1. DEFINITIONS
"Mobile Application" means software (including all existing add-ons and improvements) designed to run on smartphones, tablets, watches, and other mobile devices and developed for a specific platform (iOS, Android, Windows Phone, etc.). For the purposes of this Policy, the following software is considered as the Mobile Application: DEVÁ | HEALTH & BEAUTY .
"Personal Data" means a set of personal data and/or non-personalized information about the User, provided by the User himself/herself to the Right holder and/or automatically collected by the Right holder and/or third parties.
"Policy" means this Privacy Policy of the mobile application (including all existing add-ons and changes).
"User" means a legal or natural person who has downloaded the Mobile Application to a smartphone, tablet, watch, or any other mobile device and/or activated such Mobile Application on one of the specified devices.
"User Agreement" means an agreement concluded between the Right holder and the User regarding the procedure, rules, and features of using the Mobile Application by the User. The User agrees to such an agreement and has no right to make and/or demand any changes or additions to it.
"Right holder" means a person who owns exclusive ownership rights to the Mobile Application.
"Processor" means a person who, within the meaning of the GDPR, on behalf of the Controller, carries out the storage and/or processing of Personal data obtained from Users.
"Cookies" means small files sent by any mobile application or website and placed on smartphones, tablets, watches, and other mobile devices of the User to improve the operation of such applications or websites, as well as the quality of the content posted in them.
2. RELATIONSHIPS TO WHICH THE POLICY APPLIES
General Provisions
This Policy is used and applied solely to Personal Data obtained from the User in connection with their use of the Mobile Application. The provisions of this Policy aim to:
(1) define the types and categories of Personal Data obtained, the directions and purposes of their use (processing), as well as the sources of obtaining such Personal Data; and
(2) define the User's rights regarding the protection of the confidentiality of their transmitted Personal Data; and
(3) define the persons responsible for the processing and storage of Personal Data, as well as third parties to whom such data are disclosed (in whole or in part).
The rules of this Policy do not apply in the case of processing of Personal Data voluntarily provided by the User to third parties.
By installing and/or activating the Mobile Application on their smartphone, tablet, watch, or other mobile device, the User agrees to the terms of this Policy and gives their consent to the Owner to collect, process, retain, and store their Personal Data in the manner and on the conditions provided by this Policy.
If the User does not agree to the terms of the Policy and/or does not understand certain terms of the Policy, in such a case the User is obliged to immediately cease using the Mobile Application.
User Rights for Personal Data Protection
In connection with the provision of Personal Data, the User automatically obtains the following rights:
(1) to receive information regarding the processing of their data (grounds and purposes for such processing, methods of processing, information about persons who have access to them or to whom they may be disclosed based on a contract or law).
(2) to receive information about the location and identification data of the persons who process Personal Data.
(3) to receive information about the storage periods of Personal Data.
(4) to receive information about the carried out or intended cross-border transfer of Personal Data.
(5) to appeal against the actions or inaction of the Rights Holder to the authorized body for the protection of the rights of personal data subjects or in court.
(6) to receive compensation for damages and/or compensation for moral harm in court due to the violations of the User's rights to the protection and security of their Personal Data committed by the Rights Holder and/or third parties.
(7) to exercise other rights in the field of personal data protection provided by law or the provisions of this Policy.
3. LIST OF COLLECTED PERSONAL DATA
Non-personalized information about users
In connection with the use of the Mobile Application, the Rights Holder may automatically collect and process the following non-personalized information about the User:
(1) information about traffic, the possible number of clicks, logs, and other data.
(2) device information (identification number, mobile network), from which the login is performed, operating system, platform, browser type, and other browser information, IP address.
Personal data about users
The Rights Holder does not collect any personal data about Users that allow their identification.
Use of cookies
This Mobile Application uses certain cookies to save the IP address, User preferences, or type of device used for the purpose of (1) keeping statistics of website visits and traffic, (2) personalizing data displayed on the User's screen, (3) storing data necessary for User identification, including when accessing from different devices, and (4) displaying advertising based on the User's interests and preferences. The Mobile Application may use both its own cookies belonging to the Rights Holder and third-party cookies.
4. OBJECTIVES OF PERSONAL DATA COLLECTION AND PROCESSING
Definition of processing purposes
The collection and processing of personal data is carried out for the following purposes:
(1) to analyze User behavior and identify User preferences for certain types of content.
(2) for the timely and correct operation of the Mobile application, improvement of its functioning, improvement of the content of the Mobile application, improvement of the internal architecture and functionality of the Mobile application.
(3) for User identification.
(4) for compliance with the law.
(5) for technical support of the Mobile application, identification of problems in its operation, and their elimination.
(6) for maintaining communication with the User.
(7) for the fulfillment of other obligations of the Rights holder that have arisen before the User.
(8) for any other purposes, provided that separate consent is obtained from the User.
