Privacy Policy

1.
WHAT THIS PRIVACY POLICY COVERS
 

This Privacy Policy (hereinafter, “Policy”) covers any information about users of our products and services (“You”) that may include personal data as defined by applicable laws and regulations (hereinafter, “Personal information”), which DeloZvuka LLC and (or) its affiliated entities, may obtain when you use any of the DeloZvuka websites, programs, products or services or any other program, product or service (collectively, the “Services”), information about which you can find on delozvuka.ru, and other DeloZvuka websites (collectively, the “Sites”), and as well as during the performance of any contract or agreement DeloZvuka concludes with you in relation to your using the Services. Also, Personal information can be obtained by DeloZvuka through its partners (“Partners”), such as advertising partners, who provide you with access to or let you use websites, programs, products or services owned or operated by them. Partners can provide Personal information to DeloZvuka only as stipulated by applicable laws and regulations and in accordance with special agreements between DeloZvuka and each of the Partners.
 
Please note that your using any of the Sites and/or Services may be subject to additional terms and conditions, which may amend and/or supplement this Policy and (or) include specific privacy terms in relevant parts of legal documents for such Sites and/or Services.

2.
WHO PROCESSES YOUR PERSONAL INFORMATION
 

To provide you with access to the Sites and Services, your Personal information is collected and used by DeloZvuka which may include DeloZvuka LLC, a company incorporated under Russian law, with a head office registered at 191040, pr-kt Ligovskii, dom 73, office 403, Saint-Petersburg, Russia (“DeloZvuka” LLC), or its affiliates for particular Services or in specific jurisdictions. You can find information about the entity, which provides the particular Service in the relevant Service’s terms of use.

3.
WHAT IS THE PURPOSE OF THIS POLICY
 

Privacy and security of your Personal information are extremely important to us. When you use the Sites and/or Services, DeloZvuka processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations.
 

As part of our commitment to protecting your Personal information, we use this Policy to transparently inform you about the following:

a
why and how your Personal information is collected and used (also, “processed”) by DeloZvuka when you access the Sites or Services;

b
DeloZvuka’s role and responsibilities in this context as the legal entity deciding why and how your Personal information is processed;

c
what instruments you may use to limit the amount of Personal information collected by DeloZvuka; and

d
what your rights are in relation to the above processing.

4.
WHAT TYPE OF PERSONAL INFORMATION IS COLLECTED BY DELOZVUKA
 

Personal information collected when you use the Sites and/or Services may differ depending on whether you access the Sites or Services while logged in to your DeloZvuka user account or without logging in. When you are logged in to your DeloZvuka user account as you are using the Sites or Services, Personal information collected by DeloZvuka may be collated and combined with other Personal information (such as your identity, contact details, age and gender, if you shared this information with us) collected by DeloZvuka in your user account. DeloZvuka does not verify Personal information provided by you unless otherwise provided in the Terms of Use or License Agreement of relevant Services, and does not decide the its credibility or whether you have the legal capacity required. However, DeloZvuka assumes that the information you provide is true, sufficiently complete and up-to-date.
 
Personal information collected by DeloZvuka when you access, interact with or operate the Sites and/or Services includes:

I
information provided by you when you register (create) a user account, such as your name, mobile phone number, address and age;

II
electronic data (http headers, IP address, cookies, web beacons/pixel tags, browser information, information about your hardware and software);

III
date and time of accessing the Sites or Services;

IV
information related to your activity when using the Sites or Services (e.g. your search history);

V
(geo)location information;

VI
other information about you that needs to be processed according to the terms and conditions of any specific DeloZvuka Site or Service; and

VII
information about you that we may receive from our Partners in accordance with an agreement you made with this Partner and an agreement between DeloZvuka and this Partner.

 
In addition, DeloZvuka uses cookies and web beacons (including pixel tags) to collect your Personal information and associate this Personal information with your device and web browser (see Section 11 below).
 
DeloZvuka does not actively collect any sensitive personal data (such as racial origins, political opinions, health or biometric data) unless specified in Terms of Use of relevant Services. However, you may voluntarily provide us which such data and we may process it as part of providing you with our Services. As we do not know in advance the potentially sensitive nature of the personal data you may provide to us, you must be aware that we may not be able to request your consent with such processing.
 
DeloZvuka does not perform any form of profiling, which has the potential to significantly impact your rights and freedoms in accordance with applicable laws.

5.
WHAT ARE THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL INFORMATION AND THE PURPOSES OF IT
 
DeloZvuka is not allowed to process your Personal information if it does not have a valid legal ground. DeloZvuka will therefore only process your Personal information if:

I
the processing is necessary to perform our contractual obligations towards you including providing you with Sites and/or Services;

II
the processing is necessary to comply with our legal or regulatory obligations;

III
in case it is provided by applicable law, the processing is necessary for the legitimate interests of DeloZvuka and does not unduly affect your interests or fundamental rights and freedoms. Please note that when we process your Personal information on this basis, we will always seek to maintain a balance between our legitimate interest and the protection of your privacy. Examples of such ‘legitimate interests’ immediately above are:

a
to better understand how you interact with our Sites and/or Services;

b
to enhance, maintaining accessibility, modify, personalize or otherwise improve the Sites and Services for the benefit of all users; and

c
to offer you other products and services from DeloZvuka or other companies which we think can be of interest to you.

