Privacy Policy

Revision 12/2016-2 of December 3, 2016

The Privacy Policy (hereinafter, the "Policy") is an offer addressed to the general public and presented in this document.

This Privacy Policy defines the purposes of collection, storage and processing of personal information, ways of protecting it and transferring it to third parties.

The Privacy Policy applies to any information which IntelliCode Rus LLC (hereinafter, the "Company") may obtain with regard to a User when the latter uses any websites, services, and (or) software (hereinafter, "Services") and during the Company's execution of any agreements and contracts with the User.

Any user shall be regarded as such from the moment of registration or performance of other actions associated with the use of the Services or Service capabilities and until the moment the obligations of the parties are terminated on grounds provided for by Russian law.

1. Personal data

1.1. Within the frames of this Privacy Policy, personal data shall mean, without limitation:

1.1.1. Personal information (including surname, first name, patronymic, date of birth, address, contact telephone, e-mail) provided by the User voluntarily and knowingly when creating an account and (or) when using the Services, as may be necessary to execute the user agreement under which the registered user is a beneficiary, and for the purpose of the User's access to the Services.

1.1.2. Data that are automatically transferred when using the Company Services through software installed on the User's device from which the Services are accessed, including IP address, cookies, and information on the User's software and hardware. The Company hereby guarantees that as a result of the User using the Services it will not receive access to data (including personal data) which constitute the User's OS content.

1.1.3. Date and time of access to Services and other similar information.

1.1.4. Other information about the User whose processing is provided for by the terms of use of individual Company Services or current law.

1.2. This Privacy Policy shall only apply to information processed in the course of the use of Company Services.

2. General Terms

2.1. When processing Users' personal data, the Company shall comply with Federal Law of the Russian Federation No. 152-FZ dated July 27, 2006 "On Personal Data".

2.2. The procedure for the processing of Users' personal data, inter alia, for the purpose of ensuring the security of the processing of Users' personal data and safeguarding the Users' rights and interests during processing of their personal data, shall be governed by this Privacy Policy.

2.3. Use of Company services signifies the full and unconditional acceptance by the User of this Privacy Policy and its terms and (or) supplements. If the User does not agree to this Policy, he/she must stop using the Company Services immediately.

2.4. The User agrees that nothing in the Privacy Policy may be construed as establishing any other relations between the User and the Company which is not directly provided for by this Privacy Policy.

2.5. This Privacy Policy shall be governed by laws of the Russian Federation.

2.6. Any and all possible disputes with regard to this Privacy Policy and relations between the User and the Company will be settled according to the rules of Russian law in a court at the Company's location, unless otherwise directly stipulated by Russian law.

2.7. If the court declares any provision in this Privacy Policy to be invalid or unenforceable, that shall not invalidate or make unenforceable other provisions hereof.

2.8. The Company's inaction in the event the User violates the Privacy Policy shall not deprive the Company of the right to take appropriate actions to protect its interests later on, and shall not signify the waiver by the Company of its rights in the event of any similar violations in future.

2.9. The Company reserves the right to amend and (or) supplement this Privacy Policy without any special notice. A new revision of the Privacy Policy shall come into effect after its publication on this page, unless otherwise specified therein. A current revision of the Privacy Policy is always available on this page: https://intellivpn.net/privacy_policy.

2.10. The User shall notify the Company of any unauthorized access to his/her login or password and (or) any violation of the security of his/her personal account on the Services.

2.11. The Company shall not be liable for the User's data which the User provides to external resources and (or) to other third parties after going to them from the Company Services.

3. Limitation of liability for the accuracy of received information

3.1. The Company does not verify the accuracy of information provided by the User during registration and (or) other actions associated with the use of Services and is not able to evaluate the User's legal capacity.

4. Consent to personal data processing

4.1. In accordance with Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data", the User, if an individual, hereby gives his/her consent to the processing of the user's personal data by the Company (including their receipt from the user and (or) from any third parties, subject to the requirements set forth in that law), and confirms that by giving this consent the User acts on his/her own volition and for his/her own benefit.

4.2. The consent is given by the User for the purpose of concluding an agreement, other contracts directly stipulated by this Privacy Policy, or other agreements published on the pages of the website with the Company; Services and their further execution; participation in promotional events; decision-making; or for other actions which give rise to legal consequences in respect of the User or other persons, and applies to surname, first name, patronymic, address and any other information relating to the user's identity which is available or known at any particular moment of time to the Company.

4.3. This consent is given by the User until the expiry of the storage period of the respective information or documents containing such information, as determined in accordance with the Russian Federation law, after which such consent may be cancelled by the User by sending written notice thereof to the Company at least 3 months prior to such cancellation.

4.4. If the User cancels his/her consent to personal data processing, the Company shall be entitled not to stop processing personal data and not to destroy them if the storage life of the documents as established by the Russian Federation law has not expired yet at the moment of cancellation. In this case, such actions for further processing of user's personal data shall be regarded as acceptance.

4.5. This consent is given for any actions with personal data as may be necessary or desirable to achieve the aforesaid goals, including, without limitation, the following: collection, classification, accumulation, storage, clarification (updating, amendment), use, distribution (including transfer), depersonalization, blocking, destruction, or transborder transfer of personal data, as well as any other actions with the user's personal data, subject to the current laws of the Russian Federation.

4.6. The User hereby agrees that in the event it is necessary to provide personal data to a third party for the purpose of achieving the aforesaid goals, the Company shall be entitled to disclose information about the user (including the user's personal data) in the necessary scope and for the aforesaid actions to such third parties and their authorized persons, and to provide such parties with the respective documents containing such information.

