1. DEFINITION OF CONCEPTS

" 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 a 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 (hereinafter " GDRP ").

" Mobile application " is software (with all existing additions and improvements) designed to run on smartphones, tablets, watches and other mobile devices, and designed for a specific platform (iOS, Android, etc.). For the purposes of this Policy, the Mobile Application means the following software: ProxyLite - Earnings .

" Personal data " means a set of personal data and / or non-personalized information about the User, provided by him 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 or natural person who has downloaded the Mobile Application to a smartphone, tablet, watch or any other mobile device and/or has activated such Mobile Application on one of these devices.

" User Agreement " means an agreement concluded between the Copyright Holder and the User regarding the procedure, rules and features of the Users use of the Mobile Application. The user joins 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://app.proxylite.ru/legal/proxylite_android_user_agreement.pdf

" Owner " means the following person who owns the exclusive rights to own the Mobile Application

Individual entrepreneur Petrov Ilya Pavlovich
TIN: 701405662317
OGRNIP: 320703100020464
Location address: Russian Federation, Novosibirsk region, city of Novosibirsk, Krasny pr-kt, 218, apt. 51

" Processor " means a person who, within the meaning of the GDPR, on behalf of the Controller, stores and/or processes Personal Data received from Users.

" Cookies " means small files sent to any mobile application or website and placed on the Users smartphones, tablets, watches and other mobile devices in order to improve the operation of such applications or websites, as well as the quality of the content placed in them.

2. RELATIONSHIPS TO WHICH THE POLICY APPLYS

General provisions

This Policy is used and applicable solely 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; and

(2) determination of the rights of the User in relation to the protection of the confidentiality of the Personal Data transmitted by him; and

(3) identification of persons responsible for the processing and storage of 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 the 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 for the collection, processing, retention and storage of 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 individual 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 for the protection of 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, methods of processing used, information about persons who have access to them or to whom they can be disclosed on the basis of an agreement or the Law).

(2) receive data on the location and identification data of the persons performing the processing of Personal Data.

(3) receive data on the retention periods of Personal Data.

(4) to receive information about the completed or proposed cross-border transfer of Personal Data.

(5) receive information about the location and identification data of persons storing Personal Data.

(6) appeal against 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.

(7) receive compensation for losses and / or compensation for moral damage in a judicial proceeding as a result of violations of the Users rights to the protection and protection of his Personal Data committed by the Copyright Holder and / or third parties.

(8 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-personally identifiable user information

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

(1) information about traffic, the possible number of clicks 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 User provides the Copyright Holder with the following personal data:

(1) date of birth and age.

(2) email address.

(3) mobile phone number.

(4) gender of the User.

(5) the citizenship of the User.

(6) data from the following social network: Vkontakte. The Copyright Holder may collect, process and store the User ID of any of the social networks that was used by the User within the Mobile Application. If the User is registered in the Mobile Application using one of his social media accounts, the User thereby grants the Copyright Holder automatic consent to the collection, processing and storage of Personal Data that has become available to the Copyright Holder through the selected social network.

(7) data contained in the personal account (profile) of the User, all internal correspondence of the User (if any), as well as other activity of the personal account (profile) of the User.

(8) data on orders/purchases made to Users and/or services received/paid through the Mobile Application.

(9) data and information obtained as a result of combining certain Personal data of a particular User, as well as data and information received data about the User received from third parties (partners, marketers, researchers).

(10) unique device, browser or application identifiers, IMEI code and/or MSISDN (phone subscriber number), and/or Wi-Fi adapter MAC/BSSID address, Firebase version identifier and/or advertising identifier to identify the device in the system

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

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

Using Captcha

The Mobile Application integrates Captcha, which is a type of Cookies, the purpose of which in this case is (1) to protect the User from possible spam coming from third parties on the Internet, as well as from other irrelevant and / or prohibited content, and (2 ) identification of the User in order to distinguish him from bots / robots, and (3) improvement of the Users ability to use the content of the Mobile Application.

Logging into the site through the Mobile App allows Captcha to automatically access and collect the following information:

(1) Cookies set in the browser within the last 6 (six) months; and/or

(2) the number of touches on the touch screen of the device made by the User (the number of clicks made); and/or

(3) information about the styling of the web page; and/or

(4) browser language settings; and/or

(5) plug-ins installed in the Users browser; and/or

(6) all Javascript objects.

