This policy governs the manner in which personal and other confidential data of users of the Technogram mobile application is collected and processed with the use of automation tools via the Internet. Terms and Definitions For the purpose of this Policy, the following terms have the following meanings: 1. “Techogram” means the Technogram computer program installed on the User’s device and allowing the User to exchange text messages and media files. 2. “Personal (Confidential) Data” means any information relating directly or indirectly to a specific or definable individual (subject of personal data). 3. “Developer” means Sergei Gennadevich Mokeev, INN [Taxpayer Identification Number] 452600036573, an individual entrepreneur registered in accordance with the legislation of the Russian Federation. The location of the Developer is as follows: 17 Radionova Street, Kurgan, Kurgan Oblast, 625033, Russian Federation. 4. “User” means a person using the Mobile Application and providing for this purpose his/her personal data. 5. “Processing of Personal Data” means any action (operation) or a set of actions (operations) performed with or without the use of automation tools in respect of personal data, including collection, recording, systematization, accumulation, storage, correction (update, modification), retrieval, use, transfer (distribution, provision, granting access), depersonalization, blocking, deletion, destruction of personal data. 6. “Automated Processing of Personal Data” means processing of personal data by means of computers. 7. “Provision of Personal Data” means the actions aimed at disclosing personal data to a specific person or a specific group of persons. 8. “Blocking of Personal Data” means the temporary suspension of personal data processing (except in cases where processing is necessary for the correction of personal data). 9. “Destruction of Personal Data” means the actions that render it impossible to restore the content of personal data in the personal data information system and/or the actions resulting in the destruction of physical media on which personal data is stored. 10. “Personal Data Information System” means a set of personal data contained in databases together with information technologies and technical means ensuring personal data processing. 11. “Cookies” means pieces of data sent by the website and stored on a computer, mobile phone, or another device from which the User accesses the website, and used to store data about the User’s actions on the website. 12. “Device Identifier” means unique data allowing identifying the User’s device on which the mobile application is installed, and provided by the device itself or calculated by the mobile application. General Provisions 1. This document defines the policy of the Developer with regard to the processing of the Users’ personal data, the types of personal data collected through the Mobile Application, the rights and obligations of the Users, the Developer and the Copyright Holders during personal data processing. 2. Processing of the Users’ personal data is carried out by the Developer. 3. Installation of Techogram by the User on any of his/her devices, as well as the use of the web version of Techogram means the User’s consent to the terms of this policy, including the User’s consent to processing of his/her personal data in cases when such consent is required by the provisions of applicable law. 4. The purpose of collecting and processing the User’s personal data is the conclusion and implementation of the contract to provide the User with the right to use Techogram. When collecting and processing personal data, the Copyright Holder shall not pursue any other purposes, except for the implementation of the said contract. Types of Collected and Processed Personal Data Various types of personal data can be collected through Techogram, which can be divided into the following categories: 1. User profile data; 2. text messages and media files; 3. phone contact list. User Profile Data 1. This category includes the following data: 1) User profile name; 2) User phone number; 3) User profile image. 2. Any name at the discretion of the User may be used as the User profile name. You are not required to provide your true first and last name in order to use Techogram. 3. The User phone number is necessary to identify Techogram users, as well as to confirm the User’s registration. The specified phone number is used to send a short text message (SMS), which is necessary to confirm User’s registration, as well as to log in to the existing User profile on a new device. To use Techogram it is necessary to specify a valid phone number belonging to the User. 4. To use Techogram, the User may choose to use any image as the User profile image or refuse to use the User profile image at their own discretion. The use of Techogram does not require uploading a valid photo of the User. 5. The User profile data is stored by Techogram during the entire period of its use. Upon termination of the use of Techogram, the specified data is destroyed without the possibility of its subsequent recovery. To resume using Techogram after destroying the User profile data, you must register a new User profile. 6. The User profile data is available to all Techogram users. Text Messages and Media Files 1. Techogram is designed to enable the Users to exchange text messages and media files. These messages and media files are stored on Techogram servers. The Developer does not provide its employees, as well as involved specialists, with access to the content of correspondence of the Users. 2. Techogram also provides the feature of publishing text messages and media files in publicly accessible channels and groups. Messages and media files published by the User in such channels and groups are available to all Users subscribed to said channels or members of such groups. Phone Contact List 1. Techogram may request access to the contacts stored on the User’s phone in order to show which of the User’s contacts are using Techogram. In this case, the Developer gets access only to the phone number and contact name as saved on the User’s phone. Measures of Protection of Personal Data of the User 1. In order to protect personal data of the User, the Developer shall take legal, organizational and technical measures aimed at ensuring the confidentiality of the received personal data, its safety and protection from unauthorized receipt, distortion or destruction. 