PRIVACY POLICY FOR THE MOBILE APP:

CALCULATOR #1 FOR IPAD


1. DEFINITIONS

"Law" refers to the Federal Law of the Russian Federation "On Personal Data" with all amendments and additions, as well as other legislative acts of the Russian Federation.

"Controller" means the entity responsible for the processing and protection of Users' Personal Data located within the European Union, as defined by the General Data Protection Regulation (GDPR) dated April 27, 2016.

"Mobile application" is software (including all existing add-ons and improvements) designed to operate on tablets and developed for a specific platform (Apple iOS). For the purposes of this Policy, the Mobile application referred to is the following software: CALCULATOR #1 FOR IPAD.

"Personal Data" means the aggregate of personal and/or non-personal information about the User, provided by the User 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 the agreement concluded between the Right Holder and the User regarding the procedure, rules, and features of the User's use of the Mobile application. The User agrees to this agreement and has no right to make or demand any changes or additions to it. The User can review the terms of the User Agreement at the following link: https://www.apple.com/legal/internet-services/itunes/dev/stdeula/.

"Right Holder" means the following entity that holds the exclusive rights to the ownership of the Mobile application:

OOO "PIE STUDIO"
127055, Moscow, Sushchevskaya Street, building 27, building 2, unit/room/office 3/III/3/88;
sayhi@pie.studio

"Processor" means the entity that, as defined by the GDPR, performs storage and/or processing of Personal Data received from Users on behalf of the Controller.

"Cookie files" mean small files sent by mobile applications or websites and placed on Users' smartphones, tablets, watches, and other mobile devices to improve the operation of such applications or websites, as well as the quality of the content hosted in them.



2. SCOPE OF THE POLICY

General Provisions
This Policy is solely applicable to the Personal Data obtained from Users in connection with their use of the Mobile application. The provisions of this Policy are aimed at:

  1. Defining the types and categories of Personal Data obtained, the purposes and directions of the use (processing) of Personal Data, as well as the sources from which such Personal Data is acquired.
  2. Determining the rights of the User regarding the protection of the confidentiality of the Personal Data provided by them.
  3. Identifying the parties responsible for the processing and storage of Personal Data, as well as third parties to whom such data is disclosed (in whole or in part).
The rules of this Policy do not apply to the processing of Personal Data voluntarily provided by the User by third parties.

By installing and/or activating the Mobile application on their tablet, the User agrees to the terms of this Policy and gives their consent to the Right Holder for the collection, processing, retention, and storage of Personal Data in accordance with the provisions of this Policy.
If the User does not agree with the terms of the Policy and/or finds specific conditions of the Policy unclear, they must immediately cease using the Mobile application.

User Rights regarding Personal Data Protection
In connection with the provision of Personal Data, the User automatically gains the following rights:
  1. To receive information about the processing of their data (grounds and purposes for such processing, methods of processing, information about the entities with access to the data or to whom it may be disclosed based on an agreement or the Law).
  2. To receive information about the location and identification data of entities processing Personal Data.
  3. To receive information about the storage periods of Personal Data.
  4. To receive information about the completed or intended cross-border transfer of Personal Data.
  5. To receive information about the location and identification data of entities storing Personal Data.
  6. To appeal the actions or omissions of the Right Holder to the competent authority for the protection of the rights of personal data subjects or through the judicial process.
  7. To seek compensation for damages and/or compensation for moral harm through legal proceedings due to violations of the User's rights to the protection and security of their Personal Data committed by the Right Holder and/or third parties.
  8. To exercise other rights in the field of personal data protection provided by the Law or the provisions of this Policy.


3. LIST OF COLLECTED PERSONAL DATA

Non-personal Information about Users
In connection with the use of the Mobile application, the Right Holder may automatically collect and process the following non-personal information about the User:
  1. Traffic information, possible click count, logs, and other data.
  2. Device information (identification number, mobile operator network) used for login, operating system, platform.
Personal Data of Users
The Right Holder does not collect any personal data that allows the identification of Users.

Information about Transactions
Through the Mobile application, the User can make payments for goods or services by entering payment card information and the cardholder's identification data into a special field. The User can make payments in the Mobile application using the following method:

  • Apple Pay payment system.
The collection and processing of data about the User in this case are exclusively for the purpose of conducting payments, preventing fraud, and complying with other legal requirements.

The User gives consent for the Right Holder and the corresponding payment system or banking institution through which the payment is made to access and collect such Personal Data. The User also agrees with the privacy policy of the respective payment system or banking institution.


Use of Cookie Files
The mobile application uses the following Cookies:
(1) Technical (functional) Cookies, which are necessary for traffic control and data transmission, user identification, and providing user access to the content of the mobile application. Without these Cookies, the functionality of the mobile application is limited. They are also used to prevent the delivery of recommendations that do not align with the user's interests.
(2) Statistical Cookies, which are necessary for tracking the frequency of user visits to the site, identifying how the user uses the mobile application, and determining the type of content that is popular or interesting to the user.
(3) Third-party Cookies, which are set by third parties with the user's permission. These Cookies are intended for conducting statistical research on user behavior on the Internet and/or delivering personalized advertising or marketing materials to the user and/or providing goods or services.
The user has the right to disable Cookies in the mobile application at any time by changing specific settings on their tablet.