Information about 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 payment in the Mobile Application in the following way:

through a bank card.

and also in the following way: QIWI wallet, Sberbank.

The collection and processing of data about the User in 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 the Copyright Holder and the relevant payment system or banking institution through which / through which payment is made to such Personal Data, and also agrees to the privacy policy of the relevant payment system or banking institution.

Use of cookies

This Mobile Application uses certain Cookies to save the 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 data displayed on the Users screen, and (3) save data necessary to identify the User, including when accessed 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 that are needed to control traffic and data transfer, to identify Users and provide access to the content of the Mobile Application to the User 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 interests User.

(2) Statistical Cookies, which are needed to track the frequency of visits to the site by Users, to identify how the User uses the Mobile Application, and to identify the type and type of content that is popular or interesting to the User.

(3) Third party cookies, which are set by third parties with the permission of the User and are intended to carry out statistical research regarding the Users behavior on the Internet and / or the sending of personalized advertising or marketing materials to the User and / or the provision of goods or services.

4. PURPOSE OF COLLECTION AND PROCESSING OF PERSONAL DATA

Determining the purposes of processing

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

(1) to analyze the Users behavior, as well as to identify the Users preferences for a particular type of content.

(2) for the operational and correct operation of the Mobile Application, improving the operation 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 send personalized advertising and marketing materials to the specified email address and / or mobile phone of the User.

(5) to comply with the requirements of the Law.

(6) to track orders/purchases made by the User through the Mobile Application.

(7) for technical support of the Mobile application, identification of problems in its operation and their elimination.

(8) to maintain communication with the User (communication).

(9) to fulfill other obligations of the Copyright Holder that arose before the User.

(10) to conduct statistical research.

(11) for any other purpose, 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 lawfulness of the purposes and methods of processing; and (2) good faith; and (3) suitability of the purposes of the processing of Personal Data for the purposes predetermined and declared at the time of collection of such Personal Data; and (4) suitability of the scope and nature of the Personal Data being processed for the stated purposes of their processing.

Conditions for the processing of personal data

The processing of Personal Data is carried out in the following cases: (1) obtaining consent from the User; or (2) achievement by the Copyright Holder of the goals provided for by an international treaty or the Law; or (3) the provision by the User of his Personal Data to an unlimited circle of persons; or (4) fulfillment of other obligations of the Copyright Holder to the User, including, but not limited to, 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 case of depersonalization of Personal Data, which does not allow to directly or indirectly identify the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy are no longer applied to them.

The Rightholder takes all possible measures to protect the confidentiality of the received Personal Data, except when the User has made such data publicly available.

The processing of Personal Data is carried out using automation tools and without the use of such automation tools.

5. THIRD PARTY ACCESS TO PERSONAL DATA

Use of analytical platforms

The Copyright Holder uses the Firebase analytics platform to (1) track the frequency of site visits by Users; and (2) track the ways in which the User uses 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 Firebase.

For these purposes, the Firebase analytics platform may collect data about the Users IP address, geolocation, user behavior, as well as user preferences and interests in relation to certain content.

The Firebase analytical platform accesses 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 it is to place certain advertisements in it, as well as for the purposes of developing and / or improving existing marketing Rightholders strategies.

By installing the Mobile Application, the User agrees to the Firebase Privacy Policy, as well as the automatic installation of appropriate Cookies on the Users 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) successors of the Copyright Holder, which 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 providing the User with certain content or access to it; (5) to third parties when the User has given consent to the disclosure, transfer or processing of their Personal Data, as well as in other cases expressly provided for by the Law or this Policy.

The Right Holder discloses Personal Data only if (1) it is sure 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 Right Holder takes, and (2) consent to such disclosure has been previously expressed User and/or permitted by law.

Sending promotional materials to users

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

The User has the right to opt out of receiving such advertising and marketing materials at any time by performing the following actions:

Send a notification to the email address: cocbuilder.srv@yandex.ru

6. ADVERTISING

Mobile App Advertising

The Copyright Holder does not place advertisements in the Mobile Application.

