchers).
The User is the only person responsible for the completeness of the personal (personal) data provided and is obliged to change them in a timely manner (update, check, correction) on a regular basis.
The Copyright Holder assumes that all personal (personal) data provided by the User is reliable, and that the User maintains such information up to date.
Information about transactions being made
The user can make payments for goods or services through the Mobile Application by entering information about the payment card and the identification data of the owner of such a card into a special field. The user can make payments in the Mobile Application in the following way:
by bank card.
using the Paypal payment system.
using the Yandex payment system.Money.
using the Apple Pay payment system.
using the Google Pay payment system.
In this case, the collection and processing of User data is carried out solely for the purposes of payment, fraud prevention, as well as compliance with other requirements of the Law.
The User gives his consent to access and collection by the Copyright Holder and the relevant payment system or banking institution through which the payment is made to such Personal Data, and also agrees to the privacy policy of the relevant payment system or banking institution.
Use of cookies
This Mobile Application uses certain cookies to store the IP address, User preferences or the type of device used in order to (1) maintain statistics of visits and traffic to the site, and (2) personalize the data displayed on the User's screen, and (3) store data necessary for User identification, including when accessing from different devices, and (4) display ads according to the User's interests and preferences. The mobile application can use both its own cookies belonging to the Copyright Holder and Cookies of third parties.
The mobile application uses the following cookies:
(1) Technical (functional) cookies that are needed to control traffic and data transmission, to identify Users and provide access to the content of the Mobile Application to the User and without which the use of the Mobile Application is functionally limited, as well as to prevent the provision of recommendations that do not correspond to the interests of the User.
(2) Statistical cookies, which are needed to track the frequency of User visits to the site, to identify how the User uses the Mobile Application, as well as to identify the type and type of content that is popular or interesting to the User.
(3) Third-party cookies, which are installed by third parties with the User's permission and are intended for conducting statistical research concerning the User's behavior on the Internet and/or sending personalized advertising or marketing materials to the User and/or providing goods or services.

4. PURPOSES OF PERSONAL DATA COLLECTION AND PROCESSING
Definition of processing purposes
The collection and processing of Personal Data is carried out for the following purposes:
(1) to analyze User behavior, as well as to identify User preferences for a certain type of content.
(2) for the prompt and correct operation of the Mobile Application, improving the functioning of the Mobile Application, improving the content of the Mobile Application, improving the internal architecture and functionality of the Mobile Application.
(3) to identify the User.
(4) to send personalized advertising and marketing materials to the specified email address and/or mobile phone of the User.
(5) to comply with the requirements of the Law.
(6) to track orders/purchases made by the User through the Mobile Application.
(7) for technical support of the Mobile Application, identification of problems in its operation and their elimination.
(8) to maintain communication with the User (communication).
(9) to fulfill other obligations of the Copyright Holder that have arisen before the User.
(10) for conducting statistical research.
(11) for any other purposes, subject to obtaining separate consent from the User.
The processing of Personal Data is carried out on the basis of the principles of: (1) legality of the purposes and methods of processing; and (2) integrity; and (3) compliance of the purposes of Personal Data processing with the goals previously defined and declared when collecting such Personal Data; and (4) compliance of the volume and nature of the processed Personal Data with the stated purposes of their processing.
Personal data processing conditions
The processing of Personal Data is carried out in the following cases: (1) obtaining consent from the User; or (2) the Right Holder achieving the goals stipulated by an international agreement or Law; or (3) providing the User with his Personal Data to an unlimited number of persons; or (4) fulfilling other obligations of the Rights Holder to the User, including, but not limited to, providing certain content to the User; or (5) saving the life or health of the User when consent to the processing of his Personal Data cannot be obtained in advance.
In the case of depersonalization of Personal Data, which does not directly or indirectly identify the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy no longer apply to them.
The Copyright Holder takes all possible measures to protect the confidentiality of the Personal Data received, except in cases when the User has made such data publicly available.
The processing of Personal Data is carried out using automation tools and without the use of such automation tools.

