The text is a translation for information purposes and, to avoid confusion, the Russian document version shall prevail.
This Privacy Policy (hereinafter referred to as the “Policy” or “Privacy Policy”) is an official document of Net-Film (Net-Film LLC, TIN 7701708080, PSRN 1077746731215, address: Valdayskiy proezd, 16, bldg. 2, Moscow, 125445) and determines the procedure for processing and protecting information about individuals using the Website services (hereinafter referred to as the “Users”).
This Privacy Policy applies to all information and data that Net-Film can receive about a user of the global Internet network (User) using the Website and its services, and is aimed at governing the provision of proper user information protection, including their personal data, from unauthorized access and disclosure. Issues related to the collection, storage, distribution and protection of User information can be amended and set forth in other official documents of Net-Film and in the regulations of the applicable Russian legislation.
The following terms and definitions are used herein, within the meaning specified according to the User Agreement: Website, Net-Film, User, Documents.
Other terms and definitions can be provided in the text hereof.
The use of the Website, including any Website services, is governed by the Documents.
If the User does not agree with the terms hereof, then in order to terminate the Policy in relation to him/her, the User shall stop using the Website, including by visiting the Website.
By using the Website and/or any Website service, in any way and in any form within its declared functionality, including: registration and/or authorization on the Website or in any Website services; access to the Website or any Website services; other use of the Website or any Website service functionality, the User confirms that:
He/she have read the terms hereof and of the Documents in full before using the Website or any Website services.
He/she accepts all the terms hereof and of the Documents in full without any exceptions and restrictions on the part of the User and undertakes to comply with them, or in case of disagreement with any terms, the User shall completely refrain from using the Website or any Website services in any form.
The Policy (including any part hereof) and/or the Documents (including any part thereof) may be revised by Net-Film without any special notice to the Users. A new revision of the relevant documents shall come into force upon posting on the Website. The User shall independently check the revisions of the specified documents.
The Policy uses the following basic concepts:
Automated personal data processing means processing of personal data using computer equipment;
Personal data blocking means temporary personal data processing suspension (unless processing is necessary to clarify personal data);
Personal data information system means a set of personal data contained in databases, and information technologies and technical means ensuring their processing;
Depersonalization of personal data means actions that cannot be determined if the personal data belong to a specific subject of personal data, without using additional information;
Personal data processing means any action (operation) or set of actions (operations) taken with automation tools or without them, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
Operator means a state body, municipal body, legal or natural person, independently or jointly with other persons organizing and (or) processing personal data, as well as determining the purposes of personal data processing, the content of personal data to be processed, actions (operations) with personal data;
Personal data means any information relating directly or indirectly to specific or determined individual (the personal data subject);
Provision of personal data means actions aimed at disclosing personal data to a certain person or a certain set of persons;
Dissemination of personal data means actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including public disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way;
Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign individual or to a foreign legal entity;
Destruction of personal data means actions that result in the impossibility of restoring the content of personal data in the personal data information system and (or) result in destruction of the personal data physical media;
Personal information of the Users that the Website receives and processes:
As part hereof, "User's Personal Information" means:
Personal information, including personal data that the User provides about himself/herself when registering (creating an account) on the Website, within the minimum scope required for registration on the Website: email address.
Required information includes: a valid email address; consent to the terms of the Documents.
personal data that can be collected and processed by the personal data base owner (Net-Film), among other things, can mean (in this case, a specific list of personal data will be determined solely based on the registration data and registration forms of the Website and Website services): last name, first name, patronymic; date of birth; contact phone number; e-mail address; city, country and/or address of residence; sex; social media account; marital status; social status; information about the main identity document; native language and/or information about the knowledge of foreign languages; information about education; profession, specialization; official position; work experience; information about registration with the tax authority; information about registration with the pension fund; field of scientific interests; information on obtaining funding for education; information about publications of scientific papers (discoveries, inventions); photo images (photos); IP address (unique network address of a node in an IP protocol-based computer network); information from cookies (a small piece of data sent by the web server and stored on my computer, which the web client or web browser sends to the web server each time in an HTTP query when trying to open the page of the corresponding website); browser information (or other program that provides access to displaying advertising); Website access time; advertising block URL address; referrer (address of the previous page); geolocation services data; any other information the Website User enters independently on his/her own initiative, and which can be attributed to personal data (however, as part of the submitted personal data, the User shall not specify data that pose a particular risk to the User rights and freedoms (so-called "sensitive personal data"): about racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, data related to health, sexuality, biometric or genetic data)).