Distribution of promotional materials

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

The User has the right to opt out of receiving such advertising and marketing materials at any time by performing the following actions:

Send a notification to the email address: cocbuilder.srv@yandex.ru

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

7. SENDING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER

Request to stop processing personal data

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

Send a notification to the email address: cocbuilder.srv@yandex.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:

Send a notification to the email address: cocbuilder.srv@yandex.ru

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

The User has the right to independently change or delete his Personal Data at any time, except in cases where such change or deletion may lead to (1) a violation of the rules of this Policy; or (2) in violation of the Law; (3) the nature of such Personal Data is evidence in any litigation that has arisen between the Copyright Holder and the User. To do this, the User needs to delete his personal account (profile) in the Mobile Application.

The Copyright Holder has the right to delete the Users personal account/profile at any time, as well as all Personal Data about the User, if he has violated the terms of this Policy and/or the User Agreement.

8. TERMS AND PROCEDURE FOR STORING PERSONAL DATA

Storage is carried out by third parties on behalf of the Copyright Holder. The User agrees to the storage of his Personal Data by third parties on behalf of the Copyright Holder, provided that such third parties maintain the confidentiality of the Personal Data received. The functions of storing Information are entrusted to the following person: INDIVIDUAL ENTREPRENEUR PETROV ILYA PAVLOVICH (hereinafter referred to as the " Custodian "). The storage of Personal Data is carried out on the territory of the Russian Federation.

Storage is carried out during the entire period of use by the User of this Mobile application.

The Right Holder undertakes to destroy or depersonalize his Personal Data immediately after the termination of the Users use of the Mobile Application.

9. ACCESS OF MINORS TO THE MOBILE APP

Users in the Russian Federation

The mobile application can be used by persons under the age of 18.

The mobile application collects personal data about Users, therefore, the use of this application by minor Users is allowed only subject to prior consent from the legal representative (guardian) for the processing of Personal data.

If the minor User cannot provide consent to the processing of his Personal Data from the legal representative (guardian), in this case, such User is obliged to immediately stop using the Mobile Application.

Users in the European Union

The mobile application and/or its content is intended for persons under the age of 16.

Since the Mobile Application collects personal data about Users, the use of this application by Users under the age of 16 (unless a lower threshold is established by the national law of the Member State of the European Union in whose territory access to the Mobile Application is provided) is allowed only subject to obtaining prior consent from legal representative (guardian) for the processing of Personal data, which must be provided in the following way:

Send to email address: cocbuilder.srv@yandex.ru

10. PERSONAL DATA PROTECTION

Protecting the confidentiality of Personal Data is a paramount and important task for the Copyright Holder. The Rightholder adheres to all required international standards, rules and recommendations for the protection of Personal Data.

The Rightholder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access by third parties. To ensure the safety and confidentiality of the received Personal Data, the Copyright Holder uses the following means of protection:

(1) SSL (Security Sockets Layer) protocol.

(2) automatic data saving.

(3) Firewalls.

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 comply with the provisions of the GDPR.

The controller in the understanding of this Policy is the Copyright Holder. The Processor for the purposes of this Policy is the Custodian under Article 8 of the Policy.

The Rightholder 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 whose territory the Mobile Application is available, for storing one or another type of Personal Data. Upon the expiration of the period established for storage, the Copyright Holder undertakes to immediately destroy or depersonalize such data.

Official representative

Since the Controller is located outside the territory of the European Union, the following person is appointed as its official representative for the protection of personal data of Users in the European Union:

Petrov Ilya Pavlovich, address:

Russian Federation, Novosibirsk region, city of Novosibirsk, Krasny pr-kt, 218, apt. 51,

contact details: cocbuilder.srv@yandex.ru.

User rights in the field of personal data protection

Under 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 the processing of Personal Data (“ the right to restrict processing ”); and (6) the right to portability of Personal Data to third parties (“ the right to data portability ”); and (7) the right to object (“ the right to object ”).

12. FINAL PROVISIONS

Availability of policy text for review

Users can read the terms of this Policy at the following link: https://proxylite.ru/privacy_policy.php

This Policy may be translated into a foreign language for those Users who access the Mobile Application outside the Russian Federation. In case of discrepancy between the original text (Russian) and its translation, the original language shall prevail.

This version of the Policy is valid from March 13, 2021.

Changing and supplementing 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 himself 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 provisions 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 of the year No. 242-FZ " On Amendments to Certain Legislative Acts of the Russian Federation in Part 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 GDRP.

Disclosure risk

Regardless of the measures taken by the Copyright Holder to protect the confidentiality of the personal data received, 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.