"Law" means any applicable law, asamended and supplemented, and other applicable laws.
"Controller" means a person who isresponsible for the processing and protection of Personal Data of Users locatedin the EU within the meaning of the General Data Protection Regulation of April27, 2016 (hereinafter "GDRP").
"Mobile application" is software(with all existing additions and improvements) designed to run on smartphones,tablets, watches and other mobile devices and developed for a specific platform(iOS, Android, Windows Phone, etc.). For the purposes of this Policy, theMobile Application means the following software: the “Summaries” application.
"Personal data" means a set ofpersonal data and / or non-personalized information about the User, provided byhim to the Copyright Holder and / or automatically collected by the CopyrightHolder and / or third parties.
"Политика"означает настоящею Политику конфиденциальности мобильного приложения (со всемисуществующими дополнениями и изменениями).
"Policy" means this MobileApplication Privacy Policy (with all existing additions and changes).
"User Agreement" means an agreementconcluded between the Copyright Holder and the User regarding the procedure,rules and features of the User's use of the Mobile Application. The user joinssuch an agreement and does not have the right to make and / or demand anychanges or additions to it. The user can read the terms of the User Agreementat the following link: in the application description.
"Owner" means the following personwho owns the exclusive rights to own the Mobile Application:
Digital Legal Tech SRL
"Processor" means a person who,within the meaning of the GDRP, on behalf of the Controller, stores and/orprocesses Personal Data received from Users.
"Cookies" means small files sent toany mobile application or site and placed on the User's smartphones, tablets,watches and other mobile devices to improve the operation of such applicationsor sites, as well as the quality of the content placed in them.
2. RELATIONSHIPS TO WHICH THE POLICY APPLYES
General provisions
This Policy is used and applicable solely to PersonalData received from the User in connection with his use of the MobileApplication. The provisions of this Policy are aimed at:
(1) determination of the types of personal data received,directions and purposes of use (processing) of personal data, as well assources of obtaining such personal data; and
(2) determination of the rights of the User in relationto the protection of the confidentiality of the Personal Data transmitted byhim; and
(3) identification of persons responsible for theprocessing and storage of Personal Data, as well as third parties to whom suchdata is disclosed (in whole or in part).
The rules of this Policy do not apply in the case ofprocessing by third parties of Personal Data that is voluntarily provided bythe User.
By installing and/or activating the Mobile Applicationon a smartphone, tablet, watch or other mobile device, the User agrees to theterms of this Policy and gives his consent to the Copyright Holder for thecollection, processing, retention and storage of Personal Data in the mannerand under the conditions provided for in this Policy.
If the User does not agree with the terms of thePolicy and / or certain terms of the Policy are not clear to him, in this casethe User is obliged to immediately stop using the Mobile Application.
User rights for the protection of personaldata
In connection with the provision of Personal data, theUser automatically receives the following rights:
(1) receive data relating to their processing (groundsand purposes of such processing, methods of processing used, information aboutpersons who have access to them or to whom they can be disclosed on the basisof an agreement or the Law).
(2) receive data on the location and identification dataof persons performing the processing of Personal Data.
(3) receive information about the storage period ofPersonal Data.
(4) receive information about the completed or proposedcross-border transfer of Personal Data.
(5) receive information about the location andidentification data of persons storing Personal Data.
(6) appeal against the actions or inaction of theCopyright Holder to the authorized body for the protection of the rights ofsubjects of personal data or in court.
(7) receive compensation for losses and / or compensationfor moral damage in court as a result of violations of the User's rights to theprotection and protection of his Personal Data committed by the CopyrightHolder and / or third parties.
(8) exercise other rights in the field of personal dataprotection provided for by the Law or the provisions of this Policy.
3. LIST OF PERSONAL DATA COLLECTED
Non-personally identifiable userinformation
In connection with the use of the Mobile Application,the Copyright Holder may automatically collect and process the followingnon-personalized information about the User:
(1) information about traffic, the possible number ofclicks made, logs and other data.
(2) information about the device (identification number,mobile operator network) from which you are logging in, operating system,platform, browser type and other information about the browser, IP address.
Personal data about users
The Copyright Holder does not collect any personaldata about Users that allow him to be identified.
Information about transactions
The User through the Mobile Application can pay forgoods or services by entering information about the payment card and theidentification data of the owner of such a card into a special field. The Usercan make payment in the Mobile Application in the following way:
The collection and processing of data about the Userin this case is carried out solely for the purposes of making payments,preventing fraud, as well as complying with other requirements of the Law.
The User consents to the access and collection by theCopyright Holder and the relevant payment system or banking institution throughwhich / through which payment is made to such Personal Data, and also agrees tothe privacy policy of the relevant payment system or banking institution.
