Date of publication: 03.02.2021
The current version of the document is available at:
2. The person processing the information.
3. The purpose of this PC.
Guided by the Contractor’s obligation to protect the User’s Personal Information, the Contractor, in this PC, most fully informs the User about the following:
1) why and how the Contractor collects and uses/processes the User’s Personal Information;
2) the scope of the Contractor’s duties as a person who has the right to engage in business activities and is entitled to make decisions on the methods and purposes of processing the User’s Personal Information;
3) tools available to the User to reduce the amount of information collected by the Contractor about the User;
4) the scope of the User’s rights within the scope of the processing of Personal Information.
4. Personal information about the User collected by the Contractor.
The Contractor may collect the following categories of Personal Information about the User while using the functionality of the Service and the Site:
1) Personal information provided by the User during registration (creating an Account in the Messenger), such as last name, first name, username, User language code, User ID, but not limited to the list (if applicable to the circumstances);
2) Personal information provided by the User during registration and / or authorization, when taking a survey on the CHATKEEPER.APP Website (creating an Account in the Service), such as last name, first name, phone number, address and age, but not limited to the list;
3) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information);
4) date and time of access to the functionality of the Service and the Site;
5) information about a particular User activity during the use of the functionality of the Service and the Site;
6) other information about the User that is available and necessary for processing in accordance with the terms governing the use of the Service functionality and the Contractor’s Website directly;
7) information about the User that the Contractor receives from the Partners (if applicable to the current situation) in accordance with the terms of contracts and agreements concluded between the User and the relevant Partner, as well as contracts and agreements concluded between the Contractor and the Partner.
It should be noted that the Contractor does not receive the User’s personal data from the Messenger, it is not possible to clearly identify the received data with any particular person, since:
– the User’s name in the Message is a pseudonym, its choice is limited to the User’s imagination, it can also not be interpreted as the real name and/or surname of the User, it can not be identified with any particular person;
– a unique User ID within the Messenger is a certain number of registration of an alias in the Messenger system, this id does not allow you to determine the address and/or geolocation of the User, as well as any other data that allows you to identify them with any particular person;
– User image-Avatar, a public graphic representation of the User, where the content of the image is limited to the User’s imagination, the User personally places such an image in the public space, but it is impossible to establish the fact that this image belongs directly to a specific person who is the User.
This information allows the Performer to identify only the Account in the Messenger system, and not a specific person.
No information provided by the Messenger with the consent of the Account owner gives the Contractor the opportunity to determine its belonging to a particular territorial jurisdiction.
In this case, to personalize the Account, the Contractor surveys the User. The collected information is used for the purpose of fulfilling the terms of the Agreement and for the period of its validity.
For example, the Contractor may collect and process Personal Information received from the User: at the time of registration/authorization; when making purchases; when the User subscribes to the Contractor’s newsletters; when the User responds to surveys or marketing messages; when the User views the Site or uses the available functionality of the Service.
The Contractor does not purposefully collect specific personal data (for example, information about health, racial origin, biometric data, political views). At the same time, the User has the opportunity to independently provide this or that Personal Information to the Contractor, in which case the Contractor will process it as part of the provision of services to provide the functionality of the Service. At the same time, the User must take into account that the Contractor cannot request the User’s consent to such processing, since it is not aware in advance of the likely sensitive nature of the Personal Information that the User may provide to the Contractor.
By collecting data, the Contractor does not seek to create an “image” of the User to the extent that this may significantly affect his rights and freedoms in accordance with applicable law.
The Contractor does not violate the rights of the User who used the “Do not track” (DNT) browser functionality and does not track the signal, does not set cookies, does not use advertising. In this case, the User does not have the opportunity to use the CHATKEEPER.APP website and the functionality of the Service.
In accordance with applicable law, the Contractor does not accept or process Personal Information from minors, including children under the age of 13. The Contractor does not offer goods and / or services to minors, including children under the age of 13.
5. Legal basis and purpose of processing Personal Information about the User.
5.1 The Contractor does not have the right to process the User’s Personal Information without sufficient legal grounds. In this regard, the Contractor processes the User’s Personal Information under the following conditions, if:
1) processing is necessary to fulfill the Contractor’s contractual obligations to the User, including ensuring the operation of the Service and Site functionality (for example, providing the User with the results of processing for his search queries);
2) processing is necessary to comply with legal obligations;
3) where this is provided for by applicable law, the processing is necessary to ensure the legitimate interests of the Contractor, if such processing does not significantly affect the interests of the User, his fundamental rights and freedoms.
