PRIVACY POLICY FOR THE MOBILE APPLICATION Righthub

Moscow, February 12, 2025





1. Basic concepts and general provisions

1. The following terms are used within the framework of this Privacy Policy:

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


1.2. "User" is an individual who accepts the terms of the User Agreement, has full legal capacity, has his own mobile device with a mobile device number assigned to him and who has downloaded the Mobile Application to a smartphone, tablet, watch or any other mobile device and/or activated such Mobile Application on one of the specified devices.



1.3. Copyright Holder (Operator)- Rezvov Andrey Vladimirovich,Address: 129226, Moscow, Selskokhozyaistvennaya st., bld. 20, bld. 3, contact information: [email protected] ,to whomowns exclusive rights to the Mobile Application and processes personal data in accordance with the provisions of this Policy.

1.4. "Mobile application" is software (with all existing additions and improvements), the exclusive rights to which belong to the Copyright Holder, and intended for operation on smartphones, tablets, and other mobile devices, and developed for a specific platform (iOS, Android) anddistributed through the Google Play store and the App Store.

1.5. "Policy" - means this Privacy Policy of the mobile application (with all existing additions and changes

1.6. Processing of personal data - any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools, with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.7. Automated processing of personal data - processing of personal data using computer technology.

1.8. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of persons.

1.9. Blocking of personal data - temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data).

1.10. Destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed.

1.11. The Operator's Server is a software tool for running service software, located on a dedicated or specialized computer or virtual server and forming a single structure for ensuring the operability of the mobile application and data storage.

1.12. Personal data information system - a set of personal data contained in databases and information technologies and technical means on the Operator's server that ensure their processing.

1.13. Device - a mobile technical device (smartphone, tablet or other device) with access to the Internet, on which the Mobile Application is installed.

1.14. User Agreement - an agreement concluded between the Copyright Holder and the User regarding the procedure, rules and conditions for the User's use of the Mobile Application. The User accedes to such an agreement and has no right to make and/or demand that any changes or additions be made to it.

1.15. Device identifier - unique data that allows identification of the User's device on which the Mobile Application is installed, provided by the device itself or calculated by the Mobile Application.

1.16. The installation of the Mobile Application by the User on his/her device or the use of the Mobile Application in any other way means the User’s unconditional consent to the terms of this Policy, including the User’s consent to the processing of his/her personal data by the Copyright Holder, in cases where the provisions of the current legislation require such consent.

1.17. This Policy applies to all information that the Mobile Application may receive from the User’s Device during the User’s use of the Mobile Application.


1.18. By installing the Mobile Application, the User unconditionally agrees to this Policy and all the conditions for processing information received from the User's device specified therein. In case of disagreement with this Policy, the User must refrain from using the Mobile Application.



1.19. The Copyright Holder does not control and is not responsible for the content, Policy or practices of any third-party sites or services that the User may access via links available in the Mobile Application. Such sites may collect or request other personal information from the User, and may also perform other actions.

1.20. This Policy applies only to the Mobile Application. The Copyright Holder does not control and is not responsible for information (consequences of its transfer) transferred by the User to a third party, if such transfer was performed on a third party resource to which the User could follow links from the Mobile Application.

1.21. The Copyright Holder does not verify the accuracy of personal information provided by Users and does not exercise control over their legal capacity.

1.22. The Copyright Holder assumes that the information transferred to him from Users is reliable and maintains this information up to date.

1.23. By installing the Mobile Application on their Device, the User gives consent to the Copyright Holder to collect, process, record, systematize, store, modify, depersonalize, delete, change, and use the User’s personal data, the list of which is set out in Section 3 of this Policy, within the framework of the User Agreement and for the purpose of providing services under license agreements concluded between the User and the Copyright Holder.

1.24. The purpose of this Privacy Policy is to ensure proper protection of information about Users, including their personal data, from unauthorized access and disclosure.

1.25. Relations related to the collection, storage, distribution and protection of information about Users are regulated by this Privacy Policy, other official documents of the Operator, and the current legislation of the Russian Federation.


2. Purposes of collecting, processing and storing information,

provided by site users


2.1. The Mobile Application collects and stores only that personal information of the User that is necessary for his registration within the framework of the provision of the Mobile Application, obtaining a non-exclusive license by the User, including on the terms, scope and in the manner established by the User Agreement.