Net-Film does not purposefully collect "sensitive personal data", and Net-Film cannot ask the User's consent to such processing, since it is not aware in advance of the potentially sensitive nature of such personal information if the User, despite the warning (stated above), can provide Net-Film with it.
Based on the stated herein, at the request of Net-Film in order to fulfill Net-Film's obligations to the Users under the terms of the Documents, Net-Film shall have the right to additionally request the User to provide a copy of an identity document or other document containing the User's first name, last name, photo, as well as other additional information that, at the discretion of Net-Film, will be necessary and sufficient to identify such User and will prevent abuse and violations of the rights of third parties.
Optional information includes:
Avatar (an image posted by the User next to the Username/Nickname);
Confirmation of the User's access rights to applications of third-party websites.
Data that, in the process of technological interaction, is automatically transmitted to the Website for its use by means of the software installed on the User's device, including:
Electronic data: Host IP address (unique User's computer number), cookies information (allowing to identify the User's browser and store the User's settings and other information), information about the User's browser (or other software accessing the Website), access time, the requested page URL, the User's operating system, the browser, the geographic location, the Internet service provider, the data from the address book, the data obtained as a result of access to the camera, microphone and similar devices, web beacons/pixel tags.
Date and time of access to the Websites and/or the Services;
Information about the User's activity while using the Websites and/or the Services (for example, the search query history; files stored on the Net-Film server, uploaded by users);
Geographic information;
Other information about the User necessary for processing in accordance with the terms governing the use of a particular Website;
Information received by Net-Film from its partners in accordance with the terms of agreements concluded between the User and the respective partner, and agreements concluded between Net-Film and the partner.
Net-Film shall have the right to use cookies, web beacons, pixel tags to collect Personal Information and associate such personal information with the User's device and web browser (for more details, see the Cookies Policy).
This Policy applies only to the Website. Net-Film does not control and is not responsible for the websites and software of third parties where the User can go by clicking on the links available on the Website, and the use of personal information provided by the User on the websites of third parties.
Net-Film does not verify the accuracy of Personal Information provided by the Users and does not exercise control over its legal capacity, based on the fact that the User provides reliable and sufficient Personal Information and keeps this information up to date.
By posting information on his/her personal page, including his/her personal data, the User understands and agrees that this information may be available to other Internet users, taking into account the peculiarities of the Website architecture and functionality.
Purposes of Collecting and Processing the Users' Personal Information.
Net-Film collects and stores only the User's Personal Information necessary for the provision of the services (execution of agreements and contracts with the User).
Net-Film can use the User's Personal Information for the following purposes:
Identify the User within the Website and the Website services;
Provide the Website Users with the capability of using the personal data base owner's services, identify the Website Users to provide them with an individual environment and settings of the personal data base owner's services;
Promote goods, works, services in the market by making direct contacts with the Website User by means of communication (including showing advertising to the users that meets their interests);
Ensure the availability of communication with the Website User, send him/her notifications, requests and information, as well as receive and process requests, complaints and applications from the Website Users by the Website support provided by Net-Film;
Analyze and study the User preferences in order to improve the Service;
Send news, advertising, polling, statistical, marketing and other information about the Website, or the services of the Net-Film partners;
Send informational messages (for example, to recover the User account access password);
Prevent and detect fraud and illegal use of the Service;
Sell goods and services to the Website Users via the Internet;
Hold promotions, incentive lotteries and contests for the Website Users;
Hold marketing, statistical and audience research, including surveys of the Website User satisfaction;
Provide access to the Websites and services of third parties;
Determine the User location (including based on IP address, GPS data, information about objects around the user, for example, Wi-Fi hotspots, cellular antennas and devices with Bluetooth enabled) to ensure security, prevent fraud, email news, advertising, polling, statistical, marketing and other information about the Service, or Net-Film service partners. At the same time, the types of location data that Net-Film can receive depend on the settings of the User's device and his/her account.