Please note that when processing the User’s Personal Information on this basis, the Contractor will always strive to maintain a balance between its legitimate interests and the protection of the User’s privacy.
5.2 The Contractor processes the User’s Personal Information to ensure its legitimate interests, in accordance with the list, but not limited to it:
1) to understand the processes of User interaction with the functionality of the Service and the Site when receiving the services of the Contractor;
2) to make improvements and other improvements to the functionality of the Service and the Site in the interests of all Users who interact with the Contractor;
3) to expand the capabilities, functionality, available tool and in order to diversify the proposed list of services provided to the User by means of the functionality of the Service and the CHATKEEPER.APP Site, which will be in demand, in which Users will be interested (for example, displaying ads to the User taking into account the aspects of interest to the User);
4) in accordance with the requirements of the applicable legislation, the Contractor may request a separate consent to the processing of the User’s Personal Information. For jurisdictions where consent is recognized as a separate legal basis, the beginning of the User’s use of the CHATKEEPER.APP Website and/or any functionality of the Contractor’s Service expresses the User’s consent to such processing. The Contractor hereby informs the User, and the User confirms that the User has no obligation to provide the Contractor with any Personal Information when the User uses the functionality of the Service and the Site and / or the services and is based solely on the free will of the User. At the same time, the User is aware that without providing Personal Information, the Contractor will not be able to provide the User with the opportunity to use the functionality of the Service, and the use of the Site will not be available.
5.3 The Contractor always processes the User’s Personal Information for certain purposes and only the Personal Information that is relevant to the achievement of such goals. Namely, the Contractor processes the User’s Personal Information for the following purposes:
1) providing the User with access to the functionality of the Service and / or the Site (among other things, providing the results of processing search queries taking into account the needs of the User and other Personal Information about him available to the Contractor);
2) providing access to the User’s Account, including the User’s personal account and other functionality of the Service and the Site;
3) communication with the User to send him notifications, requests and other information related to the operation of the functionality of the Service and / or the Site, to fulfill the terms of the agreements concluded with the User and to process his requests and requests;
4) personalization of advertising and offers, taking into account the User’s preferences and other Personal information about the User available to the Performer;
5) improving the comfort of using the functionality of the Service and the Site, including to improve the services provided by the Contractor;
6) provision of services using new products, utilities and offers of the Contractor;
7) protection of the rights of the User and the rights of the Performer;
8) collection, processing and presentation of statistical data and other research.
6. Methods of protecting the User’s Personal Information used by the Contractor.
The User’s personal information is stored in secure networks and is available only to a limited number of persons who are obliged to maintain the confidentiality of the information. However, all confidential information that you provide is encrypted using Secure Socket Layer (SSL) technology.
For the most part, Personal Information is processed automatically without access to it by any of the Contractor’s employees. If such access is necessary, it can only be granted to the employee of the Contractor who needs such access to perform the assigned tasks. To protect and ensure the confidentiality of data, all employees must comply with internal rules and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect the User’s Personal Information.
The Contractor also uses appropriate technical and organizational resources to protect Personal Information from unauthorized, accidental or illegal destruction, alteration, loss, unfair use, access or disclosure, and other illegal forms of processing. The existing security measures are implemented taking into account the cost of their implementation, the current state of the art, and the risks associated with the processing and nature of Personal Information.
All transactions are processed through the gateway provider with which the Contractor has entered into a contract. Information about transactions is not stored or processed on the Contractor’s Website and Service.
7. Persons who have access or the right to get acquainted with the User’s Personal Information.
7.1 Within the Contractor’s working group.
7.2 Outside of the Performer’s group.
Such third parties may include:
1) Partners, such as owners of websites and applications, advertising networks and other partners, including those providing services to the Contractor related to the placement and display of advertising on websites, programs, products or services that are owned or controlled by such partners;
2) advertisers or other Partners who display ads for the User on the Site and / or using the functionality of the Service, as well as such Partners as information service providers or consultants.
The Contractor may transfer Personal Information to third parties that are not part of the Contractor’s group:
a) to third parties in respect of whom the assignment of rights or obligations has been made, or novation under the relevant agreement;
b) any national and / or international regulatory authority, law enforcement agencies, central or local executive authorities, other official or state bodies or courts, in respect of which the Contractor is required to provide information in accordance with applicable law upon request;
c) to third parties, if the User has agreed to the transfer of Personal Information or the transfer of Personal Information is required to provide the User with the appropriate functionality or Service, as well as to fulfill a certain agreement or contract concluded with the User;
8. The place of storage and processing of the User’s Personal Information.
The User’s personal information will be stored in the Russian Federation and / or in the EEA.
