Version from the 15th of April 2022
You provide our company with your personal data and give us full and unconditional consent to processing of your personal data, including cross-border transfer, only in accordance with the Policy.
1. General Provisions
1.1. The Policy is an official document of "Action Portal" LLC (hereinafter the Company; legal name of the Сompany in Russian – ООО "Экшн Портал"), a Legal Entity established under the laws of the Russian Federation with registration number (MSRN) 1185476015141, TIN 5408019173, TRC 540801001, located at 4a Inzhenernaya St. office 601a Novosibirsk, Russia 630090, which determines the procedure of processing and protection of information about individuals (hereinafter the “Users”) using the Website https://action-portal.com, its services and applications of the Company.
1.2. Akadem GmbH, a legal entity established under the laws of the Republic of Austria, registered at the address: Wipplingerstrasse 1/2/1, 1010, Vienna, Austria is the authorized representative of the Company for users located in the European economic area (EEA) or Switzerland.
1.3. The purpose of this Policy is to ensure proper protection of information about Users, including their personal data, from unauthorized access and disclosure.
1.4. Collection, storage, distribution and protection of information about Users of the Products are governed by this Policy, other official documents of the Company and the current legislation of the Russian Federation.
1.5. The current version of the Policy, which is a public document, is available to any Internet user by clicking on the link https://action-portal.com/privacy. The Company is entitled to amend the Policy. Previous versions of the Policy are available in the Company's documentation archive.
1.7. By registering and using the Products, the User agrees to the Policy.
1.8. In case of disagreement with the Policy the User must immediately stop using the Site and its services.
2. Purposes of Personal Data Processing
2.1. The Company processes information about Users, including their personal data, in order to fulfill the obligations of the Company to Users in relation to use of the Products.
3. Condition of Use
3.1.The Сompany providing services to the User on the use of Products, acting reasonably and in good faith, believes that the User:
- has all the necessary rights to register, install and use the Products;
- indicates accurate information about yourself in the amounts required to use the Products;
- acquainted with the Policy, expresses its agreement with the Policy and assumes the rights and obligations specified in the Policy.
3.2. The Company does not verify accuracy of information received (collected) about users, except in cases where such verification is necessary for the purpose of fulfilling the Company's obligations to the User.
4. Volume of Processed Information About Users
4.1. The Company may process the following categories of personal information, depending on the Product used by the User:
4.1.1. Personal information provided by Users themselves when using the Product, namely: surname, name, patronymic, phone number, country of residence, address, age, data on expenses and income, account balance, email, Skype number;
4.1.2. Electronic data (IP address, cookies, browser ID data, hardware and software information, mobile operator name);
4.1.3. Date and time of access to the Product (including time zone);
4.1.4. Information about activity during the use of the Product;
4.1.5. Information about geolocation;
4.1.6. Information received from third parties in accordance with the terms of agreements concluded between Users and third parties and/or agreements concluded between the Company and third parties.
4.3. If the Product contains a face editing function, the Company declares that the Company does not process User’s images and does not get access to these images. These Products allow the User to edit image and save it in the device's memory without transferring the resulting image to the Company.
5. Processing of User Information
5.1. The processing of personal data is carried out on the basis of the following principles:
a) Legality of purposes and methods of personal data processing;
b) Good faith;
C) Compliance of the purposes of personal data processing with the purposes defined in advance and declared when collecting personal data, as well as with the company's powers;
d) Compliance of the volume and nature of personal data processed, methods of personal data processing with the purposes of personal data processing;
e) Inadmissibility of combining databases containing personal data created for incompatible purposes.
5.2. Terms and purposes of personal data processing.
The Company processes the User's personal data in order to fulfill the contract between the Company and the User for the provision of services (Clause 2.4 of the User agreement https://action-portal.com/tos). By virtue of article 6 of the Federal law of 27.07.2006 No. 152-FZ "On personal data" a separate consent of the User to the processing of his personal data is not required. By virtue of Sub-Paragraph 2 of Paragraph 2 of Article 22 of this law, the Company has the right to process personal data without notifying the authorized body for the protection of the rights of personal data subjects.
5.3. Transfer of personal data.
The Company may transfer the personal information to third parties in order to achieve the purposes specified in this Policy. Such third parties may include:
a) Partners, such as site and app owners, advertising networks and other partners providing services related to the placement and display of advertising on sites or services owned or controlled by partners;
b) Any national and/or international regulatory body, law enforcement authorities, central or local executive authorities, other official or public authorities or courts in respect of which the Company is obliged to provide information in accordance with applicable law upon request;
C) Third parties, if the User has agreed to the transfer of personal information or the transfer of personal information is required to provide services or perform a certain agreement or contract concluded with the User;
d) To any third party in order to ensure the legal protection of the Company or third parties in case of violation of the User agreement of the Company's services, this Policy or the conditions governing the use of individual Services, or in a situation where there is a threat of such violation.
5.4. Storage and use of personal data.
Personal data of Users are stored exclusively on electronic media and processed using automated systems, except for cases when non-automated processing of personal data is necessary in connection with the fulfillment of the requirements of the legislation.
The Company stores the User's personal data for the purposes for which it was collected and is deleted when you stop using the Product, or until the expiration of the mandatory storage of personal information provided by applicable law. If the necessary conditions are met, the User's personal data will be completely deleted.
6. Rights and Obligations of Users
6.1. You have the right to access Personal information about yourself processed by the Company in accordance with this Policy.
If the information about the User is incorrect or incomplete, the User may correct and/or supplement the Personal information himself (if it is provided by the Product) or contact the Company and request correction and/or Supplement the incorrect information.
In addition the User has the right to:
a) Require the complete removal of Personal information;
b) Require restrictions on the processing of Personal information;
C) Object to the processing of Personal information.
The Company will comply with these requests in accordance with applicable law. Please note, since most of the User information contains data about a particular browser or device and can no longer identify the User, it will be necessary to provide additional information so that the Company can identify the Personal information stored by us about the User, and ensure that the User's request is accurately fulfilled.
To exercise the above rights, you must contact the Company (see clause 7 of this Policy).
7.1. Users have the right to send their requests to the Company, including requests regarding the use of their personal data provided for in clause 6.1. of these Rules, in writing to the address: 4a Inzhenernaya St. office 601a Novosibirsk, Russia 630090 or in the form of an electronic document signed by a qualified electronic signature in accordance with the legislation of the Russian Federation, at the e-mail address: email@example.com.
7.2. The Company undertakes to consider and send a response to the User's request within 30 days from the date of receipt of the request.