Russian version of THE PRIVACY POLICY

PRIVACY POLICY FOR THE MOBILE APPLICATION "I'M PROFESSIONAL"

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.

"Mobile application" is software (with all existing additions and improvements) designed to work on smartphones, tablets, watches and other mobile devices, and designed for a specific platform (iOS, Android, Windows Phone, etc.). For the purposes of this Policy, the Mobile Application means the following software: I'M PROFESSIONAL.

"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 entity or individual who has downloaded the Mobile Application to a smartphone, tablet, watch or any other mobile device and/or 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 User's use of the Mobile Application. The user joins such an agreement and has no right to make and/or require any changes or additions to it. The User can read the terms of the User Agreement at the following link: https://im-prof.com/terms-EN/

"Rightholder" means the following person who owns exclusive ownership of the Mobile Application Vladimir Viktorovich Shopinskiy, Moscow

"Cookies" means small files sent to any mobile applications 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 posted on them.

2. RELATIONSHIPS 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 of Personal Data received, the directions and purposes of the use (processing) of Personal Data, as well as the sources of obtaining such Personal Data; and

(2) determination of the User's rights to protect the confidentiality of Personal Data transmitted to 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 case of processing by third parties of Personal Data that are 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, then 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, methods of processing used, information about persons who have access to them or to whom they may be disclosed under a contract or the Law).

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

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

(4) receive data on the carried out or alleged 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 omissions 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 damages and/or compensation for moral damage in court as a result of violations by the Copyright Holder and/or third parties of the User's rights to protect and protect his Personal Data.

(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-personalized 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) traffic information, possible number of clicks made, logs and other data.

(2) information about the location of the User (geolocation). The user can disable geolocation at any time by changing the settings of the device from which the Mobile Application was logged in. Geolocation is used by the Mobile Application only when the User actively uses such an application. When you exit the Mobile Application, geolocation stops functioning.

(3) information about the device (identification number, mobile operator's network) from which you log in, operating system, platform, browser type and other browser information, IP address.

Personal data about users

Face Data Collection and Usage

Our app collects facial data, including facial landmarks, depth information, and expressions, using the TrueDepth API on your device. This data is collected solely for enhancing user experiences within the app, such as enabling personalized avatars and augmented reality effects.

We want to assure you that we doе not store collected face data on our servers or any external storage. The data is processed locally on your device in real-time to provide the intended features of the app. We understand the importance of your privacy and have designed our app's architecture to ensure that your face data remains within your control.

The User provides the Copyright Holder with the following personal data about himself:

(1) full surname, first name and patronymic.

(2) date of birth and age.

(3) e-mail address.

(4) mobile phone number.

(5) the User's gender.

(6) photo with the User's image.

(7) all photos, video clips, audio files and other types of media that are stored on the device from which you log in to the Mobile Application.

(8) all contacts from the phone book of the device from which you log in to the Mobile Application.

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

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

(11) data on all publications made by the User in the Mobile Application, including, but not limited to, comments, rating, reviews, publication of reports, videos and photos, likes, ratings and/or any other forms of activity available to the User in the Mobile Application and/or content created.

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

The user is the sole person responsible for the completeness of the provided personal (personal) data and is obliged to carry out their timely change (update, verification, adjustment) 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 kind of Cookies, the purpose of which in this case is (1) to protect the User from possible spam from third parties on the Internet, as well as from other irrelevant and/or prohibited content, and (2) identify the User in order to distinguish him from bots/robots, and (3) to improve the User.

Login to the website through the Mobile Application allows Captcha to automatically access and collect the following information:

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

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

(3) web page styling information; and/or

(4) browser language settings; and/or

(5) plugins installed in the User's browser; and/or

(6) all Javascript objects.

Information about transactions made

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

● by a 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.

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

The User agrees to access and collection by the Copyright Holder and the relevant payment system or banking institution 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 store the IP address, preferences of Users or type of device used in order to (1) maintain statistics of visits and traffic of the site, and (2) personalize the data displayed on the User's screen, and (3) save the 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 Third Party Cookies.

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 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 that are needed to track the frequency of visitors to the site 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) Geolocation Cookies that are needed to determine the location of the User to personalize the content displayed on the screen of his device in the Mobile Application.

(4) Advertising (marketing) cookies that are necessary to place advertising and/or marketing ads in the Mobile Application that correspond to the preferences and interests of the User.

(5) Third-party cookies that are established by third parties with the permission of the User and are intended to conduct statistical research on the User's behavior on the Internet and/or send personalized advertising or marketing materials to the User and/or provide 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 a disconnection may result in limiting or changing the User's access to the functionality of the Mobile Application and/or content. To disable cookies, the following actions should be done: to refuse to use this application

4. PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA

Determination of processing goals

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

(1) to analyze the User's behaviour, as well as to identify the User's preferences for a certain type of content.

(2) for the prompt and correct operation of the Mobile Application, improve the functioning of the Mobile Application, improve the content of the Mobile Application, improve 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 e-mail 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) to determine the location of the User.

(9) to technically support the Mobile Application, identify problems in its operation and eliminate them.

(10) to communicate with the User.

(11) to fulfill other obligations of the Copyright Holder that have arisen before the User.

(12) for statistical research.

(13) for any other purpose, subject to obtaining separate consent from the User.

Processing of Personal Data is carried out on the basis of the principles: (1) legality of the purposes and methods of processing; and (2) integrity; and (3) compliance of the purposes of processing of Personal Data with the goals predetermined and declared during the collection of such Personal Data; and (4) compliance of the volume and nature of the Personal Data processed with the stated purposes of their processing.

