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Privacy Policy

1. TERMS

1.1. Company - legal entity providing the Service to Users: Limited Liability Company "VO-Media" (LLC "VO-Media"); OGRN 1131841006142; INN 1841036310; registration address: 426000, Udmurt Republic, Izhevsk, st. Maxim Gorky, 221.

1.2. Resource - Badageoni website (www.topwar.ru) in the information and telecommunications network "Internet", software and/or other Internet resource of the Company.

1.3. Service - the functionality of the Resource provided by the Company, including providing access to the Resource or part thereof, Content and other materials.

1.4. User - an individual using the Service.

1.5. Data - personal data of the User, as well as other user information.

 

2. APPLICATION OF THE POLICY

2.1. By using the Service (including access to the Resource, Registration, Authorization), the User agreesagrees with the terms of processing of the Data by the Company, described in this Privacy Policy (Policy). In case of disagreement of the User with such terms, the use of the Service, including access to the Resource, must be terminated.

2.2. The Policy may be changed by the Company. The changed Policy is posted on the Resource. By using the Service after the Policy has been changed, the User agrees to the changed terms of Data processing.

 

3. PURPOSES AND CONDITIONS OF PROCESSING

3.1. The Company processes Data for the purpose of providing the Service, including:

- ensuring the functioning of the Service and providing the functionality of the User's personal account through the forms "Feedback", "Password recovery", "Registration" (name, Email);

- пproviding the opportunity to participate in news discussions, comment on news on the Resource;

- improving the quality and ease of use of the Service;

- personalization of content and other offers;

- User receiving messages on the Resource;

- Promotion Resourceа, products and/or services of the Company and its partners;

- receiving requests from Users and providing responses to such requests;

- conducting statistical and other studies of the use of the Service.

For the specified purpose, the Company processes the following Data: name (if in the field nickname The user has specified a name), nickname (nickname); date of birth; gender; email address; telephone number; residential address; information collected through metric programs (including Yandex Metric and AppMetrica, LiveInternet); avatar; information about the user device; Cookies; user ID; resource usage data; login and password; network address; third-party service account (if the User uses a third-party service account when registering on the Resource).

Note Resource may contain links to resources of other providers goods, services and informationThat Company not in controlт and to which the Policy does not apply.

If there is information aboutb account social network in your personal account settings User (when registering via a social network account or third party service through the forms “Feedback”, “Password recovery”, “Registration” (name, Email), the processing of personal data is carried out on the territory of the Russian Federation, the USA and other countries where the social network provider is present or a third party service. If there is no information about social networks in the personal account settings of User processing of personal data is carried out only on the territory of the Russian Federation.

3.2. For the purpose specified in paragraph 3.1 of the Policy, the following processing conditions apply:

3.2.1. The Company does not process biometric and special categories of personal data of Users. The personal data processed by the Company belong to other categories of personal data. The company does not process personal data.User data concerning racial, national origin, political views, religious or philosophical beliefs, health status, intimate life, biological characteristics, with the help of which it is possible to determine the identity of the User. The Company also does not purposefully collect personal data of Users from publicly available sources, unless otherwise provided by applicable legislation relating to the activities of the media.

3.2.2. List of actions with Data: collection, recording, systematization, accumulation, storage, clarification (update, change), retrieval, use, transfer (provision, access), depersonalization, blocking, deletion and destruction. The specified actions can be carried out in both non-automated and automated ways.

3.2.3. Duration of processing and storage of Data: until the purpose of processing is achieved, until the consent expires, or until the consent is revoked (if there are no other grounds for processing such Data), depending on which event occurs earlier.

3.3. The Company undertakes to ensure the recording, systematization, accumulation, storage, clarification (updating, modification), and extraction of personal data of Users using databases located on the territory of the Russian Federation.

3.4. In order to provide the relevanto Service To the User, the Company, if there is a legal basis, may transfer (provide, access) Data for their subsequent processing to service providers and partners specified in the relevant documents of the Company posted on the Resource.

 

4. GROUNDS FOR PROCESSING

4.1. The legal grounds for processing Data by the Company include, but are not limited to:

- User consent;

- execution Rules of use Resource or other agreements with the User;

- the exercise of rights and legitimate interests of the Company or third parties, if this does not violate the rights and freedoms of the User;

- processing for statistical or other research purposes, subject to mandatory anonymization of Data;

- the necessity of processing to achieve the purposes provided by law, as well as the fulfillment of obligations imposed on the Company by law.

 

5. USER RIGHTS

The user has the right:

- receive information regarding the processing of their Data;

- demand that the Company clarify his/her Data, block it or destroy it if it is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;

- revoke consent to the processing of your Data by sending a written statement to the Company;

- take measures to protect their rights as provided for by Russian legislation.

