SMS Services LLC Privacy Policy
1. Who we are and what this document is about
1.1. We are SMS Services Limited Liability Company, a Russian Federation company, located at Lodeynopolskaya street, building 5-A, Saint-Petersburg, 197110, Russia (“SMS services”). We can be addressed via e-mail support@smsservisy.ru.
1.2. We developed this document to provide you with essential information in relation to the personal data we collect using the mobile application. Hereinafter we will refer such mobile application as “Application” for short, meaning the mobile application in which this privacy police is placed.
1.3. Purpose of this document is to explain what kind of your personal data we use, how exactly do we use it, for what reasons do we need your personal data and what rights do you have concerning your personal data.
1.4. Here are the cornerstones on how SMS services views data privacy:
· collect only a minimum amount of information, only what is needed to run Application or protect our legal interest;
· do not monetize your data;
· only use it as it is necessary for the purposes of providing services to you and earning money on Application we developed, particularly to make payments to us or identification of users for advertisement statics; more details about legal ground and ways we use your personal data you can find in section 2 of this document;
· be as transparent as practically possible on how we process your personal data;
· collect any data only on a lawful grounds.
2. Voluntary provided information
2.1. Some of information you can provide to us is not necessary for providing services or to protect our legitimate interests. Such information is information about your age, your location and your gender. You are not required to provide such information and once provided you can delete or edit such information any time. But, once provided, we believe that you ordered to provide you with more personalized services, particularly to recommend you some books, which might be of your interest. That’s why in that case we will consider that processing of such information is necessary to fulfill our obligations.
2.2. You can edit or delete such voluntary provided information anytime – all you have to do is to modify or delete such information in Application. Such information will be updated (deleted if necessary) on our servers within 48 hours (unless some problems with internet-connection between your device and our server occurred).
3. Why do we need your information and what information exactly we collect
3.1. We use your personal and non-personal information, both individually and combined together, in the following ways:
|
Information Collected |
When Data will be collected |
Purpose or Collection of Data |
Legal Basis for processing of Data |
|
e-mail address, password and/or information about your facebook or vkontakte accounts
|
During registration process and each time you login within Application |
Your identification within Application, including for restoring or transferring of your purchasing history on a new devices |
Processing is necessary for the performance of the contract (our obligations in accordance with the terms of service, end-user license agreement or any other similar documents placed in Application) |
|
Purchase history, i.e. date, time, amount of payment, information identifying you in the payment system, without exact payment details. |
Each time you make payment with usage of payment instruments of third parties. |
Accounting of remuneration, verification of calculation with payment system of third parties, providing to you purchased books and restoration of previously purchased documents. |
Processing is necessary for the performance of the contract (our obligations in accordance with the terms of service, end-user license agreement or any other similar documents placed in Application) |
|
Your phone number and quantity of request made with usage of Application. |
Such data shall be collected when payment made within the Application by sending SMS message on the service number of your operator. |
Calculation of our remuneration from mobile network operators and solving any claims linked with such remuneration. |
We consider it is our legitimate interest to collect such data solely for the purpose of collecting our payment you made within Application and necessary for the establishment, exercise or defence of legal claims of mobile network operators or yours; |
|
Unique identification number of your mobile device (UIT) |
Each time your phone sends request to our server for the purposes of accessing of some features within our applications (including requests to view advertisement within Application) |
(i) Your identification before your registration within application (without ability to restore or transfer your purchase history) (ii) Calculation of our remuneration for services provided to you or to the third parties (including advertisement networks) and solving any claims linked with such remuneration. |
We consider it is our legitimate interest to collect such data solely for the purpose of collecting and verifying remuneration for advertisement services we provide to third parties through Application; and necessary for the establishment, exercise or defence of legal claims of advertisement networks. |
|
Data you voluntary provide to us (such as a randomly chosen nickname, age, city gender, in some cases additional info might be provided) |
During the registration process or any time you update such information within application. |
Such information will be made publically available on-line in hi-score tables or will be made available to other users of application for the purposes of their counteraction within application with you or comparison of users results with your results. |
Processing is necessary for the performance of the contract (our obligations in accordance with the terms of service, end-user license agreement or any other similar documents placed in Application) |
|
Statistical data not identifying you exactly, such as your region, country, city, town (without information about your exact location). |
When you install the Application, and when you use the Application. |
