Политика конфиденциальности для мессенджера «ТамТам»
1. Who we are
1.1. We are LLC Mail.Ru registered at Moscow, Leningradskiy prospect, 39, bldg. 79, 125167. We are represented, for the purposes of this policy, by MGL MY.COM (CYPRUS) LIMITED of 28 Oktovriou, 365 VASHIOTIS SEAFRONT, office 402 Neapoli, 3107, Limassol, Cyprus.
2. Настоящая политика конфиденциальности
2.1. By making available the Services we, acting reasonably and in good faith, believe that you:
- (a) have all necessary rights to register on and use the Services;
- (b) provide true information about yourself to the extent necessary for use of the Services;
- (c) understand that by the posting your personal information (on chats (channels)) you have manifestly made this information public, and this information may become available to other Service users, may be copied and disseminated by them;
- (d) understand that some types of information transferred by you to other Service users cannot be deleted by you or us;
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.
3. Information we collect about you
3.2. We set out in more detail the information we collect when you use our Services, why we collect it and the legal bases below.
|Information Collected||Purpose||Legal Basis|
|Data you provide for registering in the Service such as first name, last name and phone number.||We use this information in order to manage and administer the Services provided to you.|
We use this data to enable us to fulfill our obligations to you as part of the Services (e.g. in cases where you request restoration of your account).
|Additional data you provide when you edit your profile settings such as profile picture, name, additional data provided by you in section «About Me» and profile link.||We use this information in order to provide our Services to you, to manage and administer Services.|
|Additional data received when you access the Services, including information regarding technical devices, technical interaction with the Service such as your IP-address, time of registration in the Service, device ids, device model and operating system used, screen resolution, information about your activity when using the Services (including your «online» or «offline» status).||We use your data for internal review in order to constantly improve the content of our Services and web pages, optimizing your user experience (including to let other users who are near you could see your profile), to understand any errors you may encounter when using the Services, to notify you of changes to the Services and to personalise the use of our Services.||1. Legitimate interests|
|Сontacts from your phonebook||We use this information to show you people from your phonebook, who also use TamTam|
|Location Data||We use this information in order to TamTam application users nearby can see each other in contacts section («People nearby» feature).|
|Information that is created or posted by you as the result of your actions when using the Services (including photos and videos). This information can be available to other users of our Services if you sending it to other Tam Tam users or posting one in any chats (channels).||We use this information in order to manage and administer the Services including providing our Services to you.|
|Information that is received about you as the result of other users’ actions on the Services (in particular, information posted in any chats (channels) by other users).||We use this information in order to manage and administer the Services including providing our Services to you.|
|Data obtained via third parties, including first name, last name, profile picture, email, gender when you connect through your Google account to our Services.|
|Data received from your OK.RU profile (in case you are authorized in the Service through OK.RU), including first name, last name, profile picture, gender, phone number, list of OK.RU friends, as well as your messages in OK.RU.|
|E-mail address||We use this information in order to contact you for an answer to your letter (request)|
|Where necessary, a copy of your identity or another document containing your name, surname, photograph, number of the principal identity document of you or your representative, with that you may provide us, including through our support service. We may take additional verification steps where we consider reasonable in order to verify your account.||We use this data in order to identify you, verify your account and prevent abuse and infringements of your or other persons' rights. For example, we use this information to verify your identity if you lose your credentials and wish to access your account with us.|
3.3. Our legitimate interests include (1) maintaining and administrating the Services; (2) providing the Services to you; (3) improving the content of the Services; (4) processing of the data that was manifestly made public to the Service users by you; (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law.
3.5. 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.
3.6. 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 when using the Services. Once you have provided this data it will be accessible by other Service users 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 the Services, you may not be able to access the Services.
4. Data sharing
4.1. Your nickname and other information posted on chats (channels), can be available to all of the Service users. 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 Mail.Ru Group Limited and our affiliates. Sometimes we may also need to share your data with a third party in order to provide our services to you or to administer the Services, for example if you choose to share your data across social media platforms.
4.3. LLC Mail.Ru and other companies in the Mail.ru Group and/or others with permission of LLC Mail.Ru, using their own ad servers, can show advertisements to you.
5. International Transfers
5.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.
5.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We have put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
6. Retention Periods
6.1. 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.
6.2. You may request to remove your account and data on our Services by contacting the Service support (see Section 11 for details).
6.3. We may remove your account, or the information you post as provided by the Terms.
7. Your Rights
7.1. 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.
7.2. 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.
7.3. If you would like to exercise these rights, please contact Service support at email@example.com or send your request to us, in writing to Moscow, Leningradskiy prospect, 39, bldg. 79, 125167. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.
8. Security Measures
8.1. 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.
8.2. In case you don’t want the application to use your geolocation, you can disable “People is nearby” feature in application’s Privacy settings.
8.3. In case you don’t want the import your phonebook contacts into TamTam, you can disable it in your mobile phone privacy settings.
9. Changes to this Policy
10. Свяжитесь с нами
10.2. 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.
10.3. The e-mail address of our DPO is firstname.lastname@example.org