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PRIVACY POLICY

Date of last revision: March 01, 2019
 

1. INTRODUCTION

This Privacy Policy (hereinafter referred to as the «Policy») informs you about the types, scope and purposes of processing of personal information (including personal data), which the Company and/or its affiliates may receive when you use mobile applications MyOffice (hereinafter referred to as «Mobile applications») and their components (including but not limited to MyOffice Documents, MyOffice Logos, MyOffice Mail).

Mobile Applications are also referred to as «Applications».

This Policy uses the definitions corresponding to Article 3 of Federal Law No. 152-FZ «On Personal Data» of July 27, 2006 (hereinafter referred to as «152-FZ»).

 

1.1. Authorized person

Name:

Limited liability company «NEW CLOUD TECHNOLOGIES» (NEW CLOUD TECHNOLOGIES LTD, hereinafter referred to as «Company»).

Legal address:

420500, Russian Federation, Republic of Tatarstan, Innopolis city, Universitetskaya str., 7, of.302.

Post address:

125009, Russian Federation, Moscow, Bol. Gnezdnikovskiy per., 1, build.2.

Contact information:

contact@ncloudtech.ru

 

1.2. Types of information collected and processed

  • user credentials;
  • information about the user’s device;
  • contact information;
  • Applications’ crash reports;
  • other information.

 

1.3. Processing of special information categories

Special information categories (in accordance with Article 10, paragraph 1 of 152-FZ) shall not be processed.

 

1.4. Categories of data subjects

  • Users of the Applications.

 

1.5. Processing purposes

  • to provide stable operation of Applications;
  • to maintain and improve Applications;
  • to develop new functions of Applications;
  • to provide security and reliability of Applications.

2. APPLICABLE LEGAL BASIS

The legal basis for processing personal information (including personal data) is your consent. By using Mobile Applications, you agree that the Company may collect, store, use and otherwise process your personal information (including personal data).

3. CHANGES AND AMENDMENTS TO THIS POLICY

Please read this Policy regularly. The policy will adapt to regulatory changes. The current version of the Policy is available at https://myoffice.ru/policy_mobile_en.

As soon as the changes require your additional consent or obligatory familiarization, you will be informed about this fact.

4. INFORMATION SECURITY

Data collection and processing processes ensure security at every stage of the data lifecycle.

The following factors are taken into account in the information security:

  • current technological horizon;
  • the cost of implementing protection measures;
  • types, categories and purposes of processing, as well as the probability and degree of risk to the rights and freedoms of individuals;
  • compliance of technical and organizational protection measures with the risks.

Measures include, but are not limited to, providing for the confidentiality, integrity and availability of data by controlling physical access to the data, as well as the processes of data entry, modification, deletion and transfer.

The Company has developed and implemented procedures to ensure that the rights of data subjects are observed, and to respond to data disclosure.

In addition, we consider the protection of personal data when developing or selecting hardware and software according to the principles of «privacy by default» and «privacy by design».

Security measures include, in particular, data transmission over encrypted communication channels (TLS).

5. DATA PROCESSING

 

5.1. Mobile applications

When you use the Company’s Mobile Applications, information about the user’s location, the user’s device, data about the use of Mobile Applications and Mobile Applications crash reports (see the section 6 of this Policy) is transferred to third parties, for the purpose of analysis, optimization, and troubleshooting.

6. TRANSFER OF DATA TO THIRD PARTIES

For the purposes of analysis, optimization, and troubleshooting in the Applications, information is transferred to the following analytical systems:

  • Facebook: Analytics;
  • Mixpanel;
  • Crashlytics.

 

6.1. Facebook Analytics

We use the Facebook Analytics service to collect and analyze technical data about the use of Applications developed by the Company.

The following information is transferred to Facebook Analytics:

  • location data such as: country, region, city obtained by IP address conversion;
  • information about the device, such as: device ID, model and type, operating system version and name, device and language settings;
  • identifiers of the operations to be performed and the results of the performed operations;
  • application version.

Facebook Analytics is used in Applications developed by the Company in accordance with Facebook recommendations:

The information transferred to Facebook Analytics is not additionally stored or transferred to other services or resources, nor is it linked to other data held by Facebook.

Information about Facebook’s data privacy policy and data protection measures can be found on the following resources:

The transfer of analytical information to Facebook Analytics can be disabled by the user in the Application settings.

 

6.2. Mixpanel

We use the Mixpanel service to collect and analyze technical data about the use of Applications developed by the Company.

The following information is transferred to Mixpanel:

  • location data such as: country, region, city obtained by IP address conversion;
  • information about the device, such as: device ID, model and type, operating system version and name, device and language settings;
  • identifiers of the operations to be performed and the results of the performed operations;
  • application version.

Mixpanel is used in Applications developed by the Company in accordance with the installation recommendations:

Information transferred to Mixpanel is not additionally stored or transferred to other services or resources.

Information about Mixpanel’s data privacy policy and data protection measures can be found on the following resources:

The transfer of analytical information to Mixpanel can be disabled by the user in the Application settings.

 

6.3. Crashlytics

We use the Crashlytics service, which provides information about unforeseen failures and other malfunctions of the Applications developed by the Company.

The following information is transferred to Crashlytics in case of failures or malfunctions:

  • information about the IP address of the device;
  • information about the device, such as: device ID, model and type, operating system version and name, device and language settings;
  • the application version and functionality;
  • the time of failure.

Information transferred to Crashlytics is not additionally stored or transferred to other services or resources.

Information about Crashlytics’s data privacy policy and data protection measures can be found on the following resources:

Google’s Privacy Policy is available at:

The transfer of information about failures and malfunctions to the Crashlytics service can be disabled by the user in the Application settings.

7. LIMITATIONS

Our Applications are not intended for children under 16 years.

Thus, we do not collect, at least knowingly, information about persons under 16 years, and do not transfer it to third parties.

8. TERMS OF INFORMATION PROCESSING

We process your data only for the period of time necessary to achieve the goals set out in this Policy. Your data will be deleted immediately when the specified objectives are achieved.

9. YOUR RIGHTS

You are not obliged to consent to the transfer of your data to us and/or third parties.

If you refuse to provide us and/or third parties with your data, you cannot use the Applications that require you to provide certain data.

When processing your data in accordance with this Policy, you have the right to withdraw your consent at any time without affecting the legality of the processing performed prior to such withdrawal of consent.

If you have any questions, requirements or requests related to the processing of your data under this Policy, you may contact us using the contact information provided in section 1.1. of this Policy.