PRIVACY POLICY FOR THE «ANY QUIZ» MOBILE APPLICATION

1. DEFINITION OF TERMS

“Law” means the Federal Law of the Russian Federation “On Personal Data” with all amendments and additions, as well as other legislative acts of the Russian Federation.

“Controller” means the person who is responsible for the processing and protection of Personal Data of Users located in the EU within the meaning of the General Data Protection Regulation of April 27, 2016 (“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, the Mobile Application means the following software: ANY QUIZ.

“Personal data” means a set of personal data and/or non-personalized information about the User provided by the User himself to the Copyright Holder and/or automatically collected by the Copyright Holder and/or third parties.

“Policy” means this Mobile Application Privacy Policy (with all existing additions and changes).

“User” means a legal entity or individual who has downloaded the Mobile Application to a smartphone, tablet, watch or any other mobile device and/or activated such a Mobile Application on one of the specified devices.

“User Agreement” means an agreement concluded between the Copyright Holder and the User regarding the procedure, rules and features of the User’s use of the Mobile Application. The user accedes to such an agreement and does not have the right to make and/or demand any changes or additions to it. The user can read the terms of the User Agreement at the following link: https://main.adaurum.ru/en/any-quiz-policy/.

«Copyright Holder» means the following person who has exclusive ownership rights to the Mobile Application

AdAurum LLC Bulgaria, Sofia city, Capital Municipality, Izgrev dist. zh.k Iztok, Lyulyakova gradina, No 17 fl. 2 apt. 8

“Processor” means a person who, within the meaning of the GDPR, on behalf of the Controller, carries out the storage and/or processing of Personal Data received from Users.

“Cookies” means small files sent to any mobile application or site and placed on the User’s smartphones, tablets, watches and other mobile devices to improve the performance of such applications or sites, as well as the quality of the content contained therein.

2. RELATIONS COVERED BY THE POLICY

General provisions

This Policy is used and applies exclusively to Personal Data received from the User in connection with his use of the Mobile Application. The provisions of this Policy are aimed at:

1. determination of the types and types of Personal Data received, directions and purposes of use (processing) of Personal Data, as well as sources of obtaining such Personal Data;
2. determination of the User’s rights regarding the protection of the confidentiality of the Personal Data transferred to him;
3. identification of persons responsible for processing and storing Personal Data, as well as third parties to whom such data is disclosed (in whole or in part).

The rules of this Policy do not apply in case of processing by third parties of Personal Data that is voluntarily provided by the User.

By installing and/or activating the Mobile Application on a smartphone, tablet, watch or other mobile device, the User agrees to the terms of this Policy and gives his consent to the Copyright Holder to collect, process, retain and store Personal Data in the manner and under the conditions provided for in this Policy.

If the User does not agree with the terms of the Policy and/or certain terms of the Policy are not clear to him, in this case the User is obliged to immediately stop using the Mobile Application.

User rights to protect personal data

In connection with the provision of Personal Data, the User automatically receives the following rights:

1. receive data relating to their processing (grounds and purposes of such processing, applied processing methods, information about persons who have access to them or to whom they can be disclosed on the basis of a contract or Law);
2. receive data on the location and identification data of persons processing Personal Data;
3. receive information about the storage period of Personal Data;
4. receive information about completed or expected cross-border transfer of Personal Data;
5. appeal the actions or inaction of the Copyright Holder to the authorized body for the protection of the rights of personal data subjects or in court;
6. receive compensation for losses and/or compensation for moral damage in court as a result of violations of the User’s rights to the protection and protection of his Personal data committed by the Copyright Holder and/or third parties;
7. exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.

3. LIST OF PERSONAL DATA COLLECTED

Non-personal information about users

In connection with the use of the Mobile Application, the Copyright Holder can automatically collect and process the following non-personal information about the User:

1. information about traffic, the possible number of clicks, 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 User provides the Copyright Holder with the following personal information about himself:

1. date of birth and age;
2. E-mail address;
3. data on orders/purchases made by Users and/or services received/paid through the Mobile Application;
4. data on all publications made by the User in the Mobile Application, including, but not limited to, comments, ratings, reviews, publication of reports, videos and photographs, liking, ratings and/or any other forms of activity available to the User in the Mobile Application, and/or content created;
5. data and information obtained as a result of combining certain Personal Data of a particular User, as well as data and information obtained about the User received from third parties (partners, marketers, researchers).