 

6. TERMS OF USE OF COOKIES

6.1. В within the framework of the purpose specified in paragraph 3.1 of the Policy, the Company carries out processing cookies including to ensure the functioning of the Service; personalization of Content and other offers; conducting statistical and other studies of the use of the Service. The User can view the validity period Cookies, and also prohibit their saving in your browser settings. Cookies - small pieces of data about past visits. Cookie policy are necessary, among other things, to ensure the functioning of the Service. Cookies are processed, including using web analytics services, metric programs, in particular: Statistics from SberAds, Yandex metric, AppMetrica, LiveInternet.

 

7. ORDER OF DESTRUCTION

7.1. With respect to the Data processed by the Company for the purpose specified in paragraph 3.1. of the Policy, a uniform procedure for their destruction applies in accordance with the legislation of the Russian Federation and local regulations of the Company.

7.2. The data is subject to destruction by the Company, in particular, if the purpose of processing has been achieved or the User has revoked consent to their processing (and there are no other grounds for processing such Data), or the fact of their illegal processing has been revealed.

7.3. If the purpose of processing the Data is achieved, the Company shall stop processing them and destroy them within a period not exceeding 30 (thirty) days from the date of achieving the purpose of processing. In the event that the User revokes consent to the processing of his/her Data, the Company shall cease processing them and, if the storage of the Data is no longer required for the purpose of processing, shall destroy them within a period not exceeding 30 (thirty) days from the date of receipt of the said review.

7.4. In the event of detection of unlawful processing of personal data carried out by the Company, the Company shall, within a period not exceeding 3 (three) business days from the date of this discovery, shall cease such processing. If it is impossible to ensure the legality of such processing, the Company shall, within a period not exceeding 10 (ten) business days from the date of detection of illegal processing, destroys such Data. In this case, the Company notifies the User about the elimination of the violations committed or about the destruction of the Data.

 

8. INFORMATION ON THE IMPLEMENTED PROTECTION REQUIREMENTS

8.1. The Company undertakes to ensure the confidentiality of Users’ personal data.

8.2. The Company ensures the security of Users’ personal data through the implementation of legal, organizational and technical measures.

8.2.1. Legal measures taken by the Company include the publication by the Company of documents defining the policy in relation to processing of personal data, local acts on issues of processing personal data, as well as local acts establishing procedures aimed at preventing and identifying violations of Russian legislation and eliminating the consequences of such violations.

8.2.2. Organizational measures taken by the Company include:

- ensuring unlimited access to the Policy, to information on the implemented requirements for the protection of personal data;

- implementation of internal control and (or) audit of compliance of personal data processing with the Federal Law of 27.07.2006 number 152-FZ "On personal data" (Law) and regulatory legal acts adopted in accordance with it, requirements for the protection of personal data, the Company's policy regarding the processing of personal data, and local regulations of the Company;

- assessment of the harm that may be caused to personal data subjects in the event of a violation of the Law, the ratio of the said harm and the measures taken by the Company aimed at ensuring the fulfillment of the obligations stipulated by the Law;

- familiarization of the Company's employees directly involved in the processing of personal data with the provisions of the Russian Federation legislation on personal datapersonal data, including requirements for the protection of personal data, documents defining the Company's policy regarding the processing of personal data, local acts on issues of processing personal data, and (or) training of the specified employees;

appointment of a person responsible for organizing the processing of personal data;

- appointment of a person responsible for ensuring the security of personal data in personal data information systems;

- approval by the head of the Company of a document defining the list of persons whose access to personal data processed in personal data information systems (ISPDN), is necessary for the performance of their official (labor) duties;

- ensuring the safety of personal data carriers;

- accounting of machine-readable media containing personal data;

- identification of threats to the security of personal data when processing them in personal data information systems;

- organization of a controlled zone within which stationary technical means for processing information and means of information protection, as well as means of ensuring functioning, are permanently located;

- organization of the security regime for the premises in which the ISPDN, preventing the possibility of uncontrolled entry or presence in these premises of persons who do not have the right of access to these premises.

8.2.3. Technical measures taken by the Company include:

- the use of information security tools that have undergone a procedure for assessing compliance with the requirements of Russian legislation in the field of information security, in cases where the use of such tools is necessary to neutralize current threats;

- assessment of the effectiveness of measures taken to ensure the security of personal data before commissioning ISPDN;

- establishing rules for access to personal data processed in ISPDN, as well as ensuring the registration and accounting of all actions performed with personal data in ISPDN;

- detection of facts of unauthorized access to personal data and the adoption of measures, including measures to detect, prevent and eliminate the consequences of computer attacks on ISPDN and responding to computer incidents in them;

- restoration of personal data modified or destroyed due to unauthorized access to them;

- control over the measures taken to ensure the security of personal data and the level of protection ISPDN.

 

9. OTHER

9.1. The User is responsible for the legality of the provision, relevance and accuracy of the data of the User and other persons that the User provides to the Company.

9.2. The Company considers requests related to the Policy, including requests from Users regarding the use of their Data, at the address: 426000, Udmurt Republic, Izhevsk, st. Maxim Gorky, 221.