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PRIVACY POLICY AND PERSONAL DATA PROCESSING GE

PRIVACY POLICY AND PERSONAL DATA PROCESSING

This present Privacy Policy and Personal Data Processing (hereinafter referred to as the Policy) contains the rules for the use by the Waterbalance mobile application of the User personal data which IDS Borjomi, LLC (hereinafter referred to as the Operator), including all persons belonging to the same group with the Operator, can get about the User while them using the Mobile application, features, functionalities, programs, products or services rendered by the Operator as well as in the course of implementation of any agreements and contracts by the Operator with the User. The User’s consent to the Policy expressed in the scope of relations with one of the listed persons shall apply to all other listed persons.
The use of the Mobile application shall mean unconditional consent of the User with this Policy as well as the terms of processing of their personal data specified herein; in case of disagreement with these terms, the User shall refrain from using the Mobile application.
1. General Provisions
1.1. This Policy is drawn up in accordance with the Russian Federal Law on Personal Data (№ 152-FZ dated July 27, 2006), as well as other laws and regulations of the Russian Federation relating to protection and processing of personal data, and shall apply to all personal data that the Mobile application can receive from the User who is a party to the civil law contract.
1.2. The Operator has the right to make changes to this Policy. When changes are made, the Policy header shall indicate the date of the last revision. A new version of the Policy shall enter into force upon its posting on the following website: https://ids-borjomi.com/ unless otherwise provided by the new version of the Policy.
1.3. This Policy, including the interpretation of its provisions as well as the procedure for its acceptance, execution, modification and termination, shall be subject to the laws of the Russian Federation.
1.4. The main purpose of this Policy is to lay the groundwork for the observance of human and civil rights and freedoms while processing personal data by the Mobile application.
2. User Personal Data Processed by the Mobile Application
2.1. Personal data in this Policy shall be understood as:
2.1.1. the information provided by the User when registering (creating an account/profile) or using the Mobile Application, including the User’s personal data (e-mail address, name, surname, patronymic or pseudonym, phone). The information required for the Mobile application is marked in a special way. Other information is provided by the User at their own discretion;
2.1.2. data that is transmitted automatically by the Mobile application in the course of its use through the software installed on the User’s device, technical specifications of the equipment and software used by the User, the date and time of access to the Mobile application and other similar information;
2.1.3. any other information about the User which is subject to be processed under the terms of use of the Mobile Application.
2.2. Processing of personal data by the Mobile application shall be carried out in the following cases:
2.2.1. with the consent of the Personal Data Owner (User) to processing their personal data;
2.2.2. to implement a contract to which the Personal Data Owner may either be a party, beneficiary or guarantor, including the cases when the Operator may enforce its right to assign the rights (claims) under such contract, as well as for making a contract initiated by the Personal Data Owner (User) or a contract under which the Personal Data Owner shall be a beneficiary or guarantor;
2.2.3. to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the Personal Data Owner (User) are not violated;
2.2.4. when so required for the administration of justice, execution of the court ruling, an act of another body or an official subject to be executed in accordance with the enforcement proceedings laws of the Russian Federation;
2.2.5. in the case when the access by an unlimited number of persons to the personal data of the Data Owner (User) is granted by the Personal Data Owner themselves, or at their request (hereinafter — personal data made public by the Personal Data Owner);
2.2.6. for the purposes of statistical or other research provided that the personal data are depersonalized;
2.3. Special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, sex life, criminal record, and biometric personal data shall not be processed by the Mobile application. Processing of the specified data is possible by the Operator only as authorized under the User’s written consent.
2.4. The Operator shall not verify the accuracy of the personal data provided by the User, and is not able to assess their legal capacity.
3. Purposes for Processing Users’ Personal Data
3.1. The Operator shall process the User’s personal data for the following purposes:
3.1.1. to implement a contract to which the Personal Data Owner may either be a beneficiary or guarantor (User), as well as to effect a contract initiated by the User and the Personal Data Owner shall be a beneficiary or guarantor thereunder;
3.1.2. to comply with the requests of the competent public authorities including those involved in criminal intelligence activities;
3.1.3. to identify a party within the scope of services, agreements and contracts with the Operator;
3.1.4. to provide the User with some personalized services;
3.1.5. to comply with the requests coming from the Users, sending notifications and information related to the use of the Mobile application at the request of Users;
3.1.6. to improve the quality of the Mobile application, user experience, development of new services;
3.1.7. to target promotional materials;
3.1.8. to conduct statistical and other researches based on depersonalized data.

4. Terms of Transfer of Users’ Personal Data to Third Parties
4.1. The User’s personal data shall be held in strict confidence except for the cases of voluntary provision of personal data by the User through granting access to an unlimited number of persons.
4.2. The Operator has the right to transfer the User’s personal data to third parties in the following cases:
4.3.1. when the User has agreed or authorized the Operator of the Application to carry out such actions;
4.3.2. when the transfer is necessary for the User to take advantage of a certain service or for the implementation of a certain agreement or contract with the User;
4.3.3. when the transfer is necessary for the Mobile application itself to function and operate properly;
4.3.4. when the transfer is provided for by the Russian or any other applicable law within the procedure established by the laws;
4.3.5. when such a transfer takes place within the scope of sale or other transfer of business (in whole or in part), while the purchaser assumes all obligations to comply with the terms of this Policy in relation to the personal data received by them;
4.3.6. to ensure the possibility of protecting the rights and legitimate interests of the Operator or third parties in cases where the User violates the Operator’s User Agreement, this Policy, or documents containing the terms of use of specific services;
4.3.7. when the depersonalized statistical data are obtained as a result of processing of the User’s personal data by depersonalizing it, which are transmitted to a third party for research, work or services authorized by the Operator.
5. User Personal Data Protection
5.1. The Operator shall take all necessary and sufficient organizational and technical measures to protect the User’s personal data from an unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other illegal actions therewith taken by third parties.
6. Privacy Policy Revision and Updates
6.1. The Operator has the right to make changes to this privacy Policy. When changed, the current version shall indicate the date of the last update thereon. The new version of the Policy shall enter into force upon its posting, unless otherwise provided by the new version of the Policy. The current version is constantly available at https://ids-borjomi.com/
7. Contacts and Questions About Personal Data
7.1. The User has the right to send all offers, questions, requests and other queries regarding this Policy and the use of their personal data to the Operator:
— via email: info@borjomi.ru
— by regular mail: 5, Pervy Derbenevsky Pereulok, Bld. 2, entrance 3, office 301, 115114, Moscow
— by phone: (495) 660-73-11

Issue date: _________________________