2. During the processing of personal data, the User is entitled to: 1) receive information relating to the processing of his/her personal data, including confirmation of the processing of personal data; legal basis and purposes of the processing of personal data; purposes and applicable methods of the processing of personal data; information about the name and location of the person processing personal data, information about the persons (except for employees of the Developer) that have access to personal data or to that personal data may be disclosed based on a contract with the Developer or based on the current legislation; processed personal data relating to the respective subject of personal data, the source of personal data unless another procedure for submitting such data is provided for by the current legislation; time limits of the processing of personal data, including the time limits of its storage; procedure for the exercise by the User of the rights provided for by the current legislation; information on the completed or intended cross-border data transfer; name or last name, first name, patronymic, and address of the person processing personal data on behalf of the Developer, in case the processing is or is to be assigned to such a person, as well as to receive other information provided for by the current legislation; 2) require the Developer to correct his/her personal data, to block it or to destroy it in cases where the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of the processing, as well as to take legal measures to protect his/her rights; 3) appeal the actions or omissions to an authorized body for the protection of the rights of subjects of personal data, or in court, in case the User believes that his/her personal data is processed in violation of the requirements of the current legislation or his/her rights and freedoms are otherwise violated. 4) protect his/her rights and legitimate interests, as well as to claim compensation for damages and/or compensation for moral damages in court. 3. During the processing of personal data, the Developer shall: 1) provide the User at his/her request with the following information: • confirmation of the processing of personal data; • legal basis and purposes of the processing of personal data; • purposes and applicable methods of the processing of personal data; • his name and location, information about the persons (except for employees) that have access to personal data or to that personal data may be disclosed based on a contract or based on the current legislation; • processed personal data of the User, the source of personal data unless another procedure for submitting such data is provided for by the current legislation; • time limits of the processing of personal data, including the time limits of its storage; • procedure for the exercise by the User of the rights provided for by the current legislation; • information on the completed or intended cross-border data transfer; • name or last name, first name, patronymic, and address of the person processing personal data on behalf of the Developer, in case the processing is or is to be assigned to such a person; • other information provided for by the current legislation; 2) ensure the adoption of measures for the prevention of unauthorized access to the User’s personal data; 3) publish or otherwise provide unrestricted access to the document defining the personal data processing policy, as well as to the information about the requirements implemented for the protection of personal data. 4. The User’s personal data is stored on electronic media and processed with the use of automated personal data processing systems. 5. Access to the User’s personal data shall be provided only to the employees of the Developer. The Developer shall not distribute the User’s personal data, and shall not provide access to it to third parties without obtaining the prior consent of the User, except for cases where personal data is provided at the request of authorized state bodies in accordance with the current legislation. 6. The Developer shall implement the following measures for the prevention of unauthorized access to the User’s personal data: 1) the Developer shall appoint the employees responsible for organizing the processing of personal data; 2) the Developer shall implement organizational and technical measures to ensure the safety of the User’s personal data. 7. The User is entitled to require the Developer to correct (update) his/her personal data, to block or to destroy it, if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated processing purpose, and also to withdraw his/her consent to the processing of personal data by sending the Developer an appropriate request and/or demand in writing. The corresponding request can also be sent electronically to the following email address developer@technogramios.ru. The specified request/demand shall include the number of the main identifying document of the User or his/her representative, the date of issue of the specified document and the name of the issuing authority, the address of the User’s place of residence, information confirming the User’s registration with Techogram, or information that otherwise confirms the fact of the processing of personal data, request to correct, block or destroy the User’s personal data, or notice of withdrawal of consent to the processing of personal data, signature of the User or his/her representative. The Copyright Holder shall give a reasoned respond on the merits of the User’s request/demand within 30 calendar days from the date of receipt.