PhotoRoomer Pro Privacy Policy 

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1. GENERAL PROVISION

1.1. Methods of processing of Personal Information include any action (operation) or a combination of actions (operations) with Personal Information including collection, recording, systematization, storage, updating (refreshment, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction in the purposes established by this Policy with/without the use of automated facilities

1.2. The terms and definitions provided for by the EULA are used herein, as well as other agreements entered into with the User, unless otherwise provided for by this Policy or follows from the merits thereof.

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1.3. This privacy policy (including any of its parts) is subject to change by PhotoRoomer without any special notice and without compensation in connection therewith. The new edition of the Privacy Policy comes into force from the moment it is posted on the PhotoRoomer website.

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2. THE COLLECTION OF THE DATA 

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2.1. Non-personalized data about users

 

2.1.1. In connection with the use of the Mobile Application, the Rightholder 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.

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(2) information about the location of the User (geolocation). The user can turn off geolocation at any time by changing the settings of the device from which the Mobile application is entered. Geolocation is used by the Mobile Application only when the User actively uses such an application. When you exit the Mobile Application, geolocation stops functioning.​

(3)  Data transmitted in a depersonalized form in automatic mode, depending on the settings of the User's software including operating system of User's device.

(4) User acknowledges and accepts the possibility of using third party software in the Mobile application; as a result, such third parties can receive and transmit the data in a depersonalized form as stipulated in the paragraph 2.2.2 hereof.

2.1.2. The aforementioned third party software may include following analytic systems:
 

(1)  Firebase, that is software product of Google and that collects and processes data according to data use policy available at: https://policies.google.com/privacy;

 

(2) Amplitude, that collects and processes data according to privacy policy available at: https://amplitude.com/privacy;

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(3) Facebook SDK, that is software product of Facebook and that collects and processes data according to data use policy available at: https://web.facebook.com/full_data_use_policy;

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2.1.3. Such data collected with third party software may include:

(1) User's device data, including unique identifiers of User's device, its location (country and city), operating system data (type, version, screen resolution) and so on;

(2) query data (time, source, IP address);

(3) other information about User's activity in the Mobile application.

2.1.4. The scope and conditions for collection and use of impersonal data by such software's titleholders are determined directly by its titleholders and governed by documents available at their websites.

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2.1.5. Accepting this Policy as well applying certain setting in his/her software including device's operating system, the User agrees with conditions for collection and use of data by the titleholders of above listed software.

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2.2. Personal Information

 

2.2.1. The User provides the following personal data:

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(1) full surname and first name.

(2) date of birth and age.

(3) mobile phone number.

(4) the gender of the User.

(5) a photograph with a picture of the User.

(6) data contained in the personal account (profile) of the User, as well as other activity of the personal account (profile) of the User.

(7) data on all publications made by the User in the Mobile Application, including, but not limited to, comments, ratings, reviews, publication of reports, videos and photos, likes, ratings and / or any other forms of activity available to the user in Mobile application and / or generated content

(8) data and information obtained as a result of combining certain personal data of a specific User, as well as data and information received data about the User received from third parties (partners, marketers, researchers).

 

2.2.2. The user is the only person responsible for the completeness of the provided personal data and is obliged to timely change them (update, check, correct) on a regular basis.

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2.2.3. The Rightholder assumes that all personal data provided by the User are reliable, and that the User maintains such information up to date.

 

2.3. Use of Captcha

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2.3.1. Captcha is integrated into the Mobile Application, which is a type of Cookies, the purpose of which in this case is:

(1) protecting the User from possible spam coming from third parties on the Internet, as well as from other irrelevant and / or prohibited content

(2) identification of the User in order to distinguish him from bots / robots

(3) improving the User's ability to use the content of the Mobile Application.

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2.4. Use of cookies

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2.4.1. This Mobile Application uses certain Cookies to store the IP address, User preferences or the type of device used in order to

(1) keeping statistics of site visits and traffic

(2) personalization of the data displayed on the User's screen

(3) saving the data necessary to identify the User, including when accessing from different devices. The mobile application can use as its own Cookies belonging to the Copyright Holder. and third party cookies.