2.2. The personal information of the Mobile Application User specified in paragraph 3.3. of this Policy may be used by the Copyright Holder for the following purposes:


2.2.1. Creating an account for the User to use the Mobile Application.


2.2.2. Providing the User with personalized services.


2.2.3. Communication with the User, including sending notifications, requests and information regarding the use of services, provision of services, as well as processing requests and applications from the User.


2.2.4. Improving the quality of the Mobile Application, its ease of use, and developing new services.


2.3. The processing of Personal data is carried out on the basis of the principles:

2.3.1. Legitimacy of the purposes and methods of processing;

2.3.2 Good faith;

2.3.3. Compliance of the purposes of processing Personal data with the purposes previously determined and declared when collecting such Personal data;

2.3.4. Conformity of the volume and nature of processed Personal Data to the stated purposes of their processing.

2.3.5. It is not permitted to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

2.3.6. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive amounts of personal data processed in relation to the stated purposes of their processing are not allowed. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. The copyright holder takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.

2.3.7. Inadmissibility of storing the User’s personal information in a form that allows the subject of the User’s personal information to be identified, for no longer than is required by the purposes of its processing;

2.3.8. Destruction upon achievement of the purposes of processing the User’s personal information or in the event of loss of the need to achieve it.

2.4. The mobile application does not process special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, intimate (private) life.

2.5. The Copyright Holder does not carry out cross-border (to the territory of a foreign state to a foreign government agency, a foreign individual or a foreign legal entity) transfer of the User’s personal information.

2.6. The personal data of Users is stored (processed) by the Operator on the territory of the Russian Federation.


3. List of collected personal data


3.1. The volume of information received and processed by the Mobile Application is limited solely by the need to ensure the operation of the declared functions of the Mobile Application. The Mobile Application does not process information about users for marketing or other commercial purposes.


3.2. The processed information about the user is not used by the Copyright Holder to determine the identity of the User, sinceEach User may use individual functions of the Mobile Application without disclosing their name or email address to the Operator. In this regard, all Users who use the Mobile Application may remain anonymous until they voluntarily decide to log in to the Mobile Application.


3.3. As part of the more functional use of the Mobile Application, when logging into the Mobile Application, Users may be asked to provide the User's name and email address. This information is included in the User's account, through which the User uses the Mobile Application.
In this case, the Mobile Application has access to and uses the following information on the User's device:

- Username;

- User's email address.


3.4. The mobile application may automatically collect and process the following non-personalized information (in accordance with the legislation of the Russian Federation) about the User:

3.4.1. Information about traffic, possible number of clicks made, logs and other data.

3.4.2. Information about the device (identification number, mobile operator network) from which the login is performed, operating system, platform, IP address, collection and sending of statistics about the IP addresses of its users to the Operator's server. This information is used to identify and resolve technical problems if necessary.

3.4.3.The Copyright Holder's servers store information about the User's activities in the Mobile Application.


3.3.4.As part of the functioning of the Mobile Applicationnot used "Cookies and similar technologies."



4. Conditions for processing personal information provided

by the User and its transfer to third parties


4.1. The processing of the User’s personal data is carried out in the Mobile Application and/or the Copyright Holder’s management servers with or without the use of automation tools.


4.2. The Copyright Holder undertakes to process the User's personal data, as well as to ensure the confidentiality and protection of the processed personal data in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data". When processing personal data, the Copyright Holder takes the necessary legal, organizational and technical measures to protect the personal data received from the User from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to the personal data received from the User.

4.3. The User’s personal information will never, under any circumstances, be transferred to third parties, except in cases where the obligation to disclose information about the User is provided for by the legislation of the Russian Federation.


4.4. When processing personal data of Users, the Copyright Holder is guided by the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (as amended by all current amendments and additions).


4.5. The Copyright Holder shall take the necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties. The Copyright Holder shall follow generally accepted industry standards for the protection of personal information provided to it at all stages of personal data processing.In order to ensure the confidentiality of information and the protection of personal data, the Copyright Holder maintains an appropriate IT environment and takes all measures necessary to prevent unauthorized access.


4.6. In accordance with the Federal Law of the Russian Federation of July 27, 2006 No. 152-FZ "On personal data", the Copyright Holder independently determines the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by legislation in the field of personal data.

4.7. 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.


4.8. Data security is ensured by standard operating system tools. If the User uses the Mobile Application, additional protection is provided in the form of a Mobile Application login page, which is protected by a user password.

4.9. Users use the Mobile Application as is and independently ensure the protection of their data in it from security threats, including, but not limited to:

protect your device and the Mobile Application installed on it from theft or loss;

protect your device and the Mobile Application installed on it from unauthorized access.