If it is necessary to use the User's Personal Information for purposes not mentioned herein, Net-Film requests the User's prior consent/permission to do so.
Terms of the User's Personal Information Processing and Its Transfer to Third Parties.
Net-Film shall process the User's personal data (User's Personal Data) in accordance with the legislation of the Russian Federation, and additionally, where applicable, in accordance with the EU General Data Protection Regulation (GDPR).
Principles of Personal Data Processing.
The Operator shall process the personal data on the basis of the following principles:
legality and fair basis;
restrictions on personal data processing by achieving specific, predetermined and legitimate goals;
preventing personal data processing incompatible with the purposes of collecting personal data;
preventing the unification of databases containing personal data to be processed for purposes incompatible with each other;
processing only those personal data that meet the purposes of their processing;
compliance of the content and scope of processed personal data with the stated purposes of processing;
preventing processing of personal data redundant in relation to the stated purposes of their processing;
ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;
destruction or depersonalization of personal data upon achievement of the purposes of their processing or in case of loss of the need to achieve these purposes, if it is impossible for the Operator to eliminate violations of personal data, unless otherwise provided by federal law.
With regard to the User's Personal Information, its confidentiality is preserved, except in cases of voluntary provision by the User of information about him-/herself for general access to an unlimited number of persons.
Net-Film shall have the right to transfer the User's Personal Information to third parties, as well as the results of automated processing of such data collected on its basis using various information assessment models, in the form of integer and/or text values and identifiers that correspond to the evaluation criteria specified in requests for processing data by Net-Film and/or the persons specified in this paragraph in the following cases (in all cases, Personal Information will be processed only for the purposes set out herein, unless otherwise provided by the terms of use of the Websites and/or the Services, of such third parties):
Net-Film may transfer the User's Personal Information to its employees (within the limits established hereunder), and to its affiliates, including other companies from the group of persons which may include Net-Film;
The User has expressed his/her consent to such actions;
The transfer is required to provide a service to the User, or the transfer of Personal Information is required to provide the relevant Service or to fulfill a certain agreement or contract concluded with the User;
The transfer is required to comply with the applicable legislation of the Russian Federation (including in order to prevent and/or suppress illegal and/or unlawful actions of the Users) and/or international regulatory legislation. The information provided by the User can be disclosed only in accordance with the applicable legislation of the Russian Federation at the request of the court, law enforcement agencies, as well as in other cases provided for by the legislation of the Russian Federation.
Net-Film transfers the information to Net-Film partners (copyright holders of audiovisual works posted on the website and in relation to which the services are provided to the User, owners of websites and applications, advertising networks and other partners providing Net-Film with the services, including those related to the placement and display of advertisements on websites, in software, products or services owned or controlled by such partners);
Net-Film transfers the information to third parties in respect of which the assignment of rights or obligations has been made, or novation under the relevant agreement;
Net-Film transfers the information to any third party in order to ensure legal protection of Net-Film or third parties in case of violation by the User of the terms of the Documents, or in a situation where there is a threat of such a violation.
Changes by the User of His/Her Personal Information
The User can at any time change (update, supplement) the Personal information provided by him/her or part thereof, using the editing function in the Website personal account.
The User can also completely delete the Personal Information provided by him/her within a certain account, as well as the Materials and Information posted/uploaded by him/her, including by requesting the deletion of the Net-Film account by contacting Net-film.
If the personal page is deleted, Net-Film shall store personal and other necessary data of the User on its electronic media for the period necessary and established by the applicable legislation of the Russian Federation (as well as, if there are grounds specified in the Federal Law dated July 27, 2006 No. 152-Federal Law "On Personal Data", shall have the right to continue processing the User's personal data). In case the User deleted his/her personal page, the User shall have the right to restore his/her personal page within 30 days after such deletion of the personal page.
Measures to Protect the User's Personal Information
Net-Film shall take necessary and sufficient organizational and technical measures to protect the User's Personal Information from unauthorized or illegal access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties in respect thereof.
