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Policy on the Processing of Personal Data

Purpose of this Privacy Policy

The purpose of this Personal Data Privacy Policy (hereinafter referred to as the “Privacy Policy”) is to ensure the proper protection of information about Users, including personal data, from unauthorized access and disclosure. This Privacy Policy applies to all types of information that the Company may receive through the SkyPtoP mobile application (hereinafter referred to as the “Application”), the website https://skyptop.com, or other channels related to the Application (for example, through electronic messages sent to customer support).

By using the Application and/or the website, and/or the services of the Application, the User fully and unconditionally agrees to the terms of this Privacy Policy and the conditions specified herein for processing their personal information. If the User disagrees with the terms of this Privacy Policy, they are advised to refrain from using the Application or the Website, and/or any Services available through its use. The User consents to the processing of personal data by the Company obtained in connection with the conclusion and execution of the Agreement, including the provision of personal data to credit organizations or electronic money operators (depending on the situation) for the purpose of concluding and executing this Agreement, as well as for the purpose of complying with the requirements of the current regulatory legal acts of the Russian Federation.

The Company is entitled to perform automated processing of personal data, including using special software within the framework provided by law, as well as to entrust the processing of personal data to third parties. User consent to the processing of personal data is obtained in writing during the registration in the Application. All copyrights and other rights to the intellectual property results contained in the Application (including the Application itself) and its content, including (but not limited to): design, trademarks and service marks, trade names, textual and numerical information, photographs, images, audio and video recordings, systematization, layout, as well as other materials (their elements), belong to SkyPtoP or are lawfully provided to it by other persons. Use of the listed information is permitted only with the consent of SkyPtoP.

1. TERMS

1.1. The following terms are used in this Privacy Policy:

1.1.1. Application or Mobile Application - software designed to work on smartphones, tablets, and other mobile devices providing access to the “SkyPtoP” delivery service. The Application can be downloaded for free on the User’s device from online application stores such as AppStore, Google Play, etc. The rights to the mobile application belong to the Company. When the words “Application” or “Mobile Application” are mentioned in the text of the Agreement, it refers to the “SkyPtoP” Application.

1.1.2. Company – SkyPtoP, managing the Application, which organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

1.1.3. Personal data - any information related directly or indirectly to an identified or identifiable individual (subject of personal data).

1.1.4. Processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.1.5. Confidentiality of personal data - a requirement mandatory for the Company to prevent their intentional dissemination without the consent of the personal data subject or other legal grounds.

1.1.6. Automated processing of personal data - processing of personal data using computer technology.

1.1.7. Distribution of personal data - actions aimed at disclosing personal data to an indefinite number of persons.

1.1.8. Provision of personal data - actions aimed at disclosing personal data to a specific person.

1.1.9. Blocking of personal data - temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).

1.1.10. Destruction of personal data - actions resulting in the impossibility of restoring the content of personal data in the personal data information system and/or resulting in the destruction of tangible personal data carriers.

1.1.11. Depersonalization of personal data - actions resulting in the impossibility to determine the affiliation of personal data to a specific personal data subject without using additional information.

1.1.12. Personal data information system - a set of personal data contained in databases and ensuring their processing of information technologies and technical means.

1.1.13. Announcement - information regarding the Shipment, its conditions, and the necessary delivery point.

2. GENERAL PROVISIONS

2.1. The processing of personal data is carried out based on international legislation applicable to the processing and protection of personal data, as well as the current legislation of the Russian Federation.

2.2. Registration and use of the Application, website implies acceptance of this Privacy Policy and the terms of processing the User’s personal data.

2.3. If the User disagrees with the terms of the Privacy Policy, the User should cease using the Application, website.

2.4. This Privacy Policy applies to the SkyPtoP mobile application, website, and any other means of communication through which the Company may obtain information related to the personal data of subjects. The Company does not control and is not responsible for third-party websites that the User may navigate to via links available in this Application or on the website.

2.5. The Company is not obliged to verify the accuracy of all personal data provided by the User.

2.6. To ensure the possibility of using the Application, personal data is collected and used by SkyPtoP, created under the laws of the Russian Federation.

3. SUBJECT OF THE PRIVACY POLICY

3.1. This Privacy Policy establishes the obligations of the Company regarding the intentional non-disclosure and ensuring the safety of personal data that the User provides upon various requests from the Company (for example, when registering in the Application, submitting an application, subscribing to notifications, etc.). At the same time, the User understands and agrees that it is impossible to ensure absolute protection of personal data on the Internet from existing threats. Hereby, the User gives their unconditional consent to the Company to determine the sufficient level of protection of Personal data, as well as the methods and place (territory) of their storage.

