PERSONAL DATA 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 – individuals, including personal data, from unauthorized access and disclosure.
This Privacy Policy for personal data 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 through other channels associated with the Application (for example, via emails sent to customer support).
By using the Application and/or the website and/or the services of the Application, the User expresses his/her full unconditional consent to the terms of this Privacy Policy and the conditions for processing his/her personal information specified therein.
In case of disagreement with the terms of this Privacy Policy, the User is advised to refrain from using the Application or the Site, and/or any Services available when using it.
The User gives his/her consent to the processing by the Company of personal data received in connection with the conclusion and execution of the Agreement, including the provision of personal data to credit institutions or operators of electronic money (depending on the situation) for the purpose of concluding and executing this Agreement, as well as for the purpose of fulfilling the requirements of the current regulatory and legal acts of the Russian Federation.
The Company has the right to carry out automated processing of personal data, including with the help of special software within the framework provided by law, and also to entrust the processing of personal data to third parties.
Consent to the processing of the User's personal data is obtained in writing upon registration in the Application. All copyrights and other rights to the results of intellectual activity contained in the Application (including the Application itself) and in its content, including (but not limited to): design, trademarks and service marks, company name, text and numerical information, photographs, images, audio and video recordings, systematization, arrangement, 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 run on smartphones, tablets and other mobile devices providing access to the SkyPtoP parcel delivery service. The Application can be downloaded free of charge to 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 word "Application" or "Mobile Application" is mentioned in the text of the Agreement, it means the SkyPtoP Application.
1.1.2. Company – SkyPtoP, which manages the Application, organizes and (or) carries out the processing of personal data, and also determines the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.
1.1.3. Personal data - any information relating directly or indirectly to an identified or identifiable natural person (subject of personal data).
1.1.4. Processing of personal data - any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.1.5. Confidentiality of personal data is a mandatory requirement for the Company to prevent their intentional dissemination without the consent of the subject of personal data or the presence of other legal grounds.
1.1.6. Automated processing of personal data - processing of personal data using computer technology;
1.1.7. Dissemination 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 disclosure of personal data to a specific person;
1.1.9. Blocking of personal data - temporary cessation of processing of personal data (except in cases where processing is necessary to clarify personal data);
1.10. Destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which the material carriers of personal data are destroyed;
1.11. Depersonalization of personal data - actions as a result of which it becomes impossible to determine the ownership of personal data by a specific subject of personal data without the use of additional information;
1.12. Personal data information system - a set of personal data contained in databases and the information technologies and technical means that ensure their processing;
1.13. Advertisement - information regarding the Shipment, its conditions and the required point of delivery;

2. GENERAL PROVISIONS

2.1. The processing of personal data is carried out on the basis of 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 and the website constitutes consent to this Privacy Policy and the terms of processing of the User’s personal data.
2.3. In case of disagreement with the terms of the Privacy Policy, the User must stop using the Application, the website.
2.4. This Privacy Policy applies to the SkyPtoP mobile application, the website and any other means of communication through which the Company can receive information related to the personal data of subjects. The Company does not control and is not responsible for third-party websites to which the User can go 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. In order 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 PRIVACY POLICY

3.1. This Privacy Policy sets forth the Company's obligations to intentionally maintain confidentiality and ensure the safety of personal data that the User provides in response to various requests from the Company (e.g. when registering in the Application, submitting an application, subscribing to notifications, etc.). At the same time, the User understands and agrees that the Internet cannot provide absolute protection of personal data from the threats that exist therein. The User hereby gives his unconditional consent to the Company to determine an adequate level of protection of Personal Data, as well as the methods and place (territory) of their storage.
3.2. When registering or using the Application or website, the Company may process the following personal data or information about the User:
3.2.1. the User’s last name, first name, patronymic;
3.2.2. e-mail address;
3.2.3. information about the User’s payment details, including, but not limited to, data about the fact of the payment made 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, mobile service provider information, the User’s place of residence (if necessary), browser information 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, usage patterns in general, tracking of interactions with certain functions, 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 as part of information traffic between the User and the Company, when using the Application, the Site, as well as in the process of concluding or executing the Agreement.
3.3. Registration and use of the Application is permitted to persons who have this right in accordance with the current legislation and the Company's Offer Agreement. The Company undertakes to immediately delete the account and/or personal data
User data if it becomes known for certain that the account and/or personal data belong to a person who, by virtue of current legislation and the Company's Offer Agreement, does not have the right to independently carry out these actions.
3.4. The Mobile Application and the Site may collect statistics on the IP addresses of their visitors. This information is used to prevent, detect and solve technical problems.
3.5. Any other personal information not specified above (browsing history, browsers used, operating systems, etc.) is subject to secure storage and non-dissemination, except in cases provided for in this Privacy Policy.

