SPACEBOT privacy policy

PREAMBLE

This document contains information about the rules for the use of your personal data, your rights and obligations, as well as the rights and obligations of our company in relation to your personal data.

This privacy policy (hereinafter - the Policy) applies to all information, including personal data in the understanding of the applicable law (hereinafter - the ``Personal Information``), which SPACEBOT and / or our affiliates, including those belonging to the same group as Us, may to receive about you during your use of the program, the SPACEBOT mobile application, as well as during the performance by us / our affiliates of any agreements and contracts concluded with you in connection with your use of the SPA program CEBOT. We can also receive Personal Information from our partners (hereinafter referred to as the “Partners”), the sites, programs, products or services of which you use in such cases, the transfer of Personal Information is possible only in cases established by applicable law, and is carried out on the basis of special agreements between us and each of the Partners.

Understanding the importance of ensuring the confidentiality and inviolability of the personal data of our Users, as well as the information materials posted by the Users on our website, we are introducing this Privacy Policy to determine the procedure for conducting operations with confidential data of the Parties when using the SPACEBOT program.

Please note that the use of SPACEBOT may be subject to additional conditions that may make changes and / or additions to this Policy.

We have the right to make changes to the Privacy Policy at any time by posting the amended version on this site with the date the changes take effect. If significant changes are made to this document, we will notify you of this by e-mail specified by you during the registration process.

This privacy policy applies to all services of the program, as defined below, regardless of how you use them or use them, including through mobile devices.

By concluding this Agreement, the User gives SPACEBOT the right to process and authorize the collection and processing of personal data to a third party with whom the Company enters into an agreement on the processing of personal data (including, but not limited to: collection, systematization, accumulation, storage, clarification, updating , change, use, domestic transfer) of your personal data and other private information in any way that does not contradict the current Russian legislation (including without using dstv automation) for the purpose of execution of undertaken contract obligations.

Information for citizens of the Russian Federation: in accordance with Art. 6 of the Federal Law of July 27, 2006 N 152-ФЗ (as amended on December 31, 2017) `` On Personal Data '', the Operator has the right to entrust the processing of personal data to another person with the consent of the subject of personal data.

A person who processes personal data on behalf of the operator is required to comply with the principles and rules for the processing of personal data provided for by this Federal Law. The operator’s instructions must determine the list of actions (operations) with personal data that will be performed by the person processing the personal data, and the purpose of the processing, the obligation of such a person to maintain the confidentiality of personal data and ensure the safety of personal data during their processing, as well as must specify the requirements for the protection of processed personal data in accordance with Article 19 of this Federal Law.

A person who processes personal data on behalf of the operator is not required to obtain the consent of the personal data subject to the processing of his personal data.

Please read this document carefully, as it is legally binding if you use the services of our platform in the manner described below.

The latest version of this Policy was published on 12/24/2019

1. TERMS

In this document, unless expressly provided otherwise from the main text of this document, the following words and phrases will have the following meanings:

“Personal data” “personal information” or “personal data” or “Your data - any information relating directly or indirectly to a specific or determinable natural person (subject of personal data).

SPACEBOT - a computer program.

The SPACEBOT mobile application (hereinafter referred to as the “Application”) is the software available to the User through the Application Store in full compliance with the Agreement, which is an information application developed for mobile devices running Android and Apple iOS operating systems. Intellectual property rights to the Application and its elements belong to the Company.

Materials derived from the Program - any program, work, information developed by the User or a third party using the Program or any part thereof.

Use of the Program - any actions related to the functioning of the Program in accordance with its purpose.

Client assistance system - software installed in the Mobile application and including the User support service.

Confidential information - the contents of the Program (source code), all copies of the Program and all derivative works associated with the Program, including, but not limited to, all updates, modifications.

Account, SPACEBOT personal account - means a user account accessible through the SPACEBOT program. This is a personal page of a registered User with an individual number, access to which is available only to a registered User with a username and password for this page, which is a computer program whose interface is hosted and accessible via the SPACEBOT mobile application or in any other accessible way.

“Digital assets” - is a digital representation of value, which means “cryptocurrency”, “virtual currency”, “digital currency” such as bitcoin, ether, or prisms that is based on the cryptographic protocol of a computer network, can be centralized or decentralized, closed or open source and used as a means of sharing and / or storing value.

