This English text is a translation for convenience only; if it differs from the Russian text (ru/04-politika-personalnyh-dannyh.md), the Russian text prevails.

Personal Data Processing Policy

1. General provisions

1.1. The Policy describes which personal data are processed when the "Fortochka" service is used, for what purpose, on what ground and for how long, and what rights the person whose data are processed has. The Policy is drawn up in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" (hereinafter the Personal Data Law). In the Bot the Policy is opened with the "Privacy Policy" («Политика конфиденциальности») button.

1.3. The other terms (Fortochka, Service, User, Bot, Mini App, Site, Order, Access Term, Free Period, Extra Days, Device, Payment Service, Support) are used with the meanings given in the Offer.

1.4. The Policy is a document of the Operator. It is not a contract, and it does not need to be accepted. The Policy does not limit the User's rights established by law.

2. Whose data and which data are processed

2.1. The data processed are those of natural persons who have started the Bot or the Mini App or have contacted Support. Fortochka is intended for persons who have reached the age of 18; the Operator does not verify age and relies on the person's own declaration.

2.2. List of data:

— Telegram user identifier, Telegram username, interface language; — date and time of the first and the last access to the Bot or the Mini App; — a record of the declaration of having reached the age of 18 (time and edition of the text); — Orders and their status: Plan, amount, payment method (SBP or card), time, the Payment Service's transaction identifier; the payment information that the Payment Service reports to the Operator: transaction ID, payment status, amount, currency, payment method and internal order ID; information about refunds; information for returning money by another method, if the User provided it; — the Access Term and the limits (number of Devices, volume of traffic); — information about suspension of access and its reason; records of the Operator's actions with the account (extension of the Access Term, refund, suspension); — technical logs of Fortochka's operation: internal account number, Order number, time and type of event; — information about the Devices on which the connection application is used: the Device identifier sent by the application, platform, model, the dates of the first and the last request; — counters of the volume of traffic; — information about who invited whom, and about the crediting and cancellation of Extra Days; — messages to Support and, if the User wrote by e-mail, the User's e-mail address.

2.3. The Operator receives these data from the person himself or herself when the Bot and the Mini App are used and when Support is contacted, from the Telegram messenger (the identifier, the username and the language are transmitted when the Bot and the Mini App are started), from the connection application (Device information) and from the Payment Service (transaction status and identifier). The Telegram messenger also transmits to the Bot and the Mini App the display name and other profile information; the Operator does not record them.

2.4. Special categories of personal data and biometric personal data are not processed. The Operator does not ask for a surname, first name, phone number or passport details as a condition of providing the Service.

3. Purposes, grounds and periods

The data are processed using automated means. Actions with the data: collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer to the persons stated in section 5, deletion, destruction.

— No. — Purpose — Data — Legal ground — Retention period — 1 — Creating an account, concluding and performing the contract: giving access, keeping track of the Access Term and the limits — Telegram identifier and username, interface language, date and time of the first and the last access, the record of the declaration of having reached the age of 18, the Access Term, the limits, information about suspension of access, records of the Operator's actions with the account — Conclusion of a contract on the User's initiative and performance of the contract, including the contract for a Free Period (clause 7.7 of the Offer) (item 5 of part 1 of Article 6 of the Personal Data Law) — During the Access Term and for 12 months after it ends — so that the User can resume access with the same account (clause 13.4 of the Offer). If an Access Term never started — 90 days from the day of the last access to the Bot or the Mini App — 2 — Accepting payment, refunding money, issuing receipts — Orders: Plan, amount, payment method, time, status, the Payment Service's transaction identifier; the payment information reported by the Payment Service; information about refunds; information for returning money by another method, if the User provided it — Performance of the contract (item 5); performance of the obligations of a payer of the tax on professional income (item 2; Article 14 of Federal Law No. 422‑FZ of 27.11.2018) — 3 years from the day of payment — 3 — Observing the limit on Devices and on the volume of traffic — Device identifier, platform, model, the dates of the first and the last request; counters of the volume of traffic — Performance of the contract (item 5) — Device information — during the Access Term; it is deleted within 30 days after the Access Term ends. The traffic volume counter of the current period — until the period ends; the all-time counter — for the lifetime of the user account — 4 — Invitation Programme: keeping track of invitations, crediting and cancelling Extra Days — Information about who invited whom; credits and their cancellation — Performance of the contract (item 5) — As in row 1 — 5 — Replying to requests, considering claims — Messages to Support, Telegram identifier and username, e-mail address (if the User wrote by e-mail) — Performance of the contract (item 5); the Operator's legitimate interests — confirming the content of requests during the limitation period (item 7) — 3 years from the day of the request — 6 — Protecting Fortochka against misuse: a Free Period being given only once, the limits on the number of Orders, checking compliance with the rules of the Invitation Programme — Telegram user identifier, the record that a Free Period was used, information about Orders and invitations — The Operator's legitimate interests, with the User's rights observed (item 7) — The record that a Free Period was used — 3 years after the Access Term ends; the other data — within the periods stated in rows 1–4 — 7 — Keeping Fortochka working: finding and fixing faults — Technical logs: internal account number, Order number, time and type of event — The Operator's legitimate interests, with the User's rights observed (item 7) — 30 days

4. What the Operator does not record and does not store

4.1. The Operator does not record and does not store the content of the traffic transmitted, the list of websites and services visited, or DNS queries (queries to the domain name system). This information passes through the servers at the moment of connection; otherwise the Service cannot be provided. Only the volume of traffic is stored.

4.2. The Operator does not receive or store bank card data. The User enters them on the Payment Service's side.

4.3. The IP address (network address) of the Device is processed during a connection and when the Device requests the connection details: without this a connection cannot be established.

