- GENERAL PROVISIONS
Use of the Platform means the User’s unconditional consent to this Policy and the conditions for processing his personal information specified in it, namely to perform the actions stipulated by the Regulation of the European Parliament and of the Council (EU) 2016/679 of 04/04/2016 “On the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC"(" GDPR"), Federal Law of July 27, 2006 No. 152-FZ" On Personal Data ", both without and using automation tools , and confirms that, giving such consent, he acts freely, by his will and in his interest. In case of disagreement with these conditions, the user should refrain from using the Platform.
This Policy is applicable only for the conduct of activities by the Platform, as well as for the Individual Entrepreneur Nikita Sergeyevich Shkilev, his affiliates or employees. The Platform does not control and is not responsible for the sites of third-party entities to which the user can click on the links available on the Platform. On such sites, the user may collect or request other personal information, and other actions may be performed.
The owner of the platform, its affiliates or employees, as a general matter, does not verify the credibility of personal information provided by users and does not exercise control over their legal capacity. However, the Platform Owner, its affiliates or employees proceeds from the fact that the user provides reliable and sufficient personal information on the issues proposed in the registration form, that the personal data indicated by him during registration belongs to him personally and maintains this information up to date. The risk of providing false information is borne by the user who provided it.
The user's consent to the processing of personal data is valid indefinitely from the moment of using the Platform and does not require periodic confirmation. The Platform Owner, its affiliates or employees will store personal information for as long as necessary to achieve the purpose for which it was collected, or to comply with laws and regulations.
Attention: In case of any discrepancies between the English and Russian language versions of this Policy, the Russian version is crucial. The Russian version is available at: https://cutout.cloud/rules/politika-konfidencialnosti
- KEY TERMS AND DEFINITIONS
1.1. Address and contact details of the Platform Owner
- Full name: ST Nikita Sergeyevich Shkilev
- PSRNSP: 316527500050624
- ITN: 526021642599
- Residence address: 603000 Nizhny Novgorod, Bolshaya Pokrovskaya St., 58, apt. 24
- Address for correspondence: 603000, Nizhny Novgorod, Bolshaya Pokrovskaya St., 58, apt. 24
- Phone: +79200141317
- E-mail: email@example.com
Personal Data Protection Specialist: ST Nikita Sergeyevich Shkilev
2.2. Terms used in the Policy and their definitions:
2.2.1. «Personal data» – any information that is related directly or indirectly to a specific or identifiable individual (the subject of personal data).
- Personal information that the user provides about himself / herself when registering (creating an account) or in the process of using the Platform, including personal data of the user. The information required for the provision of the Platform (provision of services) is marked in a special way. Other information is provided by the user at his discretion.
- Data that is automatically transmitted to the Platform in the course of their use using the software installed on the user's device, including IP address, cookie information, information about the user's browser (or other program with which the Platform is accessed), time access, address of the requested page.
Third party software includes Google Analytics site statistics collection systems. The composition and conditions for the collection of anonymized data using third-party software are determined directly by their copyright holders and may include:
- browser data (type, version, cookie);
- device data and location;
- operating system data (type, version, screen resolution);
- request data (time, transition source, IP address).
2.2.2. «Personal data processing» – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.2.3. «Confidentiality of personal data» – a mandatory requirement for the Company or another person who has gained access to personal data to prevent their dissemination without the consent of the subject of personal data or other legal grounds.
2.2.4. «User of the online platform Cutout.Cloud / Platform (the "User")» – a person who has access to the Platform through the Internet and uses the Platform.
2.2.5. «Cookies» – a small piece of data sent by the web server and stored on the User's computer, which the web client or web browser sends to the web server each time in an HTTP request while attempting to open the page of the corresponding site.
2.2.6. «IP-адрес» – unique network address of a node in a computer network built on IP protocol.
2.2.7. «MAC-address» – a code written in hexadecimal that is assigned to each unit of network equipment.
2.2.8. «Publicly available information» – information that, at his/her discretion, the User provides in order to fill out a profile on the Platform. It includes the following personal data: last name, first name, middle name, phone number. The User gives informed consent to access his/her profile data to an unlimited circle of persons. Profile data becomes publicly available taking into account his/her settings from the moment it is posted on his/her own by the User or at his/her request.
