Политика конфиденциальности и обработки персональных данных

Вступает в силу 01 декабря 2020 года. Обновлено 04 марта 2021.

Настоящая политика в соответствии с частью 2 статьи 18.1 Федерального закона от 27.07.2006 № 152-ФЗ «О персональных данных» определяет политику компаний правообладателей ООО «Лемон Технолоджис Груп» (ОГРН 1161690171598, Россия, 420500, Республика Татарстан, Иннополис, ул. Университетская, д. 7, офис 333) и ООО “ЦСП” (ОГРН 1201600025736, Россия, 420500, Республика Татарстан, г. Иннополис, ул. Университетская, д. 7, офис 333), далее по тексту – Оператор, в отношении обработки персональных данных и содержит сведения о реализуемых Оператором требованиях к защите персональных данных. Настоящая политика действует в отношении всех персональных данных, обрабатываемых с помощью Веб приложения, имеющего название “Здоровое тело” и расположенного по адресу в сети Интернет https://body-health.online (далее по тексту - Веб приложение), которые Оператор получает или может получить от Пользователя. Настоящая политика является неотъемлемой частью внутреннего документа Оператора, определяющего общую политику Оператора в отношении обработки персональных данных и раскрывающего общие сведения о реализуемых Оператором требованиях к защите персональных данных.

1. ОБЩИЕ ПОЛОЖЕНИЯ

2. ПРАВОВЫЕ ОСНОВАНИЯ ОБРАБОТКИ ПЕРСОНАЛЬНЫХ ДАННЫХ

3. ЦЕЛИ СБОРА ПЕРСОНАЛЬНЫХ ДАННЫХ

4. ОБЪЕМ И КАТЕГОРИИ ОБРАБАТЫВАЕМЫХ ПЕРСОНАЛЬНЫХ ДАННЫХ, КАТЕГОРИИ СУБЪЕКТОВ ПЕРСОНАЛЬНЫХ ДАННЫХ

5. ПОРЯДОК И УСЛОВИЯ ОБРАБОТКИ ПЕРСОНАЛЬНЫХ ДАННЫХ

6. ДОСТУП К ПЕРСОНАЛЬНЫМ ДАННЫМ

7. АКТУАЛИЗАЦИЯ, ИСПРАВЛЕНИЕ, УДАЛЕНИЕ И УНИЧТОЖЕНИЕ ПЕРСОНАЛЬНЫХ ДАННЫХ

8. ОТВЕТЫ НА ЗАПРОСЫ ПОЛЬЗОВАТЕЛЯ НА ДОСТУП К ПЕРСОНАЛЬНЫМ ДАННЫМ

9. СВЕДЕНИЯ О РЕАЛИЗУЕМЫХ ТРЕБОВАНИЯХ К ЗАЩИТЕ ПЕРСОНАЛЬНЫХ ДАННЫХ

10. СОГЛАСИЕ НА ОБРАБОТКУ ПЕРСОНАЛЬНЫХ ДАННЫХ

11. ЗАКЛЮЧИТЕЛЬНЫЕ ПОЛОЖЕНИЯ

PRIVACY POLICY

LAST UPDATED ON DEC 01, 2020

Introduction

"Digital Service Provider" LLC (with certain affiliates under its control, the “Company”, “we” or “us”) collects information about you when you use our mobile, online and downloadable application and services ("web application").

This privacy policy explains how we collect, use, share and protect your information when you use our web application, as well as your rights and choices about such use and sharing.

By using our web application you acknowledge that you have read and understand the terms of this privacy policy, including how we use personal information.

Company located at the address set forth in Section 6 is the data controller for the information collected via our web application.

The privacy policy may be revised periodically, and any such revisions will be reflected by the “Effective Date” above. Please revisit this page to stay aware of any changes. If we make material changes to this privacy policy, we will provide you with additional notice of such changes by providing in-Product alerts or via email to you.

