MOBILE APPS SERIES PRIVACY POLICY

"" BRAINY KIDS""


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.
"Controller” Means the person who is responsible for the processing and protection of the Personal Data of Users located in the EU in the sense of the General Data Protection Regulation of April 27, 2016 (hereinafter “GDRP").
"Mobile app” 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, the Mobile Application means the following software: “BRAINY KIDS”.
"Personal Information” 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 entity or individual who downloaded the Mobile Application on a smartphone, tablet, watch or any other mobile device and / or activated such Mobile Application on one of the specified devices.
"Terms of use” 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 the introduction of any changes or additions to it. The user can familiarize himself with the terms of the User Agreement at the following link: https://brainykids.games/privacy/.
"Copyright holder” Means the next person who owns the exclusive rights to own the Mobile Application
IE Ovchinnikova Yulia Leonidovna
141410, Khimki, st. May 9, 16-100
Contact information: publishinghouseJF@yandex.ru
"Processor” Means a person who, in the understanding of the GDRP, on behalf of the Controller, stores and / or processes Personal Data received from Users.
"Cookies” Means small files sent to any mobile application or site and placed on smartphones, tablets, watches and other mobile devices of the User to improve the operation of such applications or sites, as well as the quality of the content posted in them.

2. RELATIONS TO WHICH THE POLICY APPLIES
General provisions
This Policy is used and applies exclusively 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 received Personal data, directions and purposes of use (processing) of Personal data, as well as sources of obtaining such Personal data; and
(2) determination of the User's rights in relation to the protection of the confidentiality of the Personal data transmitted by him; and
(3) determination of the 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 the processing of Personal Data by third parties that are 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 stipulated by this Policy.
If the User does not agree with the terms of the Policy and / or certain conditions 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 concerning their processing (the grounds and purposes of such processing, the processing methods used, information about the persons who have access to them or to whom they may be disclosed on the basis of an agreement or the Law).
(2) receive data on the location and identification data of persons who process Personal Data.
(3) receive data on the storage periods of Personal Data.
(4) receive data on the performed or expected cross-border transfer of Personal Data.
(5) to appeal against the actions or inaction of the Copyright Holder to the authorized body for the protection of the rights of subjects of personal data or in court.
(6) receive compensation for losses and / or compensation for moral damage in court 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 COLLECTED PERSONAL DATA
Non-personalized information about users
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, logs and other data.
(2) information about the device (identification number, network of the mobile operator) from which you log in, operating system, platform, browser type and other information about the browser, IP address.
Personal data about users
The Copyright Holder does not collect any personal data about the Users, which allows him to be identified.
Use of cookies
This Mobile Application uses certain Cookies to store the IP address, User preferences or the type of device used in order to (1) keeping statistics on site visits and traffic, and (2) personalization of the data displayed on the User's screen, and (3) storing data necessary to identify the User, including when accessing from different devices, and (4) displaying advertisements in accordance with the interests and preferences of the User. The mobile application can use both its own Cookies belonging to the Copyright Holder and the Cookies of third parties.
The mobile application uses the following cookies:
(1) Technical (functional) cookieswhich are needed to control traffic and data transfer, to identify Users and provide the User with 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) Statistics Cookies, which are needed to track the frequency of visits to the site by Users, to identify ways of using the Mobile Application by the User, as well as to identify the type and type of content that is popular or interesting for the User.
(3) Third party cookies, which are installed by third parties with the permission of the User and are intended to conduct statistical research regarding the behavior of the User on the Internet and / or the direction of 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 disconnection does not entail 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. PURPOSES OF COLLECTING AND PROCESSING PERSONAL DATA
Determination of the purposes of processing
The collection and processing of Personal Data is carried out for the following purposes:
(1) to analyze the behavior of the User, as well as to identify the User's preferences for a certain type of content.
(2) for the prompt and correct operation of the Mobile Application, improving the functioning of the Mobile Application, improving the content of the Mobile Application, improving the internal architecture and functionality of the Mobile Application.
(3) to identify the User.
(4) to comply with the requirements of the Law.
(5) for technical support of the Mobile application, identification of problems in its operation and their elimination.
(6) to maintain communication with the User (communication).
(7) to fulfill other obligations of the Copyright Holder that arose before the User.
(8) for statistical research.
(9) for any other purpose, subject to obtaining a separate consent from the User.
The processing of Personal Data is carried out on the basis of the principles: (1) the legality of the purposes and methods of processing; and (2) conscientiousness; and (3) compliance of the purposes of processing Personal Data with the purposes predetermined and declared when collecting such Personal Data; and (4) compliance of the volume and nature of the processed Personal Data with the stated purposes of their processing.
Personal data processing conditions
Personal data processing is carried out in the following cases: (1) obtaining consent from the User; or (2) achievement by the Copyright Holder of the goals stipulated by an international treaty or the Law; or (3) provision by the User of his Personal Data to an unlimited number of persons; or (4) fulfillment of other obligations of the Copyright Holder to the User, including, but not limited to, the 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 the case of anonymization of Personal Data, which does not directly or indirectly determine the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy no longer apply to them.
The Copyright Holder takes all possible measures to protect the confidentiality of the received Personal Data, except for cases when the User has made such data publicly available.
The processing of Personal Data is carried out using automation tools and without using such automation tools.