The user is the only responsible person for the completeness of the personal data provided and is obliged to change it in a timely manner (updating, checking, adjusting) on a regular basis.

The Copyright Holder assumes that all personal data provided by the User is reliable and that the User keeps such information up to date.

Information about completed transactions

The user, through the Mobile application, can pay for goods or services by entering information about the payment card and the identification data of the owner of such a card in a special field. The user can make payments in the Mobile Application in the following way:

• via bank card.
• using the Pay Pal payment system.
• using the Yandex.Money payment system.
• using the Apple Pay payment system.
• using the Google Pay payment system.

In this case, the collection and processing of data about the User is carried out solely for the purposes of payment, fraud prevention, and compliance with other requirements of the Law.

The User consents to access and collection by the Copyright Holder and the corresponding payment system or banking institution through which/through which payment is made to such Personal Data, and also agrees with the privacy policy of the corresponding payment system or banking institution.

Use of cookies

This Mobile Application uses certain Cookies to store the IP address, preferences of Users or the type of device used in order to (1) maintain statistics of visits and traffic to the site, and (2) personalize the data displayed on the User’s screen, and (3) save data necessary to identify the User, including when accessing from different devices, and (4) display advertising in accordance with the interests and preferences of the User. The mobile application may use both its own Cookies belonging to the Copyright Holder and Cookies of third parties.

The mobile application uses the following cookies:

1. Technical (functional) Cookies, which are needed to control traffic and data transfer, to identify Users and provide the User with access to the content of the Mobile Application and without which the use of the Mobile Application is functionally limited, as well as to prevent the provision of recommendations that do not correspond to the interests of the User;
2. Statistical Cookies, which are needed to track the frequency of site visits by Users, to identify how the User uses the Mobile Application, as well as to identify the type and type of content that is popular or interesting to the User;
3. Advertising (marketing) Cookies, which are necessary for placing advertising and/or marketing ads in the Mobile Application that correspond to the preferences and interests of the User;
4. Third party cookies, which are installed by third parties with the permission of the User and are intended to conduct statistical studies regarding the User’s behavior on the Internet and/or sending personalized advertising or marketing materials to the User and/or providing goods or services.

The User has the right to disable cookies in the Mobile Application at any time by changing certain settings on his smartphone, tablet, watch or other mobile device. Such disabling does not entail restricting or changing the User’s access to the functionality of the Mobile Application and/or content.

4. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA

Determination of processing purposes

The collection and processing of Personal Data is carried out for the following purposes:

1. to analyze the User’s behavior, as well as identify the User’s preferences for a certain type of content;
2. for prompt and correct operation of the Mobile Application, improving the functioning of the Mobile Application, improving the content of the Mobile Application, improving the internal architecture and functionality of the Mobile Application;
3. to identify the User;
4. to provide personalized advertising and marketing materials;
5. to send personalized advertising and marketing materials 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 through the Mobile Application;
8. for technical support of the Mobile application, identifying problems in its operation and eliminating them;
9. to maintain contact with the User (communication);
10. to fulfill other obligations of the Copyright Holder that have arisen to the User;
11. for any other purposes, subject to obtaining separate consent from the User.

The processing of Personal Data is carried out on the basis of the following principles: (1) the legality of the purposes and methods of processing; and (2) good faith; and (3) compliance of the purposes of processing Personal Data with the purposes predetermined and stated when collecting such Personal Data; and (4) compliance of the volume and nature of the Personal Data processed with the stated purposes of their processing.

Conditions for processing personal data

Processing of Personal Data is carried out in the following cases: (1) obtaining consent from the User; or (2) the Rightholder achieves the goals provided for by an international treaty or Law; or (3) the User providing his Personal Data to an unlimited number of persons; or (4) fulfillment of other obligations of the Copyright Holder to the User, including, but not limited to, the provision of certain content to the User; or (5) saving the life or health of the User when consent to the processing of his Personal Data cannot be obtained in advance.

In the event of depersonalization of Personal Data, which does not allow direct or indirect identification of the User, subsequent use and disclosure of such data to third parties is permitted and the rules of this Policy no longer apply to them.

The Copyright Holder takes all possible measures to protect the confidentiality of the received Personal Data, except in cases where the User has made such data publicly available.

Processing of Personal Data is carried out using automation 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 to the User the content of the Mobile Application on other sites visited by the User.

