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Legal Documentation Donation Alerts NON-EU PRIVACY POLICY

NON-EU PRIVACY POLICY

Last updated: June 01st, 2018

1. Who we are

1.1. We are My.com B.V. located at Barbara Strozzilaan 201, 1083HN, Amsterdam, the Netherlands.

1.2. This Privacy Policy sets out how we collect and use your personal information when you visit our site http://www.donationalerts.ru/(“Site”) or use our online service “DonationAlerts” (“DA Services”) offered by My.com B.V. at http://www.donationalerts.ru/ and the choices available to you in connection with our use of your personal information (“Privacy Policy”).
The Site and DA Services are hereinafter collectively referred to as the “DA Platform”.
This Privacy Policy should be read alongside, and in addition to, our terms and conditions at http://www.donationalerts.ru/terms-of-service (“Terms”) and our Cookie Policy (accessible online at https://legal.my.com/us/general/cookie).
In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.

2. This Privacy Policy

2.1. By making available the DA Platform we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register and use the DA Platform;
(b) provide true information about yourself  to the extent necessary for use of the DA Platform;
(c) understand that by the posting your personal information you have manifestly made this information public, and this information may become available to other DA Platform users and internet users, be copied and disseminated by them;
(d) understand that some types of information transferred by you to other DA Platform users cannot be deleted by you or us;
(e) are aware of and accept this Privacy Policy.

2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.

2.3. This Privacy Policy applies only to the Non-European Union-based users. If you are a European Union-based user, please refer to the Privacy Policy applicable in the  relevant jurisdiction.

3. Information we collect about you

3.1. In order to implement the agreement between you and us, and provide you with access to the use of the DA Platform, we will improve, develop and implement new features to the DA Platform, and enhance the available DA Platform functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data. We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.

3.2. We set out in more detail the information we may collect when you use the DA Platform, why we collect and process it and the legal bases below.

Information Collected

Purpose

Legal Basis

1

Data you provide for registering in DA Platform: data obtained via third parties - your social network nickname and email (Facebook, Google), your nickname that you create at the process of registering

We use this information in order to manage and administer DA Platform provided to you. We use this data to enable us to fulfill our obligations to you as part of DA Platform (e.g. in cases where you request restoration of your account). See section 8.3 of this Privacy Policy for more information.

Legitimate interests

Performance of our contract with you

2

Additional data you provide when you edit your profile page at http://www.donationalerts.ru/or on dedicated service profile page via including your name, surname, mobile phone, email, nickname, country.

We use this information in order to provide DA Platform to you, to manage and administer DA Platform and as additional information to verify your account to prevent abuse and infringements of your or other persons' rights.
We also use this information in order to provide you with updates and information on our and selected third parties' products and DA Platform we think you may be interested in.

Legitimate interests

Performance of our contract with you

3

Additional data received when you access DA Platform, including information regarding technical interaction with DA Platform such as your IP-address, time of registration on DA Platform, time of your last visit of DA Platform, device ids, country and language settings.

We use your data for internal review in order to constantly improve the content of  DA Platform and web pages, optimizing your user experience, to understand any errors you may encounter when using DA Platform, to notify you of changes to DA Platform and to personalise the use of our DA Platform.

Legitimate Interests

4

Information that is automatically received at the time of access to DA Platform with the use of cookies.

Please see our cookies policy, which sets out the types of cookies we use and what we use these cookies for. 

Consent

5

Information that is created by you while using DA Platform (including User Content). This information can be available to all viewers of the Broadcaster Content where the User Content is placed

We use this information in order to manage and administer DA Platform including providing our DA Platform to you.

Legitimate interests

6

Information that is created by you while placing requests to our Services support.

We use this information in order to verify your identity and to fullfil your support request.
We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.

Legitimate interests

Performance of our contract with you

7

Information that is received as the result of your using payment functionality on the Site (e.g. first and last four digits of your card number that are needed for the option of matching these details with user’s id number).

We use this information in order to manage and administer the Site including providing our Site Services to you.
We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.

Legitimate interests

Performance of our contract with you

8

Data collected via third parties, including your social network ids, application store ids, nickname, email and friends list, avatar, when you register on the DA Platform  via you social or application store accounts and/or connect your social account to our DA Platform.

We use this information in order to manage and administer the DA Platform provided to you.

Legitimate interests
Performance of our contract with you. 

3.3. Our legitimate interests include (1) maintaining and administrating DA Platform; (2) providing DA Platform to you; (3) improving the content of DA Platform and web pages; (4) processing of the data that was manifestly made public by you (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law. 

3.4. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

3.5. You may withdraw your consent for sending you marketing information by amending your privacy settings of your account. An option to unsubscribe will also be included in every email sent to you by us or our selected third party partners.

3.6. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data on DA Platform.
Once you have provided this data it will be accessible by the users of the web-sites (including mobile versions) where this data is posted and it becomes difficult for us to remove this data.

3.7. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer DA Platform, you may not be able to access and use DA Platform.

3.8. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.

4. Data sharing

4.1. Your nickname can be available to all viewers of your Broadcasting Content in the Internet when you use DA Platform. We take technical and organizational measures to ensure that your data is safe. Please note that by the posting your personal information you have manifestly made this information public, and this may become available to other Service users and internet users and be copied and/ or disseminated by such users. Once this data is transferred by you to other users you will not be able to delete this data.

4.2. We may share your data with our affiliates. Sometimes we may also need to share your data with a third party in order to provide DA Platform to you or to administer DA Platform, for example if you choose to share your data across other social media platforms. 

4.3. My.com B.V., other companies in the Mail.ru Group or our selected third party partners with our permission, using their own ad servers, can show advertisements to you.

5. Privacy Settings

5.1. DA Platform may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party DA Platform and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.

5.2. We bear no liability for the actions of third parties which, as the result of your use of the internet or the DA Platform, obtain access to your information in accordance with the confidentiality level selected by you.

5.3. We bear no liability for the consequences of use of the information which, due to DA Platform nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted in DA Platform.

6. International Transfers

6.1. We may transfer and maintain on our servers or databases some of your personal information in different countries worldwide. 

7. Retention Periods

7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.

7.2. You may delete your personal data by removing the data from your account or by sending us an email to da.support@corp.my.com.

7.3. We may remove your account, or the information you post as provided by the Terms.

8. Your Rights

8.1. You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information:  you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant  for the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased.
(e) Right to object to processing of your personal information.
(f) Right to data portability (in certain specific circumstances).
(g) Right not to be subject to an automated decision.
(h) Right to lodge a complaint with a supervisory authority.

8.2. You also have a right to independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you.

8.3. If you would like to exercise these rights, please contact Support Service  at da.support@corp.my.com or send your request to us, in writing to Barbara Strozzilaan 201, 1083 HN, Amsterdam, the Netherlands. We will aim to respond to you within period established by applicable law. We will need to verify your identity before we are able to disclose any personal data to you.

9. Security Measures

9.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

9.2. Access to DA Platform is authorized using by the relevant social network your login (e-mail address or mobile phone number) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential. 

10. Changes to this Policy

10.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.

11. Contact Us

11.1. If you have any questions, please send your inquiries to Service support at da.support@corp.my.com or in writing to Barbara Strozzilaan 201, 1083 HN, Amsterdam, the Netherlands. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within period established by applicable law. 

11.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

Only the English version of this document has legal effect. Any translations of this document to other languages are provided for your convenience only.