Privacy Policy of N-GINN LLC

Last updated on: 6 September 2023

1. General Provisions

 

1.1. The subject of regulation of this Privacy Policy (hereinafter referred to as the "Policy") are the relations between Limited Liability Company " N-GINN", (OGRN (Primary State Registration Number 1237700008347), 25 Smirnovskaya Str., bldg. 12, floor 4, room 09), hereinafter referred to as the "Company ", which is the right holder of the website: https://nauengine.org (hereinafter referred to as the " Website ") and you (an individual, the Internet user), hereinafter referred to as the "User", regarding the processing of information about the User, including personal data, in the process of using the Site by such person (hereinafter referred to as the "Information"). This Policy is available at: https://nauengine.org/en/service/privacy

 

1.2. The relationship associated with the processing of information, including but not limited to the collection, use, storage, distribution and protection of information about Users of the Website, are governed by this Policy and the applicable law of the Russian Federation. Before using the Company's Website, the User shall read this Policy, as well as all applicable rules.

 

1.3. Upon registration, each access and/or actual use of the Website, the User:

(а) agrees to be bound by the terms of this Policy;

(б) has all necessary rights to register and use the Website;

(в) provides accurate information about yourself to the extent necessary to use the Website;

(г) represents and warrants that he or she is of legal age under the laws of the country of registration, but not less than 18 years of age. If the User is underage, use of the Website is prohibited.

 

2. Composition of Information and purposes of Information processing

 

2.1. The table below details the Information that the Company collects and processes in order to fulfill the agreement with the User to provide the Website:

 

Information Purpose of processing
1) Data provided by the User when registering on the Website: data received from third parties in case of login via third-party social media or authentication services, including the User's name and identifier in the social media, e-mail address, broadcast list, channel name, channel description, channel URL, avatar or profile picture, broadcast key, User's name and identifier created during the registration on the Website; The Company uses this information to manage and administer the Website, including providing Website services to the User. The Company uses this data so that it can fulfill its obligations to Users when they use the Website (for example, when a User requests to restore their account). The Company also uses this data to communicate with the User.
2) Additional data obtained when the User accesses the Website, including information regarding technical interaction with the Website, such as: email address, telephone number, last name, first name, date of birth, the User's IP address, time of registration on the Website, time of the last visit to the Website, device identifiers; Fulfillment of the agreement with the User to provide access to the Website. In particular, to improve the operation of the Website, manage and administer the Website, improve the system for detecting and eliminating failures and errors in the operation of the Website and other resources and services of the Company.
3) Information that is automatically received at the time of accessing the Website through the use of cookies; Please read section 2.3 of the Policy, which sets out the types of cookies used by the Company and the purposes for which the Company uses them.
4) Information created by the User when placing requests to the Website's support team; The Company uses this information to manage and administer the Website, including providing Website services to the User. In particular, the Company may use this information to verify the User's identity and to process the User's request to the support service. The Company may also use this data to investigate any complaints made on behalf of the User and provide the User with a more efficient service.

 

Information processed by the Company to the extent necessary and sufficient for it to be classified as personal data in accordance with the current legislation of the Russian Federation is processed by the Company as personal data on the terms of this Policy.

 

2.2. The Company does not verify the Information provided by the User and cannot judge its authenticity, as well as whether the User has sufficient legal capacity to provide such Information, except when such verification is necessary so that the Company can fulfill its obligations to the User.

The Company proceeds from the fact that the User provides reliable and sufficient Information and timely updates it. By submitting information on the Website, the User confirms that he/she has reached the acceptable age of use of the Website in accordance with applicable law, but not less than 18 years of age.

Otherwise, registration on the website and its use is prohibited.

 

2.3. Cookie processing

Cookies are small pieces of data that websites request from the browser used on the User's computer or mobile device. Cookies are stored locally on an Internet user's computer or mobile device. The Company collects and processes cookies in relation to Users visiting the Website.

