1.1. This policy of processing personal data (hereinafter - Policy) is written according to requirements of the Federal law of the Russian Federation from 27.07.2006. №152 "About Personal Data" (hereinafter - the Law about Personal Data) and defines the order of processing of personal data and measures on providing security of personal data, undertaken by IE Alexander Gordeev (hereinafter - Operator).
1.2. Operator sets its main purpose and condition of its activity to observance of rights and freedoms of a man and citizen during processing of his personal data, including protection of rights to privacy, personal and family secrets.
1.3. This Policy applies to all information that the Operator can obtain about issa application users, posted in the official distribution source at the following address:
2.1. Automated processing of personal data - processing of personal data by means of computer technology.
2.2. Blocking of personal data - temporary termination of personal data processing (except when processing is necessary to clarify personal data).
2.3. Application means an aggregate of graphic and informational materials, as well as computer programs and databases, making them available on the Internet at:
2.4. issa Services - technological services provided by Operator to Users.
2.5. Information system of personal data - a set of personal data contained in databases of personal data, and providing their processing of information technology and technical means.
2.6. Depersonalization of personal data - actions, as a result of which it is impossible to determine without the use of additional information the personal data related to a certain User or other subject of personal data.
2.7. Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, removal, destruction of personal data.
2.8. Operator - a state body, municipal authority, legal entity or individual, independently or together with other people, which organizes and (or) carries out processing of personal data, as well as defining the purpose of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
2.9. Personal data is any information related directly or indirectly to a certain or defined User of the Application.
2.10. Personal data permitted by the subject of personal data for dissemination - personal data, access to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for dissemination in the manner prescribed by the Personal Data Law (hereinafter - personal data permitted for dissemination).
2.11. User means any User of the Application.
2.12. Subject of personal data - natural person, which is possible to define via collected personal data
2.13. Provision of personal data - any action aimed at disclosure of personal data to a certain person or a certain circle of persons.
2.14. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data to an unlimited circle of persons, including publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data by any other means.
2.15. Transboundary transfer of personal data - transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or a foreign legal entity.
2.16. Destruction of personal data - any action, in the result of which personal data is destroyed irretrievably with the impossibility of further restoration of the content of personal data in the information system of personal data and(or) destruction of tangible media personal data.
3.1. The Operator has the right to:
3.1.1. receive from the subject of personal data reliable information and/or documents containing personal data;
3.1.2. in case of revocation of the personal data subject's consent for processing of personal data, the operator has the right to continue processing of personal data without the consent of the personal data subject on the grounds specified in the Personal Data Law;
3.1.3. independently determine the composition and list of measures, necessary and sufficient to ensure fulfillment of obligations provided by the Personal Data Law and regulations adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.
3.2. The operator is obliged to:
3.2.1. provide the subject of personal data at his/her request with information relating to the processing of his/her personal data;
3.2.2. organize personal data processing in the manner prescribed by the applicable laws of the Russian Federation;
3.2.3. to respond to requests and inquiries of subjects of personal data and their legal representatives, in accordance with the requirements of the Law on personal data;
3.2.4. inform the authorized body for protection of the rights of subjects of personal data, at the request of such body, the necessary information within 30 days from the date of receipt of such request;
3.2.5. publish or otherwise ensure unrestricted access to this Policy on personal data processing;
3.2.6. take legal, organizational and technical measures to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other unlawful acts in relation to personal data;
3.2.7. cease the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Law;
3.2.8. not to use technological methods to bypass the limited data transfer mode installed on the User's device;
3.2.9. perform other duties prescribed by the Personal Data Law.
4.1. The Subjects of personal data have the right to:
4.1.1. to receive information relating to the processing of his personal data, except in cases provided for by federal laws. Information is provided to the subject of the personal data operator in an accessible form, and it must not contain personal data relating to other subjects of personal data, except in cases where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
4.1.2. to require the operator to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as to take statutory measures to protect their rights;
4.1.3. to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
4.1.4. to withdraw consent to the processing of personal data;
4.1.5. to complain to the authorized body for protection of the rights of subjects of personal data or in court against unlawful acts or omissions of the Operator in the processing of his personal data;
4.1.6. exercise other rights provided by the legislation of the Russian Federation.