Summary

Our privacy policy will help explain what information we collect, how we use it and what options you have in relation to it. The key points of our privacy policy are provided below, however you can also learn more by simply following the link below or by continuing to scroll down:

1. Information we collect and receive

We collect personal information about you and the devices you use to access and interact with us and our web application. We collect:

2. Our use of collected information

Collected information may be used in the following ways:

  1. Registration information:

    1. to provide web application you request;

    2. to identify you when you sign-in;

    3. to give you access to your user preferences;

    4. to contact you for your views on our web application;

    5. to allow participation in special events or contests (if specifically approved by you);

    6. to notify you of changes or updates to our web application; and

    7. for marketing purposes, based on your communication preferences.

  2. Billing information:
    1. to verify your purchase of our web application and process any refunds;

    2. to reply to any queries and questions and to resolve billing-related problems;

    3. to carry out analysis and research to develop our web application; and

    4. to protect you and the web application by seeking to detect and prevent fraud or other acts in breach of our terms of service or policies relevant to the web application.

  3. Technical and device information:
    1. to provide you with an optimal experience;

    2. to understand how you interact with our web application;

    3. to provide web application you request;

    4. to measure and analyze the use and effectiveness of our web application;

    5. to understand which of your devices are using our web application;

    6. to provide safe and fair in-app environment;

    7. to track consents for use of personal information related to our web application;

    8. to customize and optimize the targeting of advertising both on our web application and across third party websites, apps and web application;

    9. to operate and improve our web application; and

    10. to fix errors.

  4. Your stories (your texts) and feedback:
    1. to reply to your questions or queries;

    2. to record comments and information which you provide on our web application; and

    3. to conduct analysis and research to improve and develop the web application.

  5. Third party information:
    1. to facilitate your in-app experience.

3. When we share information

We may share the information we collect about you (subject to the necessary security, contractual and transfer safeguards). These are some of the partners we may share your personal information with:

Personal information may be transferred to other countries where we or our service providers maintain operations. These countries may not have equivalent data protection laws to the country from where you access the web application.

4. Security and data retention

Your privacy is important to us and we take reasonable technical and organizational measures to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.

Your personal information will be kept by the Company for the duration of your relationship with us and for as long as you use our web application and may be retained for a period after this time if it is necessary and relevant to our legitimate operations, our terms with you and in accordance with applicable laws.

5. Your choices and rights

You have options and choices over how we use your personal information.

You can contact us directly with requests to correct, erase, restrict, object to, or move your personal information. If you do not want us to process and/or access your personal information, you may be unable to use our web application.

If you contact us with requests to restrict or erase your personal information, we will stop using it or remove your personal information from our web application, but we will store it within 1 year before complete removal.

6. Your questions and how to contact us

If you have any questions or comments about this policy or our practices you can contact us:

By email at: support@body-health.online




By writing to us at:

"DIGITAL SERVICE PROVIDER" LLC

Universitetskaya 7, Office 333

Innopolic, Tatarstan Republic, 420500

Russian Federation

More information

1. Information we collect

We collect personal information about you and the devices you use to access our web application and interact with us. We collect:

(a) Billing information

Our first-party partners may collect payment information such as credit or debit card details (including expiration dates) and other billing information such as your name and address in order to verify your purchases, process any refund payments, contact you to resolve any product issues, and/or deliver web application to you.

(b) Technical and device information

We collect information from your device and activity about the way you use our web application. We may also collect information about you from messages you post or send online in our app as well as what you look at and engage with. Information obtained from social features related to web application, such as public forums or chat, may be stored, copied or used by Company, the public, or third party companies.

By accessing our Product, we will collect technical information from your device, for example your location information where you choose to share this with us to facilitate the use of our web application. We will automatically collect information such as your IP address, how often and how long you interact with our web application, as well as other web application usage data. We also use software to enable us to provide safe and fair gaming environments for all users of our web application.

(c) Feedback:

We will collect personal information from the texts, messages and reviews you post, and when you contact us, for example with a question, problem or comment. If you contact our Support team by email we will keep copies of your correspondence with us for a limited period of time after completing your query.

(d) From third parties:

We collect information obtained from your use of our web application from third party analytics providers and other third parties to provide you and other users with an optimal experience, to facilitate use of the web application as advertised and to optimize our web application.