3.2. During registration or use of the Application, website, the Company may process the following personal data or information about the User:

3.2.1. last name, first name, patronymic of the User;

3.2.2. email address;

3.2.3. payment details of the User, including but not limited to, data on the fact of the payment itself, conducted through third-party payment systems, as well as individual payment details of the User;

3.2.4. location information, including geolocation data (navigation data), IP address, time zone, information about the mobile service provider, place of residence of the User (if necessary), information about the browser and access time;

3.2.5. information collected using cookies and other tracking technologies, in particular, which elements and functions of the Application the User visits, general usage patterns, tracking interactions with certain features, etc. To collect this information, the Company may send cookies to the User’s electronic device;

3.2.6. any other personal data or information transmitted within the information traffic between the User and the Company, when using the Application, Website, as well as during the conclusion or execution of the Agreement.

3.3. Registration and use of the Application are allowed to persons who have the right to do so under the current legislation and the Company’s offer Agreement. The Company undertakes to immediately delete the User’s account and/or personal data if it becomes reliably known that the account and/or personal data belong to a person who, under the current legislation and the Company’s offer Agreement, does not have the right to independently perform these actions.

3.4. The Mobile Application and the Website may collect statistics on the IP addresses of their visitors. This information is used to prevent, identify, and solve technical problems.

3.5. Any other personal information not specified above (browsing history, used browsers, operating systems, etc.) is subject to secure storage and non-disclosure, except in cases provided for in this Privacy Policy.

4. PURPOSES OF COLLECTING USER’S PERSONAL INFORMATION

4.1. The purpose of processing the User’s personal data is to inform the User by phone calls, sending emails, messages, through the phone, and other means of communication; providing the User with access to services, information, consultations, and/or materials contained in the Mobile Application and the website.

4.2. The Company also has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending a letter to the Company’s registration address with a note “Refusal of notifications about new products, services, and special offers.”

4.3. Anonymized User data collected using internet statistics services is used to collect information about User actions on the website, in the Mobile application, to improve the quality of the website, Mobile application, and their content.

4.4. The User’s personal data may be used by the Company for the following purposes:

4.4.1. User registration in the Application;

4.4.2. Conclusion and execution of the Agreement;

4.4.3. Providing the User with access to the SkyPtoP delivery service;

4.4.4. Identification of the User registered in the Application for posting or searching for an Announcement;

4.4.5. Establishing feedback with the User, including sending notifications, requests regarding the use of the Application, providing services, processing Announcements, and responses to them;

4.4.6. Confirming the accuracy and completeness of personal data provided by the User;

4.4.7. Providing effective customer and technical support to the User in case of problems related to the use of the Application;

4.4.8. Providing the User, with their consent, with updates on services, special offers, price information, newsletters, and other information;

4.4.9. Carrying out advertising activities with the User’s consent;

4.4.10. Improving the quality of service to Users by processing User requests and applications;

4.4.11. Providing data upon requests from authorized bodies in cases provided by law;

4.4.12. Protecting the interests of the Company or third parties, collecting debts, or compensating damages, identifying individuals who have violated the law;

4.4.13. Making decisions or performing other actions that have legal consequences concerning the User or other persons, as well as for achieving other purposes of processing Personal data.

4.5. The Company processes personal data for the purpose of concluding and executing User agreements on the use of the Software, concluding and executing the Agreement, verifying the User’s integrity in connection with the use of the Software, monitoring the obligations of the Companion to the Sender and Recipient, evaluating and analyzing the Software’s performance, as well as for the purpose of complying with the requirements of the current regulatory legal acts of the Russian Federation.

5. CONDITIONS AND METHODS OF PROCESSING USER PERSONAL INFORMATION AND ITS TRANSFER TO THIRD PARTIES

5.1. The User consents to the processing of their personal data by accepting the Agreement.

5.2. Processing of the User’s personal data means the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of the User’s personal data.

5.3. Confidentiality of User’s personal information is maintained except in cases of voluntary disclosure by the User of information about themselves for general access to an unlimited number of persons.

5.4. The Company is entitled to transfer the User’s personal information to third parties in the following cases:

5.4.1. The User has expressed their consent to such actions;

5.4.2. The transfer is necessary for the User to use a specific service of the Mobile Application, Website, or to execute a specific agreement or contract with the User;

5.4.3. The transfer is required by authorized state authorities of the Russian Federation on the grounds and in the manner established by the legislation of the Russian Federation;

5.4.4. As a result of processing the User’s personal information through its depersonalization, anonymized statistical data is obtained, which is transferred to a third party for research, work, or services on behalf of the Company.

6. METHODS AND TERMS OF PROCESSING PERSONAL INFORMATION

6.1. As part of the use of the Mobile application or Website, the Company receives personal data from the User. Processing of such personal data is regulated by the Agreement, this Privacy Policy, and is carried out in accordance with the current legislation (including Federal Law “On Personal Data” No. 152-FZ of July 27, 2006) for the purpose of concluding and executing agreements with personal data subjects (Users), as well as for other purposes specified in this Privacy Policy and the Agreement.

6.2. Processing of the User’s personal data is carried out without time limit, by any lawful method, including in personal data information systems using automation tools or without using such tools.

6.3. During the processing of personal data, security procedures are observed to prevent unauthorized access to personal data and their illegal use.