The following types of cookies are used on the Company's Website:

• strictly necessary cookies / technical cookies: these cookies are necessary for the operation of the site and the provision of the Website to the User; among other things, they allow the Company to identify the User's hardware and software, including browser type;

• statistical / analytical cookies (e.g. Top.Mail.Ru): these cookies make it possible to recognize users, count their number and collect information such as the operations performed on the websites, including information about the pages visited and the content the User receives;

• technical cookies: these cookies collect information about how users interact with the Website, which allows us to identify errors and test new features to improve the performance of the Website;

Cookies are processed by the Company solely for the purpose of fullfilling agreements concluded with Users on the use of the Website, on the terms and in the manner specified in this Policy, in particular, on the basis of data obtained through cookies, the Company develops the most useful functionality for the Website available to the User, conducts statistical studies, fixes errors on the Website and tests new features to improve the performance of the Website.

The User can refuse to have his/her cookies processed in his/her browser settings. In this case, the Company's Website will use only those cookies that are strictly necessary for the operation of the Website and the provision of its functionality.

 

3. Terms and Conditions of Information Processing

 

3.1. Processing of the User Information is performed by the Company in accordance with the following principles:

The Company uses this information to manage and administer the Website, including providing Website services to the User. In particular, the Company may use this information to verify the User's identity and to process the User's request to the support service.

The Company may also use this data to investigate any complaints made on behalf of the User and provide the User with a more efficient service.3.1.1. legitimacy of the purposes and methods of Information processing;

 

3.1.2. good faith of the Company;

 

3.1.3. conformity of the purposes of processing of the Information to the purposes pre-determined and declared upon collection thereof, as well as to the powers and authority of the Company;

 

3.1.4. conformity of the volume and nature of the Information processed, methods of its processing to the purposes of processing of the Information;

 

3.1.5. inadmissibility of integration of databases containing the User Information created for incompatible purpose.

 

3.2. Collection of Information

Personal Data Collection, as well as other information that does not relate to personal data, is carried out during registration and/or authorization on the Website, as well as in the future when the User edits the previously provided information or supplements it on his own initiative using the tools of the Website.

In some cases, the Company collects other information, which does not relate to personal data, independently in the course of the User's use of the Website. The collection of such information begins from the moment the User accesses the Website (e.g., when loading an Internet page) until the moment the User registers on the Website.

 

3.3. Information Processing and Transmission

User Information shall not be disclosed to third parties, except as expressly provided for in this Policy, other applicable rules, and applicable law.

The Company may transfer User Information to third parties in order to fulfill the agreements concluded with Users on the use of the Website. Such third parties may include:

• persons who have legal grounds to process Information, for example, if the transfer of Data Information to such persons is carried out with the User's consent, including if the Information is necessary to provide the Website to the User or to fulfill a certain agreement or contract concluded with the User.

• third parties in respect of which the rights or obligations have been assigned, or novation under the relevant agreement;

• any state or local authority to which the Company is obliged to provide information in accordance with applicable law upon request.

In order to provide a high-quality, multifunctional, and user-friendly Website, the Company develops, improves, optimizes the current and introduces new functionality of the Website), including with the participation of partners and/or affiliates.

Taking into account the above, and considering the Company's compliance with the purpose of processing, namely the fulfillment of the agreements concluded with the

Users on the use of the Website, the User agrees and authorizes the Company to perform the following actions:

- processing, including collection, record, systematization, accumulation, storage, specification (update, change), retrieval, use, transfer (distribution, provision, access), depersonalization, deletion/destruction of Information, including User Personal Data;

- transfer of Information to partners and affiliates and its processing by partners and affiliates on the basis of an order from the Company (by the methods specified in this clause), as well as joint processing by partners and affiliates of Information available to partners and affiliates;

- collecting (receiving) results of Information processing from partners and/or affiliated persons together with data at the disposal of partners and affiliated persons, including in the form of integer and/or text values and identifiers.It is not allowed to extract and use User Information, including for commercial purposes, without the permission of the Company.

