Personal Data Processing Policy
I. Declaration on Personal Data Processing Policy
Confidentiality is a priority for the Developer. The purpose of the Policy is to ensure the protection of the rights and freedoms of a person and a citizen when processing their personal data, including the protection of the rights to privacy, personal and family secrets from unauthorized access and disclosure. All core features are secured with end-to-end encryption: one-on-one messages, group messages, private media sharing and secondary devices. This means that the encryption keys are stored only on the clients' devices and no one, not even Application itself, has access to them.
II. Information Collected by Developer
The processing of personal data is carried out by the Developer on a lawful and fair basis, acting reasonably and in good faith based on the following principles: - the legality of the purposes and methods of processing personal data; - good faith; - the compliance of the purposes of the processing of personal data with the goals predetermined and declared by collecting personal data, as this of the Company; - correspondence of the volume and nature of the personal data being processed, the methods of personal data processing to the purposes of personal data processing.
When registering in the Application, the User provides the following information to the Developer: contact phone number, email address, date of birth. This Policy applies to the processing of personal data collected by any means, both active and passive, both through the Internet and without it, from persons anywhere in the world.
Developer collect the minimum information required to achieve the purposes set out in this Policy (see below), and it has the ability to limit such collection, as specified below under "Your Choices":
(a) Registration and Account Information: When User uses various Services he\she give personal information (e.g., name, email, birth date, age, phone number and, when necessary, billing information) and User become not anonymous to Developer.
(b) Social Media Information: If User sign in to account through third-party social media sites like Facebook, Twitter or VK, User agrees to give Developer on-going access to User personal information on such sites (e.g., public profile, friend list, accounts followed by User or who follow User, email address, birthday, work the Developertory, education the Developertory, interests, current city, and video viewing). The Developer may receive certain information about User which is stored on social media sites if users of those sites give access to their profiles and User is one of their friends or connections, depending upon User settings on those sites.
(c) Activity Information: While using the Application Services, the Developer will collect, and other users can see, User connection status, whether User has received and seen messages sent to User and information related to the messages User have sent and received such as who messaged who and at what time; if User does not want people to know that User's online or that User seen messages, User can change these options in Users settings. As for delivered status and call information (length of the call, missed calls etc.), the Developer believe they are important for other Application users and therefore cannot be cancelled. For Secret Chats, the Developer will notify the other members of any screenshots User've been taking (so please respect and do not take them).
The Developer will receive interaction information from Users use of our Services. When User interacts with Public Accounts, bots and Communities on our Service, the Developer may obtain information about the messages User have liked, comments User have left and also the Developer websites User via the Application through links in them. When User use Chat Extensions and shopping solution the Developer may know which items User searched and shared. In addition, the Developer collects information about the accounts User have visited and the content User has made in order to improve the relevance of Services.
The Developer collects information about the value-added services User are using over Application and/or apps (such as games) User have downloaded through Application. This includes whether User is presently online, Users personal preferences (such as connecting the service to Application) and the way User use that service (for example how often, for how long). The Developer may also tell other Application users that User is using a certain service or app (to recommend them to try that service as the Developer).
(d) Information from Other Sources: The information the Developer collect may be combined with information from outside records (e.g. demographic information and additional contact information) that the Developer has received in accordance with the law.
(e) Additional Information: The Developer collects additional information when User access our App through a certain device (e.g. Users mobile device's unique identifier; information about Users device's operating system, Users browser, browser or operating system language; Users wireless network, and User mobile carrier; the Application call log). The Developer may also collect User WPS location data – User can choose whether to allow this by changing User geolocation tracking settings.
III. Uses and Retention
By providing their personal data to the Developer, the User agrees to their processing by the Developer. Including in order for the Developer to fulfill its obligations to the User of the Application, promote the Sellers/Producers of goods and services, conduct electronic and SMS surveys, monitor the results of marketing campaigns, and invite to participate in ongoing programs to improve the quality of service, customer support, holding raffles among the Users of the Application, monitoring customer satisfaction, as well as the quality of services provided by the Developer. This Policy governs any kind of personal data and personal information processing (any information that allows establishing a person, and any other information related to this).
The User, by registering in the Application, gives the Developer/her consent to transfer the Developer data (including, if available, personal data) only to those Commercial users, including producers of goods/services, retailers, etc. (hereinafter referred to as "Brands"), for which the User directly gives the Developer consent (hereinafter referred to as "subscription"), including, but not excluding the other, to the club Deals Direct. Thus, by subscribing to Brands, the User consents to interact with Brands, by the ways not contradicting to the current legislation, including: receiving video messages, personal discounts, offers, information about the product, Brand and its features, new launches - expanding the product line , information from celebrities, opinion leaders about the brand, etc. The invitation is made by SMS or sending an e-mail, with a link to download the application Deals Direct.