4. PURPOSES OF PERSONAL DATA COLLECTION AND PROCESSING

Defining the Purposes of Processing
The collection and processing of Personal Data are carried out for the following purposes:
  1. To analyze User behavior and identify User preferences for specific types of content.
  2. To ensure the smooth and correct operation of the Mobile application, improve its functionality, enhance the content, internal architecture, and features of the Mobile application.
  3. To identify the User.
  4. To comply with legal requirements.
  5. To track orders/purchases made by the User through the Mobile application.
  6. For technical support of the Mobile application, detecting and resolving issues related to its functioning.
  7. To fulfill other obligations of the Right Holder towards the User.
  8. For any other purposes, subject to obtaining separate consent from the User.

The processing of Personal Data is based on the following principles:
  1. Legitimacy of the purposes and methods of processing.
  2. Fairness.
  3. Consistency of the processing purposes with those defined and declared during the collection of such Personal Data.
  4. Correspondence of the volume and nature of the processed Personal Data with the declared purposes of their processing.

Conditions for Personal Data Processing
The processing of Personal Data is carried out in the following cases:
  1. Upon obtaining consent from the User.
  2. When the Right Holder achieves the purposes provided by an international treaty or Law.
In the case of anonymization of Personal Data, which prevents the direct or indirect identification of the User, subsequent use and disclosure of such data to third parties are permissible, and the rules of this Policy no longer apply to them.

The Right Holder takes all necessary measures to protect the confidentiality of the obtained Personal Data, except in cases where the User has made such data publicly available.

The processing of Personal Data is carried out using automation means and without the use of such automation means.



5. ACCESS OF THIRD PARTIES TO PERSONAL DATA

Use of Analytical Platforms
The Right Holder utilizes the Apple Analytics analytical platform for the following purposes:
  1. Tracking User visits frequency to the Mobile application.
  2. Monitoring User's usage patterns and preferences regarding the Mobile application and/or its content.
  3. Identifying popular types of content among Users.
  4. Determining the User's location. The User also gives their consent to the Right Holder for the use of information obtained about them from Apple Analytics.
For these specified purposes, the Apple Analytics analytical platform may collect data related to IP address, geolocation, User behavior, as well as their preferences and interests regarding specific content.

The Apple Analytics analytical platform accesses Personal Data to provide the Right Holder with an understanding of the Mobile application's effectiveness, the popularity of specific content, the effectiveness of certain advertisements within it, and for the purposes of developing and/or improving the Right Holder's existing marketing strategy.
By installing the Mobile application, the User agrees to the Privacy Policy of Apple Analytics and automatic installation of corresponding Cookie Files on their device.

Disclosure of Personal Data to Third Parties
The Right Holder has the right to disclose Personal Data to the following entities:
  1. Its affiliated companies, branches, and representative offices, located both within the territory of the Russian Federation and in other countries.
  2. Successors of the Right Holder resulting from its liquidation, reorganization, or bankruptcy, who have obtained exclusive ownership rights to the Mobile application.
  3. Payment service providers or banking (financial) institutions for the purpose of processing User transactions through the Mobile application.
  4. Third parties solely for the purpose of providing the User with access to specific content.
  5. Third parties when the User has given consent for the disclosure, transfer, or processing of their Personal Data, as well as in other cases directly stipulated by the Law or this Policy.

The Right Holder discloses Personal Data only if it is confident that third parties will comply with the conditions of this Policy and take similar measures to protect the confidentiality of Personal Data, as the Right Holder does. Additionally, such disclosure requires prior consent from the User and/or is permissible based on the Law.


6. ADVERTISEMENT PLACEMENT
Advertisement in the Mobile Application
The Right Holder does not place any advertisements in the Mobile Application.


7. COMPLAINTS AND REQUESTS TO THE RIGHT HOLDER

Request for the Cessation of Personal Data Processing
Each User has the right to object to the processing and/or storage of their Personal Data by the Right Holder. Such objection can be expressed as follows:

Please submit the corresponding request to the following email address: sayhi@pie.studio

Request for Information about Personal Data
If the User has any questions related to the application or usage of this Policy, the procedures and/or methods of Personal Data processing, they can make such inquiries as follows:

Please submit the corresponding request to the following email address: sayhi@pie.studio

Modification (Update, Amendment, Correction), or Deletion of Personal Data
The User has the right to independently modify or delete their Personal Data at any time, except in cases where such modifications or deletions may lead to:

  1. Violation of the rules of this Policy, or
  2. Violation of the Law, or
  3. The nature of such Personal Data serves as evidence in any legal proceedings between the Right Holder and the User.
The User can modify or delete their Personal Data in the following manner:
Please uninstall the application.