“Processing personal data” - 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.

“Confidentiality of personal data” - a requirement for the Operator or other person who has gained access to personal data to comply with the requirement not to allow their dissemination without the consent of the subject of personal data or the presence of any other legal basis.

“User”, “client” - a person who has access to the SPACEBOT program

“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 HTTPS request when trying to open the page of the corresponding site.

``IP address`` - a unique network address of a node in a computer network built over IP.

Personal data operator:

To ensure your use of the SPACEBOT program, Personal Information is collected and used by SPACEBOT, a legal entity created under the laws of England and Wales or its affiliate providing the corresponding Service. You can familiarize yourself with the information about which person provides this or that Service in the conditions for using the corresponding Service.

Personal data processor:

“Processor” - a person who processes personal data on behalf of the operator, based on the instructions of the operator (within the meaning of Article 6, part 3 of the Law of the Russian Federation “On Personal Data”).

By accepting the terms of this Privacy Policy, the personal data subject agrees to the instruction by the Operator of the processing of personal data to another person.

Administration of the SPACEBOT application - authorized employees to manage the application, program, acting on behalf of SPACEBOT, who organize and (or) process personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2. GENERAL PROVISIONS

2.1. Use by the User of the SPACEBOT program, including through a mobile application, means acceptance of this Privacy Policy and the conditions for processing the User’s personal data.

2.2. In case of disagreement with the terms of the Privacy Policy, the User must stop using the SPACEBOT application.

2.3. This Privacy Policy applies only to the SPACEBOT program, sites, the SPACEBOT mobile application that do not control and are not responsible for third-party sites to which the User can click on the links from the SPACEBOT mobile application

3. SAFETY MEASURES FOR YOUR PERSONAL DATA

3.1. We use encryption to protect the information you provide and store decryption keys in separate systems. The operator and the personal data processor process and store your personal information on our server in the data center.

3.2. In cases stipulated by law, we undertake to appoint employees to protect your personal data who will be responsible for maintaining the privacy policy.

3.3. We make every effort to ensure the protection of your personal data from unauthorized access, disclosure or destruction of information that we collect and store.

3.4. The measures we take:

- encryption using SSL;

- the presence of two-factor authentication;

- analysis of methods for collecting, storing and processing information.

We carry out activities to train our employees in the rules of working with personal data.

We strive to ensure full compliance of our methods of processing and storage of your personal data with applicable law.

Unfortunately, despite the security measures taken by us, the transmission of information via the Internet is not completely secure. Despite the fact that we do our best to protect your personal data, we cannot guarantee the security of your personal data during their transfer, in this regard, all actions for the transfer of your personal data are carried out at your own risk.

If you have any questions about how we protect or use your personal data, you can contact us by e-mail at the user support service address.

4. SUBJECT OF PRIVACY POLICY

4.1. This Privacy Policy establishes the obligations of the SPACEBOT Administration to not disclose and ensure the regime for protecting the confidentiality of personal data that the User provides at the request of the SPACEBOT Administration during registration when using the SPACEBOT program.

The personal information that you provide during the registration process may be retained even if your registration is left incomplete.

4.2. INFORMATION WE COLLECT:

The personal information collected during the operation of the SPACEBOT program, applications may vary depending on whether you use to access the SPACEBOT program. Your account or not. In those cases when you log in to your account, the Personal information collected by You by us during the use of the program can be compared and related to other Personal information collected by Us as part of your use of your account (for example, information about your personalities, contact details, age and gender, if they were provided during registration on our other sites). We do not check the Personal Information you provided, except as otherwise provided by the user agreement HAND or conditions of use of certain services, and can not judge its authenticity, as well as whether you have sufficient legal capacity to provide your Personal Information. Nevertheless, we assume that you provide reliable and sufficient Personal Information, as well as timely update it.

4.2.1. Information you provide to us:

When using the platform, we have the right to collect and use the following data about you:

- FULL NAME;

- Home address, including country of residence;

- E-mail address;

- Telephone number;

- Date of Birth;

- proof of identity (for example, a driver’s license, passport or identity card issued by a government agency);

- a social security number or any comparable identification number issued by a government agency;

- other personal information or commercial and / or identification information that, at our sole discretion, is necessary for us in order to fulfill our legal obligations to comply with anti-money laundering legislation (AML / CFT), for example, in accordance with the 4th EU Directive anti-money laundering, etc.