2. How we use the information we collect

We use the personal information we collect for the following purposes:

(a) Billing information

This information will enable us to verify your purchases with a first party store and to contact you in order to assist with resolving any problems with your purchases and to process any refund payments that you may be due.

We will also use and analyze information on transactions on your account for our legitimate interests by data matching or statistical analysis so that we can administer, support, improve and develop our business and to help us detect and prevent fraud or other illegal activities or acts prohibited by our terms of service or any policies applicable to the web application.

(b) Technical and device information

We analyze information about how you engage with our web application to understand how our web application is used and to provide you with an optimal in-app experience, such as by rolling out performance-optimizing updates for our web application. We use anonymous data in order to analyze and produce statistics relating to the habits, usage patterns and demographics of users as a group or as individuals.

(c) Feedback

We use your feedback to reply to your questions or queries, to provide customer support and resolve problems relating to our web application under the relevant terms of service. We will also publish reviews that you submit to us for this purpose about the web application and will conduct analysis of feedback for the purpose of improving and developing the web application

(d) From and to third parties:

We use information obtained from third parties to provide you with an optimal experience, to facilitate use of the web application as advertised, to enable you to play our web application on various platforms

3. When we share information

In delivering the web application to you, we may share your personal information with:

We do not control information which is sent from your device to third parties, and may not control certain information which is sent from our web application to third parties, including social media platforms, analytics companies that receive information in the normal course of your online activities.

4. Where information is stored

We store your personal information in the Russian Federation.

For users in Russian Federation: we record, systematize, accumulate, store, clarify (updates, changes), extracts personal information of the citizens of the Russian Federation using databases located on the territory of the Russian Federation.

Russian Federation is a jurisdiction outside the European Economic Area, which has not been recognized by the European Commission as providing an adequate level of personal data protection. Therefore, we have taken appropriate measures to ensure personal information is handled according to applicable EU data protection rules.

In particular, we rely upon Standard Contractual Clauses approved by the European Commission to ensure an adequate level of protection for your personal information transferred to Russian Federation. A copy of these Standard Contractual Clauses can be obtained upon request.

If you are located in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then by using our web application you provide us with your express and unambiguous consent to such transfer, storage, and/or processing of the information in other jurisdictions, including Russian Federation.

5. Security and data retention

We take reasonable physical, technical and organizational measures, to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.

Your personal information will be retained by us for the duration of your use or access to our web application and may be retained for a period after this time as necessary and relevant to our legitimate operations, our terms with you and in accordance with applicable laws and obligations. This may include retention necessary to meet our tax reporting requirements as well as time required to enforce the relevant terms of service, any requirements or to identify, issue or resolve legal proceedings.

We may retain a record of your stated objection to the processing of your data, including in respect of an objection to receiving marketing communications, for the sole purpose of ensuring that we can continue to respect your wishes to not contact you further, during the term of your objection.

We will take appropriate steps to seek to destroy or permanently de-identify personal information at the point this information is no longer needed by us for our business or legal purposes, when you withdraw consent (as applicable) or at your request.

6. Your choices and rights

You have options and choices over how we use your information. We provide you with tools to access and update specific information relating to your use of the web application at any time. If you need to sign in to access our web application, you can update and amend your key contact information directly.

We respect the rights you may have under applicable law to request access to your personal information and where applicable, to request to receive that information in a commonly used electronic format (or ask for this information to be provided in that format to a third party where feasible). You may also have the right under applicable law to request the correction or erasure of your personal information, to seek to object to the further processing under certain circumstances of your information or to request that the processing of specific information about you is restricted while we verify or investigate your concerns about this information. We do not verify the correctness of your personal information.

Please contact us as described in Section 7 “Contact Us” to exercise any of these rights.

In addition, if you believe that we have not responded to your privacy-related inquiry or your inquiry has not been satisfactorily addressed, please contact us (support@body-health.online)

7. Your questions and how to contact us

If you have any questions or comments about this policy or our practices you can contact us:

By email at: support@body-health.online

By writing to us at:



"DIGITAL SERVICE PROVIDER" LLC

Universitetskaya 7, Office 333

Innopolic, Tatarstan Republic, 420500

Russian Federation