In relation to citizens of the Russian Federation: The Contractor performs the systematization, recording, accumulation, storage, updating, modification, extraction of personal data of Users using databases located on the territory of the Russian Federation.
From the position of the European Commission, an adequate level of protection of Personal Information is not provided on the territory of the Russian Federation. Therefore, the Contractor has taken appropriate measures to ensure data protection in accordance with the current rules established by the EU, namely, the General Data Protection Regulation (GDPR), which entered into force in Europe on May 25, 2018. It should be noted that the European Convention (from 28.01.1981, ETS No. 108, as amended) defines the main feature of personal data as the possibility of using it to accurately identify a particular individual.
In the case of Users from the EEC, Switzerland or Israel who are located in accordance with the above-mentioned regulation, the Contractor may transfer such data using Standard Contractual Terms approved by the European Commission to ensure an adequate level of protection. The User can obtain a copy of the Standard Contract Terms upon request.
If the User’s territorial jurisdiction requires their consent to the transfer and / or storage of Personal Information to another jurisdiction, then by using the functionality of the Service and/or the CHATKEEPER.APP Website and its subdomains, the User gives the Contractor their obvious and unambiguous consent to such transfer and / or storage, as well as to the processing of Personal Information in other jurisdictions, including the territory of the Russian Federation.
9. Terms of storage of the User’s Personal Information.
The Contractor stores the User’s Personal Information for as long as it is necessary to achieve the purpose for which it was collected, or to comply with the requirements of applicable law.
In accordance with applicable laws, unless otherwise required by agreement with the User (provided that this applies to the current situation), information stored in the Service’s systems or on the CHATKEEPER.APP Site will be stored as long as the User has an Account in the Messenger, but it can be deleted by the User personally. Please note that after deleting the Account in the Messenger, access to the CHATKEEPER.APP Site and the Service will not be available to the User.
If desired, the User can delete their Personal Information selected for these purposes from the Contractor’s databases. For these purposes, the User must contact the Contractor using the information specified in Section 13 of this PC.
10. The User’s rights in relation to the Personal Information provided.
10.1 User Rights.
If the User assumes that any information that the Contractor stores about him is incorrect or incomplete, he can log in to his Account in the Messenger and correct his Personal Information independently, as well as, if applicable, make corrections on the CHATKEEPER.APP website.
However, within the limits provided for by applicable law, the User has the right to:
– request the deletion of the User’s Personal Information (if applicable to the current situation) or part of it, as well as revoke consent to the processing of the User’s Personal Information;
– require restrictions on the processing of the User’s Personal Information;
– request a copy of the Standard Contractual Terms that allow the transfer of the User’s Personal Information to other jurisdictions, including the territory of the Russian Federation;
– object to the processing of the User’s Personal Information, if this is provided for by applicable law.
The Contractor will accept and process the above requests in accordance with applicable law.
In addition, the User has the right not to receive e – mail messages from the Contractor in the form of a “commercial e-mail message” defined as “any e-mail message whose main purpose is commercial advertising or promotion of commercial products and services (including commercial content on the Internet site)”. In accordance with applicable law, the User must contact the Contractor using the information specified in Section 13 of this Agreement and the Contractor will immediately remove the User from such correspondence.
At the same time, the Contractor allows the User to deactivate his Account if he wants to reactivate it later. However, if the User wishes to completely delete the Personal Information, he can contact the Contractor by email (email@example.com). Such a request will serve as the basis for the complete removal of information about the User from the Contractor’s systems. The Contractor does not allow the User to delete information directly, due to the fact that there were cases when the User mistakenly deleted their information, and such information cannot be restored.
When the User uses the Service, the transfer of Personal Information is carried out with his consent, expressing the free will and interest of the User (including on the basis of an accepted Offer) and is not an obligation under the law.
10.2 Ways to implement User rights.
If the User wants to exercise any of the rights specified in clause 10.1 of this PC, he must contact the Contractor using the information specified in Section 13 of this PC.
If the User is not satisfied with the result and / or methods of processing Personal Information, this fact must be reported to the Contractor, and the Contractor will consider the User’s claim.