4.7. The User hereby agrees that this consent shall be deemed given by the User to any third parties, as mentioned above, subject to the respective amendments and that such third party shall be entitled to process the personal data on the basis of this consent.

5. Collection, storage and processing of personal data

5.1. The Company shall store the User's personal data in accordance with its internal regulations and the current laws of the Russian Federation.

5.2. The Company processes personal data in using automated and non-automated means, with or without using computer equipment.

5.3. The Company processes personal data using the following key methods (without limitation): storage, recording on electronic media and their storage, compilation of lists.

5.4. The databases containing the Personal Data of Russian citizens shall be located in the territory of the Russian Federation.

5.5. The Company shall collect and store only those personal data which are necessary to provide the Services and (or) to execute agreements and contracts with the User, and data which is subject to mandatory storage for a certain period of time, as provided for by Russian law.

5.6. The User's personal data shall be processed by the Company, including, without limitation, in the following cases:

5.6.1. Identifying the User within the framework of the Services and agreements and contracts with the Company;

5.6.2. Provision of personalized Services to the User and execution of agreements and contracts;

5.6.3. Statistical and other research on the basis of depersonalized data;

5.6.4. Improvement of the quality and user friendliness of the Services and development of new Services.

5.6.5. Communications with the User, including sending of notifications, requests and information concerning the use of the Services, as well as processing of requests and applications from the User.

5.7. By using the Company's Services, any User expresses his/her unconditional consent to the use of personal data in a generalized, depersonalized form and to their communication to any number of unspecified persons. In this case, the Company guarantees that it will be impossible to identify a specific User on the basis of such data.

6. Transfer of personal data to third parties

6.1. The Company shall be entitled to transfer the User's personal data to third parties in the following cases:

6.1.1. Such transfer is provided for by Russian or other applicable laws within the framework of the procedure established by law;

6.1.2. Such transfer shall be performed in the course of the sale or other handover of the business (in full or in part) or universal succession (e.g., reorganization),in which case the acquirer/legal successor inherits all obligations to comply with the terms of this Policy as applicable to the personal data it receives;

6.1.3. Depersonalized statistical and analytical data received as a result of personal data processing which results in the deletion of data (including e-mail addresses) which makes it possible to identify the User may be transferred to a third party for the purpose of research, performance of works or provision of services, as may be ordered by the Company;

6.1.4. For the purpose of ensuring the ability to protect the rights and lawful interests of the Company or third parties in cases where the User violates the User Agreement for the Company's services, this Policy, or other documents containing the terms of use for specific Services;

6.1.5. The User has given his/her consent for such actions during registration and (or) performance of other actions associated with the use of the Company's Services.

6.1.6. Transfer for the purpose of conclusion by the Company of an agreement or other contracts directly provided for by this Privacy Policy or other agreements published on the pages of the website or Services, and their subsequent execution.

7. Amendment and deletion of personal data

7.1. The User may change his/her personal data or part thereof at any time by using the option for editing personal data in the personal account of the respective Service.

7.2. The User may delete his/her personal data by using the corresponding option in the personal account of the respective Service. The User hereby agrees that deletion of the account may lead to the inability to use the Services.

7.3. The rights set forth in clauses 7.1. and 7.2. hereof may be limited in accordance with legislative requirements. In particular, such limitations may provide for the Company's duty to keep information altered or deleted by the User for a time period established by the Russian Federation law, and to transfer such information in accordance with the procedure established by law to a government authority.

8. Cookies and counters

8.1. Cookies and (or) other similar technologies may be used on the websites of the Company, in the Services, and in e-mails.

8.2. Information collected using cookies and other similar technologies are not considered personal data. Such information shall be of a purely technical nature.

8.3. Cookies may be used to provide personalized Services, for statistical and research purposes, for marketing purposes to study Users' preferences, and to improve Services.

8.4. The User may switch off or delete cookies in the software used to interact with the Company Services, if such capability is provided for.

8.5. The structure of a cookie, its content and technical parameters shall be determined by the Company, and may be changed by the latter unilaterally on its own, without giving prior notice to the User.

8.6. Analytical counters and services, and hit counters used in the Company Services may also use cookies.

9. Personal data protection

9.1. The company will take all necessary and sufficient organizational and technical measures to protect the User's personal data from illegal or accidental access, destruction, alteration, blocking, copying, or distribution, as well as from other illegal actions with such data by third parties.

9.2. The User's personal data shall be kept in confidential, except as otherwise provided for by current Russian or other applicable law.

9.3. The company shall ensure the security of personal data during their processing, inter alia, by means of their encryption and storage in encrypted form.

10. User queries

10.1. All queries associated with this Policy, including queries regarding the use of personal data, can be sent in the following ways:

  • To the e-mail address legal@intellicode.ru;
  • Through the User Support Line of the specific Services;
  • To the mailing address of the Company: 6/1 Akademika Lavrentyeva St., Office 1104, Novosibirsk, Russian Federation, 630090.

11. Final provisions

11.1. All disputes, disagreements or claims of the parties which arise out of or in connection with this Privacy Policy, including those concerning its execution, violation, termination or invalidity, shall be settled through negotiations between the Parties. When it is impossible to settle disagreements out of court, they shall be subject to consideration in court at the Company's location.

11.2. The Parties to this Privacy Policy acknowledge e-mail correspondence and exchange of SMS messages between them as written evidence.

11.3. Any of the Parties to this Privacy Policy shall be entitled to document their own relations at any time by signing the necessary documents in hard copy, including this Privacy Policy and the Consent to Personal Data Processing.