4. PURPOSES OF COLLECTING THE USER'S PERSONAL INFORMATION

4.1. The purpose of processing the User's personal data is to inform the User by calling, sending emails, messages, via telephone 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 opt out of receiving informational messages by sending a letter to the Company at its registered address marked "Opt-out of notifications about new products, services and special offers".
4.3. Anonymized data of Users collected using Internet statistics services are used to collect information about the actions of Users on the website, in the Mobile Application, to improve the quality of the website, Mobile Application and their content.
4.4. The Company may use the User’s personal data for the following purposes:
4.4.1. Registering the User in the Application;
4.4.2. Conclusion and execution of the Agreement;
4.4.3. Providing the User with access to the SkyPtoP Shipment delivery service;
4.4.4. Identification of the User registered in the Application for posting or searching for an Advertisement;
4.4.5. Establishing feedback with the User, including sending notifications, requests regarding the use of the Application, provision of services, processing of Advertisements and responses to them;
4.4.6. Confirmation of the accuracy and completeness of personal data provided by the User;
4.7. Providing the User with effective customer and technical support in the event of problems related to the use of the Application;
4.4.8. Providing the User with his consent, service updates, special offers, price information, newsletters and other information;
4.4.9. Carrying out advertising activities with the consent of the User;
4.4.10. Improving the quality of service to Users by processing requests and applications from the User;
4.4.11. Provision of data upon requests from authorized bodies in cases stipulated by law;
4.4.12. Protecting the interests of the Company or third parties, collecting debts or damages, identifying a person who has violated the law;
4.4.13. Making decisions or performing other actions that give rise to legal consequences in relation to the User or other persons, as well as to achieve other purposes of processing Personal Data.
4.5. The Company processes personal data for the purpose of concluding and executing the User's agreements on the use of the Software, concluding and executing the Agreement, verifying the User's good faith in connection with the use of the Software, monitoring the fulfillment by the Traveler of obligations to the Sender and Recipient, evaluating and analyzing the operation of the Software, as well as for the purpose of fulfilling the requirements of the current regulatory and legal acts of the Russian Federation.

5. TERMS AND METHODS OF PROCESSING USERS' PERSONAL INFORMATION AND ITS TRANSFER TO THIRD PARTIES

5.1. The User agrees to the processing of his/her personal data by accepting the Agreement.
5.2. Processing of the User’s personal data means collecting, recording, systematizing, accumulating, storing, clarifying (updating, changing), extracting, using, transferring (distributing, providing, accessing), depersonalizing, blocking, deleting, destroying the User’s personal data.
5.3. The User’s personal information remains confidential, except in cases where the User voluntarily provides information about himself/herself for general access to an unlimited number of persons.
5.4. The Company has the right to transfer the User’s personal information to third parties in the following cases:
5.4.1. The User has expressed consent to such actions;
5.4.2. The transfer is necessary for the User to use a certain service of the Mobile Application, the Site, or for the execution of a certain contract or agreement with the User;
5.4.3. Transfer to 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 by depersonalizing it, depersonalized statistical data is obtained, which is transferred to a third party to conduct research, perform work or provide services on behalf of the Company.