2.3. The Copyright Holder is not responsible for the procedure for using the User’s Personal Information by third parties with whom the User independently interacts in the framework of using the Service.
2.4. At registration the user is required to indicate the name (login), e-mail address and password. If registration is performed using social network authorization services (Facebook, Vkontakte), these services provide the Copyright Holder with information about the User, which may include the following details: name, user identification number and / or username in this authentication service, e-mail address.
The Users who have concluded agreements providing for the payment of funds to the Platform Owner also provide information necessary for making payments, which may include: payment system account, account number, ITN, last name, first name, middle name.
3.1. This Policy establishes the obligations of the Platform Owner, its affiliates and employees to not disclose and ensure the regime for protecting the confidentiality of personal data that the User provides when registering on the Platform or when concluding an agreement on the provision of services between him/her and the Platform Owner.
3.2. The personal data processed by the Platform Owner in the framework of this Policy are provided by the User and include the following information:
3.2.1. Provided by the User by filling out the registration form of the Platform and include the following information:
- Login and username;
- telephone number of the User;
- e-mail address (e-mail);
- interests, hobbies, information about education, work information and other personal information of the User specified in the entry box «About Me» (access via the link: https://cutout.cloud/account/profile/) when filling out a profile on the Platform;
- User photos and other images, media files uploaded by the User to the Platform;
- links to the User’s page on other Internet resources (for example, Vkontakte, Facebook, etc.);
- type of service selected by the User, within the framework of using the Platform.
3.2.2. Personal data contained in messages that the User sends or transfers through the Platform to the Platform Owner, its affiliates and employees, as well as other Users;
- IP address;
- subscriber number;
- MAC address;
- information from cookies;
- User geolocation;
- browser language;
- external source of the transition to the site;
- the user's device, including the model and manufacturer of the device;
- operating system;
- type and version of the browser;
- user screen size;
- information about the User’s visits and use of the Platform, including the source of referrals, duration of visits, page views and navigation paths on the Platform;
- user’s internet service provider.
3.2.4. Personal data obtained during the registration of the User and the use of services provided by the Platform Owner, including:
- financial information, including credit or debit card number (only the last four digits of the card number) or other payment information;
- history of the acquisition of services offered by the Platform Owner;
- history of appeals in the framework of using the Platform and interaction with the owner of the Platform;
- interests and preferences when choosing the services of the Platform, etc.
3.2.5. With the separate consent of the User, other personal data at the discretion of the User and the discretion of the Platform Owner.
3.2.6. Other personal data that the User wished to leave on the Platform and its registration forms.
3.3. The platform uses cookie technology, with the help of which it is configured to work personally with the User. Disabling cookies may result in the inability to access parts of the Platform that require authorization. This function can be disabled through the browser settings regarding cookies. The user can find detailed information on the website of the browser manufacturer or manufacturers of extensions and plug-ins for browsers.
3.4. The platform protects Personal data that is automatically transmitted during the viewing of advertising units and when visiting pages on which the system’s statistical script is installed (“pixel”):
- IP address;
- information from cookies;
- information about the browser (or other program that provides access to the adware);
- access time;
- address of the page on which the ad unit is located;
- referrer (address of the previous page).
3.4.2. The platform collects statistics about the IP addresses of its visitors. This information is used to identify and solve technical problems, control the legality of financial payments.
3.5. Any other personal information not stipulated above is subject to reliable storage and non-dissemination, with the exception of cases provided for in paragraphs 5.2. and 5.3. of this Policy.
3.6. The platform has “social plugins” - the “Like” button on Facebook, VKontakte, YouTube, Instagram, Twitter, Pinterest
If you are a member of a social network and click on the corresponding social plug-in, the owner of this social network can associate information about visiting our site with your profile.
3.7. The User’s email address and login is used when registering his/her account on the Platform, to enter and manage this account, information, services and other objects associated with it as part of the use of the services provided by the Platform.
3.8. The User’s email address is used when registering his/her account on the Platform, to enter and manage this account, information, services and other objects associated with it as part of the use of the services provided by the Platform.