4.10. The user also protects his personal data by revoking consent to the processing of his personal data or by other means provided for by the legislation of the Russian Federation.



4.11. The Copyright Holder has the right to use the information provided by the User, including personal data, in order to ensure compliance with the requirements of the current legislation of the Russian Federation (including for the purpose of preventing and/or suppressing illegal and/or unlawful actions of Users). Disclosure of the information provided by the User may only be made in accordance with the current legislation of the Russian Federation at the request of a court, law enforcement agencies, as well as in other cases provided for by the legislation of the Russian Federation.

4.12. The Copyright Holder does not check the accuracy of the information provided by the User and assumes that the User, in good faith, provides accurate and sufficient information and ensures that changes to previously provided information are made in a timely manner when such changes appear.

4.13. The User is the sole person responsible for the completeness of the personal (personal) data provided and is obliged to change (update, check, correct) it in a timely manner on a regular basis.

4.14. The mobile application has the right to transfer the User's personal information to third parties, and the User has expressed consent to such actions in the following cases:

4.14.1 The transfer is necessary for the User to use a certain service or for the execution of a certain agreement with the User.

4.14.2. The transfer is provided for by Russian or other applicable legislation within the framework of the procedure established by law.

4.15. Public information:

4.15.1. Within the Mobile Application, the User has the right to publish and post any content at his own discretion and in any of the available forms (photo, video, comment, article, rating, blog, etc.). Such publications and content are publicly available to other users of the Mobile Application, in connection with which the Copyright Holder does not undertake any obligations to protect Personal Data that may be independently disclosed by the User or published by him within the framework of such publication and/or content.



4.16. The User has the right to demand from the Copyright Holder clarification (updating) of his personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also to revoke his consent to the processing of personal data by sending the Copyright Holder a corresponding request and (or) demand in writing to the e-mail address: [email protected] .

The specified request/demand must contain the number of the main document certifying the identity of the User or his representative, information on the date of issue of the specified document and the issuing authority, the address of the User's place of residence, information confirming the fact of personal data processing, a request to clarify, block or destroy the User's personal data or a notice of withdrawal of consent to the processing of personal data, the signature of the User or his representative. The copyright holder is obliged to give a reasoned response on the essence of the User's request/demand within 30 calendar days from the date of its receipt.



5. User’s consent to the processing of personal data:

5.1. By sending a message and information through the feedback forms of the Mobile Application, the User expresses his/her consent to the processing of personal data for the purposes and to the extent specified in this Policy.

5.2. The User hereby gives his/her consent to the Licensor (Copyright Holder) Operator for the purposes and to the extent specified in the Privacy Policy, and for the purposes of fulfilling the User Agreement, to process the personal data of the Licensee (User), specified by him/her during registration in the Mobile Application, for the purpose of providing (the Licensee) the User with the functional ability to use the Mobile Application and receive a response to the information requested from the Licensor (Copyright Holder), and also grants the Licensor (Copyright Holder) the right to transfer the personal data of the Licensee (User), specified by him/her during registration in the Mobile Application, to third parties in cases established by the legislation of the Russian Federation, without paying the Licensee (User) remuneration, both without the use of automation tools and with their use. During the processing of personal data, the Licensor (Copyright Holder) may perform the following actions: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction, as well as any other actions. Storage of personal data is carried out in accordance with the current legislation of the Russian Federation and the Privacy Policy of the Mobile Application. By providing this consent, the Licensee (User) confirms that he assumes responsibility for the accuracy and reliability of my personal data specified during registration and / or use of the Mobile Application, their timely updating, and also confirms that the content of his rights as a subject of personal data in accordance with the requirements of the current legislation of the Russian Federation on personal data is known and understandable to him, and in the part concerning him, the Licensee (User) undertakes to comply with them and fulfill them in full (including, but not limited to: the legislation of the Russian Federation in the field of personal data protection.

The Licensee (User) undertakes not to include in the personal data transferred by him/her any data that poses a particular risk to his/her rights and freedoms (the so-called “sensitive personal data”): racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, data concerning health, sexual life, biometric or genetic data. The Licensee (User) hereby provides this consent to the processing of personal data for a period until the User deletes the Mobile Application and revokes his/her consent to the processing of personal data.The Licensee (User) confirms that he/she is familiar with the Privacy Policy of the Licensor (Copyright Holder). In this case, a written form or other evidence for additional confirmation of the User's free expression of will to provide consent to the processing of personal data will not be required.



