PRIVACY POLICY
This privacy statement was last updated on November 12, 2024.
The mobile application (the "App") is developed and operated by LLC "A-CONTENT RESHENIYA", which acts as the data controller and data processing operator within the meaning of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).
Iteora Media UG (haftungsbeschränkt) acts solely as a distribution agent for App Store publishing purposes. It does not collect, process, store, or have access to any personal data of users of the App.
Upon reading this privacy statement, you will know:
The organization collecting the information.
What Personal information of yours or third party Personal information is collected from you through the mobile app.
How the information is used.
With whom the information may be shared.
The kind of security procedures that are in place to protect the loss, misuse or alteration of information.
What choices are available to you regarding collection, use, distribution and other processing of the information.
How you can access, rectify or erase Personal information collected and processed about you.
Iteora Media UG (haftungsbeschränkt) acts solely as a distribution agent for App Store publishing purposes and does not collect, process, or have access to any personal data.
LLC "A-CONTENT RESHENIYA"
All personal data is collected and processed exclusively by LLC "A-CONTENT RESHENIYA" and may be stored on servers located outside the European Economic Area (EEA).
Questions regarding this Privacy Policy should be directed to LLC "A-CONTENT RESHENIYA" at:
P.O. Box No. 76, Moscow, 105120
LLC "A-CONTENT RESHENIYA" has a strong commitment to providing superior service to all of our customers of mobile applications and particularly respecting your concerns about privacy. We understand that you may have questions about how our mobile applications collect and use information and we have prepared this statement to inform you of the privacy principles that govern the mobile applications (the "Privacy Policy"). We will not sell or rent your Personal information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy.
This Privacy Policy contains numerous general and technical details about the steps we take to respect your privacy concerns. We have organized this Privacy Policy by major processes and areas so that you can quickly link to the information of most interest to you.
In the sense of GDPR "Personal information" means any information that identifies directly or indirectly a particular individual, such as individual's name, postal address, e-mail, telephone number.
LLC "A-CONTENT RESHENIYA" wants you to be always aware of what Personal information we collect, how we process and use it and under what circumstances we disclose it. All Personal information that we process will be subject to the version of the Privacy Policy in effect at the time of such processing.
LLC "A-CONTENT RESHENIYA" reserves the right to change this Privacy Policy from time to time at its sole discretion and will prominently post any material changes in the App.
You will be given the opportunity to opt-out. If as the result of such changes, you want to alter the ways in which LLC "A-CONTENT RESHENIYA" is allowed to use your Personal information, you can do so by following the procedure described in Section Choices and Rights Available to You. You will be deemed to have been made aware of, and will be subject to, the changes to the Privacy Policy by your continued use of the mobile app after such notice has been posted for thirty (30) days with the following exception: if at the time you provide Personal information to LLC "A-CONTENT RESHENIYA" you limit how such information will be used to communicate with you, either by LLC "A-CONTENT RESHENIYA" or by third parties, LLC "A-CONTENT RESHENIYA" will not change your preference in this regard without your express consent.
LLC "A-CONTENT RESHENIYA" does not control the information collection and distribution policies on Internet domains other than those Internet domains that are under the control of LLC "A-CONTENT RESHENIYA" itself. When you are on the App or website, you may be directed to other sites that are beyond our control. These other sites may independently process data, solicit personal information, or send their own cookies to you. LLC "A-CONTENT RESHENIYA" is not responsible for any use of the information including click-stream data created when using such third party sites.
LLC "A-CONTENT RESHENIYA" may establish relationships with various service providers whose services may become available to you from this mobile app or from other websites. Typically, these providers would offer services that customers might find useful. In order to use those services, you may be required to provide Personal information to the providers. Unless expressly provided to the contrary, Personal information that you provide while you are visiting a provider's website will be subject to the privacy policy posted on such site, and personal information you provide in this mobile application will be governed by this Privacy Policy. You should be aware that our agreements with these service providers often provide that they will share with LLC "A-CONTENT RESHENIYA" Personal information collected from you. In such instances, LLC "A-CONTENT RESHENIYA" may use this information in a manner consistent with this Privacy Policy.
LLC "A-CONTENT RESHENIYA" will disclose personal information without your permission when required by law, or in good faith belief that such action is necessary to investigate or protect against harmful activities to guests, visitors, associates, or property, or to others. Laws related to Personal information vary by country. For example, personal information processed in the European Union is subject to the EU Directives and Regulations concerning personal data, privacy and electronic communications, including but not limited to The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), Directive 2002/58/EC of the European Parliament and of the Council of 12 July 2002 concerning the processing of personal data and the protection of privacy in the electronic communications sector.