We use this data to verify that our Application distributed on the correct territory and to understand the amount of remuneration we have to pay to the authors (other holders of copyrights) of the Applications you use and to the distributors of our Applications or other our partners. |
We consider it is our legitimate interest to collect such data solely for the purpose of proper fulfilment of our obligations before holders of copyrights and distributors of Application and necessary for the establishment, exercise or defence of legal claims of copyright holders or distributors of Application. |
|
Information you provide to our support team. |
When you address our support team. |
We use this information in order to verify your identity and to fulfil your support request; to provide you support, including to help identify and troubleshoot problems with your account or application; to survey your opinions through surveys or questionnaires; communicate with you and respond to your specific requests or questions; and manage and send you confirmations and important information about your account, products, purchases, subscriptions, and warranties. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service. |
Processing is necessary for the performance of the contract with you (our obligations in accordance with the terms of service, end-user license agreement or any other similar documents placed in Application) |
4. Third parties. Processor.
4.1. To maintain the work of Application we use the servers and software of a data processor – BEFREE Ltd., a Russian Federation company, located at Lodeynopolskaya street, building 5-A, office 610, Saint-Petersburg, 197110, Russia (hereafter – “Processor”). All data from the Application is transferred directly to the server of Processor via web-address https://mmi.ru/. We confirm that we monitor all of the usage of the data by Processor, its security measures and do all necessary to ensure that your personal information shall be processed and protected by Processor in a manner set out in this Privacy Policy.
4.2. In some cases, we need to pass some of your information to third parties other than Processor. In all such cases, we making all necessary to pass as minimum information as possible. Also in some cases, we collecting your personal information from third parties. For more understanding of how we collect and who can receive your personal data we placed the conform information into the table below:
|
Information Collected |
Source of personal data |
Recipients of |
Legal Basis |
|
e-mail address, password and/or information about your facebook or vkontakte accounts
|
From you directly |
None |
Processing is necessary for the performance of the contract (our obligations in accordance with the terms of service, end-user license agreement or any other similar documents placed in Application) |
|
Purchase history, i.e. date, time, amount of payment, information identifying you in the payment system, without exact payment details. |
Payment systems |
none |
Processing is necessary for the performance of the contract (our obligations in accordance with the terms of service, end-user license agreement or any other similar documents placed in Application) |
|
Your phone number and quantity of request made with usage of application |
Network Operator |
None |
We consider it is our legitimate interest to collect such data solely for the purpose of collecting our payment you made within Application and necessary for the establishment, exercise or defence of legal claims of mobile network operators or yours; |
|
Unique identification number of your mobile device (UIT) |
Directly from your mobile phone |
- mobile network operators and aggregators; - advertisement network; |
We consider it is our legitimate interest to collect such data solely for the purpose of collecting and verifying remuneration for advertisement services we provide to third parties through Application; and necessary for the establishment, exercise or defence of legal claims of advertisement networks. |
|
Data you voluntary provide to us (such as a randomly chosen nickname, age, city gender, in some cases additional info might be provided) |
From you directly |
None |
Processing is necessary for the performance of the contract (our obligations in accordance with the terms of service, end-user license agreement or any other similar documents placed in Application) |
|
Statistical data not identifying you exactly, such as your region, country, city, town (without information about your exact location). |
Mobile network operator; some information is received from you mobile phone (if you allow such actions in your settings) |
Distributors of mobile application, holders of copyrights |
We consider it is our legitimate interest to collect such data solely for the purpose of proper fulfilment of our obligations before holders of copyrights and distributors of Application and necessary for the establishment, exercise or defence of legal claims of copyright holders or distributors of Application. |
|
Information you provide to our support team. |
From you directly |
None |
Processing is necessary for the performance of the contract with you (our obligations in accordance with the terms of service, end-user license agreement or any other similar documents placed in Application) |
4.3. Application contains some elements developed by third parties, such as block responsible for advertisement within the Application. For short, we will refer such blocks developed by third parties as Third Parties SDK. To our best knowledge, such third parties through Third Parties SDK collect and process personal data on a legal basis and with responsible approach to personal data protection. Moreover, in any case it is well known companies with respected reputation and we always discuss with them necessity to process your personal data on a legal basis. However, we do not make decisions about amount of processing information by such third parties and purposes of such processing and not entirely sure what information they process. Because of that, we do not include information about exactly actions and purposes of personal data collection of such third parties.