Processing of personal data is carried out based on the principles of (1) legality of processing purposes and methods; and (2) fairness; and (3) compliance of personal data processing purposes with the purposes previously determined and declared during the collection of such personal data; and (4) compliance of the volume and nature of processed personal data with the stated purposes of their processing.
Conditions for personal data processing
Personal data processing is carried out in cases: (1) when the User has given consent; or (2) when the Rights holder has achieved the purposes provided for by an international treaty or the Law; or (3) when the User has provided his personal data to an unlimited circle of persons; or (4) when the Rights holder fulfills other obligations to the User, including, but not limited to, providing certain content to the User; or (5) in case of saving the life or health of the User, when it is impossible to obtain consent for processing personal data in advance.
In case of depersonalization of personal data, which does not allow the User to be directly or indirectly identified, the subsequent use and disclosure of such data to third parties is permitted, and the rules of this Policy no longer apply to them.
The Rights holder takes all possible measures to protect the confidentiality of the personal data received, except in cases where the User has made such data publicly available.
Processing of personal data is carried out using automation tools and without the use of such automation tools.
5. ACCESS BY THIRD PARTIES TO PERSONAL DATA
Use of remarketing services
The rights holder uses remarketing to advertise Mobile Application content to the User on other websites visited by the User.
Remarketing services are provided to the rights holder through the Telegram platform. Telegram collects and processes non-personalized data that does not directly allow the identification or establishment of the User's identity. The collected information may typically include (1) the content viewed by the User, (2) the date and time when the User viewed the content, and (3) geolocation data. Collecting and processing such non-personalized information enables the User to receive more targeted advertising or marketing content.
By installing the Mobile Application, the User agrees to Telegram's Privacy Policy, as well as the automatic installation of corresponding cookie files on the User's device.
The User has the right to opt-out of such advertising at any time by changing the relevant browser and device settings used to log into the Mobile Application.
Disclosure of personal data to third parties
The rights holder has the right to disclose Personal Data to (1) its affiliated companies, branches, and offices, both within the territory of the Russian Federation and in other countries, (2) the rights holder's successors, which have arisen as a result of its liquidation, reorganization or bankruptcy, and which have acquired exclusive rights to own the Mobile Application, (3) third parties solely for the purpose of obtaining certain content or access to it from the User, and (4) third parties when the User has consented to the disclosure, transmission or processing of their Personal Data, as well as in other cases expressly provided for by law or this Policy.
The rights holder discloses Personal Data only if (1) it is confident that third parties will comply with the conditions of this Policy and take the same measures to protect the confidentiality of Personal Data as those taken by the rights holder, and (2) consent to such disclosure has been previously expressed by the User and/or is permitted on the basis of the law.
6. ADVERTISING PLACEMENT
Advertising in the mobile application
The rights holder does not place advertising in the Mobile Application.
7. COMPLAINTS AND REQUESTS TO THE COPYRIGHT HOLDER
Demand to cease the processing of personal data
Each User has the right to object to the processing and/or storage of their Personal data by the Copyright holder. Such an objection may be expressed as follows:
info@annadeva.group
Request for information on personal data
If the User has questions related to the application or use of this Policy, the procedure and/or method of processing Personal data, the User may ask such a question as follows:
info@annadeva.group
Change (update, supplement, correct) or delete personal data
The User has the right at any time to independently change or delete their Personal data, except in cases where such changes or deletion may lead to (1) violation of the rules of this Policy; or (2) violation of the law; (3) the nature of such Personal data is evidence in any legal proceeding between the Copyright holder and the User. To do this, the User needs to delete their personal account (profile) in the Mobile application.
The Copyright holder has the right at any time to delete the User's personal account/profile, as well as all Personal data about the User, if the User has violated the conditions of this Policy and/or the User Agreement.
8. TERMS AND CONDITIONS FOR THE STORAGE OF PERSONAL DATA
The storage is carried out by the Copyright holder themselves.
The storage is carried out for the following period: 1 year from the moment of receiving such information.
After the storage period for Personal data has ended, such data shall be immediately destroyed or depersonalized, unless otherwise prohibited by the law or provisions of this Policy.
9. ACCESS FOR MINORS TO THE MOBILE APPLICATION
You must be at least 17 to use the App. We do not knowingly collect personal information from children under 13 (16 for EEA and UK residents), and we do not allow people to use the App if they are younger than 17.
10. CONCLUDING PROVISIONS
Availability of the policy text
Users can review the terms of this Policy at the following link: https://forms.gle/N6oH3vqM2kpNzESA7
This version of the Policy is effective as of 21.04.2023.
Changes and additions to the policy
This Policy may be amended from time to time. The copyright holder shall not be liable to the user for any changes to this Policy without the user's permission and/or consent.
The user agrees to regularly review the provisions of this Policy for possible changes or additions.
Risk of disclosure
Regardless of the measures taken by the copyright holder to protect the confidentiality of personal data obtained, the user is hereby deemed to have been properly informed that any transmission of personal data over the Internet cannot be guaranteed to be secure, and the user undertakes such transmission at their own risk.