4.2. The Subjects of personal data are obliged to:
4.2.1. provide the Operator with reliable data about themselves;
4.2.2. inform the Operator of any clarification (updating, modification) of their personal data.
4.3. Persons who provide the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, shall be liable in accordance with the laws of the Russian Federation.
5.1. Name, Last Name, Email, Image - in case the User provides us with this data (for example by contacting our support).
5.2. The Application also collects and processes anonymized data about Users with the help of Google Analytics Internet statistics services.
5.3. We may process some impersonal User information if this is allowed in the User Device settings (for example, when the User has allowed the Application to track its GAiD or iDFA ad identifier).
5.4. The above-mentioned data hereinafter in the text of the Policy are combined with the general concept of Personal Data.
5.5. The Operator does not process special categories of personal data related to race, ethnicity, political views, religious or philosophical beliefs, intimate life.
5.6. Processing of personal data allowed for dissemination among special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is allowed if the prohibitions and conditions stipulated by Article 10.1 of the Personal Data Law are observed.
5.7. The User's consent to the processing of personal data permitted to be disseminated shall be executed separately from other consents to the processing of their personal data. The conditions stipulated, in particular, by Article 10.1 of the Personal Data Law shall be observed. Requirements for the content of such consent are established by the authorized agency for the protection of personal data subjects' rights.
5.8. The User shall provide his/her consent to the processing of personal data permitted for dissemination directly to the Operator.
5.9. Within three business days of receiving the above consent from the User, the Operator shall publish information about the processing conditions, prohibitions and conditions on the processing of personal data permitted for distribution to an unlimited number of persons.
5.10. Transfer (distribution, provision, access) of personal data, authorized by the subject of personal data for distribution, must be terminated at any time at the request of the subject of personal data. This requirement should include the surname, first name, patronymic (if any), contact information (phone number, e-mail or mailing address) of the subject of personal data, as well as a list of personal data, processing which is to be terminated. The personal data specified in this request may only be processed by the operator to whom it is sent.
5.11. Consent to the processing of personal data allowed for dissemination shall cease upon receipt by the Operator of the requirement referred to in paragraph 5.10 of this Policy with respect to the processing of personal data.
6.1. The processing of personal data shall be carried out on a lawful and fair basis.
6.2. Processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data which is incompatible with the purposes for which the data is collected shall not be permitted.
6.3. Databases containing personal data that are processed for purposes incompatible with each other shall not be combined.
6.4. Only personal data that meets the purposes for which it is processed may be processed.
6.5. The content and scope of processed personal data shall comply with the stated processing purposes. Processed personal data shall not be excessive in relation to the stated processing purposes.
6.6. When processing personal data, the accuracy of personal data, its sufficiency, and, if necessary, relevance in relation to the purpose of personal data processing shall be ensured. The operator shall take necessary measures and/or ensure that they are taken to remove or clarify incomplete or inaccurate data.
6.7. Storage of personal data shall be in a form that allows to identify the subject of personal data, no longer than required by the purposes of processing of personal data, unless the period of storage of personal data is established by federal law, the contract, which party, beneficiary or guarantor under which the subject of personal data is. Processed personal data shall be destroyed or depersonalized upon attainment of processing objectives or if it is no longer necessary to attain such objectives, unless otherwise provided for by federal law.
7.1. The purpose of processing of personal data of the User:
7.1.1. Providing User access to the Services, information and/or materials contained in the App.
7.1.2. Improvement, modification, performance improvement, and personalization of the Services for Users;
7.1.3. Providing technical support to Users of Applications.
7.1.4. For other legitimate purposes and legitimate interest.
7.2. User's anonymized data collected through the Internet statistics services serves to collect information about the Users' actions in the Application, to improve the quality of the Application and its content.