 

3.4. Storage of Information

The User Information is stored on the territory of the Russian Federation on electronic media only and processing is performed with the use of automated systems, unless non-automated processing of the data is required in furtherance of requirements of the applicable law.

The information is stored until the purposes of its processing are achieved.

 

3.5. Information Retention Periods

Information is stored by the Company during the term of the agreement between the User and the Company on the use of the respective Service and after termination of such agreement — during the period required and established by the applicable legislation of the Russian Federation.

 

3.6. Termination of Information Processing

When the purposes of Information processing are achieved, the Company shall terminate Information processing in one of the ways stipulated by the Federal Law No. 152-FZ "On Personal Data" dated 27 July 2006.

 

4. Rights and obligations of Users in the processing of their Information

 

The Users are entitled to:

4.1. require the Company to refine, block or destroy the User information, if such information is

incomplete, outdated, inaccurate, improperly obtained or is not necessary for the declared purpose of processing and if the functionality of the Service does not allow the User to delete such information on his/her own;

 

4.2. on the basis of a request receive from the Company the information regarding processing of the User information.

 

4.3. refuse to have their Information processed by sending a proper request to the Company in the manner provided for in Section 7 hereof.

 

5. Information Protection Measures

 

5.1. The Company takes technical, organizational and legal measures to ensure protection of the User Information against unauthorized or accidental access thereto, destruction, modification, blocking, copying, distribution, as well as other illegal actions.

 

5.2. Technical security measures are implemented by the Company in accordance with the requirements of the applicable law, current level of technology, nature of the information processed and risks associated with its processing.

The Information for the most part is processed automatically without access thereto by employees and/or contractors of the Company. If such access is provided to employees or contractors of the Company, then only to the extent necessary for such persons to perform their official duties or obligations under the contract with the Company, and such persons shall comply with security requirements when accessing Information.

To protect and ensure data confidentiality, all employees/contractors follow internal policies and procedures regarding the processing of information. The said persons also comply with all technical and organizational security measures provided for by the applicable law and required to protect the User information.

 

6. Limitation of the Company’s Liability

 

6.1. The Company shall not be liable for disclosure and distribution of information about the User in case the User violates the safety of his login and/or password or other data necessary for authorization.

 

7. Users’ Communication

 

7.1. Information about the data processed by the Company, including personal data of the User, due to their use of the Service shall be provided to the User or his representative when applying (requesting).

 

7.2. Requests shall be sent in writing to the Company's registered office or by sending a request to the support service at info@nauengine.org.

 

7.3. The User has the right to withdraw consent to the processing of his/her personal data by sending a written application to the Company at the location of the Company in accordance with the requirements of applicable law or by sending a request to the support service at info@nauengine.org.

 

8. Amendments and Modifications to this Policy

 

8.1. This Policy may be amended by the Company at any time, except as expressly permitted by applicable law. Any amendment to this Policy shall be notified to the Users, in particular, by publishing the updated version on the Website and/or notifying the Users by any means available to the Company. The updated Policy is effective as of the date of its publication, unless otherwise expressly provided by applicable law. User is advised to periodically check the Website for notices of such changes. The User's refusal to read the Policy may not serve as a basis for non-fulfillment of the User's obligations and the User's failure to comply with the restrictions set forth in the Policy. If the User does not agree with the changes, the User is entitled to stop using the Website. User's continued use of the Website shall be deemed acceptance of any revised terms and conditions.

 

8.2. The User may refuse to accept amendments and modifications to this Policy, which means the User’s refusal to use the Website and waiver of all rights previously granted to him/her.

 

8.3. This Policy shall be governed by and construed in accordance with the laws of the Russian Federation. Issues not regulated by this Policy shall be resolved in accordance with the legislation of the Russian Federation.