If the User is not satisfied with the Contractor’s response, he has the right to contact the competent authority.
11. Cookies and other similar technologies on the Site, the policy of their use when using the functionality of the Service.
11.1 Definition of cookies and similar technologies, for which they are used by the Contractor.
Cookies are small data files that are received and processed by the device that the User uses to access the functionality of the Service and the Sites. They store information that is collected from the User’s device and sent back to the Site at each subsequent visit in order to remember the User’s actions and preferences over a period of time, which significantly helps the User’s work.
Cookies help a website recognize your device the next time you visit it. This task can be performed by web beacons, Indexed DB, local storage, browser cache, HSTS status cache, or other similar files. The contractor applies the term “cookie” to files that collect information in the above manner.
The above files and cookies perform many tasks, for example:
– help you remember and process information about products in the User’s shopping cart;
– help to understand the User’s preferences based on previous or current activity on the Site, and this allows the Performer to improve and improve the services provided to the User;
– facilitate and simplify the collection of aggregated data on traffic and interaction with the Site, which in the future will allow the Performer to offer a more functional tool for working with the Site;
– make it easier to navigate between pages, save your settings, and generally improve your experience with the website;
– make the interaction between the User and the website faster and easier.
Cookies used and similar files listed above:
– technical files: these files are intended to collect information about User interaction with the Site and / or Service, which allows you to improve the performance of Sites and Services by means of detecting errors and testing new functionality;
– strictly necessary technical files: these files are necessary for the operation of the Site and the provision of the Service to the User; also, with their help, the Contractor identifies the User’s hardware and software, including the type of browser;
– statistical or analytical files: such files are used to identify Users, determine their number, collect information about the User’s activity on the Site and in the Service, collect information about the web pages visited by the User and the content received;
– function files: files of this type allow you to facilitate the use of Sites by providing certain functions, while preserving the User’s preferences (for example, the User’s language);
– (third-party) tracking files or advertising files: the purpose of such files is to collect information about Users, traffic sources, visited pages and ads displayed for them, including the one that led the User to the advertised page. Such files allow you to display ads that may be of interest to the User, based on the analysis of Personal Information collected about him. The scope of their application is statistical and research purposes.
By studying the data obtained through cookies, the Contractor creates and implements useful functionality of the Service that the User uses, conducts marketing and statistical research, corrects errors in the Service, tests new features to improve the performance of the Service, personalizes them and shows the most relevant and relevant information for the User.
11.2 Terms of storage of cookies and similar files on the User’s device.
11.3 Access to information contained in cookies and similar files.
The Contractor and/or third parties (if applicable to the current situation) specified in Section 7 of this PC have the right to access and transfer Personal Information collected using the files specified in clause 11.1 of this PC installed on the User’s device. The use of Personal Information for advertising purposes outside the Site, if possible, may be subject to separate user agreements available on third-party websites. The User is given the opportunity to opt out of the personalization of advertising by the Contractor and/or third parties, which is subject to the applicable legislation applicable to such products and offers.
11.4 Applicable technologies of third-party websites.
At the discretion of the Contractor, products or services of third-party websites are used or offered on the Contractor’s Website, including:
– GoogleAnalytics (https://analytics.google.com/)
– YandexMetrika (https://metrika.yandex.ru/)
– Telegram login widget (https://core.telegram.org/widgets/login)
– other products or services of third-party websites.
Such third-party products or services have separate and independent privacy policies. Therefore, the Contractor is not responsible or liable for the content and activities of these linked sites. We strive to protect our resources and Users, and therefore, we welcome any feedback about these sites.
12. Update of this Policy.
This PC may be changed by the Contractor, in the following cases::
– when the relevant changes are related to changes in the applicable legislation;
– when the corresponding changes are related to changes in the operation of the CHATKEEPER.APP Site and its subdomains, the functionality of the Service;
– in other cases.
The Contractor makes changes at its discretion as necessary and without warning, unilaterally.
The Contractor does not seek to further encumber or restrict the User in his rights established by this PC and intends to notify the User about the changes made in personal messages.
13. Questions and suggestions
The Contractor welcomes questions and suggestions from Users regarding this PC.
If you have any questions about privacy and our data policy, please contact the Contractor.
Use @chatkeeperbot and the /get_gdpr_data command to find out how to get a copy of your data, as well as use your email address firstname.lastname@example.org to leave a request, which we will respond to as soon as possible.