5.3. The Operator transfers/processes only that personal information of the User that is necessary for the specified purpose. The provisions of this paragraph regarding the processing of personal and other information of the User shall apply to all materials and information received or transferred by the User in the process of using the Mobile Application and its functions.



6. Terms of Use of the Mobile Application

6.1. When using the Mobile Application, the User confirms that

What:


6.1.1. Has all the necessary rights that allow him to register (create an account) and use the Mobile Application;


6.1.2. Provides reliable information about himself in the volumes necessary for using the Mobile Application; all other information is provided by the User at his own discretion;


6.1.3. Understands that information posted by the User about himself/herself in the Mobile Application may become available to third parties not specified in this Policy and may be copied and distributed by them.


6.2. I have read this Policy, express my consent with it and accept the rights and obligations specified therein. Reading the terms of this Policy and checking the box under the link to this Policy constitutes the User's written consent (acceptance) to the collection, storage, processing and transfer to third parties of personal data provided by the User.


6.3. The User undertakes not to use the Application in violation of the rights and legitimate interests of the Operator in accordance with this Policy, the User Agreement and the legislation of the Russian Federation.


6.4. The User undertakes to take appropriate measures to ensure the safety of his Mobile Device and bears personal responsibility in the event of third parties accessing his Mobile Device.


6.5. The User has no right to perform any unauthorized actions with the Mobile Application, including distributing the Application or its individual Services through various Internet resources and portals, hacking the functionality of the Mobile Application, using parts of the Mobile Application or Services in other mobile applications.


6.6. The User receives a non-exclusive right to use the Mobile Application from the moment of its installation on his device through the application store (Google Play or App Store) in the amount, manner and under the conditions established by the User Agreement, which also means the proper fulfillment by the Operator of the obligation to transfer to the User a non-exclusive right to use the Mobile Application in the amount, manner and under the conditions established by the User Agreement.


6.7. The Mobile Application can only perform its functions if there is access to the Internet. The User independently obtains and pays for access to the Internet under the terms and rates of their communications operator or Internet access provider.


6.8. The User is notified by this Policy and agrees that, when using the Mobile Application, in the event that the User has given consent, service and technical information not associated with the User is transferred to the Operator.


6.9. The User is prohibited from taking the following actions without the prior written consent of the Copyright Holder:


6.9.1. Grant rights to the Mobile Application to any third parties, in any way;


6.9.2. Independently or with the help of third parties, modify, create similar software in whole or in part, improve, translate into other languages, perform engineering analysis, including for the purpose of reproduction, decompile, perform reverse assembly, decode, perform emulation, violate the integrity of the security system, restore or attempt to restore the source code or protocols of the mobile application or any of its parts or functional capabilities.


6.9.3. Delete, hide and modify notifications of the exclusive rights of the Copyright Holder posted in the Mobile Application.

6.10. The User is prohibited from using the services and capabilities of the Mobile Application for the following purposes:

- insults to Users and third parties, dissemination of slanderous information, threats;

- dissemination of information that causes or may cause damage to the honor, dignity, business reputation of an individual or the business reputation of an organization;

- political, religious, anti-religious propaganda and agitation;

- incitement of national, racial, religious, social hatred and propaganda of national, racial, religious, social superiority;

- calls for violence, crimes and other illegal actions;

- preparation for committing crimes and other illegal actions;

- dissemination of materials of a discriminatory nature, materials that degrade human dignity, as well as materials that use “hate speech”;

- distribution of pornography;

- dissemination of materials of an extremist nature;

- dissemination of restricted information;

- dissemination of personal data without the prior written consent of the relevant subjects of personal data;

- spam mailings;

- dissemination of information aimed at advertising, promotion, creation of interest, popularization or discrediting of any goods or services.

- performing other actions specified in the User Agreement.

6.11. The Operator, at its own discretion, makes changes, modifies the Mobile Application, expands its individual functional capabilities, or terminates the development and technical support of the Mobile Application without prior notice to the User.

6.12. The Operator has the right to suspend the User’s access to the Mobile Application, including due to technical work (server maintenance, correction of technical problems, etc.).

6.13. The Operator has the right to terminate the User's access to the Mobile Application without justification in cases established by the User Agreement, including when the User violates the legislation of the Russian Federation on intellectual property.