Net-Film provides access to the User's Personal Information only to those employees, contractors and partners of Net-Film who need this information to ensure and improve the level of Website operation and provide services to the User, and only to the extent necessary and consistent with the processing purposes specified in p 2. hereof. Based on this, Personal Data is processed automatically without access thereto by any of Net-Film employees or third parties. If such access is required, it can only be provided to those employees of Net-Film or third parties who need it to complete their tasks. To protect and ensure the data confidentiality, all employees shall comply with internal policies and procedures regarding the Personal Information processing. They shall also follow all technical and organizational security measures in place to protect users' personal data.
Net-Film, taking into account the current level of technology, the cost of its implementation, the risks associated with the personal data processing and the nature, shall implement and constantly improve sufficient technical and organizational measures to protect users' personal data from unauthorized, accidental or illegal destruction, loss, alteration, unfair use, disclosure or access, as well as other illegal forms of processing.
Net-Film does not guarantee the security of the data the User transfers to the Website and its services, unauthorized access to which can be obtained by third parties as a result of any illegal actions. The User transfers all data at his own risk.
Procedure for Storing the User's Personal Information
Recording, systematization, accumulation, storage, clarification (update, revision), extraction of personal data of the Russian Federation citizens, shall be stored by Net-Film exclusively on server facilities localized in the territory of the Russian Federation.
For users from the European Economic Area or Switzerland: Russia is a jurisdiction outside the European Economic Area that has not been recognized by the European Commission as providing an adequate level of personal data protection. On this basis, for such Users, Net-Film takes appropriate measures to ensure that such transfers are in accordance with applicable EU data protection regulations.
Net-Film shall ensure that the foreign state, where it is planned to transfer personal data, ensures reliable protection of the rights of personal data subjects prior to such transfer.
Cross-border transfer of personal data to the territories of foreign states that do not provide adequate protection of the rights of personal data subjects can be effected in the following cases:
Upon written consent of the personal data subject for cross-border transfer of his/her personal data;
Execution of an agreement which the personal data subject is a party to.
Rights and Obligations of the Users
If this is provided by applicable law, the User shall have the right to access his/her Personal Information processed by Net-Film in accordance herewith.
If the User believes that any information about the User that Net-Film stores is incorrect or incomplete, then the User shall have the right to demand that Net-Film clarify his/her personal data, block or destroy it if such data is incomplete, outdated, unreliable, illegally obtained or not necessary for the stated purpose of processing, and if the User him-/herself, using the Website software specially provided to the Net-Film User for this purpose, cannot enter his/her account and correct his/her Personal Information on his/her own;
If this is provided by applicable law, the User shall have the right to:
request the deletion of his/her Personal Information;
demand restrictions on the processing of his/her Personal Information;
object to the processing of his/her Personal Information, if this is provided by applicable law.
Net-Film shall comply with such requests in accordance with applicable law.
In cases provided for by applicable law, you may also have other rights not listed above.
The Users shall have the right to send their requests to Net-Film, including requests regarding the use of their personal data, in writing to the address specified herein, or in the form of an electronic document signed with a qualified electronic signature in accordance with the legislation of the Russian Federation, to the email address: [email protected]. Each request shall contain the following information:
The number of the main identity document of the User or his/her representative;
Information on the date of issue of the specified document and the issuing authority;
User account ID;
Email address specified by the User when registering on the Website;
Signature of the User or his/her representative.
Net-Film shall consider and send a response to the User’s request within 30 days from the request receipt.
All correspondence received by Net-Film from the Users (in writing or electronic form) refers to information of limited access and is not disclosed without the written consent of the User. Personal data and other information about the User who sent the request cannot be used without the express consent of the User other than in case stipulated herein and to respond to the topic of the received request or in cases expressly provided for by law.
Miscellaneous
Net-Film does not control and is not responsible for the websites and services of third parties where the User can go by clicking on the links/buttons available on the Website, as well as for the content of such websites and services.
Any changes herein shall come into force upon posting a new version hereof on the Website. Continued use of the Website after posting a new version hereof on the Website shall mean the User consent to the changes herein. In case of disagreement with the policy changes that have come into force, the User shall stop using the Website by deleting his/her account on the Website.
The applicable law hereunder is the law of the Russian Federation.
All disputes about the Policy shall be resolved in accordance with the applicable legislation of the Russian Federation at the Net-Film location.
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