PRIVACY POLICY
Entering into (accepting) this User Agreement via the direct use of the Services, viewing information, etc., including, but not limited to: the Website, Services, feedback forms; acting freely, by their own will and in their own interest or in the legitimate interest/representation on behalf of the User and/or on consent/approval of the legal representative, as well as confirming their legal capacity, the User agrees and accepts the terms of the Privacy Policy (hereinafter referred to as the Policy) in relation to Personal Data, laid out in this User Agreement and in this section.
The policy laid out in this section of the User Agreement determines: types of Personal Data, methods of obtaining Personal Data, actions performed with Personal Data, the purposes of processing Personal Data, methods of protecting Personal Data, legal grounds for processing Personal Data and other terms regarding processing Personal Data used by Metoshi and third parties processing Personal Data.
The processing of Personal Data means any action (operation) or a set of actions (operations) performed with Personal Data provided for by this User Agreement, including:
| № | Type of operation | Description of the operation |
|---|---|---|
1 | Collection | The process of obtaining Personal Data in the ways established by this User Agreement. |
2 | Recording | The process of acquiring Personal Data for storage on digital (electronic) media, as well as the result of this process. |
3 | Accumulation | The process of forming an unstructured array of Personal Data in the databases of the Product. |
4 | Systematization | The process of organizing Personal Data in accordance with the logic (algorithms) specified in the databases of the Product. |
5 | Storage | The process of storing Personal Data on digital (electronic) media in the ways designated for such media in order to ensure appropriate access to them later on. |
6 | Extraction | The process of automatic extraction (construction) ofstructured Personal Data from unstructured or semi-structured Personal Data. |
7 | Analysis | The process of researching, filtering, transforming and modeling Personal Data in order to extract useful information and make decisions based on it. |
8 | Clarification | The process of changing (updating) Personal Data. |
9 | Use | The process of utilizing Personal Data for the purposes provided for in the User Agreement. |
10 | Depersonalization | The process that makes it impossible to establish a connection between Personal Data and a specific User without resorting to additional information. |
11 | Blocking | Temporary suspension of processing Personal Data (except when processing is necessary to clarify Personal Data). |
12 | Transfer | The process of transferring Personal Data from their place of storage to a third party in the form of a digital bitstream by means of telecommunications over a data transmission channel, by exchanging the data, copying, distributing them, providing access to them for subsequent processing by means of computer technology. |
13 | Cross-border transfer | The transfer of Personal Data to the territory of a foreign state, to the authorities of a foreign state, to a foreign individual or a foreign legal entity. |
14 | Provision | Actions aimed at the transfer of Personal Data to a specific party or parties. |
15 | Disclosure | Actions aimed at the transfer of Personal Data to any number of unspecified parties. |
16 | Destruction | A sequence of actions and operations using software or hardware tools, including physical destruction of physical storage media intended for the irreversible deletion of Personal Data, as a result of which such data is destroyed irrevocably, making it impossible to restore their content. |
Metoshi and third parties process the User's Personal Data if they are filled in and/or sent by the User on their own via special forms located on the Services and/or obtained with the consent/approval of the User from third-party resources (social media, etc.) where the User is registered or which they use (if it is provided for by the functionality of the Service), and/or directly from the User using feedback forms and/or received with the consent/approval of the User automatically in the form of data (information) from the devices and software used by the User.
Metoshi processes the User's Personal Data automatically only, using computer equipment and software. In its work, Metoshi strives to use modern, up-to-date and at the same time reasonable methods and means utilized in informational, technological and technical systems for processing Personal data.
Metoshi does not collect or process special categories of Personal Data related to the User’s age, race, nationality, political opinions, religious or philosophical beliefs, medical status, personal life, as well as biometric Personal Data that characterizes the physiological and biological characteristics of the User which can be used to identify them.
The Services are not intended for use by persons under 13 years of age or other age provided for by the laws of the country of citizenship/affiliation/residence of the User. Metoshi does not knowingly collect Personal Information about the age of the User, including personal information from children under 13 years of age. In the event that Metoshi discovers that a child under the age of 13 provides Personal Data or personal information, Metoshi immediately deletes it. If the legal representative (parent or guardian) is aware that a person under the age of 13 or other age of legal capacity has provided Personal Data or other personal information, they may contact Metoshi so that the necessary steps can be taken.
Metoshi strives to ensure that the Users’ interaction with the Website and Services is as informative as possible and meets the interests of the Users. Therefore, Metoshi considers it important to notify Users that Metoshi and third party service providers (services) with which Metoshi cooperates (such as Google Analytics by Google Inc.) process or may process Cookies and similar technologies and that the User needs to know which Cookies are processed and for what purposes. This will help toward protecting the User's Personal Data. More information about the processing of Cookies can be found in this section and in the COOKIE NOTICE section of this User Agreement.
In the process of processing Personal Data, Metoshi uses a specialized external third-party Google Analytics service by Google Inc. to analyze the actions of Users on the Services. This information is provided to Metoshi from the Google Analytics service in the form of Anonymized Data, and is processed by Metoshi for the purposes provided for by this Policy.