5. Who receives the data

5.1. The Platega payment service (website platega.io) receives the amount and identifier of the Order, the name of Fortochka and of the Plan, and the internal number of the User's account in Fortochka (not the Telegram identifier and not the Telegram username), in order to accept payment and to make a refund. The User passes payment details to the Payment Service himself or herself; the Payment Service processes them as an independent operator under its own rules.

5.2. The Telegram messenger delivers the Bot's messages, opens the Mini App and stores the User's correspondence with the Bot and with Support. The User uses the Telegram messenger independently, on the terms of its rights holder.

5.3. Hosting providers from which the Operator rents servers: data are stored on those servers and transmitted through them, only for the purposes stated in section 3. The Operator is responsible to the User for the processing of data on those servers.

5.4. The e-mail provider VK LLC (Russia) stores the correspondence if the User wrote by e-mail.

5.5. The provider that hosts the backups of the database: backup storage on a server in the Russian Federation (Selectel JSC, Russia).

5.6. Data are provided to state bodies and other persons only in the cases and in the manner established by the legislation of the Russian Federation.

5.7. The Operator does not transfer data for purposes not stated in section 3.

6. Where the data are stored. Cross-border transfer

6.1. Fortochka's main database, in which personal data are recorded, systematised, accumulated, stored, clarified and retrieved, is hosted on a server located at: the Russian Federation, Moscow.

6.2. The connection is established through servers located outside the Russian Federation, in the following states: Sweden, the Netherlands, Finland. The following are processed on those servers: a conventional account name not linked to the Telegram account; the end date of the access term; traffic counters; the identifiers, platform and model of Devices and the dates of their first and last request. The ground for the transfer is performance of the contract with the User.

6.3. The Bot's messages and the correspondence with Support in the Telegram messenger pass through that messenger's servers and are stored on them. Those servers are located outside the Russian Federation: the Netherlands, the USA, Singapore.

6.4. E-mail correspondence and backups are stored with the providers and in the states stated in clauses 5.4 and 5.5.

7. Ending of processing and destruction of data

7.1. When the retention period stated in section 3 expires, the data are destroyed within 30 days.

7.2. On a justified demand of the User, data that are no longer needed for the purposes of processing or are processed unlawfully are destroyed within the time limits stated in section 9. Data which the Operator is obliged or entitled by law to keep (information about payments and refunds, requests, the record that a Free Period was used) are kept until the end of their period.

7.3. Destruction means deletion of the records from Fortochka's database and from the control panel's database. The Operator deletes the correspondence with Support in the Telegram messenger and in the mailbox within the same time limits. Data are removed from backups as the backups are replaced on schedule, no later than after 30 days.

8. Protection measures

The Operator takes legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, dissemination and other unlawful actions, including by limiting access to the data and using encryption when they are transmitted.

9. The User's rights and how to apply

9.1. The User may:

— find out whether the User's data are processed and receive information about them: the set of data, the purposes, grounds, methods and periods of processing, the recipients, information about cross-border transfer; — demand that inaccurate data be corrected; — demand that processing be temporarily stopped or that data be destroyed if they are incomplete, out of date, inaccurate, unlawfully obtained or not needed for the stated purpose; — withdraw consent to processing — in those cases where processing is based on consent; — complain about the Operator's actions to the authorised body for the protection of the rights of personal data subjects (Roskomnadzor) or to a court.

9.2. To do this, write to Support (Telegram @get_fortochka_bot) or by e-mail to reach_fortochka@mail.ru and state which account is concerned: the Telegram user identifier or the Order number. Passport details are not required. If the request came from a Telegram account other than the one to which the data relate, the Operator may ask for the request to be confirmed by a message from that account or, if there is no longer access to it, for the Order to be named (its number, or the date and amount of the payment).

9.3. Time limits:

— a reply to a request for information — within 10 working days; the time limit may be extended by no more than 5 working days, with a notice of the reasons sent to the User; — correction of inaccurate data, destruction of unlawfully obtained or unneeded data — within 7 working days after the User has provided confirming information; — ending of processing on the User's demand — within 10 working days, except for processing which by law continues without consent (for example, to perform a contract or obligations imposed by law).

9.4. Information is provided free of charge.

10. Cookies and analytics

10.1. The Site does not use cookies (small files that a site saves in the browser), visit counters, analytics systems or advertising networks. The Mini App stores in the browser only the information without which logging in to the account is impossible: the launch data from Telegram and the theme settings, for the current session only (kept by Telegram's script); in addition, the Mini App remembers the chosen interface language (the fortochka.lang record). Counters, analytics systems and advertising networks are not used in the Mini App.

10.2. When the Mini App is started, the Telegram messenger transmits to Fortochka the Telegram identifier and username and the interface language — they are needed for logging in to the account (section 3, row 1). The Telegram messenger also transmits the display name and other profile information; the Operator does not record them.

11. Minors

Fortochka is intended for persons who have reached the age of 18. The Operator does not knowingly process the data of minors. If the Operator learns that a User has not reached the age of 18, provision of the Service ends (clause 10.6 of the Offer) and the data are destroyed, except for those the Operator is obliged by law to keep.

12. Amendment of the Policy

The Operator may amend the Policy by publishing a new edition on the Site with its date stated. A new edition is in force from the day of publication. The Operator gives notice of material changes in the Bot chat.

13. The Operator's contacts

Султыгов Сандро Ниясович, INN 151211100811, city of Грозный. E-mail: reach_fortochka@mail.ru. Telegram: @get_fortochka_bot. Full information is in the document "Contacts and Details".