Privacy policy Jazz - Communication Platform

Privacy Policy

1. GENERAL PROVISIONS

Privacy policy (here in after - the Policy) is developed in accordance with the Law Russian Federation dated 27.07.2006 No. 152-FZ “On Personal Data” (here in after - the Law).

This Policy defines the procedure for processing personal data and measures to ensure of the Licensor (here in after also - the Operator) the security of personal data in order to protect the rights and freedoms of man and citizen in the processing of his personal data, including the protection of rights to privacy, personal and family secrets.

The following basic concepts are used in this Policy:

Automated processing of personal data - processing of personal data by means of computer technology. 

Blocking of personal data - temporary termination of personal data processing (except when processing is necessary to clarify personal data). 

Information system of personal data - a set of personal data contained in databases of personal data and information technologies and technical means ensuring its processing. 

Depersonalization of personal data - actions, as a result of which it is impossible to determine without the use of additional information what personal data belongs to a particular personal data subject.

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

Operator - a legal entity or an individual, independently or together with other persons organizing and (or) carrying out processing of personal data, as well as defining the purpose of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data. 

Personal data - any information related, directly or indirectly to a specific or identifiable individual (personal data subject).

Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain circle of persons;

Distribution of personal data - actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or to familiarize an unlimited circle of persons with personal data, including publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.

personal data subject

Transboundary transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign authority, a foreign individual or a foreign legal entity.

Destruction of personal data - actions resulting in the impossibility to restore the content of personal data in the information system of personal data and (or) as a result of which tangible carriers of personal data are destroyed.

Personal Data Subject (The User) - a natural person to whom the personal data directly or indirectly relate.

2.2. PRINCIPLES, OBJECTIVES, CONTENTS AND CONDITIONS OF PERSONAL DATA PROCESSING

2.2.1. Principles of personal data processing

The Operator's processing of personal data is based on the following principles:

 legality and fair basis;

 restriction of personal data processing to achievement of specific, predetermined and legitimate objectives;

prevention of personal data processing, incompatible with the purposes of personal data collection;

 not to combine databases containing personal data, processing of which is carried out for purposes, incompatible with each other

 processing only those personal data that meet the purposes of its processing

 compliance of the content and volume of processed personal data with the stated processing purposes;

inadmissibility of processing of personal data excessive in relation to the stated purposes of its processing;

ensuring accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data; processing;

 destruction or depersonalization of personal data upon attainment of the objectives of personal data processing or in case of loss of necessity in attainment of those objectives, in case of impossibility of the Operator to eliminate violations of personal data, unless otherwise provided by the Law.

2.2.2. The collection and further processing of personal data is carried out for the following purposes:

- for to fulfill the execution of the terms of the Agreement between the User and the Licensor, including for authorization purposes the application.

- sending the User information messages about the application operation and application notifications, as well as providing the User with information related to the execution of the terms of the Agreement between the User and the Licensor by sending the User e-mails.

- analytics of User's actions.

2.3. Terms of processing of personal data

The operator performs processing of personal data in the presence of at least one of the following conditions:

- processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;

- processing of personal data is necessary for achieving goals, stipulated by the international treaty of the Russian Federation or by the Law, for implementing and executing functions, powers and duties, imposed on the operator by the legislation of the Russian Federation;

- processing of personal data is necessary for administration of justice, execution of a judicial act, act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;

- processing of personal data is necessary for execution of the contract, which party or beneficiary or guarantor, under which the subject of personal data is, as well as for the conclusion of the contract on the initiative of the personal data subject or the contract, under which the subject of personal data will be a beneficiary or guarantor

- the processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially important objectives, provided that this does not violate the rights and freedoms of the personal data subject.

2.4. Confidentiality of personal data

The operator and other persons who have access to personal data are obliged not to disclose to third parties and not to distribute personal data without consent of the subject of personal data unless otherwise stipulated by the Law, the consent to processing of personal data, or the terms of the Agreement concluded between the Licensor and the subject of personal data.

2.5. Entrusting the processing of personal data to another person

The operator may entrust the processing of personal data to another person with the consent of the personal data subject, unless otherwise provided by law, based on a contract to be entered into with that person. The person processing personal data on behalf of the Operator must comply with the principles and rules of personal data processing provided by the Law.

2.7. The Operator does not perform trans-border transfer of personal data. 

2.8. On the basis of exclusively automated processing of personal data, no decision may be made which entails legal consequences in relation to the personal data subject or otherwise affects his/her rights and legitimate interests, except in cases provided for by law or with the written consent of the personal data subject.

3. RIGHTS OF THE SUBJECT OF PERSONAL DATA

3.1. The subject of personal data independently decides to provide his/her personal data and agrees to their processing freely, voluntarily and in his/her own interests.

3.2. The personal data subject has the right to receive information from the Operator regarding the processing of his/her personal data, except where such right is restricted by law. The personal data subject has the right to demand from the Operator to clarify his/her personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, obtained illegally or is not necessary for the stated purpose of processing, as well as to take measures provided for by law to protect his/her rights.

3.3. Processing of personal data for the purpose of promotion of goods, works, services on the market by direct contact with potential consumers through means of communication is allowed only with the prior consent of the subject of personal data. 

3.4. If the personal data subject believes that the operator processes his/her personal data in violation of the requirements of the Law or otherwise violates his/her rights and freedoms, the personal data subject has the right to appeal the actions or omissions of the Operator to the Authorized Body for the Protection of the Rights of Personal Data Subjects.

4. ENSURING SECURITY OF PERSONAL DATA

Security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to ensure the requirements of legislation in the field of personal data protection.

To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:

 Limitation of persons having access to personal data;

 Organization of accounting, storage and circulation of data carriers;

 Verification of readiness and efficiency of use of information protection means;

 Use of antivirus and recovery tools of personal data protection system. 

5. COOKIE 

Cookies are files that describe Users' preferences to an application. It is a small piece of data created and placed on the website/application. It is stored on the User's computer and is used by the web browser/application if the User authorizes it.

Cookie contains information about the User's interaction and traffic in the application. Operator uses this data to enhance the usability of the application. The Operator may also share some of this data with third-party services that help to better understand User needs. These services may not use these cookies in any way other than to assist the Licensor in developing the application.

6. FINAL PROVISIONS

Other rights and obligations of the Licensor, as operator of personal data are determined by the legislation of the Russian Federation in the field of personal data.