5. ACCESS OF THIRD PARTIES TO PERSONAL DATA
Using analytical platforms
The copyright holder uses the Firebase analytics platform to (1) tracking the frequency of website traffic by Users; and (2) tracking the ways the User uses the Mobile Application and / or its content; and (3) identifying the type and type of content that is popular among Users; and (4) determining the location of the User. The User also gives his consent to the Copyright Holder to use the information received about the User from Firebase.
For these purposes, the Firebase analytical platform may collect data about the IP address, geolocation, User behavior, as well as his preferences and interests in relation to certain content.
The Firebase analytical platform gains access to Personal Data in order to provide the Copyright Holder with an understanding of how effectively his Mobile Application works, what kind of content is popular, how effective is the placement of one or another advertisement in it, as well as for the purposes of developing and / or improving the existing marketing strategies of the Copyright Holder.
By installing the Mobile Application, the User agrees with the Privacy Policy of Firebase, as well as with the automatic installation of the corresponding Cookies on the User's device.
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) legal successors of the Copyright Holder who 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 disclose, transfer or process his Personal Data, as well as in other cases expressly provided for by the Law or this Policy.
The Copyright Holder 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 himself takes, and (2) consent to such disclosure was previously expressed by the User and / or is allowed on the basis of the Law.

6. PLACEMENT OF ADVERTISING
Advertising in the mobile application
The Copyright Holder does not place advertisements in the Mobile Application.

7. SENDING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER
Request to terminate the processing of personal data
Each User has the right to express his objection to the Copyright Holder against the processing and / or storage of his Personal Data. Such an objection may be expressed as follows:
the request can be sent to the Copyright Holder at the following address:
publishinghouseJF@yandex.ru
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 can be sent to the Copyright Holder at the following address:
publishinghouseJF@yandex.ru
Change (update, addition, correction) or deletion of personal data
The User has the right to change or delete Personal Data at any time by sending a special request to the Copyright Holder at the following address: publishinghouseJF@yandex.ru.
The Copyright Holder has the right to refuse to change or delete Personal Data if such actions lead to (1) to violation of the rules of this Policy; or (2) to violate the Law; (3) the nature of the Personal Data is evidence in any legal process that arose between the Copyright Holder and the User.

8. TERMS AND PROCEDURE FOR STORING PERSONAL DATA
Storage is carried out independently by the Copyright Holder.
Storage is carried out for the entire period necessary to achieve the stated purposes of processing Personal Data.
The Copyright Holder undertakes to destroy or depersonalize them immediately after achieving the goals of processing Personal Data.

9. MINOR ACCESS TO THE MOBILE APPLICATION
Users on the territory of the Russian Federation
The mobile application can be used by persons under the age of 18. Since the Mobile Application does not collect personal data about Users, consent to the processing of Personal Data of minors is not required.
If a minor User cannot provide consent to the processing of his Personal data from a legal representative (guardian), in this case, such User is obliged to immediately stop using the Mobile Application.
Users in the European Union
The mobile application and / or its content is intended for persons under the age of 16. Since the Mobile Application does not collect personal data about Users, consent to the processing of Personal Data from Users under the age of 16 is not required.

10. PROCEDURE FOR PROTECTING PERSONAL DATA
Protecting the confidentiality of Personal data is the primary and important task for the Copyright Holder. The Copyright Holder adheres to all required international standards, rules and recommendations for the protection of Personal Data.
The Copyright Holder has introduced a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access to them by third parties.

11. EUROPEAN UNION USERS
General provisions
Since the Mobile Application is available to users from the European Union, the Copyright Holder undertakes to additionally adhere to the provisions of the GDRP.
The controller in the understanding of this Policy is the Copyright Holder.
The Copyright Holder stores Personal Data for a reasonable period of time necessary to achieve the purposes of processing, but not less than the period established by the local legislation of the Member State of the European Union, on the territory of which the Mobile Application is available, for storing this or that type of Personal Data. Upon the expiration of the period established for storage, the Copyright Holder undertakes to immediately destroy or depersonalize such data.
Official representative
Since the Controller is located outside the territory of the European Union, the following person is appointed as its official representative for the protection of Personal Data of Users in the European Union: Mr. Evgeniy Ovchinnikov, contact details: +66627156810.
User rights in the field of personal data protection
According to Chapter 3 of the GDRP, Users located in the European Union have the following rights in the field of Personal Data protection: (1) the right to receive information about your Personal Data (“the right to be informed”); and (2) the right to access your Personal Data (“the right of access”); and (3) the right to rectification of Personal Data (“the right to rectification”); and (4) the right to erasure of Personal Data (“the right to erasure”); and (5) the right to restrict the processing of Personal Data (“the right to restrict processing”); and (6) the right to transfer Personal Data to third parties (“the right to data portability”); and (7) the right to object (“the right to object”).

12. FINAL PROVISIONS
Availability of Policy Text for Review
Users can familiarize themselves with the terms of this Policy at the following link:
https://brainykids.games/privacyeng/
This Policy can be translated into a foreign language for those Users who access the Mobile Application outside the Russian Federation. In the event of a discrepancy between the original text (Russian) and its translation, the original language shall prevail.
This version of the Policy is valid as of April 22, 2021.
Changes and additions to the policy
This Policy is subject to change 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 amendments and additions), the Federal Law of July 21, 2014 year No. 242-FZ "On amendments to certain legislative acts of the Russian Federation in terms of clarifying the procedure for processing personal data in information and telecommunication networks" (with all additions and changes), as well as the provisions of the General Data Protection Regulation dated April 27, 2016 GDRP.
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 duly aware that any transfer of Personal Data on the Internet cannot be guaranteed safe, and therefore the User carries out such transfer at his own risk.
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