Metoshi recommends that the User independently familiarize themselves with the terms of service of Google Analytics and the technologies used by Google Inc. when collecting and processing Personal Data of the Subject (https://policies.google.com/technologies/partner-sites ), including Cookies (https://policies.google.com/technologies/cookies ), and their obligations to protect privacy and security of the data obtained through the Google Analytics service, as well as the ways to manage one’s privacy modes (https://support.google.com/analytics/answer/6004245 ).
In order for Users to make payments or other transactions for paid and/or restricted resources of the Service via the Internet, Metoshi suggests that the User use dedicated Payment services or other third-party resources provided on (built into) the pages of the relevant Services.
In the process of making a payment or other transaction through the Payment Services or other third-party resources offered by Metoshi as a payment or transaction tool, the Payment Service or other resource may process Payment Information or other information provided by the User for the purposes provided for in this Policy and/or other information on the terms and for the purposes provided by the service.
Depending on the country (region), legislation and technical availability, Metoshi may choose to use the services of different Payment Services, therefore, it is recommended that the User independently familiarize themselves with the terms of the proposed Payment Service, the technologies used by such a service, the legal bases it operates on when processing payments, the matters of collection and processing of the User’s Personal Data, and their obligations to protect the confidentiality and security of data received through their Payment Service; Users are encouraged to analyze the information received and make their own decision on whether to use or not to use the suggested Payment Service.
Metoshi never processes the User’s Payment Information in its normal operation, except for information received from the Users in relation to the orders made by them, and information from the Payment Services about any completed or rejected transactions carried out by the Users in relation to specific orders.
The table below describes the categories and types of Personal Data, as well as the purposes of collecting and processing Personal Data performed by Metoshi or third parties when the User uses the Website and/or its Services:
| Category of Personal Data | Types of Personal Data | Purpose of processing Personal Data |
|---|---|---|
User Account Information | - nickname (pseudonym); - country; - contact phone numbers; - e-mail addresses; | - For Registration/Authorization, as well as creating an Account; - To identify the owner of the Account and protect the Account when the User Authorizes and/or logs in; - To provide the User with access to certain Services, including personalized ones, such as the Personal Profile and/or Account; - To provide the Service in a specific localization language, if such a language is supported by the Services (English is the default setting); - To provide the User with special offers, Services, newsletters and other information on behalf of and on the recommendation of Metoshi; - To run contests, sweepstakes and other promotions, which can be run by Metoshi and/or its partners and/or third parties; - To conduct surveys and research in order to improve the quality of the Services or services provided, control the results of marketing campaigns, control User satisfaction and the quality of services provided through the Services; - To send advertising, news and information mailings to the Subject from Metoshi or third parties; - To promote Metoshi products and services; - To prevent or suppress actions of the User or third parties that are illegal and/or unauthorized and/or prohibited by Metoshi; - To establish communication with the User, including sending notifications, requests and payment information regarding the use of the Product and/or its Services, as well as to provide services and process requests and claims from the User, and provide customer support; - To conclude and execute the present User Agreement or a separate license agreement and/or other agreement/transaction concluded in the form of an offer or otherwise legally between the Parties; - To ensure compliance with legal requirements or the User Agreement; - To prevent or suppress illegal and/or unauthorized actions of Users or third parties; |
User Data | - order information (order details, payment status, transaction date/time, payment amount, payment method, payment purpose and used bonuses); - data contained in messages submitted through the Services feedback form; - device location information (depending on device settings); - device IP address; | - To enable Users to interact (exchange information) with other Users; - To ensure proper operation (functioning) and/or use of the functionality of the Services; - To synchronize data when operating on multiple devices simultaneously and across multiple Services; - To confirm payments made by the User; - To process incoming requests from the User with the view of providing assistance, technical support and customer support in regard to the User’s use of the Services or any issues arising from their use; - To ensure compliance with legal requirements or the User Agreement; - To prevent or suppress illegal and/or unauthorized actions of Users or third parties; - To expand the scope of Services provided; - To check the information for compliance with the User Agreement; - To confirm the accuracy and integrity of the Personal and other information provided by the User; - To suppress or prevent violation of the User Agreement and/or damage to the Website; |
Payment Information | - Bank card information; - Billing address or postal code; - Bank account information; - Payer’s credentials (address, phone number, date of birth, social security number, TIN or another relevant taxpayer ID issued by a government agency); | - To enable User payments; - To confirm User payments; - For other purposes provided for by the relevant Payment Services; - To ensure compliance with legal requirements or the User Agreement; - To prevent or suppress illegal and/or unauthorized actions of Users or third parties; |
Cookies | - small text fragments; - files; - pixel tags; - web beacons; - device fingerprints; | - To make the User's interaction with the Website and the Services more efficient; - To obtain statistical and analytical data on the use of the Website and the Services in order to improve their functioning; - To receive and process Anonymized Data; - For other purposes provided for by the relevant service providers (services) with which Metoshi cooperates; |
Anonymized Data | - information about the actions of Users on the Service, such as: tracking page hits and interactions with the Website interface; - information about the device used to access the Services (brand and type of the device used, screen resolution, any device identifiers, and the IP address of the device); - information about the browser used on the device, as well as the type and version of the operating system installed of the device; - information about the current location of the device (depending on device settings); - source: determining where the user came to the Website from, from which specific site or ad; | - To analyze the performance of the Services with the view of improving their quality; - To develop and deliver new Service updates and modifications to the Users; - To analyze the actions of Users on the Services; - To obtain statistical and analytical data useful for improving the performance of the Services; - To produce statistical reports for marketing purposes; - To determine the location of the Subject to ensure security and prevent fraud; - To enable other third parties acting on behalf of Metoshi to process this data; |
In view of the availability of the Website and/or its Services in different regions and countries and the need for decentralized management of information databases related to the Website, Metoshi has the right to entrust the processing of Personal Data to its Affiliates, while these companies are obliged to comply with the principles and rules for the processing of Personal Data provided for by this User Agreement and/or separate license agreements and/or other agreements/contracts concluded with the User in the form of an offer or in another legal way as well as the laws of the country of registration of these companies.