6. METHODS AND TERMS OF PROCESSING PERSONAL INFORMATION

6.1. As part of using the Mobile Application or the Site, the Company receives personal data from the User. The processing of such personal data is regulated by the Agreement, this Privacy Policy and is carried out in accordance with current legislation (including Federal Law "On Personal Data" No. 152-FZ dated July 27, 2006) for the purpose of concluding and executing agreements with personal data subjects (the User), as well as other purposes specified in this Privacy Policy and the Agreement.
6.2. The processing of the User’s personal data is carried out without time limitation, in any legal manner, including in personal data information systems using automation tools or without using such tools.
6.3. When processing personal data, security procedures are observed to prevent unauthorized access to personal data and their unauthorized use.
6.4. The User agrees that the Company has the right to transfer personal data to third parties, in particular other Users, solely for the purpose of posting and processing Advertisements, as well as responding to them using
Applications or Site. Transfer of personal data of the Traveler to the Sender, as well as the Sender to the Traveler is a necessary action to ensure the possibility of further interaction between Users after the response and acceptance of the terms of the Advertisement.
6.5. Personal data may be transferred to national and/or international regulatory authorities, law enforcement agencies, central or local executive authorities, other official or state bodies or courts, in relation to which the Company is obliged to provide information in accordance with the legislation of the User’s country of residence or other countries, for the purpose of preventing, detecting or suppressing criminal acts and fraud, or if there is another legal obligation to transfer them. Personal data is transferred at the relevant request of authorized bodies to the Company or its representative in 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.
6.7. In case of loss or disclosure of Personal Data, the Company shall not be liable if this confidential information:
6.7.1. Became publicly known prior to its loss or disclosure.
6.7.2. Was disclosed with the consent of the User.
6.8. The Company shall not be liable for the risk of adverse consequences that will occur or may occur as a result of the non-compliance of the User’s equipment, the software used by him or the communication channels with the established requirements for the protection of personal data from
unauthorized (illegal) encroachment by third parties.

7. OBLIGATIONS OF THE PARTIES

7.1. The User undertakes to:
7.1.1. Provide correct and truthful information about personal data necessary for using the Application.
7.1.2. Update or supplement the provided information about personal data in the event of changes to this information.
7.1.3. Take measures to protect access to your confidential data stored in the Application.
7.2. The Company undertakes to:
7.2.1. Implement appropriate security procedures to the appropriate extent to prevent unauthorized access to processed personal data or their unauthorized use.
7.2.2. Use the information received solely for the purposes specified in this Privacy Policy.
7.2.3. Block personal data related to the relevant User from the moment of the User’s request or appeal, or of their legal representative or authorized body for the protection of the rights of personal data subjects for the period of verification, in the event of detection of inaccurate personal data or illegal actions.

8. USER RIGHTS

8.1. The User has the right to control the process of using his/her personal data by the Company. This right can be exercised in the following ways: 8.1.1. Request an overview of the personal data that the Company has at its disposal;
8.1.2. Report any changes in the User's personal data or request that any information in the personal data stored by the Company be corrected. The User can also make such changes independently through the personal account;
8.1.3. Request that the Company delete personal data or part of it, block or restrict its processing, and also send a refusal regarding specific methods of using personal data;
8.1.4. Revoke consent to the processing of personal data.

9. DISPUTE RESOLUTION

9.1 This Privacy Policy is governed by and shall be interpreted in accordance with international law, 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 Site through negotiations.
9.3. In the event that it is impossible to resolve a dispute through negotiations, disputes arising from relations between the Parties shall be subject to consideration by a judicial body of the Russian Federation in accordance with the legislation of the Russian Federation.
9.4. Before filing a claim in court regarding disputes arising from the relationship between the User and the Company, it is mandatory to file a claim (a written proposal for a 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, may be sent by message in the Application or to the User's e-mail specified during registration and the Company's e-mail 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 force 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 is obliged to independently monitor changes to the Privacy Policy on the Site and/or in the Application.
Continued use of the Mobile Application or the Site after such changes have been made confirms the User's consent to such changes. 10.4. This Privacy Policy is an integral part of the Agreement. In the event of a conflict between the terms of the Privacy Policy and the Agreement, the terms of the Privacy Policy shall apply in terms of issues related to the collection and processing of personal data.
10.5. This Privacy Policy is written in Russian and may be translated into other languages ​​at the Company's discretion. In case of discrepancies, the version written in Russian shall prevail.

10. DETAILS

Full name: Limited Liability Company "SKISHIFT" Abbreviated name: LLC "SKISHIFT" Legal address: 300041, Tula region, Tula city, Turgenevskaya street, house No. 69, office 326, floor 3 Actual address: 300041, Tula region, Tula city, Turgenevskaya street, house No. 69, office 326, floor 3 Postal address: 300041, Tula region, Tula city, Turgenevskaya street, house No. 69, office 326, floor 3 INN 7107133239 KPP 710701001 OGRN 1197154011933 current account 40702810508500011702 k/s 30101810745374525104
BIC 044525104 POINT OF PJSC BANK "FC OTKRITIE" CEO Rinat Kryukov