Privacy policy - SIGNAL 2023

Privacy policy

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 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, Mobile Application means the following software: SIGNAL LIVE.

«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 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 does not have the right to make and / or demand any changes or additions to it.

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

Limited Liability Company «ARCH-SIGNAL»
legal address: 141410, MO, Khimki, st. Maria Rubtsova, d. 7, room. VII, com. 3 postal address: 109559, Moscow, PO Box 57, ARCH-SIGNAL LLC

«Cookies» means small files sent by some mobile applications or website, and placed on smartphones, tablets, watches and other mobile devices of the User, to improve the operation of such applications or websites, as well as the quality of the content posted in them.

2. RELATIONSHIPS TO WHICH THE POLICY APPLIES 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 persons performing the processing of Personal Data.
  3. receive information about the storage period of Personal Data.
  4. receive information about the completed or proposed cross-bordertransfer of Personal Data.
  5. appeal against the actions or inaction of the Copyright Holder to theauthorized body for the protection of the rights of personal data subjectsor in court.
  6. receive compensation for losses and / or compensation for moral damagein a judicial proceeding 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-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 location of the User (geolocation). The User can disable geolocation at any time by changing the settings of the device from which he logged into the Mobile Application. Geolocation is used by the Mobile Application only when the User is actively using such application. When you exit the Mobile Application, geolocation ceases to function.
  3. information about the device (identification number, mobile operator network) from which you log 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. E-mail address.
  2. data contained in the personal account (profile) of the User, all internalcorrespondence of the User (if any), as well as other activity of thepersonal account (profile) of the User.
  3. data and information obtained as a result of combining certain Personaldata of a particular User, as well as data and
  4. information, received data about the User, received from third parties(partners, marketers, researchers).

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.

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 User’s 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 transmission, to identify Users and provide User 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. Location Cookies, which are needed to determine the location of the User in order to personalize the content displayed on the screen of his device in the Mobile Application.
  3. Third party cookies, which are set by third parties with the permission of the User and are intended for statistical research regarding the User’s behavior on the Internet and/or sending personalized advertising or marketing materials to the User and/or the provision of 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 may result in restriction or change of the User’s access to the functionality of the Mobile Application and/or content. To disable Cookies, follow these steps:

4. PURPOSE OF COLLECTION AND PROCESSING OF PERSONAL DATA

Definition of the purposes of processing

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

  1. to analyze the User’s behavior, as well as to identify the User’s 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.

  1. to identify the User.
  2. to send personalized advertising and marketing materials to the specifiedemail address and / or mobile phone of the User.
  3. to comply with the requirements of the Law.
  4. to determine the location of the User.
  5. for technical support of the Mobile application, identification of problemsin its operation and their elimination.
  6. to maintain contact with the User (communication).
  7. to fulfill other obligations of the Copyright Holder that arose before theUser.

10. 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 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 their Personal Data to an unrestricted circle face; 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. ACCESS OF THIRD PARTIES TO PERSONAL DATA

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) to third parties solely for the purpose of providing the User with certain content or access to it; (4) 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 Rightholder discloses Personal Data only if

(1) I am 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 Copyright Holder takes, and (2) consent to such disclosure was previously expressed by the User and / or is allowed on the basis of the Law.

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 an appropriate opt-out letter to feedback@signal.live

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.

8. SENDING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER

Demand 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:
The request must be sent to the Copyright Holder at the following address: feedback@signal.live

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 question should be sent to the Copyright Holder at the following address: feedback@signal.live

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 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.

8. TERMS AND PROCEDURE FOR STORING PERSONAL DATA

Storage is carried out independently by the Copyright Holder.

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 User’s use of the Mobile Application.

9. ACCESS OF MINORS TO THE MOBILE APP

The use of the Mobile Application is intended for persons over 18 years of age, who access it only subject to the provision of prior consent to the processing of their Personal Data.

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

10. PROCEDURE FOR PROTECTION OF PERSONAL DATA

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. FINAL PROVISIONS

Availability of the text of the policy for review

Users can view the terms of this Policy at the following link: https://static.signal.live/privacy_policy.pdf.

This version of the Policy is valid from August 27, 2024.

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).

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.