4.2.2 Information that we collect about you automatically.

- Information about your location.

- Information that is automatically collected through suppliers of analytical systems to determine your location, including your IP address and / or domain name, as well as any external page that connects you to you, your login information, browser type and version, time zone settings , types and versions of browser plug-ins, operating system and platform;

- Log information - information that is created when using the platform services, which are automatically collected and stored in our server logs. This may include, but is not limited to, information about a particular device, location information, system activity, and any internal and external information associated with the pages you visit, including the full URL of a single URL (URL), through and from our website or application (including date and time, page response time, loading errors, duration of visits to certain pages, information about the interaction of pages (e.g. scrolling, clicks, etc.), as well as the methods used to navigate from pages;

- Information about the SPACEBOT account;

- Correspondence - information that you provide to us in written or oral correspondence, including opening a SPACEBOT account, in customer support, including phone numbers used to contact us.

4.2.3. Information about you that we can obtain from other sources.

We may receive information about you if you use any other website that we use, or other services that we provide.

We may receive information about you from third parties, for example:

- from the banks that you use to transfer money to us, they will provide us with your basic personal information, such as your name and address, as well as your financial information, such as your bank account information;

- from business partners who can provide us with your name and address, as well as other, including financial information;

- ad networks, search engines that can provide us with anonymous or withdrawn information about you, for example, confirmation of how you found our application

- And so on

5. OBJECTIVES OF COLLECTING PERSONAL USER INFORMATION

5.1. General provision.

Pay attention to:

- our legitimate interests are that our company continues to innovate and improve the SPACEBOT program,

- the need to process your personal data in order to fulfill the obligation where necessary (to fulfill the obligation to which you are a party, or will be),

- as well as our legal obligations that we must comply with when processing your personal data in accordance with the requirements of applicable law,
We use various methods of processing your personal data depending on the relevant grounds.

5.2. SPACEBOT Administration may use the User’s Personal Data in order to:

- Identification of the User registered in the application;

- Providing the User access to personalized application resources;

- Establishing feedback with the User, including sending notifications, requests regarding the use of the application, the provision of services, processing requests and applications from the User;

- Determining the location of the User to ensure security, prevent fraud;

- Confirmations of the accuracy and completeness of personal data provided by the User;

- Providing the User with effective customer and technical support in case of problems associated with the use of the SPACEBOT program;

- Providing the User with his consent, special offers, information about new services, newsletters and other information on behalf of SPACEBOT or on behalf of SPACEBOT partners.

5.3. When making decisions about the processing of your personal data, we analyze the risks of using your personal data in order to comply with your rights and legitimate interests.

5.4. We may process your personal data for more than one legal basis, depending on the specific purpose for which we use your data, including:

- in order to effectively fulfill our contractual obligations, provide you with quality service, as well as comply with the rules that are presented to us by applicable law, we process the information you provide.

- in order to comply with legislative and / or regulatory requirements, including, but not limited to, anti-money laundering requirements, taking into account our legitimate interests and legal obligations, as well as the need to fulfill obligations to which we are a party, we process information provided by you, information about Your devices, information about third parties.

- implementing measures to combat fraud, in order to verify identity to protect against fraud, to comply with applicable laws, as well as to confirm the right to use our products and services, to ensure the security of our services, we process the information you provide, information about your devices, information about third parties.

- in order to provide you with information about new features, functions or services of the platform, recommendations for you and other users, processing applications for platform services, taking into account our legitimate interests, we process the information you provide, information about your devices, information about third parties.

- in order to ensure that the platform can work properly, to manage the internal operations necessary for the platform to function, including troubleshooting, data analysis, testing, research, statistical and research purposes, as well as notifying you of changes in our service, changing our conditions , and as part of our efforts to ensure the safety of the platform, we process the information you provide, information about your devices.

In case you have any questions related to specific legal grounds for the processing of your personal data, please contact us at the user support service.

6. WAYS AND TERMS OF PROCESSING PERSONAL INFORMATION

The processing of the User’s personal data is carried out during the period you use our application until we receive your Application for withdrawal of permission to process your data sent in the manner specified in clause 13.7 of this Policy by any legal means, including in personal data information systems using using automation tools or without using such tools.