LLC "A-CONTENT RESHENIYA" may be required by law enforcement or judicial authorities to provide Personal information to appropriate governmental authorities. If requested by law enforcement or judicial authorities, we will provide this information upon receipt of the appropriate documentation. LLC "A-CONTENT RESHENIYA" may also provide information to law enforcement to protect its property and the health and safety of individuals as permitted by statute.
As a mobile app user, you can engage in many activities without providing any Personal information. In connection with other activities, such as subscribing to the services offered in the mobile app, subscribing to periodic newsletters sent by LLC "A-CONTENT RESHENIYA", requesting customer support, downloading trial versions of software, utilizing online software applications or purchasing any of the products and services available in the mobile app, LLC "A-CONTENT RESHENIYA" may ask you to voluntarily supply us with certain Personal information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities and/or make any purchases. If you elect to engage in these activities or make purchases, however, LLC "A-CONTENT RESHENIYA" may ask that you provide us Personal information, including but not limited to your first and last name, date of birth, e-mail address, telephone number and photo. This information is requested in conjunction with the purchase of our products, registering an account in the mobile application, contacting us for customer support. In addition, as noted below, minimum information is requested if you choose to subscribe to our newsletter service.
You never have to answer any questions, and you can decline this exchange of information at any time. However, if you should choose to withhold requested information, we may not be able to provide you with some of the services dependent upon the collection of this information. Depending upon the activity, some of the information that we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity or purchase, you will not be able to engage in that activity or make such a purchase.
Credit Card information or information about your crypto wallet are not retained by LLC "A-CONTENT RESHENIYA" as part of the registration process. This information is processed by our payment and billing providers during the purchase process and never disclosed to us except that we may receive from our payment and billing partners and process a part of your credit card number (the last 4 numbers) and information about your credit card issuer. We store this data to make future purchases in our mobile app easier for you.
In the mobile application you are given the opportunity to subscribe to a periodic newsletter. This newsletter is a marketing tool that allows LLC "A-CONTENT RESHENIYA" to inform you of new products or services, as well as other news relevant to the company. The subscription service requires you to provide your first and last name as well as your email address. You are given the opportunity to choose the type of information we provide to you.
While the subscription list is maintained by a trusted third party affiliate, the list remains the sole exclusive property of LLC "A-CONTENT RESHENIYA". Your name and email address is not shared with any third party and will not be used to send you unsolicited communications. A link is provided to allow you to change your subscription preferences, including cancellation of your subscription.
When processing is required in order to comply with a legal obligation to which we are subject, we may also obtain information about you from our partners, e.g. from our payment and advertising partners. We only use the data controlled by our partners in accordance with their legitimate instructions and applicable laws.
In addition, we may use the information made publicly available, e.g. through YouTube, Facebook, Instagram and X, to learn your opinion about the mobile application and our products so that we can take it into account when improving our mobile application and products.
LLC "A-CONTENT RESHENIYA" may collect information about the use of the mobile application, such as the types of services used and how many users we receive daily. This information is collected in aggregate form, without identifying any user individually. LLC "A-CONTENT RESHENIYA" may use this aggregate, non-identifying statistical data for statistical analysis, marketing, or similar promotional purposes.
LLC "A-CONTENT RESHENIYA" is the sole owner and controller of the information it collects in the mobile application. LLC "A-CONTENT RESHENIYA" will only share your information with outside parties in ways that are described in this privacy statement or if required to do so by law.
Iteora Media UG (haftungsbeschränkt) does not have access to any personal data collected through the App.
When you use the mobile application, LLC "A-CONTENT RESHENIYA" or third parties authorized by LLC "A-CONTENT RESHENIYA" that provide content, advertising, or other functionality in our mobile application, may use cookies, pixel tags, local storage, mobile device identifiers and other technologies ("Technologies") to automatically collect information through the mobile application. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "Device") that allow us to record certain pieces of information whenever you visit or interact with our mobile application, and to recognize, identify you across Devices and when you sign into our mobile application. Such Technologies also help us to identify incorrect behavior of mobile application, prevent fraudulent activity, improve security, understand how our users use our mobile app, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our mobile app.
We may also use advertising identifiers of third party advertising companies for recognizing your Device, serving ads on our behalf that may be relevant to your interests, understanding the usefulness to you of such ads, measuring advertising effectiveness, allowing more effective targeted advertising. Depending on your Device, you can choose to change or limit the transmission of your advertising identifier by going into your Device settings.