8.1. The legal basis for the processing of personal data by the Operator are:
8.1.1. contracts concluded between the operator and the subject of personal data;
8.1.2. federal laws, other regulations in the field of personal data protection;
8.1.3. users' consent to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only in case of filling them in and/or sending them by the User through the special forms located in the Application or sent to the Operator via email. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
8.3. The subject of personal data independently decides to provide his personal data and gives consent freely, of his own free will and in his own interest.
9.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of their personal data.
9.2. Processing of personal data is necessary to achieve the objectives envisaged by an international treaty of the Russian Federation or the law, to perform the functions, powers and duties imposed on the operator by the legislation of the Russian Federation.
9.3. Processing of personal data shall be necessary for administration of justice, execution of a judicial act, act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
9.4. Processing of personal data shall be necessary for execution of an agreement, a party to which or a beneficiary or a guarantor under which the subject of personal data is a party, as well as for conclusion of an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or a guarantor.
9.5. Processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially important goals, provided that the rights and freedoms of the subject of personal data are not violated.
9.6. Processing of personal data, access to which is provided to the unlimited range of persons by the subject of personal data or at his/her request (hereinafter - publicly available personal data).
9.7. Personal data subject to publication or compulsory disclosure in accordance with the federal law shall be processed.
10.1. Safety of personal data, which is processed by the Operator, is ensured by implementing legal, organizational and technical measures, necessary for fulfilling in full the requirements of applicable legislation in the field of protection of personal data.
10.2. The operator provides safety of personal data and takes all possible measures which exclude access to personal data by unauthorized persons.
10.3. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of the current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.
10.4. In case of identification of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator's email address legal@issaapp.com with a note "Updating of personal data".
10.5. The term of processing of personal data is determined by achieving the purposes for which the personal data was collected, unless another term is provided by contract or applicable law.
10.6. The user may withdraw their consent to the processing of personal data at any time by sending the Operator a notice via email to the Operator's email address legal@issaapp.com marked "Withdrawal of consent on the personal data processing".
10.7. All information which is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the mentioned persons (Operators) according to their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to get acquainted with the specified documents on his/her own in time. The Operator shall not be liable for the actions of third parties, including the service providers mentioned in this clause.
10.8. The prohibitions established by the subject of personal data on the transfer (other than granting access), as well as on the processing or processing conditions (other than obtaining access) of personal data permitted for dissemination shall not apply in cases of processing of personal data in the state, public and other public interests as defined by Russian legislation.
10.9. When processing personal data, the operator shall ensure confidentiality of personal data.
10.10. The operator shall store personal data in a form that allows to identify the subject of personal data no longer than required by the purposes of personal data processing, unless the period of storage of personal data is established by federal law, the contract, a party to which, a beneficiary or a guarantor under which the subject of personal data is.
10.11. Preconditions for termination of personal data processing may be achievement of personal data processing objectives, expiration of the consent of the subject of personal data or withdrawal of consent by the subject of personal data, as well as detection of unlawful processing of personal data.
11.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalizes, blocks, deletes and destructs personal data.
11.2. The operator carries out automated processing of personal data with or without receipt and/or transfer of information received via information and telecommunications networks.
12.1. The operator before starting transboundary transfer of personal data is obliged to make sure that a foreign country, the territory of which is intended to transfer personal data, provides reliable protection of the rights of subjects of personal data.
12.2. Transborder transfer of personal data in foreign countries that do not meet the above requirements may be carried out only if the consent in writing of the subject of personal data on the cross-border transfer of his personal data and / or performance of the contract, to which the subject of personal data is a party.
13.1. The operator and other persons who obtained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by the federal law.
14.1. The user can obtain any clarifications on questions of interest concerning the processing of his personal data by contacting the Operator via email at legal@issaapp.com.
14.2. This document will reflect any changes in the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
14.3. The current version of the Policy is freely available on the Internet at https://issaapp.com/privacy_policy_en.
14.4. The Russian-language version of this Policy shall take precedence over existing translations, which are provided for reference only.