This Personal Data Protection Policy (hereinafter the "Policy") has been developed under Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" and establishes the rules how INLINGO LLC, a company registered under the laws of the Russian Federation (Principal State Registration Number (OGRN): 1146330003005, Individual Taxpayer Number (INN): 6330043050, Tax Registration Reason Code (KPP): 633001001, legal address: 6, Ulitsa Kutuzova, Flat 6, Novokuybyshevsk, Samara Oblast, 446200, the Russian Federation, postal address: 4, Moskovskoye Shosse, Building 9, Office 1308, Samara, 443013, the Russian Federation) (hereinafter the "Company") processes any Personal Data obtained from individuals who use the website inlingogames.com, both its web version and the mobile application for iOS and Android operating systems (hereinafter the "Users").
Use of the website inlingogames.com (hereinafter the "Website") shall be acknowledged as the User's unconditional consent to this Policy and to the terms and conditions for processing of Personal Data herein.
1. Information Obtained by the Company
1.1. This Policy governs any form of processing of Personal Data and private information (any information used to confirm identity, and any other information connected thereto) regarding individuals who are consumers of the Company's products or services, as well as information that is not Personal Data (Technical Information).
1.2. "Personal Data" means any information related to a directly or indirectly specified or specifiable individual (the Personal Data subject) that can be used to identify the specified individual or to connect with them, and which the User provides to the Company about themself during the process of registration and/or while using the services of the Website, and in subsequent interaction with the Company, including:
1.2.1. Surname, name, and patronymic;
1.2.2. Email address;
1.2.3. The User's mobile phone number;
1.2.4. The User's position, place of work and/or profession;
1.2.5. The User's photograph;
1.2.4. Country and city of residence.
1.3. The accuracy of the Personal Data provided is the responsibility of the User. Furthermore, the Company will proceed from the assumption that the User has provided full and accurate personal information in response to the questions posed in the registration form.
1.4. "Technical Information" means the information that is automatically transferred to the Company during use of the Website by the software installed on the User's device. The Technical Information shall not be considered Personal Data. The Company uses cookie files and other equivalent technologies that enable identification of the User's device. Cookie files are text files that can be accessed by the Company in order to process information regarding the activity of the User's device. The User can turn off the possibility of using cookie files in the settings of their browser, in which case the User will be warned that not all the functions and services that comprise the Website may work correctly. The User may set their browser to accept all cookie files, to reject all cookie files, or to notify them when cookie files are created. The settings of each browser are different, so the User should refer to the Help menu or Settings menu of their browser to ascertain the ways of changing settings for the processing of cookie files.
1.5. The Company shall store and process Personal Data, Technical Information, and any other information regarding the User throughout the duration of the period in which it performs its activities.
2. Reasons for Processing the Information Provided by the User
2.1. The purpose of processing the User's data is to fulfill the Company's obligations to the User with regard to use of the Company's services, including:
2.1.1. Identifying the User;
2.1.2. Providing the User with personalized services on the Website;
2.1.3. Contacting the User when necessary, including by sending notifications, requests, and information connected with use of the services, provision of services, and also processing of the User's requests and inquiries;
2.1.4. Sending advertising and/or informational materials to the User.
3. Methods of Data Processing
3.1. The processing of the User's Personal Data shall include the recording, systematization, accumulation, storage, clarification (updates and alterations), extraction, use, transfer (circulation, provision, access), anonymization, blocking, deletion, and/or destruction of any of the User's Personal Data which does not fall into any special category that, under the effective law of the Russian Federation, the Company must obtain the User's written consent before processing.
3.2. The User consents to the Company processing the Personal Data they provide when completing any form on the Website and in any further interaction with the Website, including the transfer of such Personal Data to third parties in the course of the Company performing its principal activities.
