This Privacy Policy for personal data (hereinafter referred to as the “Policy”) applies to all information that the Potok VPN Mobile Application (hereinafter referred to as the “Application”) may receive about the user during their use of the Application.
This Policy for the processing of personal data is formulated in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and defines the procedure for processing personal data and measures for ensuring the security of personal data taken by PotokYou (hereinafter referred to as the “Operator”).
1.1. The Operator's primary goal and condition of its activity is to ensure the rights and freedoms of individuals and citizens when processing their personal data, including the protection of privacy, personal and family secrets.
1.2. This Policy by the Operator regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may receive about visitors to the Potok VPN Application.
2.1. Automated processing of personal data - processing of personal data using computing equipment.
2.2. Blocking of personal data - a temporary suspension of the processing of personal data (except when processing is necessary to clarify personal data).
2.3. Mobile application - a comprehensive product consisting of different elements for the protection of which various intellectual property rights may be used.
2.4. Information system of personal data - a set of personal data contained in databases and information technologies and technical means that ensure their processing.
2.5. Anonymization of personal data - actions that result in the impossibility of identifying without the use of additional information the ownership of personal data to a specific User or another subject of personal data.
2.6. Processing of personal data - any action (operation) or a set of actions (operations) performed with personal data using automation tools or without such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, usage, transfer (distribution, provision, access), anonymization, blocking, deletion and destruction of personal data.
2.7. Operator - a government authority, municipal authority, legal entity or individual that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed and the actions (operations) performed with personal data.
2.8. Personal data - any information related directly or indirectly to a specific or definable User of the Potok VPN Application.
2.9. Personal data allowed by the subject of personal data for distribution - personal data to which access is granted to an unlimited number of persons by the subject of personal data by giving consent for the processing of personal data allowed for distribution in the manner provided by the Personal Data Law (hereinafter referred to as “personal data allowed for distribution”).
2.10. User - any visitor to the Potok VPN Application.
2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Distribution of personal data - any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at making personal data available to an unlimited number of persons, including the publication of personal data in the media, posting on information and telecommunications networks or providing access to personal data in any other way.
2.13. Cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual or a foreign legal entity.
2.14. Destruction of personal data - any actions that result in personal data being irreversibly destroyed with the impossibility of further restoring the content of personal data in the information system of personal data and/or the physical media of personal data being destroyed.
3.1. The Operator has the right to:
3.2. The Operator is obliged to:
4.1. Subjects of personal data have the right to:
4.2. Subjects of personal data are obliged to:
4.3. Individuals who provide the Operator with false information about themselves or information about another subject of personal data without their consent shall be liable in accordance with the legislation of the Russian Federation.
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of their collection is not allowed.
5.3. It is not permitted to combine databases containing personal data processed for purposes that are incompatible with each other.
5.4. Only personal data that meet the purposes of their processing shall be processed.
5.5. The content and volume of processed personal data correspond to the stated purposes of processing. Excessiveness of processed personal data regarding the stated purposes of their processing is not allowed.
5.6. When processing personal data, the accuracy, sufficiency, and if necessary, relevance of personal data concerning the purposes of processing personal data is ensured. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that permits identification of the subject of personal data no longer than required by the purposes of processing personal data, unless the storage period is established by federal law, contract in which the subject of personal data is a party, beneficiary or guarantor. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or when there is no longer a need to achieve these purposes, unless otherwise provided by federal law.
Purpose of Processing: Providing the User with access to services, information and/or materials contained on the website.
Personal Data: Telegram ID.
Legal Grounds: Contracts concluded between the operator and the subject of personal data.
Types of Processing Personal Data: Collection of information to ensure the functionality of the service.
7.1. The processing of personal data is carried out with the consent of the subject of personal data for the processing of their personal data.
7.2. The processing of personal data is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, to carry out functions, powers and responsibilities imposed by the legislation of the Russian Federation on the Operator.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act or an act of another authority or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of a contract to which the subject of personal data is a party or a beneficiary or guarantor of that contract, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. The processing of personal data to which access is provided to an unlimited number of persons by the subject of personal data or at their request (hereinafter referred to as public personal data) is permitted.
7.7. The processing of personal data that is subject to publication or mandatory disclosure in accordance with federal law is permitted.
The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.
8.1. The Operator ensures the security of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
8.2. The User's personal data will never be transferred to third parties under any circumstances, except in cases related to the fulfillment of current legislation or if the subject of personal data has given consent to the Operator for the transfer of data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case inaccuracies are identified in personal data, the User can update them independently by sending a notification to the Operator at the email address [email protected] marked "Updating Personal Data."
8.4. The duration of the processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided by the contract or current legislation. The User may revoke their consent to the processing of personal data at any time by sending a notification to the Operator via email at [email protected] with the subject "Withdrawal of Consent for Processing Personal Data."
8.5. All information collected by third-party services, including payment systems, communication services and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or these specified documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.
8.6. The restrictions imposed by the subject of personal data on the transference (except for providing access) and processing or the conditions for processing (except for receiving access) of personal data allowed for distribution do not apply in cases of processing personal data in state, public and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during their processing.
8.8. The Operator stores personal data in a form that allows the identification of the subject of personal data for no longer than is required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, a contract to which the subject of personal data is a party, a beneficiary or a guarantor.
8.9. The termination of the processing of personal data may be conditioned by the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or a request to cease processing personal data, as well as the detection of unlawful processing of personal data.
9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, modifies), retrieves, uses, transfers (distributes, provides, grants access to), anonymizes, blocks, deletes and destroys personal data.
9.2. The Operator performs automated processing of personal data with the receipt and/or transmission of the obtained information through information and telecommunications networks or without it.
10.1. Before starting activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of subjects of personal data of its intention to carry out cross-border transfer of personal data (such notification is sent separately from the notification of intent to process personal data).
10.2. Prior to submitting the aforementioned notification, the Operator is obliged to obtain from the authorities of the foreign state, foreign individuals, foreign legal entities to which the cross-border transfer of personal data is planned, the relevant information.
The Operator and other persons who have access to personal data are obliged not to disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.
12.1. The User may obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at [email protected].
12.2. Any changes to the policy of personal data processing by the Operator will be reflected in this document. The Policy remains in effect indefinitely until replaced by a new version.
12.3. The current version of the Policy is available for public access in the Potok VPN Application.