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2.4.2. The mobile application uses the following cookies:

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(1) Technical (functional) Cookies, which are needed to control traffic and data transfer, to identify Users and provide the User with access to the content of the Mobile Application and without which the use of the Mobile Application is functionally limited, as well as to prevent the provision of recommendations that do not correspond to the interests User.

(2) Geolocation Cookies, which are needed to determine the location of the User in order to personalize the content displayed on the screen of his device in the Mobile Application.

(3) Cookies of third parties, which are installed by third parties with the permission of the User and are intended to conduct statistical research on the behavior of the User on the Internet.

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2.5. Requirements for the protection of personal information

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2.5.1. The Rightholder stores the User's Personal Information and ensures its protection from unauthorized access and distribution in accordance with the internal rules and regulations.

 

5.2. With regard to the User's Personal Information, its confidentiality is maintained.

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3. USER RIGHTS 

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3.1. In connection with the provision of Personal Data, the User automatically receives the following rights:

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(1) receive data concerning their processing (the grounds and purposes of such processing, the processing methods used, information about the persons who have access to them or to whom they may be disclosed on the basis of an agreement or the Law).

(2) receive information about the storage periods of Personal Data.

(3) receive data on the performed or expected cross-border transfer of Personal Data.

(4) to appeal against the actions or inaction of the Copyright Holder to the authorized body for the protection of the rights of subjects of personal data or in court.

(5) exercise other rights in the field of personal data protection provided for by the Law or the provisions of this Policy.

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4. PURPOSE OF PROCESSING THE PERSONAL DATA 

 

4.1. PhotoRoomer is entitled to use the Personal Information for the following purposes:

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(1) to analyze User behavior, as well as identify possible ways to improve the user experience in the application.

(2) for the prompt and correct operation of the Mobile Application, improving the functioning of the Mobile Application, improving the content of the Mobile Application, improving the internal architecture and functionality of the Mobile Application.

(3) to identify the User.

(4) to send personalized advertising and marketing materials to the User's mobile phone.

(5) to comply with the requirements of the Law.

(6) to determine the location of the User.

(7) for technical support of the Mobile application, identifying problems in its operation and their elimination.

(8) to keep in touch with the User (communication).

(9) to fulfill other obligations of the Rightholder that arose before the User.

(10) for statistical research.

(11) for any other purpose, subject to obtaining a separate consent from the User.

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4.1.1. The processing of Personal Data is carried out on the basis of the principles:

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(1) the legality of the purposes and methods of processing;

(2) good faith;

(3) compliance of the purposes of processing Personal Data with the purposes predetermined and declared when collecting such Personal Data

(4) compliance of the volume and nature of the processed Personal Data with the stated purposes of their processing.

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4.2. Conditions of processing the personal data

 

4.2.1. Personal data processing is carried out in the following cases:

(1) obtaining consent from the User; or (2) achievement by the Copyright Holder of the goals stipulated by an international treaty or the Law; or (3) the User provides his Personal Data to an unlimited number of people, or (4) the fulfillment of other obligations of the Copyright Holder to the User, including, but not limited to, the provision of certain content to the User, or (5) saving the life or health of the User, when consent to the processing of it Personal data cannot be obtained in advance.

 

4.2.2. In the case of anonymization of Personal Data, which does not directly or indirectly determine the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy no longer apply to them.

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4.2.3. The Copyright Holder takes all possible measures to protect the confidentiality of the received Personal Data, except for cases when the User has made such data publicly available.

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4.2.4. Processing of Personal Data is carried out using automation tools and without using such automation tools.

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5. PLACEMENT OF ADVERTISING

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5.1. Advertising in the mobile application

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5.1.1. The Rightholder does not place advertisements in the Mobile Application.

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5.2. Distribution of advertising materials.

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5.2.1. The User automatically with the installation of the Mobile Application on the device agrees with the right of the  Rightholder to send personalized advertising and marketing materials to the provided email address and / or mobile phone.

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5.2.1. The user has the right at any time to refuse to receive such advertising and marketing materials by performing the following actions: follow the link in the letter and unsubscribe from receiving letters. Please note that in case of refusal to receive advertising and marketing materials, the User may continue to receive from the Rightholder any notifications related to the procedure for using the Mobile Application and / or its content.