- GOALS, PRINCIPLES OF COLLECTING AND PROCESSING PERSONAL INFORMATION OF USERS
4.1. The Platform Owner, its affiliates or employees collect, process and store only those personal data that are necessary to provide the Platform and provide services (fulfillment of agreements and contracts with the user), in strict accordance with applicable national and international legal regulations.
4.2. The main principles of the Platform in the field of personal data processing and confidentiality of personal information are:
- the legitimacy of the purposes and methods of processing personal data and good faith;
- compliance of the purposes of processing personal data with the goals previously determined and declared during the collection of personal data;
- compliance of the volume and nature of the processed personal data, methods of processing personal data with the purposes of processing personal data;
- inadmissibility of processing personal data that is excessive in relation to the goals stated during the collection of personal data;
- Inadmissibility of combining databases of personal data information systems created for incompatible purposes.
4.3. The Platform Owner, its affiliates or employees may use the User’s personal data in the following cases:
- creation of a User account on the Platform, if he/she has consented to its creation;
- providing the User with access to the personalized resources of the Platform;
- providing the User with effective customer and technical support in case of problems associated with the use of the Platform;
- processing and monitoring the status of payments for the provision of services by the Platform Owner as part of the activities of the Platform;
- processing is necessary to fulfill the contractual obligations of the Platform Owner to the user as part of the Platform's activities;
- communication with the User, including the sending of notifications, requests and information regarding the use of the Platform, the provision of services, as well as the processing of requests and requests from the user;
- improving the quality of the Platform, usability, development of new services;
- targeting advertising materials;
- organizing and conducting events and surveys by the Platform Owner, informing Users and promoting new services, discounts and third parties at the discretion of the Platform Owner on behalf of the Platform or on behalf of the partners of the Platform, including through direct contacts with the User using communication tools;
- establishing feedback with the User, including sending notifications, requests regarding the use of the Platform, the provision of services, processing requests and requests;
- provision of additional services and services of the Platform aimed at raising awareness about the products and services of the Platform;
- analysis of preferences and monitoring of consumer behavior of the User;
- with the separate consent of the User in other cases at the discretion of the User and at the discretion of the Platform Owner;
- conducting statistical and other studies based on anonymized data;
- for other purposes, subject to applicable national and international legal acts.
4.4. With regard to the user's personal information, his/her confidentiality is maintained, except in cases where the user voluntarily provides information about himself/herself for general access to an unlimited number of people. When using certain functions, services, the Platform services, the User agrees that a certain part of his/her personal information becomes publicly available.
The Platform Owner, its affiliates or employees are entitled to transfer user personal information to third parties in the following cases:
- the user has expressed his/her consent to such actions;
- the transfer is necessary as part of the use by the user of the Platform or to provide services to the user;
- the transfer is provided for by national and international legal norms within the framework of the procedure established by law;
- the transfer takes place as part of a sale or other transfer of business (in whole or in part), while the acquirer is transferred to all obligations to comply with the terms of this Policy in relation to the personal information received by him/her;
- in order to ensure the protection of the rights and legitimate interests of the Platform Owner or third parties in cases where the user violates the User Agreement (available at: https://cutout.cloud/information/user-agreement).
4.5. The user can at any time change (update, supplement) the personal information provided by him/her or part of it, as well as the parameters of its confidentiality, using the edit personal data function in the account profile section. The user has the right to require the Platform Owner, its affiliates or employees to clarify, block or destruction (deletion) of the personal information provided by him/her or part thereof in case the personal data is incomplete, outdated, inaccurate or not e are not necessary for the stated purpose of the processing, and also take the measures prescribed by law to protect their rights.
- METHODS AND TERMS OF PROCESSING PERSONAL INFORMATION
5.1. After reviewing this Policy, when visiting and using the sites, services, the Platform services, the User provides his/her personal data and agrees to the processing of his/her personal data for the purposes indicated above, freely, by his/her will and in his interest.
5.2. The Platform Owner guarantees that the processing of personal data is no longer than is required in accordance with the stated objectives. The owner of the Platform, its affiliates and employees take measures to ensure the updating and accuracy of the processed personal data, as well as their clarification / deletion in cases stipulated by law.