Our mobile app includes social media features such as the Facebook button and others. These social media features are either hosted by a third party or hosted directly in our mobile app. Your interactions with these features are governed by the privacy policy of the company providing it.
The mobile app and any products or services are not directed at children under 18 (or 21) years of age and, therefore, the Children's Online Privacy Protection Act ("COPPA") does not apply. However, we recognize that children under the age of 18 (or 21) may access this mobile app and subscribe to the newsletter, purchase products and services, or download trial versions of software programs. The collection of information is covered above.
Parents and Legal Guardians may request from LLC "A-CONTENT RESHENIYA" to review, delete or stop the collection of the Personal information of their child. You may do so in one of two ways. If you know the user name and password or email address, follow the instructions below regarding Choices and Rights Available to You, or you may contact us by letter or email using the address information provided in this Privacy Policy.
LLC "A-CONTENT RESHENIYA" acquires, holds, uses and processes Personal information based on the legal grounds, in order to fulfill its contract with you and for the legitimate business purposes outlined herein and according to Article 6(1) of the GDPR. We will use your e-mail address to send a confirmation and, if necessary, might use the other information to contact you for help to process the purchase or service you have selected. If you subscribe to a service or register a product, for example, the information is used to register your rights, if any, to technical support or other benefits that may be made available to registered users. Your Personal information is also used to keep you informed about product upgrades, patches, special offers, features in our mobile app and other products and services of LLC "A-CONTENT RESHENIYA" and selected third parties if you have so opted to receive such communications.
LLC "A-CONTENT RESHENIYA" uses the information required for our detection, investigation and prevention of cheating in the products or mobile app and end user license agreement violations only for the purposes of detection, investigation and prevention of such cheating. If the data can be used to prove that cheating or another fraud or end user license agreement violation has occurred, we will further store the data for the establishment, exercise or defense of legal claims during the applicable statute of limitations.
LLC "A-CONTENT RESHENIYA" recognizes and appreciates the importance of responsible use of information collected in this mobile app. Without your consent, LLC "A-CONTENT RESHENIYA" will not communicate any information to you regarding products, services, and special offers available from LLC "A-CONTENT RESHENIYA" or its affiliates, although we may find it necessary to communicate with you regarding your use of the services in this mobile app. Except in the particular circumstances described in this Privacy Policy, LLC "A-CONTENT RESHENIYA" will also not provide your Personal information to other companies or organizations without your consent.
LLC "A-CONTENT RESHENIYA" operates secure data networks protected by industry standard firewall and password protection systems. Our security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to the information provided by our users. Even your registration account password is encrypted before it is sent to our computers. Any other particularly sensitive information, such as a customer's credit card number collected for a commerce transaction, is also encrypted prior to transmission.
LLC "A-CONTENT RESHENIYA" takes steps to ensure that your information is treated securely and in accordance with our Terms of Use and this Privacy Policy. Unfortunately, no data transmission over the Internet can be guaranteed secure. As a result, while we strive to protect your Personal information, we cannot guarantee the security of any information you transmit to us or from our online products or services, and you use these services at your own risk.
We treat the information you provide to us as confidential information; it is, accordingly, subject to our company's security procedures and corporate policies regarding protection and use of confidential information. After Personal information reaches LLC "A-CONTENT RESHENIYA" it is stored on a server with physical and electronic security features as customary in the industry, including utilization of login/password procedures and electronic firewalls designed to block unauthorized access. Because laws applicable to Personal information vary by country, our offices or other business operations may put in place additional measures that vary depending on the applicable legal requirements. Information collected in the mobile app covered by this Privacy Policy is processed and stored in Germany and also in other countries where LLC "A-CONTENT RESHENIYA" and its service providers conduct business. By providing information to LLC "A-CONTENT RESHENIYA" you consent to the storage of your Personal information in these locations. All LLC "A-CONTENT RESHENIYA" employees are aware of our privacy and security policies. Your information is only accessible to those employees who need it in order to perform their jobs.
LLC "A-CONTENT RESHENIYA" does use the services of third parties, such as e-mail service providers, purchase and order processing merchants, web hosting, data management and storage service providers, marketing, advertising companies for delivery of targeted advertisements, business partners providing services and products that you have requested or may be of interest to you, that act as independent contractors on behalf of LLC "A-CONTENT RESHENIYA". These parties are contractually prohibited from processing Personal information for any purpose other than for performing legitimate contractual obligations or to comply with applicable legal requirements.