6.4. The User agrees that the Company has the right to transfer personal data to third parties, in particular to other Users, solely for the purpose of posting and processing Announcements, as well as responding to them using the Application or Website. The transfer of the Companion’s personal data to the Sender, as well as the Sender’s personal data to the Companion, is a necessary action to ensure the possibility of further interaction of Users after the response and acceptance of the terms of the Announcement.

6.5. Personal data may be transferred to national and/or international regulatory bodies, law enforcement agencies, central or local executive authorities, other official or government bodies, or courts, where there is a duty for the Company to provide information in accordance with the legislation of the User’s country or other countries, for the purpose of preventing, identifying, or suppressing criminal actions and fraud, or if there is another legal obligation to transfer them. Personal data is transferred at the appropriate request of the authorized bodies to the Company or its representative on the territory of the European Union. In addition, the Company may transfer personal data to authorized bodies to protect its rights, as well as the rights of Users.

6.6. In case of loss or disclosure of personal data, the Company is not responsible if this confidential information:

6.6.1. Became public before its loss or disclosure;

6.6.2. Was disclosed with the User’s consent.

6.7. The Company is not responsible for the risk of adverse consequences that will occur or may occur due to the non-compliance of the User’s equipment, software, or communication channels used by them with the established requirements for the protection of personal data from unauthorized (illegal) encroachment by third parties.

7. OBLIGATIONS OF THE PARTIES

7.1. User Obligations:

7.1.1. Provide correct and truthful information about personal data necessary for the use of the Application.

7.1.2. Update or supplement the provided information about personal data in case of changes.

7.1.3. Take measures to protect access to their confidential data stored in the Application.

7.2. Company Obligations:

7.2.1. Implement appropriate security procedures to prevent unauthorized access to processed personal data or their illegal use.

7.2.2. Use the received information exclusively for the purposes specified in this Privacy Policy.

7.2.3. Block personal data related to the respective User from the moment of the User’s request or request of their legal representative or authorized body for the protection of personal data subjects for the period of verification, in case of identifying unreliable personal data or illegal actions.

8. USER RIGHTS

8.1. The User has the right to control the process of using their personal data by the Company. This right can be exercised in the following ways:

8.1.1. Request a review of personal data held by the Company;

8.1.2. Notify of any changes to the User’s personal data or request correction of any information in the personal data held by the Company. The User can also make such changes themselves through their personal account;

8.1.3. Demand the Company delete personal data or part of it, block or restrict its processing, and also send a refusal regarding specific ways of using personal data;

8.1.4. Withdraw consent to the processing of personal data.

9. DISPUTE RESOLUTION

9.1. This Privacy Policy is governed and interpreted in accordance with international legislation, as well as the current legislation of the Russian Federation.

9.2. The User and the Company undertake to take all measures to resolve disputes and disagreements arising during the use of the Application or the Website through negotiations.

9.3. If it is impossible to resolve the dispute through negotiations, disputes arising from the relationships between the Parties are subject to consideration in the judicial authority of the Russian Federation in accordance with the legislation of the Russian Federation.

9.4. Before applying to the court with a claim for disputes arising from the relationships between the User and the Company, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute).

9.5. The recipient of the claim within 30 calendar days from the date of receipt of the claim shall notify the claimant in writing of the results of its consideration.

9.6. The claim, as well as the response to it, can be sent by message in the Application or to the User’s email specified during registration and the Company’s email info@skyptop.pro.

10. ADDITIONAL TERMS

10.1. The Company has the right to make changes to this Privacy Policy without the User’s consent.

10.2. The new Privacy Policy comes into effect from the moment it is posted on the Website and/or in the Application unless otherwise provided by the new version of the Privacy Policy.

10.3. The User must independently monitor changes to the Privacy Policy on the Website and/or in the Application. Continued use of the Mobile Application or the Website after such changes confirms the User’s consent to such changes.

10.4. This Privacy Policy is an integral part of the Agreement. In case of discrepancies between the terms of the Privacy Policy and the Agreement, the terms of the Privacy Policy shall apply concerning the collection and processing of personal data.

10.5. This Privacy Policy is compiled in Russian and may be translated into other languages at the Company’s discretion. In case of discrepancies, the version compiled in Russian has priority.

11. DETAILS

Full name: Limited Liability Company “SKYSHIFT”

Short name: LLC “SKYSHIFT”

Legal address: 300041, Tula Region, Tula, Turgenevskaya St., No. 69, Office 326, 3rd Floor

Actual address: 300041, Tula Region, Tula, Turgenevskaya St., No. 69, Office 326, 3rd Floor

Postal address: 300041, Tula Region, Tula, Turgenevskaya St., No. 69, Office 326, 3rd Floor

TIN 7107133239

KPP 710701001

OGRN 1197154011933

Account 40702810508500011702

Correspondent account 30101810745374525104

BIC 044525104 TOCHKA PJSC BANK “FC OTKRITIE”

General Director Kriukov Rinat Igorevich