Terms of personal data processing

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 in an international treaty or the Law; or (3) provision by the User of his Personal Data to an unlimited person; 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 case of depersonalization of Personal Data, which does not allow you to directly or indirectly determine the User, the subsequent use and disclosure of such data to third parties is allowed 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 when 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. THIRD-PARTY ACCESS TO PERSONAL DATA

Use of remarketing services

The Copyright Holder uses remarketing to advertise the Content of the Mobile Application to the User on other sites visited by the User.

Remarketing services to the Copyright Holder are provided through the following platform: Yandex.Advertising. The specified provider collects and processes non-personalized data that does not directly allow you to establish or identify the User. The information collected may usually include (1) content viewed by the User, (2) the date and time when the User viewed the content, (3) geolocation data. The collection and processing of such non-personalized information makes it possible to provide the User with more targeted advertising or marketing content.

By installing the Mobile Application, the User agrees to the Privacy Policy and the Terms of Use of the specified remarketing service provider, as well as the automatic installation of the relevant Cookie Files 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 the device from which the Mobile Application is logged in.

Use of analytical platforms

The Copyright Holder uses the Yandex analytical platform to (1) track the frequency of visitors to the site by Users; and (2) track the ways the User uses the Mobile Application and/or its content; and (3) identify the type and type of content that is popular among Users; and (4) determine 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, behaviour of the User, as well as his preferences and interest in certain content.

The Yandex analytical platform gets access to Personal Data in order to provide the Copyright Holder with an understanding of how effectively his Mobile application works, what content is popular, how effective it is to place certain advertising in it, as well as for the purpose of developing and/or improving the existing marketing strategy of the Copyright Holder.

By installing the Mobile Application, the User agrees to the Privacy Policy of Yandex, as well as to the automatic installation of the relevant Cookie Files 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) to the legal successors of the Copyright Holder that arose as a result of its liquidation, reorganization or bankruptcy, and who have received exclusive ownership rights to the Mobile Application; (3) payment service providers or This Policy.

The Copyright Holder discloses Personal Data only if (1) 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 as the Copyright Holder himself takes, and (2) consent to such disclosure has been previously expressed by the User and/or allowed on the basis of the Law.

Advertising from third parties

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 clicking on 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 site of third parties is made. The Copyright Holder does not bear any responsibility for the methods, methods and procedure for processing Personal Data by third-party sites. As a result, the Copyright Holder is also not responsible in case 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 himself with the personal data protection policies of the sites used in detail.

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

Distribution of advertising materials to users

The user automatically agrees to the right of third parties to send personalized advertising and marketing materials to the provided email address and/or mobile phone with the installation of the Mobile Application on the device.

The user has the right to refuse to receive such advertising and marketing materials at any time by performing the following actions: to refuse to use this application.

6. ADVERTISING PLACEMENT

Advertising in the mobile application

The Copyright Holder, together with the content, places various advertising and marketing materials in the Mobile Application, taking into account the identified preferences of the User to a particular content. Advertising in the Mobile Application involves installing 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: to refuse to use this application

Distribution of advertising materials

The User automatically agrees to the right of the Copyright Holder to send personalized advertising and marketing materials to the provided e-mail 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: to refuse to use this application

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 COPYRIGHT HOLDER

Requirement to stop processing personal data

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

The request should be sent to the following address politica@im-prof.com

Request for information about personal data

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

The request should be sent to the following address politica@im-prof.com

Modification (update, addition, adjustment) or deletion of personal data

The User has the right to independently change or delete his Personal Data at any time, unless such change or deletion may lead to (1) a violation of the rules of this Policy; or (2) a violation of the Law; (3) the nature of such Personal Data is evidence in any judicial process arising 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 User's 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.

In case of deletion of Personal Data about the User, all publications made by such User (comments, rating, reviews, publication of reports, videos and photos, affixing likes, ratings) and/or any other forms of activity available to the User in the Mobile Application are also subject to automatic deletion.

8. TERMS AND PROCEDURE FOR STORING PERSONAL DATA

Storage is carried out by third parties on behalf of the Copyright Holder. The User gives his consent to the storage of his Personal Data by third parties on behalf of the Copyright Holder, provided that such third parties retain the confidentiality of the Personal Data received. Information storage functions are entrusted to the following person: ARROUND INC (hereinafter referred to as the "Guardian"). Personal data is stored on the territory of the Russian Federation.

Storage is carried out for the entire period necessary to achieve the stated goals of Personal Data processing.

The Copyright Holder undertakes to destroy or depersonalize them immediately after achieving the purposes of processing Personal Data.

9. MINORS' ACCESS TO THE MOBILE APPLICATION

The mobile application can be used by persons under the age of 12.

The mobile application collects personal data about Users, so the use of this application by minor Users is allowed only with the prior consent of the legal representative (guardian) to the processing of Personal Data. Such consent must be granted in the following way:

The request should be sent to the following address politica@im-prof.com

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

10. PROCEDURE FOR THE 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 the required international standards, rules and recommendations for the protection of Personal Data.

The Copyright Holder has introduced a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access to them by third parties.

11. FINAL PROVISIONS

Availability of policy text for review

Users can read the terms of this Policy at the following link: https://im-prof.com/politika-EN/.

This version of the Policy is valid as of December 20, 2022.

Changing and supplementing the policy

This Policy is subject to change 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 modification or addition.

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 Federal Law No. 152 of July 27, 2006 "On Personal Data" (with all additions and amendments), Federal Law No. 242 of July 21, 2014 "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).

Risk of disclosure

Regardless of the measures taken by the Copyright Holder to protect the confidentiality of the personal data received, the User is hereby duly 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 framework of 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, evaluation, blog, etc.). Such publications and content are publicly available to other users of the Mobile Application, and therefore the Copyright Holder does not assume any obligation to protect Personal Data that may be made public or published as part of such publication and/or content.

Russian version of THE PRIVACY POLICY

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