In table below you can find information about such third parties and direct links or texts of privacy policies developed by such third parties:
|
Processer |
Purposes of Third Party SDK |
Privacy policy of such third party |
|
Unity Technologies |
- Basic kit for development of software on iOS, Android and similar platforms; - Advertisement block |
https://unity3d.com/ru/legal/privacy-policy https://unity3d.com/ru/legal/cookie-policy#cookies
|
|
Google AdWords
|
- Advertisement block |
https://policies.google.com/technologies/ads
|
|
Google AdMob |
- Advertisement block |
https://policies.google.com/technologies/partner-sites?hl=en-GB
|
4.4. We use or may use the Ad Mob (mobile application advertising platform created by Google) advertising services in some/all of our Mobile applications where Google may collect personal or non-personal data through its own embedded technology. Google shall collect personal data directly and we shall not have any access to such information.
To our best knowledge, before Google begin to show you the advertisement, Google will propose you to make the choice whether you want to see personalized (based on previously collected or historical data to determine or influence ad selection, including previous search queries, activity, demographic information, or location; specifically, this would include, for example: demographic targeting, interest category targeting, remarketing, targeting) or non-personalized advertisement (that are not based on your past behaviour).
In order to deliver ads to you, Google may place or recognize an unique cookie or similar technology for non-identifiable information. Non-personalized ads do not use cookies or mobile ad identifiers for ad targeting, they do still use cookies or mobile ad identifiers for frequency capping, aggregated ad reporting, and to combat fraud and abuse.
Please, note that Ad Mob operates under its own privacy policy. To view AdMob’s Privacy Policy click here: https://policies.google.com/technologies/partner-sites?hl=en-GB
You can use Ads Settings or settings of your Google Account, to manage the Google ads that you see and opt out of Ads Personalisation. Even if you opt out of Ads Personalisation, Google may still show ads based on statistical information not identifying you exactly, such as your region, country, city, town (without information about your exact location).
5. Where We Hold Your Information
Personal Information we collect may be stored and processed for the purposes set out in this Privacy Policy in any country in which we operate and your personal information may be transferred, stored and processed by recipients in various countries around the world where our servers are located and our databases are operated. We do all necessary to make sure all recipients or your personal data understand the necessity to process personal data only on a legal basis taking into account any and all applicable legislation.
We may transfer and maintain your Data on our servers or databases some of your personal information outside the European Economic Area (EEA).
Specifically some of our servers located in Saint-Petersburg, Russia. We must inform you that European commission did not make a decision that Russia provides adequacy measures for personal data protection.
6. How We Protect Your Personal Information
We employ a variety of measures to safeguard the collection, transmission and storage of the information we collect. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Even so, no security measure is 100% perfect. Therefore, while we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use or access to your information under our control.