5.3. The User has the right not to provide his/her personal data by refusing to register on the specified Platform, including for the purpose of acquiring the services provided by the Platform Owner, or connecting to various information resources. The User has the right to withdraw his/her consent to the processing of personal data. In this case, the Platform Owner has the right to continue processing personal data only in cases when it is provided by legal regulation.
5.4. The User’s personal data can be transferred to authorized bodies of state power only on the grounds and in the manner established by the legislation of the relevant state and international regulatory standards. The Platform Owner, its affiliates and employees may transfer personal data to the extent that they are required to do so in accordance with national and international legal regulations, at the request of state and municipal authorities, in order to establish, exercise or protect the rights of the Platform Owner, Users and other persons (including providing information to third parties in order to prevent fraud).
5.5. The Platform Owner takes the necessary organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other illegal actions of third parties.
5.6. The User has the right to receive information regarding the processing of his/her personal data, and also has the right to demand clarification, blocking or destruction of personal data in cases provided by law.
5.7. Information collected as part of the Platform's activities may be stored, processed and transmitted between any countries in which the Platform operates and can be used in accordance with the Policy. The information collected by the Platform may be transferred to the following states that do not have data protection laws equivalent to those in force in the European Economic Area: United States of America, Russia, Japan, China and India. Personal data published by the User on the Platform or submitted by him/her for publication on the Platform can be accessed via the Internet around the world.
5.8. With regard to the User’s Personal Information, its confidentiality is maintained, with the exception of publicly available data and other cases where the technology of the provided Platform or the settings of the software used by the User provide for an open exchange of information with other participants and users of the Internet.
5.9. In order to improve the quality of the Platform, the Copyright Holder has the right to store log files about actions performed by the User in the framework of using the Platform, as well as in connection with the conclusion and execution by the User of the Agreement and other Contracts / Transactions for his part, for 1 (One) year.
5.10. Users who have gained access to the personal data of other Users or third parties in connection with the conclusion and / or execution of Agreements between them are required to comply with the provisions of clause 5.8. and 5.9. of this Policy, as well as to process the received personal data in accordance with this Policy and applicable law.
- PLATFORM IN THE POSITION OF THE ADMINISTRATOR AND IN THE POSITION OF THE PROCESSOR OF PERSONAL DATA
6.1. The Platform Owner shall take the necessary and sufficient organizational and technical measures to protect the user's personal information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other illegal actions of third parties with it.
6.4. When processing personal data of users, the Platform Owner, its affiliates and employees are guided by national and international regulatory standards.
6.5. All suggestions or questions regarding this Policy should be reported to tech support https://cutout.cloud/account/support/, or by e-mail: firstname.lastname@example.org
- RIGHTS OF USERS
7.1. In case it is provided by applicable national and international acts, Users have the right to access the personal data of other Users posted on the Platform, is submitted in accordance with this Policy.
7.2. If the User believes that any information posted on the Platform is incorrect or incomplete, he/she can enter his/her profile and correct personal information on his/her own.
7.3. The user has the right to demand the removal of their personal data and the withdrawal of consent to the processing of personal data and restrictions on the processing of personal data, to object to the processing of their personal data, if this is provided for by applicable national and international regulatory legal acts. The owner will fulfill these requests in accordance with applicable national and international law.
7.4. The User also has all the rights stipulated by the Policy, other documents regulating the activities of the Platform (available here:), and the applicable norms of national and international law.
7.5. To exercise the above rights, the User must enter his profile on the Platform or use the special feedback form provided by the Platform. If the User is not satisfied with how his/her personal data provided to the Platform is processed, then he/she needs to contact the Platform support service or contact the Platform Owner using the contact details indicated on the Platform.
- ADDITIONAL CONDITIONS.
8.1. The Platform Owner shall take the necessary and sufficient organizational and technical measures to protect the user's personal information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other illegal actions of third parties with it. However, the Platform Owner is not able to prevent the unlawful use by third parties of information that was publicly published by the User.
8.2. Using the Platform by the User means acknowledging that the transmission of information via the Internet is inherently unsafe, and the Platform Owner cannot guarantee the security of data transmitted via the Internet, and that the User is fully responsible for maintaining the confidentiality of the password for access to the Platform.
8.5. When processing personal data of users, the Platform Owner, its affiliates and employees are guided by applicable national and international regulatory standards.
Updated July 18, 2019