5. ACCESS OF THIRD PARTIES TO PERSONAL DATA
Using remarketing services
The Copyright Holder uses remarketing to advertise the content of the Mobile Application to the User on other sites visited by the User.
Remarketing services are provided to the Copyright Holder through the Google ads platform. Google Ads collects and processes non-personalized data that does not directly identify or identify the User. The information collected, as a rule, may include (1) the content that the User viewed, (2) the date and time when the User viewed the content, (3) geolocation data. The collection and processing of such non-personalized information allows you to provide the User with more targeted advertising or marketing content.
By installing the Mobile Application, the User agrees to the Privacy Policy for Google Ads and the Terms of Use for Google Ads, as well as the automatic installation of the corresponding Cookies on the User's device.
The User has the right to refuse such advertising at any time by changing the appropriate settings of the browser and the device from which the Mobile Application is logged in.
Using analytical platforms
The Copyright Holder uses the Google Analytics analytics platform to (1) track the frequency of User visits to the site; and (2) track how 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 location of the User. The User also gives his consent to the Copyright Holder to use the information received about the User from Google Analytics.
For these purposes, the Google Analytics analytics platform may collect data about the IP address, geolocation, User behavior, as well as his preferences and interest in certain content.
The Google Analytics analytical platform gets access to Personal Data in order to provide the Copyright Holder with an understanding of how effectively his Mobile Application works, what kind of content is popular, how effective is the placement of a particular advertisement in it, as well as for the purposes of developing and/or improving the existing marketing strategy of the Copyright Holder.
By installing the Mobile Application, the User agrees to the Privacy Policy of Google Analytics, as well as the automatic installation of appropriate cookies on the User's device.
Disclosure of personal data to third parties
The Right Holder has the right to disclose Personal Data (1) to its affiliates, branches and representative offices opened both on the territory of the Russian Federation and on the territory of other states; (2) to the legal successors of the Rights Holder who arose as a result of its liquidation, reorganization or bankruptcy, and who received exclusive ownership rights to the Mobile Application; (3) payment service providers or banking (financial) institutions, for conducting User transactions through a Mobile Application; (4) to third parties solely for the purpose of providing the User with certain content or access to it; (5) to third parties when the User has consented to the disclosure, transfer or processing of his Personal Data, as well as in other cases expressly provided for by Law or this Policy.
The Copyright Holder discloses 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 that the Copyright Holder himself takes, and (2) consent to such disclosure has been previously expressed by the User and/or is permitted by Law.

6. ADVERTISING PLACEMENT
Advertising in the mobile app
The copyright holder does not place ads in the Mobile Application.
Distribution of advertising materials
The User automatically agrees with the right of the Copyright Holder to send personalized advertising and marketing materials to the provided email address and/or mobile phone with the installation of the Mobile Application on the device.
The User has the right at any time to refuse to receive such advertising and marketing materials by performing the following actions:
send a corresponding letter with a refusal to receive advertising brochures to info@affi.today
Please note that in case of refusal to receive advertising and marketing materials, the User may continue to receive from the Copyright Holder any notifications related to the use of the Mobile Application and/or its content.

7. SENDING COMPLAINTS AND REQUESTS TO THE COPYRIGHT HOLDER
The requirement to terminate the processing of personal data
Each User has the right to express his objection to the Copyright Holder against the processing and/or storage of his Personal Data. Such an objection can be expressed as follows:
the request must be sent to the Copyright Holder at the following address: info@affi.today
Request for information about personal data
If the User has any questions related to the procedure for applying or using this Policy, the procedure and/or method of processing Personal Data, the User can ask such a question as follows:
the question should be sent to the Copyright Holder at the following address: info@affi.today
Modification (updating, addition, correction) or deletion of personal data
The User has the right to independently change or delete his Personal Data at any time, except in cases where such change or deletion may lead to (1) violation of the rules of this Policy; or (2) violation of the Law; (3) the nature of such Personal Data is evidence in any legal process that has arisen between the Copyright Holder and the User. To do this, the User needs to delete his personal account (profile) in the Mobile application.
The Copyright Holder has the right at any time to delete the User's personal account/profile, as well as all Personal Data about the User, if he violated the terms of this Policy and/or the User Agreement.