IV
for specific purposes or if consent is required under the applicable laws and regulations, we may ask your consent for processing of your Personal information. In those jurisdictions in which consent is the legal basis, you provide such consent by agreeing to use our Sites and/or Services. We hereby inform you, and you hereby acknowledge, that you have no legal obligation to provide us with any Personal Information when you use the Sites or Services, and the provision of it is solely based on your free will. However, you are aware that without the provision of Personal Information, we will not be able to provide you with Services and your use of the Sites will be limited.
 
DeloZvuka always processes your Personal information for a specific purpose and only processes Personal information which is relevant to achieve that purpose. In particular, we process your Personal information for the following purposes:

I
to provide you with the Sites and/or Services;

II
to provide you with access to your user account;

III
to contact you to notify and/or inform you or request information from you in relation to the Sites and Services, or to execute our agreements with you or process your request or application;

IV
to personalize advertisements and/or commercial offers based on your preferences and other Personal information available to DeloZvuka.;

V
to improve user experience, including offering more personalized Sites and/or Services, as well as improving other DeloZvuka products, applications and services;

VI
to develop new products, applications and services;

VII
to protect your rights and the rights of DeloZvuka; and

VIII
to collect, process and present statistical data or big data, or perform other research and/or analysis of Personal information.

6.
HOW DELOZVUKA PROTECTS YOUR PERSONAL INFORMATION
 

In most cases, Personal information is processed automatically without access to it by our staff. However, if such access is necessary, your Personal information can be accessed only by those DeloZvuka employees whose professional tasks require using this information. To protect your Personal information and ensure its confidentiality, these employees must comply with internal rules and follow protocols for processing Personal information. They are also required to follow all technical and organizational security measures protecting your Personal information.
 
DeloZvuka has also implemented adequate technical and organizational measures to protect Personal information against unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of Personal information.

7.
WHO ELSE HAS ACCESS TO YOUR PERSONAL INFORMATION AND WHO IS IT SHARED WITH
 

7.1.
Within the DeloZvuka
 
DeloZvuka may transfer your Personal information to our employees (within the limits set out in Section 6 above. Please note that the level of protection of Personal Information in some countries may not be identical to the level required in your jurisdiction, by using the Services you consent to such transfer. In all cases, Personal information will continue to be processed only for the purposes set out in Section 5 hereof unless otherwise stated by the terms of use of the Sites or Services.

7.2.
Outside the DeloZvuka
 
DeloZvuka may also transfer Personal information to third parties outside the DeloZvuka to complete the purposes listed in Section 5 above. Please note that the level of protection of Personal Information in some countries may not be identical to the level in your jurisdiction and by using the Services you consent to such transfer. Such third parties may include:

I
Partners, such as media publishers, advertising networks and other partners providing DeloZvuka with services related to the placement and display of advertisement on the websites, programs, products and/or services owned or operated by such Partners;

II
Advertisers or other Partners or Services; and third parties who process Personal information, such as our (IT) systems providers and/or consultants.
DeloZvuka may also transfer Personal information to the following third parties:

I
any third party to whom we assign or novate any of our rights or obligations under a relevant agreement;
II
any national or international regulatory, enforcement, exchange body, central or local government department and other statutory or public bodies or court where we are required to do so by applicable law or regulation at their request;

III
third parties if you expressed your consent to such transfer or transfer of your Personal information is required for your use of a certain Service or performance of a particular agreement or contract with you;

IV
any third party to ensure legal protection for DeloZvuka and/or the third parties if you violate the User Agreement of any of the DeloZvuka Services (https://delozvuka.ru/#!terms_of_use), this Policy or the terms of use of specific Services, or if there is a threat of such violation.

8.
WHERE YOUR PERSONAL INFORMATION IS STORED AND PROCESSED
 
DeloZvuka stores Personal information in the Russian Federation.
 
DeloZvuka records, systematizes, accumulates, stores, clarification (updates, changes), extracts Personal information of the citizens of the Russian Federation using databases located on the territory of the Russian Federation.
 
If you are located in a jurisdiction where transfer of your Personal Information to another jurisdiction requires your consent, then by using the Sites or Services you provide DeloZvuka with your express and unambiguous consent to such transfer, storage, and/or processing of the information in other jurisdictions, including Russia.

9.
HOW LONG WE STORE YOUR PERSONAL INFORMATION
 
DeloZvuka will only keep your Personal information for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements.
 
If you wish to have any Personal information removed from our databases, you can have it removed via your DeloZvuka account or using interface of the Sites or Services (where applicable).

