Application 1

to the User License Agreement
  MEDIARTIS LTD 

IQsha: development for kids


PRIVACY POLICY

The "PRIVACY Policy" (hereinafter referred to as the Policy) is a document defining the procedure for processing, systematization and disclosure of information provided by Users of the Site and the Application to the Contractor, including personal information of Users, as well as information about the requirements for the protection of personal information. 

1. GENERAL TERMS

1.1. The terms and definitions used in the License Agreement with the user "IQsha" are applicable in the text of the Policy. 

1.2. The processing of the User's personal data is carried out in any legal way, including in personal data information systems using automation tools or without the use of such tools. The processing of personal data by the User is carried out in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", as well as the General Data Protection Regulation (GDPR) of the European Union. 

1.3. By registering on the Site or in the Application, the User gives his consent to the processing of his personal information obtained during the registration and use of the Site and / or Application, as well as consent to the processing of personal data of a minor using the Site whose parent (or legal representative) is the User. 

1.4. The Contractor does not process special categories of personal data, any such data may be requested by the Contractor only in an impersonal form and only to provide appropriate benefits to Users of the Site. Anyway, by registering on the Website or in the Application, taking into account the provisions on the use of a simple electronic signature contained in the License Agreement with the User and the Agreement on the Use of IQsha mobile applications, the subject of personal data (including the parent or legal representative of the subject) is recognized as having consented to the processing of their personal data (data of a minor, the parent or legal representative of which he is) in writing.


1.5. If the User has not reached the age of 16, consent to the processing of his data must be given or approved by a person with parental responsibility for the child. If the parents/or legal representatives of a minor became aware that he, without their consent, left personal data on the Website and/or in the Application, they should contact the Contractor or the data protection inspector appointed by the Contractor with an application for the deletion of the minor's data. The deletion of all personal data of a minor will be carried out within the shortest possible time from the moment of receipt of the relevant application from parents and/or legal representatives. The User also understands and agrees that the Contractor does not have the technical ability to accurately determine the age of the User. Therefore, it is assumed that registration on the Website and / or in the Application as a User is made by a person who has reached the age of 16, or a legal representative of a minor, otherwise this fact is recognized as a violation of the Policy, the Contractor has the right to delete the Account and all data of such a User without explanation and any compensation. By registering the child's data in the personal account on the Website and/or in the Application, the legal representative gives consent to the processing of the child's personal data by the Contractor.


1.6. The above-mentioned age for which the obligation to obtain parental consent for data processing is established is common for EU countries. EU Member States may legislate for a lower age for these purposes, provided that such age is not below 13 years. If the Contractor discovers that a different age has been set for a particular EU country, and parental consent has not been obtained, the Contractor will be guided by the legislation of the User's country when making a decision to delete data and Account. In any case, the Contractor shall take reasonable measures to ensure in such cases that the consent has been given or approved by a person with parental responsibility for the child, taking into account the technical capabilities available to the Contractor.

1.7. Personal information is understood as personal information uploaded by the User during the registration procedure on the Website or in the Application, which includes: 

1.8. The storage period of any personal information may not exceed the period of use of the Site and/ or the Application by the User. When personal data is processed solely for statistical purposes, it may be stored for a longer period than the period of use of the Site and/or Application, taking into account the application of appropriate technical and organizational measures to protect the rights and freedoms of the User. 

1.9. Any personal information uploaded by the User on the Website and/or in the Application is perceived by the Contractor "as is" and is not subject to preliminary verification for reliability. The burden of responsibility for the accuracy of the information provided on the Website and/or in the Application is borne by the User personally. 

1.10. Information on the Website and / or in the Application is placed at the User's choice in Russian or English. It is allowed to use letters of the Latin alphabet in aliases.

2. PURPOSE OF THE DATA PROCESSING

2.1. Processing of personal information is based on the principles of law and justice; processing only such information that meets the goals of its processing; correlation of the contents and scope of processing information to the stated goals of the processing.

2.2. Processing of personal data is carried out to perform obligations by the Contractor under the Agreement, i.e. to ensure the full functioning of the Site, the correlation of the Site to the goals declared in the preamble of the Agreement.

2.3. Processing of information about the User's email is carried out in order to:

2.3.1. Account creation, authorization on the Site;

2.3.2. password recovery and change to access User Accounts;

2.3.3. directing to the User information, such as notifications of changes in the Site's service, notifications about the update service of the Site, information about discounts and promotions, reports on the use of the Site, performed Assignments and / or Exercises.

2.4. Information about the Visitor's email (unauthorized Internet Users) in the Site is processed in order to provide them with the following services online:

2.4.1. purchase of the Unlimited Account by the Visitor (the Account provided to Site Users with full access to the Site for a certain period) as a gift to a third party;

2.4.2. invitation i.e. direction to third party the offer to get acquainted with the Site and / or register on the Site;

2.4.3. contact Site technical support, the feedback with the Contractor.

2.5. Information about the name (nickname) of the User and a minor in whose interests the Users use the Site, is processed in order to identify the User on the Site, the personalization Site services delivery.

2.6. Processed personal information must not be excessive in relation to the stated goals of its processing.

3. DATA TRANSFER AND DELETION

3.1. The User agrees that when completing their online registration form, adding information to his account (Account), as well as elsewhere in the use of the Site services, such information enters the public access, and the User does not object to such publication.

3.2. Contractor does not collect, store and process the data of Users’ bank cards. Contractor is convinced that service xsolla.com (LLC "Xsolla"), through which the payment for User’s services is made, provides reliable personal information security. The User undertakes to learn the LLC "Xsolla" usage policy exclusively on the Site xsolla.com.

3.3. Contractor transfers Users' personal information in the cases provided for by the legislation of the Russian Federation and by international agreements.

3.4. Giving User’s personal information at the request of state agencies (local government) is carried out in accordance with the legislation of the Russian Federation.

3.5. The information contained on the Site is stored for the duration of use of the Site, and when User’s Account is deleted within a period determined by the Contractor, but not more than ___ (____________) from the time of deletion of the corresponding Account. Upon the User’s notification sent to the Contractor, Users' personal information must be deleted within 30 (thirty) days from the date of receipt of such notification by the Contractor.

4. DATA SECURITY

4.1. Contractor takes technical, organizational and legal measures in order to protect Users' personal information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, and other illegal actions.

4.2. To ensure the security of personal data the Contractor takes the following measures:

- Defines risks of personal information security when it is processed on the Site;

- Takes technical and organizational measures to ensure personal information security when it is processed on the Site;

- Applies means of protection information security which have passed in the prescribed manner the conformity assessment procedure;

- Makes an assessment of the effectiveness of measures to ensure the security of personal information;

- Adopts procedures aimed at identifying cases of unauthorized access to personal information;

- Carries out the restoration of personal information altered or destroyed as a result of unauthorized access;

- Establishes rules for access to personal information processed on the Site, and provides registration and accounting of all acts committed with personal information on the Site;

- Constantly monitors the measures taken to ensure personal information security.

4.3. The Contractor shall not be liable for the actions of third parties that have access to the personal data of the User as a result of unauthorized access to the Site.

5. FINAL TERMS

5.1. This document is publicly available; its current version is always located on the Site link - https://iqsha.com/api/page/policies/confidential/.

5.2. Monitoring of compliance with the requirements of this document is carried out by the Contractor - the person responsible for personal information security.

5.3. All disagreements and disputes arising in connection with the use of Users personal information shall be settled in the manner prescribed by p. 12.12 of User Agreement.

5.4. "PRIVACY Policy" is an integral part of the Agreement, published on the Site.