Use of cookies
This Mobile Application uses certain Cookies to savethe IP address, User preferences or the type of device used in order to (1)keep statistics of visits and site traffic, and (2) personalize the datadisplayed on the User's screen, and (3) save data necessary to identify theUser, including when accessed from different devices, and (4) displayadvertising in accordance with the interests and preferences of the User. TheMobile Application may use both its own Cookies belonging to the CopyrightHolder and Cookies of third parties.
The mobile application uses the following Cookies:
(1) Technical (functional) cookies that are neededto control traffic and data transfer, to identify Users and provide access tothe User to the content of the Mobile Application and without which the use ofthe Mobile Application is functionally limited, as well as to prevent theprovision of recommendations that do not correspond to the interests of theUser.
(2) Statistical Cookies, which are needed to trackthe frequency of visits to the site by Users, to identify how the User uses theMobile Application, and to identify the type and type of content that ispopular or interesting to the User.
(3) Advertising (marketing) Cookies that arenecessary for placing advertising and / or marketing announcements in theMobile Application that correspond to the preferences and interests of the User.
(4) Third party cookies, which are set by thirdparties with the permission of the User and are intended for statisticalresearch regarding the User's behavior on the Internet and / or sendingpersonalized advertising or marketing materials to the User and / or theprovision of goods or services.
The User has the right to disable Cookies in theMobile Application at any time by changing certain settings on his smartphone,tablet, watch or other mobile device. Such disabling does not entail limitingor changing the User's access to the functionality of the Mobile Applicationand/or content. To disable Cookies, you need to follow the algorithm describedin the application.
4. PURPOSE OF COLLECTION AND PROCESSING OF PERSONAL DATA
Determining the purposes of processing
The collection and processing of Personal Data iscarried out for the following purposes:
(1) to analyze the User's behavior, as well as toidentify the User's preferences for a particular type of content.
(2) for the operational and correct operation of theMobile Application, improving the operation of the Mobile Application,improving the content of the Mobile Application, improving the internalarchitecture and functionality of the Mobile Application.
(3) to identify the User.
(4) to provide personalized advertising and marketingmaterials.
(5) to send personalized advertising and marketingmaterials to the specified email address and / or mobile phone of the User.
(6) to comply with the requirements of the Law.
(7) to track orders/purchases made by the User throughthe Mobile Application.
(8) for technical support of the Mobile application,identification of problems in its operation and their elimination.
(9) to maintain contact with the User (communication).
(10) to fulfill other obligations of the Copyright Holderthat arose before the User.
(11) for any other purposes, subject to obtaining separateconsent from the User.
The processing of Personal Data is carried out on thebasis of the principles: (1) the lawfulness of the purposes and methodsof processing; and (2) good faith; and (3) the suitability of thepurposes of the processing of Personal Data for the purposes predetermined anddeclared at the time of collection of such Personal Data; and (4)suitability of the scope and nature of the Personal Data being processed forthe stated purposes of their processing.
Conditions for the processing of personaldata
The processing of Personal Data is carried out in thefollowing cases: (1) obtaining consent from the User; or (2)achievement by the Copyright Holder of the goals provided for by aninternational treaty or the Law; or (3) the provision by the User of hisPersonal Data to an unlimited circle of persons; or (4) fulfillment ofother obligations of the Copyright Holder to the User, including, but notlimited to, provision of certain content to the User; or (5) saving thelife or health of the User when consent to the processing of his Personal Datacannot be obtained in advance.
In case of depersonalization of Personal Data, whichdoes not allow to directly or indirectly identify the User, the subsequent useand disclosure of such data to third parties is allowed and the rules of thisPolicy are no longer applied to them.
The Rightholder takes all possible measures to protectthe confidentiality of the received Personal Data, except in cases where theUser has made such data publicly available.
The processing of Personal Data is carried out usingautomation tools and without the use of such automation tools.
5. ACCESS OF THIRD PARTIES TO PERSONAL DATA
Using remarketing services
The Copyright Holder uses remarketing to advertise thecontent of the Mobile Application to the User on other sites visited by theUser.
Remarketing services are provided to the CopyrightHolder through the following platform: all allowed by the application store.The specified provider collects and processes non-personalized data that doesnot directly allow to identify or identify the User. The information collectedmay typically include (1) thecontent the User viewed, (2) the dateand time the User viewed the content, (3)geolocation data. The collection and processing of such non-personalizedinformation allows the User to be provided with more targeted advertising ormarketing content.
By installing the Mobile Application, the User agreesto the Privacy Policy and Terms of Use of the specified remarketing serviceprovider, as well as to the automatic installation of appropriate Cookies onthe User's device.
The User has the right to refuse such advertising atany time by changing the appropriate settings of the browser and the devicefrom which the Mobile Application is accessed.