Remarketing services are provided to the Copyright Holder through the following platform: Yandex Advertising. The specified provider collects and processes non-personal data that does not directly allow the identification or identification of the User. The information collected may typically include (1) the content the User viewed, (2) the date and time the User viewed the content, (3) geolocation data. The collection and processing of such non-personal information allows us to provide the User with more targeted advertising or marketing content.

By installing the Mobile Application, the User agrees to the Privacy Policy and Terms of Use of the specified remarketing service provider, as well as the automatic installation of the corresponding Cookies on the User’s device.

The user has the right to refuse such advertising at any time by changing the appropriate settings of the browser and device from which the Mobile Application is accessed.

Using Analytics Platforms

The Copyright Holder uses the Yandex analytical platform to (1) track the frequency of site visits by Users; and (2) monitoring the User’s use of the Mobile 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 the User. The User also gives his consent to the Copyright Holder to use the information received about the User from Yandex.

For these purposes, the Yandex analytical platform may collect data about the IP address, geolocation, behavior of the User, as well as his preferences and interest in certain content.

The Yandex Analytical Platform gains access to Personal Data in order to provide the Copyright Holder with an understanding of how effectively his Mobile Application works, what kind of content is popular, how effective is the placement of certain advertisements in it, as well as for the purpose of developing and/or improving existing marketing strategies of the Copyright Holder.

By installing the Mobile Application, the User agrees to the Privacy Policy of Yandex, as well as the automatic installation of the relevant Cookies on the User’s device.

Disclosure of personal data to third parties

The copyright holder has the right to disclose Personal Data (1) to its affiliates, branches and representative offices opened both on the territory of the Russian Federation and on the territory of other states; (2) legal successors of the Copyright Holder who arose as a result of its liquidation, reorganization or bankruptcy, and who received exclusive rights to own the Mobile Application; (3) payment service providers or banking (financial) institutions to conduct User transactions through the Mobile Application; (4) to third parties solely for the purpose of facilitating the User’s receipt of or access to certain content; (5) to third parties when the User has given consent to the disclosure, transfer or processing of his Personal Data, as well as in other cases expressly provided for by the Law or this Policy.

The Copyright Holder discloses Personal Data only if (1) it is confident that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data that the Copyright Holder itself takes, and (2) consent to such disclosure has been previously expressed by the User and/or permitted on the basis of the Law.

Third Party Advertising

The content of the Mobile Application may contain advertising banners and/or links to third party sites. The User’s use of such sites (by following a link or in any other way) may entail the collection, processing and use of Personal Data, as well as the possible automatic transfer of Cookies to the User’s device from which the transition to the third party site is made. The copyright holder does not bear any responsibility for the methods, methods and procedures for processing Personal data by third party sites. As a result, the Copyright Holder is also not a responsible person in the event of disclosure of Personal Data to an unlimited number of persons in connection with the User’s use of such sites.

The Copyright Holder strongly recommends that each User familiarize themselves in detail with the personal data protection policies of the websites used.

The user has the right to disable such advertising banners and/or links at any time by performing the following actions:

Go to settings, find the advertising materials option and uncheck the box next to it

6. ADVERTISING

Advertising in a mobile application

The Copyright Holder, along with the content, places various advertising and marketing materials in the Mobile Application, taking into account the identified preferences of the User for this or that content. Placing advertisements in the Mobile Application requires the installation of certain Cookies on the Copyright Holder’s device.

The user has the right to refuse such advertising at any time by performing the following actions:

Go to settings, find the advertising materials option and uncheck the box next to it

Distribution of promotional materials

By installing the Mobile Application on the device, the User automatically agrees with the Right Holder’s right to send personalized advertising and marketing materials to the provided email address and/or mobile phone.

The User has the right to refuse to receive such advertising and marketing materials at any time by performing the following actions:

send a corresponding letter refusing to receive advertising materials to info@adaurum.ru

Please note that in case of refusal to receive advertising and marketing materials, the User may continue to receive from the Copyright Holder any notifications related to the procedure for using the Mobile Application and/or its content.

7. DIRECTING COMPLAINTS AND QUESTIONS TO THE COPYRIGHT HOLDER

Request to stop processing personal data

Each User has the right to express his objection to the Copyright Holder against the processing and/or storage of his Personal Data. Such an objection can be expressed as follows:

the request should be sent to the Copyright Holder at the following address info@adaurum.ru

Request for information about personal data

If the User has questions related to the procedure for applying or using this Policy, the procedure and/or method of processing Personal Data, the User can ask such a question as follows:

the request should be sent to the Copyright Holder at the following address info@adaurum.ru

Change (update, addition, correction) or deletion of personal data

The User has the right to change or delete Personal Data at any time by sending a special request to the Copyright Holder at the following address: info@adaurum.ru.