Metoshi and its Affiliates have the right to process Personal Data personally or entrust the processing of Personal Data to a third party, based on a contract concluded with that third party or on other legal grounds. The third party processing Personal Data on their behalf is obliged to comply with the principles and rules for the processing of Personal Data provided for by this User Agreement and federal laws. Metoshi's instructions to this third party must define: a list of actions (operations) with Personal Data that will be performed by the third party processing Personal Data as well as the purposes of processing, the obligation of such a third party to maintain the confidentiality of Personal Data and ensure the security of Personal Data during their processing. Requirements for the protection of the Personal Data under processing must also be specified.
The procedure for collecting, storing, transferring and other types of processing of Personal Data, the security of Personal Data processed by Metoshi is ensured by implementing the legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of Personal Data protection. Metoshi takes all the necessary measures to protect and preserve the User's Personal Data from unauthorized access by third parties. Metoshi values the User's trust expressed in providing Metoshi with their personal information. Therefore, Metoshi strives to use commercially reasonable means of protecting it. However, Metoshi points out that no method of transmitting information over the Internet or method of electronic storage is 100% safe and reliable, and Metoshi cannot guarantee its absolute safety. In the event of a breach of Metoshi's security measures used in the processing of Personal Data that may result or is highly likely to result in the violation of the User's rights, Metoshi is obliged to notify the User no later than 72 hours after the discovery of such breach.
Metoshi has the right to carry out Cross-Border Transfer of the User's Personal Data. Prior to the start of the Cross-Border Transfer of Personal Data, Metoshi is obliged to make sure that the foreign state to which the transfer of Personal Data is supposed to be carried out provides reliable protection of the rights of Personal Data subjects. Cross-border Transfer of Personal Data to the territory of foreign states that do not meet the above requirements can be carried out only with the User’s written consent to the Cross-Border Transfer of their Personal Data and/or in case of the execution of an agreement to which the User is a party.
Metoshi sets as its most important goal and condition for the implementation of its activities the observance of the personal and civil rights and freedoms in the processing of the Users’ Personal Data, including the protection of the rights to privacy and inviolability of personal and family secrets. Metoshi maintains the confidentiality of Users' Personal Data. This means that Users' Personal Data is not sold or transferred to third parties without legal grounds, such as: implementation of the current legislation, official requests from authorized state bodies, the consent of the User, and the execution of this User Agreement. The User independently bears the risks of disclosing their Personal Data in case of voluntary provision of such information about themselves for general access to an unlimited number of persons.
Personal Data is processed for the period necessary to achieve the Purposes of Personal Data processing, or until the User or their legal representative and/or their heir (legal successor) withdraws consent to its processing. Upon achievement of the Purposes of Personal Data processing or upon withdrawal of consent to their processing, Personal Data shall be destroyed, unless otherwise provided by law and/or agreement to which the User is a party (beneficiary), while Metoshi has the right to continue processing Personal Data without the consent of the User if grounds for this are provided for by the current legislation and/or this User Agreement and/or the terms of a separate license agreement and/or other agreement/contract concluded between the Parties in the form of an offer or in another legal way.
This Policy has been drawn up taking into account the interests of Users located in different countries. Metoshi has also tried to take into account other requirements governing the processing of Personal Data. In its work, Metoshi strives to comply with all modern standards related to the requirements for the processing and protection of Personal Data. However, due to the diversity of these standards across the world, Metoshi cannot guarantee full compliance of its Policy with the standards in the field of protection and processing of Personal Data established by a particular region (country).
If the User does not agree with the current Policy, they may forgo the use the Website and/or its Services.This User Agreement will reflect any changes to the Personal Data Processing Policy, which is valid indefinitely until replaced by a new version.
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