Use of analytical platforms
The Copyright Holder uses the following analyticsplatform: those allowed by the application store to (1) track the frequency of visits to the site by Users; and (2) tracking how the User uses theMobile Application and/or its content; and (3)identifying the type and type of content that is popular among Users; and (4) determining the location of theUser. The User also gives his consent to the Copyright Holder to use theinformation received about the User from the other option.
For thesepurposes, the following analytical platform: allowed by the application storemay collect data about the IP address, geolocation, User behavior, as well ashis preferences and interest in relation to certain content.
Thefollowing analytical platform: allowed by the app store gets access to Personaldata in order to provide the Copyright Holder with an understanding of howeffectively its Mobile Application works, what kind of content is popular, howeffective it is to place this or that advertisement in it, as well as fordevelopment and / or improve the Rightholder's existing marketing strategy.
Byinstalling the Mobile Application, the User agrees to the Privacy Policy of thefollowing analytical platform: allowed by the application store, as well as theautomatic installation of appropriate Cookies on the User's device.
Disclosure of personal data to thirdparties
TheCopyright Holder has the right to disclose Personal Data (1) to its affiliates, branches and representative offices in theterritory of any states; (2)successors of the Copyright Holder, which arose as a result of its liquidation,reorganization or bankruptcy, and who received exclusive rights to own theMobile Application; (3) to paymentservice providers or banking (financial) institutions, to conduct transactionsof the User through the Mobile Application; (4) to third parties solely for the purpose of providing the Userwith certain content or access to it; (5)to third parties when the User has given consent to the disclosure, transfer orprocessing of their Personal Data, as well as in other cases expressly providedfor by the Law or this Policy.
The RightHolder discloses Personal Data only if (1)it is sure that third parties will comply with the terms of this Policy andtake the same measures to protect the confidentiality of Personal Data that theRight Holder takes, and (2) consentto such disclosure has been previously expressed User and/or permitted by law.
Advertising from third parties
The contentof the Mobile Application may contain advertising banners and/or links to thirdparty websites. The User's use of such sites (by clicking on a link or in anyother way) may entail the collection, processing and use of Personal Data, aswell as the possible automatic transfer of Cookies to the User's device fromwhich the transition to the site of third parties is made. The Copyright Holderdoes not bear any responsibility for the ways, methods and procedure forprocessing Personal Data by third-party websites. As a result, the CopyrightHolder is also not a responsible person in case of disclosure of Personal Datato an unlimited number of persons in connection with the use of such sites bythe User.
The CopyrightHolder strongly recommends that each User familiarize himself in detail withthe personal data protection policies of the sites used.
The userhas the right to disable such advertising banners and / or links at any time byperforming actions as described in the application.
Sending promotional materials to users
Byinstalling the Mobile Application on the device, the User automatically agreeswith the right of third parties to send personalized advertising and marketingmaterials to the provided email address and/or mobile phone.
The Userhas the right to opt out of receiving such advertising and marketing materialsat any time by performing the following actions:
unsubscribe from the distribution of suchmaterials by e-mail provided in the description of the mobile application..
6. PLACEMENT OF ADVERTISING
Advertising in the mobile application
The Copyright Holder, along with the content, placesvarious advertising and marketing materials in the Mobile Application, takinginto account the User's identified preferences for this or that content.Placement of advertisements in the Mobile Application involves the installationof certain Cookies on the Rightholder's device.
The user has the right to opt out of such advertisingat any time by purchasing a subscription to the application or performing otheractions described in the application.
Distributionof promotional materials
By installing the Mobile Application on the device,the User automatically agrees with the Rightholder's right to send personalizedadvertising and marketing materials to the provided email address and/or mobilephone.
The User has the right to opt out of receiving suchadvertising and marketing materials at any time by performing the followingactions:
sendingan email to the email address specified in the Attachment.
Please note that in case of refusal to receiveadvertising and marketing materials, the User may continue to receive anynotifications from the Copyright Holder related to the procedure for using theMobile Application and/or its content.
7.SENDING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER
Requestto stop processing personal data
Each User has the right to express his objection tothe Right Holder against the processing and / or storage of his Personal Data.Such an objection can be expressed as follows:
anemail to the email address specified in the description of the Application.
Requestfor information about personal data
If the User has questions related to the procedure forapplying or using this Policy, the procedure and / or method of processingPersonal Data, the User can ask such a question as follows:
anemail to the email address specified in the mobile application.
Change(update, addition, correction) or deletion of personal data
The User has the right to independently change ordelete his Personal Data at any time, except in cases where such change ordeletion may lead to (1) a violationof the rules of this Policy; or (2)in violation of the Law; (3) thenature of such Personal Data is evidence in any litigation that has arisenbetween the Copyright Holder and the User. To do this, the User needs to deletehis personal account (profile) in the Mobile Application.