6.14. Any version of the Mobile Application is provided "as is", which means that the Operator does not provide any guarantees regarding the Mobile Application or its individual Functional capabilities, in particular, the Operator does not guarantee the User that the Mobile Application, its individual functional capabilities, their direct or indirect effect and quality will meet the requirements and goals of the User, the Mobile Application, its individual functional capabilities will be provided continuously, reliably and without errors; the results that will be obtained through the use of the Mobile Application, its individual functional capabilities, will be accurate, reliable and meet the expectations of the User.


6.15. The Operator may designate the Mobile Application or its individual functional capabilities as a beta version, including any alpha version or other preliminary version (hereinafter referred to as the "Beta Version"). The Beta Version is provided to Users for the purpose of testing, identifying possible malfunctions and inaccuracies, and receiving feedback and wishes from Users.

6.16. Regardless of the testing results, the Operator is not obliged to make the Beta version available for general use. The User does not provide any services to the Operator. The User participates in testing the Beta version on a voluntary basis, the User cannot demand any compensation and/or reward due to such participation, including for providing the Operator with discovered defects, their wishes and feedback related to the Beta version.



7. AGE RESTRICTIONS

7.1. All of the Copyright Holder's products respect the privacy of children, and the Copyright Holder does not knowingly collect personal information from children. Persons under 18 years of age may not perform any legal actions to register in the Mobile Application, including the Operator does not accept any information from persons under 18 years of age without the prior consent of their parents or legal guardians, unless this is permitted by the current legislation of the Russian Federation. A minor User may not use the Mobile Application without the prior consent of their parents (legal representatives), if they have not reached the age sufficient to conclude a User Agreement, in accordance with the current legislation of the Russian Federation. The Copyright Holder does not check or collect information about the User's age, in this regard, the full scope of civil and other liability provided for by the legislation of the Russian Federation and international law for the illegal use of the Mobile Application by minor Users in the absence of the prior consent of their parents (legal representatives) is assigned to the legal representative (guardian) of this minor User. If the User identifies himself/herself as a child by means of a request to the Mobile Application Support and Feedback Service, the Operator will not process any personal information about such User and any personal information about such minor User will be immediately deleted in a secure manner.




8.Terms of processing personal data

and the procedure for storing personal data


8.1. The personal data provided by the User is processed until the User revokes their consent to the processing of personal data and deletes the Mobile Application.

8.2. Storage is carried out independently by the Copyright Holder. Storage is carried out for the entire period of the User's use of the Mobile Application. The Copyright Holder undertakes to destroy or depersonalize Personal Data immediately after achieving the purposes of processing them.


9. Changing and deleting personal data

9.1 The User has the right to independently change or delete their Personal Data at any time, except in cases where such change or deletion may lead to a violation of the rules of this Policy, a violation of the Law, or the nature of such Personal Data is evidence in any legal proceedings arising between the Copyright Holder and the User. The User has the right to change or delete their Personal Data in the following way: Sending an email to the Mobile Application Support and Feedback Service to the email address: [email protected] .

9.2 The User is obliged to update previously provided information, otherwise the Copyright Holder shall not be liable for situations caused by outdated information.

9.3. The User may also delete the personal information provided by him/her within a specific account. However, deleting the account may result in the inability to use certain services.

9.4. The Copyright Holder has the right to delete the User's personal account/profile at any time, as well as all Personal Data about the User, if he/she has violated the terms of this Policy and/or the User Agreement. In the event of deletion of Personal Data about the User, all publications made by such User (comments, ratings, reviews, publication of reports, videos and photographs, likes, ratings) and/or any other forms of activity available to the User in the Mobile Application are also subject to automatic deletion.

9.5. The destruction of the User’s personal data is carried out without the possibility of their subsequent restoration.



10. Changes to the Privacy Policy and Applicable Law.

10.1. This Privacy Policy may be changed by the Operator without any special notice to the User; the new version of the Privacy Policy shall enter into force from the moment it is posted in the Mobile Application.

When making changes, the current version indicates the date of the last update. At the same time, the Operator does not bear any responsibility to the User for changing the terms of this Policy without the permission and/or consent of the User.


10.2. The User, by continuing to use the Mobile Application, confirms his/her consent with the new version of the Policy.


10.3. The law of the Russian Federation shall apply to this Policy and the relations between the User and the Copyright Holder arising in connection with the application of the Privacy Policy.


10.4. The responsibility for independently familiarizing themselves with the current version of the Policy lies with the User and the User undertakes to regularly check the provisions of this Policy for possible changes or additions.