In case of loss or disclosure of personal data, the SPACEBOT Administration informs the User about the loss or disclosure of personal data.

The Administrator agrees not to provide the User’s personal data to third parties for commercial purposes without the consent of the User to whom this data relates, except as otherwise specified in this Privacy Policy, as well as in cases provided by law. Including:

6.2. Disclosure of personal data

- Affiliates, business partners, parties to contracts for the performance and execution of any contract that we conclude with them or with you;

- Analysts and subjects of search engines that help us to improve and optimize our application;

6.2.2. We may disclose your personal information to third parties if:

- We sell or buy any business or assets, in which case we can disclose your personal data to a potential seller or buyer of such business or assets in order to continue providing services to you.

6.2.3. We are required to disclose your personal data in order to comply with any legal obligation or to ensure compliance with or application of our internal documents (including the Rules for using the platform, etc.) and other applicable agreements; or to protect the rights, property or safety of the platform, our customers or other persons. This includes exchanging information with other companies and organizations in order to protect against fraud and to comply with other measures established by applicable law.

6.3. In cases where it is reasonable and appropriate, we conduct and assist in investigations of illegal activities. In particular, we strive to:

- prevent and detect fraud and other criminal activities;

- comply with the requirements of state authorities;

- protect the platform from financial and insurance risks;

6.4. We cannot publish an exhaustive list of all third parties with whom we exchange your personal data, since the list of such persons depends on your specific use of our services.

If you want to receive additional information about with whom we provide your personal information, or provide you with a list that interests you, you can request this by writing to the user support service.

6.5. Exchange of data outside the European Economic Area

In some cases (including in order to satisfy your needs), we need to transfer your personal data to third parties outside the European Economic Area.

In these cases, we guarantee that we and our partners must take the necessary security measures to protect your data.

Using our platform, you consent to the transfer of your personal data to other countries, including countries that have different data protection rules that differ from the rules established in your country. In all such transmissions, we will protect your personal information as described in this Privacy Policy.

For more information, contact us at customer support.

6.6. Profiling and decision making automation

In some cases, including in order to meet your needs, we may use your personal data, for example, your country of residence and trade history. For example, if you often trade in a certain virtual currency, we can use this information to inform you about new platform updates. When we do this, we take all necessary measures to ensure the protection of your privacy and security, and we use only anonymous or identifiable data.

We can use automated decision making (ADM) to improve your experience or help you deal with financial crime. For example, so that we can provide you with a quick and efficient service, we can use ADM to verify your identity documents or to confirm the accuracy of the information provided to us.

6.7. Confidentiality when using digital assets and blockchain.

Your use of bitcoins, ether and other digital assets can be “recorded” in the public blockchain. Using public blockchains can lead to unintentional disclosure of private information.

Given the decentralized nature of the blockchain, the participation in the blockchain of third-party networks that are not controlled or managed by our platform, we cannot erase, modify or change your personal data from such networks.

7. STORAGE OF PERSONAL DATA

7.1. General Provisions

Our operations are supported by a network of computers, servers and other infrastructures and information technologies, including but not limited to third-party service providers. We and our third-party service providers store and process your personal data in the Russian Federation and in the territory of the European Economic Area.

7.2. Since the platform complies with the requirements of current legislation, including compliance with the requirements of AML, we are required by law to store some of your personal and transactional data, which will be used only in case of emergency. We will delete data that we no longer require in accordance with applicable law.

8. USE OF COOKIES AND SIMILAR TECHNOLOGIES

When you use our application, we may use cookies on your computer or other devices used to visit our application.

We use cookies to help us recognize you as a customer, collect information about your use of our services to better customize our services and content for you, and collect information about your computer or other access devices to ensure compliance with our AML obligations and to ensure that the security of your account is not compromised by detecting irregular or suspicious actions of the account.

We use both “session” and “persistent” cookies. A session cookie session expires when you log out of your account or close your browser. Cookies remain on your computer or mobile device until they are deleted. Most web browsers are set to accept cookies by default.

9. OBLIGATIONS OF THE PARTIES

9.1. The user must:

9.1.1. Provide reliable information about personal data necessary to use the application.

9.1.2. To update, supplement the provided information on personal data in case of change of this information.

9.2. SPACEBOT Administration is required to:

9.2.1. Use the information received solely for the purposes specified in this Privacy Policy.

9.2.2. Ensure that confidential information is kept confidential, not disclosed without the prior written permission of the User, and also not to sell, exchange, publish, or otherwise disclose the User’s personal data transferred, except as otherwise provided in this Privacy Policy.