3.3. The Company shall process the User's Personal Data using databases located within the Russian Federation.
4. Protection of Users' Data. Transfer and Provision of Information to Third Parties
4.1. The Company shall take measures—including legal, organizational, administrative, technical and physical measures—to ensure protection of the User's Personal Data under Article 19 of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" in order to ensure protection of the User's Personal Data from unlawful or accidental access, destruction, alteration, blocking, copying, transmission, or any other unlawful actions by third parties. The Company shall do so by limiting access to such information by other Users of the Website, employees and partners of the Company, third parties (with the exception of provision by the Company of any information required for the Company to fulfill its obligations to the User and comply with the requirements of Russian law), and also by applying sanctions to such parties if they violate the rules of confidentiality regarding such data.
4.2. The Company shall, in the event of reorganization of the Company and transfer of rights to a successor company, have the right to transfer the User's Personal Data to the successor company, while the successor company shall also assume all obligations of the Company to observe the conditions of this Policy in regard to the personal information they obtain.
4.3. The Company undertakes to ensure that the information provided by the User shall not be combined with statistical data, not be provided to third parties, and not be disclosed except in the cases stipulated herein.
4.5. The Company shall be entitled to provide information about the User to authorized state bodies of the Russian Federation, in order to rectify technical deficiencies or security problems, and in any other circumstances stipulated by the laws of the Russian Federation.
4.6. The Company shall be entitled to grant access to the User's information to third parties, if the transfer of the information is necessary to perform the principal activities of the Company.
5. The Company's rights
5.1. If the User withdraws their consent to processing of their Personal Data, the Company reserves the right to limit the User's access to any or all functions of the Website.
5.2. The Company reserves the right to use the User's email address and mobile phone number in order to deliver informational and advertising materials, including in the form of push notifications.
6. The User's rights
6.1. The User can, at any time, withdraw their consent to the processing of their Personal Data by sending the Company relevant written notice to the Company's postal address or the legal address of the Company specified herein. However, the User accepts that the Company has the right to continue processing such information in cases permitted by the effective legislation.
6.2. The User shall retain the right to demand that the Company update, block or destroy their Personal Data in cases where the Personal Data is incomplete, outdated, inaccurate, illegally obtained or not required for the stated purposes of its processing, and also to take the measures prescribed by law to protect their rights.
6.3. The User shall retain the right to obtain information concerning the processing of their Personal Data, including:
6.3.1. Confirmation that the Company is processing their Personal Data;
6.3.2. The purposes and methods used by the Company to process Personal Data;
6.3.3. The name and location of the Company;
6.3.4. The time limits on the processing of Personal Data, including the time limits on its storage;
6.3.5. Any other information prescribed in the effective laws of the Russian Federation.
6.4. By using the Website, the User grants their consent to receive information from the Company, including advertising materials, at the email address and/or on the mobile phone number they have provided. Consent to receiving informational and advertising materials can be withdrawn by the User at any time by following the relevant link specified in messages containing advertising materials sent to the email account provided by the User when completing the registration form on the Website, or by sending relevant notice to the legal address of the Company indicated herein.
6.5. The User may submit a demand (to the email address email@example.com) that their account be deleted from the Website inlingogames.com. Should they choose to do so, the User must send such a demand from the mobile phone or the email address which they specified when creating their account and to which the Company sent their account creation code, or send the demand to the legal address of the Company indicated herein.
7.1. In all other matters not directly covered by this Policy, the Company undertakes to be governed by the standards and provisions of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data", and other standards prescribed by the laws of the Russian Federation.
7.2. By providing their Personal Data and information, a visitor to the Company's Website automatically consents to the provisions hereof. If they do not consent to the conditions herein, the User should refrain from using the Website.
7.3. The Company reserves the right to unilaterally make amendments to this Policy at any time as they see fit. When the Company makes significant amendments to the Policy, they shall publish notification thereof on the Website along with the updated version of the Policy. The new version of the Policy shall come into force five (5) calendar days after it is published. Continued use of the Website after the new version of the Policy comes into force shall be deemed acceptance by the User of the Policy and its terms and conditions.
7.4. The terms of this Policy do not cover the activities or Internet resources of third parties.