10.5. This Privacy Policy is governed by and interpreted in accordance with the legislation of the Russian Federation. For all issues not regulated by this Privacy Policy, the parties are guided by the current legislation of the Russian Federation.


10.6. If for any reason one or more terms of this Privacy Policy are deemed invalid or unenforceable, this will not affect the validity or applicability of the remaining terms of the Privacy Policy.


10.7. If the Operator has made any changes to this Privacy Policy with which the User does not agree, he/she is obliged to stop using the Mobile Application.




11. Liability of the Parties

11.1. The Mobile Application is provided on an "as is" basis. The Copyright Holder does not provide any guarantees regarding the suitability of the Mobile Application for the specific purposes and expectations of the User, and does not provide any other guarantees. Under no circumstances will the Copyright Holder be liable to the User for damages, including any direct, indirect, intentional, incidental or consequential damages of any nature arising from the use or inability to use the Mobile Application (including, but not limited to, damages resulting from the loss of business reputation, work stoppage, technical failure, accident or malfunction, or any commercial damages, costs or losses, as well as lost profits or unjust enrichment), even if the Copyright Holder could have been or should have been aware of the possibility of such damage or the User was warned of the possibility of such damage.

11.2. The Copyright Holder shall take all reasonable measures and carry out any appropriate actions aimed at ensuring the safety of the User's confidential data and maintaining the operability of the Mobile Application. The Copyright Holder shall not provide warranty service for the Mobile Application.

11.3. The Copyright Holder shall not be liable for the transfer of information by the User to third parties using the Mobile Application, or if information from the Mobile Application has become available to third parties as a result of their unauthorized access to the User's Device or the actions of a virus or malware on the User's Device.

11.4. The Copyright Holder shall not be liable for the impossibility of using the Mobile Application due to circumstances beyond its control.

11.5. In case of User registration in the Mobile Application, the User is solely responsible for the safety and confidentiality of the registration data (login and password). The User is solely responsible to third parties for all actions performed using the User's login and password.

11.6. In the event of loss or disclosure of confidential information, the Copyright Holder shall not be liable if this confidential information:


11.6.1. Became publicly known prior to its loss or disclosure;


11.6.2. Was disclosed with the consent of the User.



11.7. Under any circumstances, the liability of the Copyright Holder to the User (including compensation for moral damage) is limited to the amount of 1 (one) ruble. In this case, lost profits are not subject to compensation.


11.8.The User bears full personal, material and other responsibility provided for by the current legislation of the Russian Federation and the norms of international law for all operations performed in the Mobile Application, including, but not limited to: downloading, activating and transferring for use the Mobile Application issued in the name of the User to a minor (underage) User, for all actions performed by a minor (underage) User in the Mobile Application, and similar actions.


12. Final Provisions

12.1. The legislation of the Russian Federation shall apply to the rights and obligations of the User and the Copyright Holder, regardless of the location of the Copyright Holder, the User or the User's Device.

12.2. The User is hereby notified and agrees to the following:

12.2.1 The security and confidentiality of data processed on the User's Device is ensured directly by the User. The User understands and accepts the risks associated with the transfer of personal data and other confidential information using the Internet.

12.2.2. 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 to be secure, and therefore the User carries out such transfer at his own risk.

12.3. Users use the Mobile Application as is and take measures to protect their personal data in it from security threats, including, but not limited to:

protect their Device and the Mobile Application installed on it from theft or loss;

protect your Device and the Mobile Application installed on it from unauthorized access.

12.4. The User and the Copyright Holder will seek to resolve all disputes, disagreements and claims that may arise in connection with the User's use of the Mobile Application, as well as in terms of issues of ensuring the confidentiality of personal data, through negotiations in compliance with the mandatory claims procedure. However, if the disputes that have arisen cannot be resolved through negotiations, they will be resolved in court in accordance with the legislation of the Russian Federation and in the court at the location of the Copyright Holder, the language of the proceedings being Russian.

12.5. All suggestions or questions regarding this Policy should be reported to the Mobile Application Support and Feedback Service at the email address: [email protected] .



12.6. This Policy has been developed in accordance with the current legislation on the protection of personal data of the Russian Federation, in particular, with the provisions of the Federal Law of July 27, 2006 No. 152-FZ "On Personal Data" (with all additions and amendments), Federal Law of July 21, 2014 No. 242-FZ "On Amendments to Certain Legislative Acts of the Russian Federation in Terms of Clarifying the Procedure for Processing Personal Data in Information and Telecommunication Networks" (with all additions and amendments).




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