The Developer mission is to constantly improve Services and provide User with new experiences. As part of this mission, it uses information for the following purposes:
(a) Make service available: Developer uses Registration and Account information to (i) register for the Application and create User Account; (ii) create profile and make it visible; (iii) process payments (if necessary); (iv) create ID; (v) provide customer service, give User information about the Developer/her account, and respond to requests; (vi) personalize experience by providing content (such as games and etc) on the Service, including targeted advertising of Application services and other 3rd party services that Developer believes may be of most interest to the User; personalization may include automated decisions about what User will view and when, but that will not have legal effects on User.
(b) Improve Application Services: the Developer uses log information and usage information (as described above) to better understand network behavior and trends (numbers of messages made by users, typical destinations, lengths, network type, etc.), detect potential outages and technical issues (this helps Developer notice things like a drop in call volume in a certain geography, a shift in call length, a change in typical networks, etc.) to improve Services.
(c) Provide Interesting Offerings to User and others: As part of value-added services provided by App or by a third party within App, the Developer may use the information to continuously optimize and personalize those services and send Users personal updates about new offerings which Developer believe User will find relevant.
Sending a message to a bot or Public Account, subscribing to a bot or Public Account will allow admins of that bot or Public Account to send User notifications and personal messages. If User does not wish to receive such notifications, he/she may adjust account settings to decline them or opt-out at any time from receiving further notifications. The user will be asked to allow the use of User location data before App provides specific location services offerings, and may also adjust phone preferences to disable the use of location data at any time.
(d) Process User Payments: Developer may use Information like name and phone number to process payments for Services through a secured third-party service provider and, on an aggregate basis to determine charges for our phone carriers and other service providers.
(f) Communicate With User: As part of the Viber family, we want to keep in touch with User. We use User information to contact User (via message or other means) to maintain the App, including User Viber Out User Account, to comply with User stated communication preferences or to provide updates about other services.
Data Retention: Unless otherwise specified, the Developer retains information as long as it is necessary and relevant to achieve the purposes referred to above or to enable the App to comply with legal data protection retention obligations. Upon deactivation of the User account, the Developer will minimize the personal data kept about only to such data which are required to keep to comply with laws, or other legal reasons. The Developer may keep activity data on a non-identifiable basis to improve services.
The User has the right to withdraw her/the Developer permission to use personal data without explaining the reasons for refusal by informing the Developer about her/the Developer refusal by sending a corresponding application to the Developer email address: firstname.lastname@example.org.
In the event of the User's rejection in the Application to interact with the Brand, resulting in the cancellation of a subscription to it, the Brand immediately ceases any interaction with the User.
The developer is not responsible for the information provided by the User in the Application in a generally accessible form. This does not apply to the actions and Internet resources, software and applications of third parties.
Data is kept safe with the App, but the Developer does share personal information with trusted third parties to provide Users with the services, as follows:
(a) The Developer Corporate Family. You can choose to delink your account from the Developer Corporate Family account at any time by editing your profile on the app.
(b) App Providers and other Third parties: the Developer may disclose information to service providers and other third-parties under contract who help with providing Users and others Services on Developer' behalf or other services provided by third-parties via Services (such as, but not limited to, fraud and spam investigations, payment processing, site analytics and operations, providing special partnership features in App service– either on an aggregate non identifiable basis, or using a unique identifier which is not attributable to the User). They are required to secure the data they receive.
(c) Legal and Law Enforcement: the Developer may disclose User information to law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability.
Relations related to the processing of personal data and information about users of the Application are governed by these Regulations and other official documents of the Developer. In all other respects that are not directly reflected in the Policy, the Developer undertakes to be guided by the norms and provisions of the Federal Law dated July 27, 2006 N 152-FZ "On Personal Data" and Regulation (EU) 2016/679 (General Data Protection Regulation).
The App may contain links to other third-party websites or User may access Apps from a third- party site. The Developer is not responsible for the privacy practices or the content of these third-party sites.
The Application User, who provides personal data and information, agrees with the provisions of this Policy. The Developer reserves the right to make any changes to the Policy at any time at its discretion in order to further improve the system of protection against unauthorized access to the personal data reported by Users without the consent of the User. When significant changes are made to the Policy, a notice is placed in the Application along with the updated version of the Policy.