8. STORAGE DURATION AND PROCEDURE OF PERSONAL DATA
Storage is carried out by third parties on behalf of the Right Holder. The User consents to the storage of their Personal Data by third parties on behalf of the Right Holder, provided that such third parties maintain the confidentiality of the obtained Personal Data. The storage functions are entrusted to the following entity: OOO "Pie Studio" (hereinafter referred to as the "Data Custodian"). As the entity responsible for storing Personal Data is located within the territory of the Russian Federation and the European Union/European Economic Area, the User hereby gives consent to the cross-border transfer of their Personal Data and their storage outside the Russian Federation. The User is hereby notified that countries to which the cross-border transfer of Personal Data is made may have an insufficient level of data privacy protection. However, the Right Holder takes all necessary measures to prevent the disclosure of such data.
The storage is carried out for the entire period necessary to achieve the stated purposes of Personal Data processing. The Right Holder undertakes to immediately destroy or de-identify the data upon achieving the purposes of Personal Data processing.


9. ACCESS OF MINORS TO THE MOBILE APPLICATION
Users within the territory of the Russian Federation:
The Mobile Application may be used by individuals under the age of 18. As the Mobile Application does not collect personal data from Users, consent for the processing of Personal Data of minor Users is not required. If a minor User cannot provide consent for the processing of their Personal Data from their legal representative (guardian), then such User must immediately cease using the Mobile Application.
Users within the territory of the European Union:
The Mobile Application and/or its content are intended for individuals under the age of 16. As the Mobile Application does not collect personal data from Users, consent for the processing of Personal Data from Users under the age of 16 is not required.


10. PERSONAL DATA PROTECTION PROCEDURES
Защита конфиденциальности Персональных данных является первостепенной и важной задачей для Правообладателя. Правообладатель придерживается всех требуемых международных стандартов, правил и рекомендаций по защите Персональных данных.
Правообладатель внедрил ряд технических и организационных методов, направленных на защиту Персональных данных от разглашения или несанкционированного доступа к ним третьих лиц.


11. USERS WITHIN THE EUROPEAN UNION

General Provisions:
As the Mobile Application is accessible to users from the European Union, the Right Holder commits to comply with the provisions of GDPR (General Data Protection Regulation) additionally.
The Controller, as defined in this Policy, is the Right Holder. The Processor, as defined in this Policy, is the Data Custodian according to Article 8 of the Policy.
The Right Holder retains Personal Data for a reasonable period necessary to achieve the processing purposes, but not less than the period prescribed by the local legislation of the European Union member state where the Mobile Application is available, for storing specific types of Personal Data. Upon the expiry of the storage period, the Right Holder undertakes to promptly destroy or de-identify such data.

Users' Rights Regarding Personal Data Protection:
According to Chapter 3 of GDPR, users within the European Union have the following rights regarding the protection of Personal Data:
  • The right to be informed about their Personal Data ("the right to be informed"); and
  • The right to access their Personal Data ("the right of access"); and
  • The right to rectify their Personal Data ("the right to rectification"); and
  • The right to erase their Personal Data ("the right to erasure"); and
  • The right to restrict the processing of their Personal Data ("the right to restrict processing"); and
  • The right to data portability, enabling the transfer of Personal Data to third parties ("the right to data portability"); and
  • The right to object to the processing of their Personal Data ("the right to object").

12. FINAL PROVISIONS

Accessibility of the Policy Text for Review:
Users can access the terms of this Policy through the following link: https://calculator.pie.studio/privacy-policy.

This Policy may be translated into foreign languages for those Users accessing the Mobile Application outside the territory of the Russian Federation. In case of any discrepancies between the original text (Russian language) and its translation, the language of the original text shall prevail.
This edition of the Policy is effective from July 20, 2023.


Amendments and Additions to the Policy:
This Policy may be amended from time to time. The Right Holder shall not be held responsible to the User for changing the terms of this Policy without the User's permission and/or consent.
The User agrees to regularly review the provisions of this Policy to be aware of any possible changes or additions.

Applicable Legislation:
This Policy is developed in accordance with the current legislation on personal data protection of the Russian Federation, specifically with the provisions of Federal Law No. 152-FZ "On Personal Data" dated July 27, 2006 (with all amendments and additions), Federal Law No. 242-FZ "On Amending Certain Legislative Acts of the Russian Federation to Clarify the Procedure for Processing Personal Data in Information and Telecommunication Networks" dated July 21, 2014 (with all amendments and additions), as well as the provisions of the General Data Protection Regulation (GDPR) of April 27, 2016.

Disclosure Risk:
Regardless of the security measures implemented by the Right Holder to protect the confidentiality of obtained personal data, the User is duly informed that any transmission of Personal Data over the Internet cannot be guaranteed as entirely secure. Therefore, the User undertakes such transmission at their own risk.