We do provide non-personal information to certain service providers for their use on an aggregated, anonymized basis for the purpose of performing their contractual obligations to us. We prohibit the sale or transfer of Personal information to entities outside of LLC "A-CONTENT RESHENIYA's" affiliates for their use without your approval.
LLC "A-CONTENT RESHENIYA" may disclose your Personal information if we believe in good faith that we are required to do so in order to comply with applicable law, a subpoena, or other legal process. LLC "A-CONTENT RESHENIYA" may also disclose Personal information when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Use, this Privacy Policy or to protect the safety of our users and the public or under confidentiality and licensing agreements with certain third parties which assist us in developing, operating and maintaining the mobile app and its content.
In the event that all or substantially all of LLC "A-CONTENT RESHENIYA's" stock and/or assets are transferred or sold to another entity, LLC "A-CONTENT RESHENIYA" may transfer Personal information to the acquiring entity. If, as a result of such a business transition, your Personal information will be used in a materially different manner, you will be given a choice consistent with our policy regarding notification of changes.
You can always choose whether or not to disclose Personal information and that choice will not prevent you from using the mobile app. Please note, however, if you should choose to withhold requested information, we may not be able to provide you with some of the services dependent upon the collection of this information.
You control which name, date of birth, email, photo, phone number we associate with your account. If they change, please modify the data in your personal account directly. Please inform us if any of the personal data we retain about you is inaccurate.
You can choose at any time to opt out of receiving emails from LLC "A-CONTENT RESHENIYA" or from having your Personal information shared with selected companies. If you want to opt out, you can do so by editing your preferences with respect to email or the sharing of information. If you elect to "opt out" we will not, as applicable, share your Personal information with third parties or send you emails.
We reserve the right to send a one-time registration confirmation email, and infrequent Service Alert messages to users to inform them of specific changes that may impact their ability to use a service they have previously signed up for, regardless of email contact opt-in status. We also reserve the right to contact you if compelled to do so as part of a legal proceeding or if there has been a violation of our Terms of Use or applicable licensing agreements.
You have the right to obtain deletion by LLC "A-CONTENT RESHENIYA" of Personal information concerning you by deleting your account in the mobile app. If you request us to erase your Personal information we will delete all Personal information about you, except for the data that are required for our compliance with the requirements of applicable laws (e.g. tax and accounting requirements) or for our detection, investigation and prevention of cheating in the products, mobile app and end user license agreement violations. We will retain anonymous information after your account has been closed.
LLC "A-CONTENT RESHENIYA" is retaining these rights because in limited cases we feel that we may need the right to contact you as a matter of law or regarding matters that will be important to you. These rights do not allow us to contact you to market a new or existing service if you have asked us not to do so, and issuance of these types of communications are rare.
You may access and correct your Personal information and privacy preferences, opt out of receiving emails, newsletters, the sharing or retention of any Personal information, by writing at [insert official contact email] or regular mail at LLC "A-CONTENT RESHENIYA", [insert registered address].
To ensure that your request is honored, you must provide LLC "A-CONTENT RESHENIYA" with information sufficient for us to accurately identify and access your records. The information we require is your full name, date of birth and the email address you provided to LLC "A-CONTENT RESHENIYA" when you requested services or products. LLC "A-CONTENT RESHENIYA" reserves the right to contact you to verify that we have accurately identified your record.
Where processing of your Personal information is based on legitimate interests according to Article 6(1)(f) of the GDPR, you can use your right to object at any time. If you object we will no longer process your Personal information unless there are compelling and prevailing legitimate grounds for the processing or the data is necessary for the establishment, exercise or defence of legal claims.
You also have the right to lodge a complaint at a supervisory authority.
LLC "A-CONTENT RESHENIYA" takes and addresses its users' privacy concerns with utmost respect and attention. If you believe that there was an instance of non-compliance with this Privacy Policy with regard to your Personal information or you have other related inquiries or concerns, you may contact:
LLC "A-CONTENT RESHENIYA"
P.O. Box No. 76, Moscow, 105120
help@aura7.сom
In your message, please describe in as much detail as possible the nature of your inquiry or the ways in which you believe that this Privacy Policy has not been complied with. We will investigate your inquiry or complaint promptly.
Please note that if you provide LLC "A-CONTENT RESHENIYA" with inconsistent privacy preferences (for example, by indicating on one occasion that third parties may contact you with marketing offers and indicating on another occasion that they may not), LLC "A-CONTENT RESHENIYA" cannot guarantee that your most recent privacy preference will be honored.