9.2.3. Take precautions to protect the confidentiality of the User’s personal data in accordance with the procedure usually used to protect this kind of information in existing business transactions.

9.2.4. Block personal data related to the relevant User from the moment of contacting or requesting the User or his legal representative or authorized body for the protection of the rights of personal data subjects for the period of verification, in case of revealing inaccurate personal data or illegal actions.

9.3. Release of SPACEBOT Administration from liability.

In case of loss or disclosure of Confidential Information, SPACEBOT Administration is not responsible if this confidential information:

- Has become public domain before its loss or disclosure.

- Was received from a third party until it was received by the SPACEBOT Administration.

- It was disclosed with the consent of the User.

10. USER RIGHTS

10.1 In accordance with applicable laws and regulations, we may from time to time send you information about products, additional services or events using the information received from you. When you create a SPACEBOT account, you agree to receive informational messages from us. We provide the opportunity to refuse to receive all messages from us (newsletters and so on). We will never share your personal information with third parties for direct marketing or other unrelated purposes without your written consent. We cannot allow you to refuse letters that we send you for specific legal or administrative purposes.

10.2. Cookies.

You can refuse session cookies if you have permission to use a browser or browser, but choosing to delete or disable our cookies may interfere with your use and platform features.

10.3. Right to rectification.

You have the right to correct any personal information.

10.4. The right to delete (oblivion).

You have the right to ask us to delete your data when we no longer need it for the purposes of fulfilling our duties, as well as complying with applicable laws.

10.5. You may be entitled to transfer certain personal data between personal data operators, for example, to transfer your account information from one online platform to another.

10.6. Location information.

You can stop the collection of location information through the settings of your device or perform the standard removal process to remove our applications from your device; however, since we use such data to satisfy legal requirements, as well as to constantly monitor fraud and monitor risks, choosing to remove or disable location services may interfere with your use of the platform services.

10.7. At any time, you can withdraw your consent to the processing of personal data by sending us an application for withdrawal of consent to the processing of personal data, completed in the form specified in Appendix No. 1 to this Policy.

Information for citizens of the Russian Federation: after receiving an application banning the use of personal information, the operator must stop working with the data and, if possible, ensure their destruction. The time period within which the operator must fulfill this obligation, in accordance with paragraph 5 of Art. 21 of Law No. 152-FZ, does not exceed thirty days. Federal law imposes certain restrictions on the withdrawal of permission to process information. The operator can process and transmit data if it is necessary to administer justice (clause 2 of part 2 of article 11 152-FZ) or protect the life (health) of the subject (paragraph 6 of part 2 of article 11 152-FZ).

11. ACCESS TO INFORMATION

In accordance with applicable law, you may be entitled to access the information we have about you.

Your right of access may be exercised in accordance with relevant data protection laws.

12. AMENDMENTS TO PRIVACY POLICY

Any changes that we may make to our Privacy Notice will be published on this page and, if necessary, will be emailed to you.

Please check for updates or changes on the specified page.

13. PROTECTION OF MINORS

The platform services are not intended for persons under 18 years of age, hereinafter referred to as “Minors”, and we do not knowingly collect personal information from minors.

If we find out that we accidentally collected personal information from a minor, we will take legally permissible measures to remove this information from our records. The platform will require the user to close their account and will not allow the use of their services.

14. OUR CONTACTS

Any questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to the user support service.

If you think that we do not answer your questions or problems, you can contact the personal data operator.

15. SETTLEMENT OF DISPUTES

15.1. Before applying to the court with a claim for disputes arising from the relationship between the Application User and the SPACEBOT Administration, it is mandatory to submit a claim (a written proposal for the voluntary settlement of the dispute).

15.2. The recipient of the claim, within 30 calendar days from the date of receipt of the claim, shall notify the claimant in writing of the results of the consideration of the claim.

15.3. If the agreement is not reached, the dispute will be referred to the judicial authority in accordance with the applicable laws of England and Wales.

15.4. This Privacy Policy and the relationship between the User and the SPACEBOT Administration are subject to the applicable laws of England and Wales.