 

6. SENDING COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER

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6.1. Request to terminate the processing of personal data

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6.1.1. Each User has the right to express his objection to the Rightholder against the processing and / or storage of his Personal Data. Such an objection can be expressed as follows: the request must be sent to the address of the Rightholder photoroomer.mobile@gmail.com

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6.2. Request for information about personal data

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6.2.1. If the User has questions related to the procedure for applying or using this Policy, the procedure and / or method of processing Personal Data, the User can ask such a question as follows: the question should be sent to the Rightholder at the following address photoroomer.mobile@gmail.com

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6.3. Change (update, addition, correction) or deletion of personal data

 

6.3.1. The User has the right at any time to independently change or delete his Personal Data, unless such a change or deletion can. lead to (1) a violation of the rules of this Policy, or (2) a violation of the Law; (3) the nature of such Personal Data is evidence in any legal proceeding between the Rightholder and the User.

To delete an account on your own, you need to do the following: log into your personal account (profile) in the Mobile application, select personal settings, delete your account.

 

6.3.2. The Rightholder has the right to delete the User's personal account / profile at any time, as well as all Personal Data about the User if he has violated the terms of this Policy and / or the User Agreement.

 

6.3.3. In case of deletion of Personal Data about the User, all publications made by such User (comments, ratings, reviews, publication of reports, videos and photos, rating of rations) and / or any other forms of activity available to the User in the Mobile Application are also subject to automatic deletion. 

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7. TERMS AND PROCEDURE FOR STORING PERSONAL DATA

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7.1. Storage is carried out during the entire period of use by the User of this Mobile Application.

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8. POLICY WITH REGARDS TO CHILDREN

 

8.1. PhotoRoomer does not intentionally collect personal data from children younger than 16, it does not request it and does not allow them to use the Mobile application. If PhotoRoomer gets to know that the information was collected from a child under 16, PhotoRoomer shall immediately delete such information. If you think we could have obtained any information from a child or about a child under 16, please, contact us through e-mail: photoroomer.mobile@gmail.com

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9. PROCEDURE FOR PROTECTING PERSONAL DATA

 

9.1. Protecting the confidentiality of Personal data is the primary and important task for the Rightholder. The Rightholder adheres to all required international standards, rules and recommendations for the protection of Personal Data.

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9.2. The Rightholder has introduced a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access to them by third parties. To ensure the safety and confidentiality of the received Personal Data, the Rightholder uses the following means of protection:

(1) SSL (Security Sockets Layer) protocol. (2) Firewalls and: (3) setting a one-time password

 

10. FINAL PROVISIONS

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10.1. Availability of the policy text for review.

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10.1.1. Users can read the terms of this Policy at the following link https://www.photoroomer.com/privacy policy. This version of the Policy is valid as of November 9, 2021

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10.2. Amendments to the Privacy Policy

 

10.2.1. This Policy may be amended or terminated unilaterally by PhotoRoomer without prior notice to the User. The User is recommended to read this Policy in the current version regularly. The Rightholder does not take any responsibility to the User for changing the terms of this Policy without the permission and / or consent of the User.

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10.3. Applicable law

 

10.3.1. This Policy has been developed in accordance with the current legislation on the protection of personal data of the Russian Federation, in particular, with the provisions of the Federal Law of July 27, 2006 No. 152-F3 "On Personal Data" (with all amendments and additions), Federal Law of July 21, 2014 year N 242-F3 "On amendments to certain legislative acts of the Russian Federation in terms of clarifying the procedure for processing personal data in information and telecommunication networks" (with all the additions and changes).

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10.4. Disclosure risk

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10.4.1. Regardless of the measures taken by the Rightholder to protect the confidentiality of the personal data received, the User is hereby considered to be duly aware that any transfer of Personal Data on the Internet cannot be guaranteed safe, and therefore the User carries out such transfer at his own risk.

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10.5. Public information

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10.5.1. Within the framework of the Mobile Application, the User has the right to publish and post any content at his own discretion and in any of the available forms (photo, video, comment, article, rating, blog, etc.). Such publications and content are publicly available to other users of the Mobile Application, and therefore the Rightholder does not assume any obligation to protect Personal Data that may be disclosed or published as part of such publication and / or content.

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The current version of the Policy of 06.09.2021