7. Your Choices About Collection and Use of Your Information
7.1. Among other, you have the following rights in relation to your personal information:
· Right to access your personal information: at any time, you can ask us about what your personal data do we have, what do we do with them, why do we process them, who we have told about you, etc. You also can ask us to give you a copy of the personal data processing, if you like. To request access, send us an email at support@smsservisy.ru headed "Subject Access Request";
· Right to rectify your personal information: at any time, you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or there is no need to proceed it anymore;
· Right to erasure: at any time, you can ask us to delete all the personal data that we have about you – it is your right to be forgotten, like if we have never met before. We will also deactivate your account. If you do so, you will no longer have access to the Applications associated with your account;
· Right to restrict the use of your personal information: for example, if you think, that your personal data is not accurate and we need time to check it, we can make a pause in processing of your personal data enough to clarify, is it so or not. If you do not request deletion, then it is possible to request the reactivation of your account if it was accidentally or wrongfully deactivated. Please, note, that we cannot restore permanently deleted accounts;
· Right to object to processing of your personal information: at any time, you can tell us to stop and we will no longer process your personal data, but we can still keep them if there is legitimate ground for that;
· Right to data portability (in certain specific circumstances): if you wish, you can ask us to download (export) all personal data that we have in the format acceptable to give it to someone else or ask us to give them your data directly;
· Right not to be subject to an automated decision: if we process your personal data automatically and we take some decisions according to it, and it affects you in any serious way, you can express your point of view and contest such decision. But in reality, we do not do this;
· Right to lodge a complaint with a supervisory authority: you always can complain about us and about the way, we are processing your personal data.
Before we process any request, we may ask you for certain information in order to verify your identity. Where permitted by local law, we may reject requests that are unreasonable or impractical.
We will respond to your requests in a reasonable timeframe.
7.2. Please, note that there are extra-options for opt-out for the third parties whose advertising and analyzation systems we use in our products: for example, at https://www.appsflyer.com/optout you can using your device identifier(s) remove all usage tracking from apps that use AppsFlyer Services and they will stop tracking data for that device going forward. The services will stop across all applications, not only ours.
You may also opt-out of interest-based advertisements by adjusting the settings on your mobile device. For iOS mobile devices, go to “Settings” from the device’s home screen; scroll down to “Privacy”; select “Advertising”; and turn on “Limit Ad Tracking.” For Android mobile devices, go to “Google Settings” on the device; select “Ads”; and check the box labeled “Opt Out of Interest-Based Ads.”
To learn more about targeted or interest based advertising and to opt out of certain targeting program, you may also click below for the Network Advertising Initiative (“NAI”) and Digital Advertising Alliance (“DAA”) opt-outs:
http://www.networkadvertising.org/choices
http://www.aboutads.info/choices/.
We do not control these third-party provided opt-out processes and are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.
8. Retention Periods
We may keep information that how do we think we may need to resolve any disputes, enforce our agreements with you and provide you possibility to use our products, protect our or your legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our products.
Otherwise, we will retain information about you for as long as reasonably necessary to provide you products, create and improve our products, comply with the law, and to run our business.
9. Children
Protecting children's privacy is extremely important. Our products are intended for general audiences and do not knowingly collect or process any personal information from or with respect to children under 16. Through our products, children will be able to receive local in-app notifications, which do not collect any personal information.
We will: (1) not ask children to input their personal information, (2) collect certain information for limited purposes only (consistent with applicable law), (3) block or restrict the child from accessing relevant services, if applicable.
If we make any material changes to how we use, collect, or share your child's personal information, we will notify you by in-application notice in order to obtain verifiable parental consent for the new uses of your child's personal information.
10. Changes to Our Policy
We may update this policy from time to time. We will notify you of material changes via a notice in Application or via any other applicable communication channels before such changes go into effect. Your continued use of our products means you accept the changes.
11. Contact Us
If you have a complaint or question about this policy, if you would like to make a request concerning your personal data, withdraw your consent, you may at any time contact us at support@smsservisy.ru. We will aim to respond to you within maximum 10 working days from receipt of request.
All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.