10.
YOUR RIGHTS

10.1.
What are your rights
 
If it is provided by applicable law, you have a right of access to your Personal information as processed by DeloZvuka under this Policy.
If you believe that any information we hold about you is incorrect or incomplete, you can log in to your user account and correct your Personal information yourself.
 
If it is provided by applicable law, you also have the right to:

a
request erasure of your Personal information or certain parts of it, as well as withdraw consent to the processing of the Personal information;

b
request the restriction of the processing of your Personal information;

c
object to the processing of your Personal information if it is provided by applicable law.

DeloZvuka will honour any such requests or objections as required under applicable law.
To the extent provided by applicable law, you may be subject to other rights not specifically mentioned herein.

10.2.
How can you exercise your rights
 
To exercise the above rights, please log in to your user account, which will provide you with the option to do so, or in case of absence of special function in user account interface please contact DeloZvuka (see Section 13 hereof).
 
If you are not satisfied with how DeloZvuka processes your Personal information, please let us know and we will investigate your concern. If you are not satisfied with DeloZvuka’s response, you have the right to make a complaint to the competent data protection authority.

11.
WHY WE USE COOKIES AND OTHER SIMILAR TECHNOLOGIES ON THE SITES OR USING THE SERVICES
 

11.1.
What are cookies and what does DeloZvuka use them for
 
Cookies are small text files placed on the device you use to access our Sites. They contain information that is collected from your device and sent back to the Sites on each subsequent visit so as to remember your actions and preferences over time.
The following types of cookies are used on the Sites:

a
strictly necessary cookies / technical cookies: these cookies are required to run the Sites and provide you with the Services and may, among other, allow DeloZvuka to identify your hardware and software, including your browser type;

b
statistical / analytic cookies: these cookies enable us to recognize users, count the number of users and collect information such as your actions on the Sites and the Services, including the web pages you visit and the content you retrieve;

c
performance cookies: these cookies collect information about how users interact with our Sites and Services, enabling us to identify errors and test new functionalities to improve the performance of the Sites and the Services;

d
functionality cookies: these cookies enable us to provide specific functionalities in order to improve your experience on the Sites, for example by storing your preferences (e.g. language and location);

e
(third party) tracking / advertising cookies: these cookies collect information about users, sources of traffic, page visits and advertising displayed to you and followed by you. They enable us to display advertising which may be of interest to you based on collected Personal information. These cookies are also used for statistical and research purposes.

11.2.
How long are those cookies stored on your device
 
DeloZvuka only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter.

11.3.
Who else has access to the information contained in the cookies
 
Personal information collected through cookies placed on your device may be transmitted to and accessed by DeloZvuka or the third parties referred to in Section 7 hereof. The use of Personal information outside of the Sites for advertising purposes, if any, may be subject to separate policies available on the above third parties’ websites. DeloZvuka or those third parties might also provide you with a possibility to opt out of personalized advertising, which shall be subject to laws and regulations applicable to such products, utilities and offerings.
 
The first time that you access the Sites, your approval for the use of these cookies may be requested. If after you have approved the use of cookies you want to make another choice, you can do this by deleting the cookies stored by your browser (usually via the options in your browser’s Privacy menu – please refer to your browser’s manual or developer’s website). The popup requesting your approval may then show up again and you can make a different choice. If you do not consent to the use of cookies, certain features of the Sites might become unavailable, which may affect your browsing experience. You may also set up your browser preferences to accept or decline by default all cookies or cookies from specific websites, including the DeloZvuka Sites. If you approved the use of cookies on one of the DeloZvuka Sites, we assume that the use of cookies on all Sites was approved by you.
 
DeloZvuka may also use web beacons (pixel tags) in order to access the cookies previously placed on your computer for the following purposes:

I
to track your actions on the Sites and when using the Services, by accessing and interacting with the cookies stored on your computer;

II
to collect statistical information related to operating the Sites, the Services or products, utilities, advertisements or other DeloZvuka offerings.

12.
UPDATES TO THIS POLICY
 

This Policy may be subject to amendments. DeloZvuka shall be entitled to make such amendments at its own discretion, including, without limitation, to reflect changes in applicable legislation or amendments to the Sites and/or Services.
 
DeloZvuka undertakes not to introduce significant changes, imposing additional obligations or reducing your rights under this Policy without proper notice to you. You will be notified about such changes. If applicable, changes will be announced on the Site or Services (e.g. via a pop-up or web banner) prior to such changes taking effect, and you may also be notified via other channels (e.g. by email) if you have provided us with your contact details.

13.
QUESTIONS AND SUGGESTIONS
 
We welcome your questions or suggestions concerning implementation of or amendments to this Policy.
Please send all your suggestions or questions about this Policy to the Customer Support Service of DeloZvuka (hello@delozvuka.ru), or to the address 191040, Saint Petersburg, Ligovsky prospekt, 73-403, "DeloZvuka" LLC..
 
You can also use this address to exercise your rights or report any inaccuracies in your Personal information or protest its processing.
Updated: 15.04.2020