8. TERMS AND PROCEDURE FOR STORING PERSONAL DATA
Storage is carried out by third parties on behalf of the Copyright Holder. The User gives his consent to the storage of his Personal Data by third parties on behalf of the Copyright Holder, provided that such third parties preserve the confidentiality of the Personal Data received. The information storage functions are assigned to the following person: AMAZON WEB SERVICES, INC., LLC "YANDEX.CLOUD", LLC "SELECTEL" (hereinafter referred to as the "Keeper"). Personal Data is stored on the territory of the Russian Federation.
Storage is carried out for the entire period necessary to achieve the stated purposes of Personal Data processing.
The Copyright Holder undertakes to destroy or depersonalize Personal Data immediately after achieving the purposes of processing.

9. ACCESS OF MINORS TO THE MOBILE APPLICATION
The use of the Mobile Application is intended for persons over the age of 18 who gain access to it only if they provide prior consent to the processing of their Personal Data. The Copyright Holder checks the User's age as follows:
the user will need to enter his date of birth in a special field
If the User is a minor, in this case, he must immediately stop using this Mobile Application.
Users in the European Union
The use of the Mobile Application is intended for persons aged 16 years and older who gain access to it only if they provide prior consent to the processing of their Personal Data. The Copyright Holder checks the User's age as follows:
the user will need to enter his date of birth in a special field
If the Copyright Holder has become aware that the User's age does not correspond to the permissible age for using the Mobile Application, in this case the Copyright Holder undertakes to immediately block such User's access to the Mobile Application.

10. PERSONAL DATA PROTECTION PROCEDURE
Protecting the confidentiality of Personal Data is a primary and important task for the Copyright Holder. The Copyright Holder adheres to all required international standards, rules and recommendations for the protection of Personal Data.
The copyright holder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access to them by third parties.

11. USERS LOCATED IN THE TERRITORY OF THE EUROPEAN UNION
General provisions
Since the Mobile Application is accessible to users from the European Union, the Copyright Holder undertakes to additionally adhere to the provisions of the GDPR.
The Controller within the meaning of this Policy is the Copyright Holder. The Processor within the meaning of this Policy is the Custodian according to Article 8 of the Policy.
The rightsholder stores Personal Data for a reasonable period necessary to achieve the purposes of processing, but not less than the period established by the local legislation of the member State of the European Union, on the territory of which the Mobile Application is available, for storing this or that type of Personal Data. Upon expiration of the period established for storage, the Copyright Holder undertakes to immediately destroy or depersonalize such data.
Official representative
Since the Controller is located outside the territory of the European Union, the following person is appointed as its official representative for the protection of Users' Personal Data in the European Union: sole proprietor Shamil Kuramshin., location address: 143582, Moscow region, Istra district, Konyukhov S. str., 6-20, contact via sh@affi.today.
User rights in the field of personal data protection
According to Chapter 3 of the GDPR, Users located in the territory of the European Union have the following rights in the field of Personal Data protection: (1) the right to receive information about their Personal Data ("the right to be informed"); and (2) the right to access their Personal Data ("the right of access"); and (3) the right to correct Personal Data ("the right to rectification"); and (4) the right to destroy Personal Data ("the right to erasure"); and (5) the right to restrict the processing of Personal Data ("the right to restrict processing"); and (6) the right to transfer Personal Data to third parties ("the right to data portability"); and (7) the right to object ("the right to object").

12. FINAL PROVISIONS
Availability of the policy text for review
Users can read the terms of this Policy at the following link: https://affi.today/privatepolicy .
This Policy can be translated into a foreign language for those Users who access the Mobile Application outside the Russian Federation. In case of discrepancy between the original text (Russian) and its translation, the original language shall prevail.
This version of the Policy is valid from November 15, 2021.
Changing and supplementing the policy
This Policy may be changed from time to time. The Copyright Holder does not bear any responsibility to the User for changing the terms of this Policy without the permission and/or consent of the User.
The User himself undertakes to regularly check the provisions of this Policy for possible changes or additions.
Applicable law
This Policy has been developed in accordance with the current legislation on the protection of personal data in particular with the provisions of telecommunications networks (with all additions and changes), as well as the provisions of the General Data Protection Regulation (General Data Protection Regulation) of April 27, 2016 GDPR.
Risk of disclosure
Regardless of the measures taken by the Copyright Holder to protect the confidentiality of the personal data received, the User is hereby deemed to be duly informed that any transfer of Personal Data on the Internet cannot be guaranteed safe, and therefore the User carries out such transfer at his own risk.


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