The Copyright Holder has the right to delete theUser's personal account/profile at any time, as well as all Personal Data aboutthe User, if he has violated the terms of this Policy and/or the UserAgreement.
The User has the right to delete the User's personalaccount/profile at any time.
In case of deletion of Personal data about the User,all publications made by such User (comments, ratings, reviews, publication ofreports, videos and photos, likes, ratings) and / or any other forms ofactivity available to the User in Mobile application.
8.TERMS AND PROCEDURE FOR STORING PERSONAL DATA
Storage is carried out by third parties on behalf ofthe Copyright Holder. The User gives his consent to the storage of his PersonalData by third parties on behalf of the Copyright Holder, provided that suchthird parties maintain the confidentiality of the received Personal Data. TheInformation storage functions are entrusted to the following person: DigitalLegal Tech SRL (hereinafter referred to as the "Custodian"). Thestorage of Personal Data is carried out on a server used by the Custodian atits own discretion.
Storage is carried out for the entire period necessaryto achieve the stated purposes of processing Personal Data.
The Rightholder undertakes to destroy or depersonalizethem immediately after achieving the goals of processing Personal Data.
9.ACCESS OF MINORS TO THE MOBILE APP
Usersin the territory of any states
The use of the Mobile Application is intended forpersons over 18 years of age.
If the User is a minor, then he must immediately stopusing this Mobile Application.
Usersin the European Union
The use of the Mobile Application is intended forpersons aged 16 and over.
If the Copyright Holder becomes aware that the User'sage does not correspond to the allowable age for using the Mobile Application,in this case the Copyright Holder undertakes to perform the actions providedfor by the applicable law.
10.PERSONAL DATA PROTECTION
Protecting the confidentiality of Personal Data is aparamount and important task for the Copyright Holder. The Rightholder adheresto all required international standards, rules and recommendations for theprotection of Personal Data.
The Rightholder has implemented a number of technicaland organizational methods aimed at protecting Personal Data from disclosure orunauthorized access by third parties.
11.USERS LOCATED IN THE EUROPEAN UNION
Generalprovisions
Since the Mobile Application is available to usersfrom the European Union, the Copyright Holder undertakes to additionally complywith the provisions of the GDPR.
The controller in the understanding of this Policy isthe Copyright Holder. The Processor for the purposes of this Policy is theCustodian under Article 8 of the Policy.
The Right Holder stores Personal Data for a reasonableperiod of time necessary to achieve the purposes of processing, but not lessthan the period established by the local legislation of the Member State of theEuropean Union, in whose territory the Mobile Application is available, forstoring one or another type of Personal Data. Upon the expiration of the periodestablished for storage, the Copyright Holder undertakes to immediately destroyor depersonalize such data.
Officialrepresentative
Since the Controller is located outside the territoryof the European Union, the following person is appointed as its officialrepresentative for the protection of Personal Data of Users in the EuropeanUnion: Digital Legal Tech SRL.
Userrights in the field of personal data protection
Under Chapter 3 of the GDPR, Users located in theEuropean Union have the following rights in the field of Personal Dataprotection: (1) the right to receiveinformation about their Personal Data ("the right to be informed");and (2) the right to access yourPersonal Data ("the right of access"); and (3) the right to rectification of Personal Data ("the right torectification"); and (4) theright to erasure of Personal Data ("the right to erasure"); and (5) the right to restrict processing ofPersonal Data ("the right to restrict processing"); and (6) the right to portability ofPersonal Data to third parties ("the right to data portability"); and(7) the right to object ("theright to object").
12.FINAL PROVISIONS
Availabilityof policy text for review
Users can read the terms of this Policy at thefollowing link: in the application description.
This Policy may be translated into any foreignlanguages. In the event of a discrepancy between the original text (Russian)and its translation, the original language shall prevail.
This version of the Policy is effective from June 1,2022.
Changing and supplementing the policy
This Policy may be changed from time to time. TheCopyright Holder does not bear any responsibility to the User for changing theterms of this Policy without the permission and / or consent of the User.
The user undertakes to regularly check the provisionsof this Policy for possible changes or additions.
Applicable law
This Policy has been developed in accordance with thecurrent legislation on the protection of personal data of the Republic ofMoldova, as well as the provisions of the General Data Protection Regulation ofApril 27, 2016 GDRP.
Disclosurerisk
Regardless of the measures taken by the CopyrightHolder to protect the confidentiality of the received personal data, the Useris hereby considered to be properly aware that any transfer of Personal data onthe Internet cannot be guaranteed secure, and therefore the User carries outsuch transfer at his own risk.