The Copyright Holder has the right to refuse to change or delete Personal Data if such actions lead to (1) a violation of the rules of this Policy; or (2) to violate the Law; (3) the nature of the Personal Data is evidence in any litigation arising between the Copyright Holder and the User.

If Personal Data about the User is deleted, all publications made by such User (comments, ratings, reviews, publication of reports, videos and photographs, liking, ratings) and/or any other forms of activity available to the User in Mobile application.

8. TERMS AND PROCEDURE FOR STORING PERSONAL DATA

Storage is carried out independently by the Copyright Holder.

Storage is carried out for the following period: 3 years from the date of receipt of such information.

After the expiration of the storage period for Personal Data, such data is subject to immediate destruction or depersonalization, unless otherwise prohibited by the Law or the provisions of this Policy.

9. ACCESS OF MINORS TO THE MOBILE APPLICATION

Users in the Russian Federation

The use of the Mobile Application is intended for persons over 18 years of age, who access it only with prior consent to the processing of their Personal Data. The Copyright Holder checks the User’s age as follows:

the user will need to enter his date of birth in a special field

If the User is a minor, then he must immediately stop using this Mobile Application.

Users in the European Union

The use of the Mobile Application is intended for persons aged 16 years and older, who access it only with prior consent to the processing of their Personal Data. The Copyright Holder checks the User’s age as follows:

the user will need to enter his date of birth in a special field

If the Copyright Holder becomes aware that the User’s age does not correspond to the acceptable age for using the Mobile Application, in this case the Copyright Holder undertakes to immediately block such User’s access to the Mobile Application.

10. PROCEDURE FOR PROTECTION OF PERSONAL DATA

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 it by third parties.

11. USERS LOCATED IN THE EUROPEAN UNION

General provisions

Since the Mobile Application is available to users from the European Union, the Copyright Holder undertakes to additionally adhere to the provisions of the GDPR.

The Controller in the understanding of this Policy is the Copyright Holder.

The Copyright Holder stores Personal Data for a reasonable period of time necessary to achieve the purposes of processing, but not less than the period established by the local legislation of the Member State of the European Union in which the Mobile Application is available for storing one or another type of Personal Data. Upon expiration of the period established for storage, the Copyright Holder undertakes to immediately destroy or depersonalize such data.

Official representative

The functions of the official representative of the Controller for the protection of Personal Data in the European Union will be performed by the following representative office of the Controller: ADAURUM LLC, address: Bulgaria, Sofia city, Capital Municipality, Izgrev dist. zh.k Iztok, Lyulyakova gradina, No. 17 fl. 2 apt. 8, contact details: info@adaurum.ru.

User rights in the field of personal data protection

According to Chapter 3 of the GDPR, Users located in the European Union have the following rights in the field of Personal Data protection: (1) the right to receive information about their Personal Data (“the right to be informed”); and (2) the right to access your Personal Data (“the right of access”); and (3) the right to rectification of Personal Data (“the right to rectification”); and (4) the right to erasure of Personal Data (“the right to erasure”); and (5) the right to restrict processing of Personal Data; and (6) the right to portability of Personal Data to third parties (“the right to data portability”); and (7) the right to object.

12. FINAL PROVISIONS

Availability of the policy text for review

Users can familiarize themselves with the terms of this Policy at the following link: https://main.adaurum.ru/en/any-quiz-policy/.

This version of the Policy is valid from May 31, 2023.

Changes and additions to the policy

This Policy may be changed from time to time. The Copyright Holder does not bear any responsibility to the User for changing the terms of this Policy without the permission and/or consent of the User.

The User undertakes to regularly check the provisions of this Policy for possible changes or additions..

Applicable Law

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 norms of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” (with all additions and changes), the 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 changes), as well as the provisions of the General Data Protection Regulation dated April 27, 2016 GDPR.

Risk of disclosure

Regardless of the measures taken by the Copyright Holder to protect the confidentiality of the received personal data, the User is hereby considered to be properly aware that any transfer of Personal data on the Internet cannot be guaranteed secure, and therefore the User carries out such transfer at his own risk.

Public information

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, and therefore the Copyright Holder does not undertake any obligations to protect Personal Data that may be made public or published as part of such publication and/or content.