20th of July 2022

Privacy Policy

This Privacy Policy defines the procedure for processing and protecting the information about the Users, including personal data of Users, which Edu Terra, LLC (ООО «Эдьюкейшн Терра» in Russian) (hereinafter referred to as the Company) may receive during registration/authorization and/or use by Users of any of the Company's software products or website (hereinafter collectively referred to as – Company Services, Services).

Before using the Company's Services, the User has to research himself with the terms of this Policy. If the user does not agree with the terms of the Policy, the use of the Services must be immediately terminated.

Personal data means any information related directly or indirectly to a specific or identifiable user of any of the Company's Services, as well as information that identifies, relates to, describes, is associated with or can reasonably be associated, directly or indirectly, with a specific consumer or household.

1. General provisions

1.1. By using the Company's Services, the User agrees that:

1) User has read the terms of this Policy in full before using the Company's Services;

2) Information processing is necessary to fulfill the Company's contractual obligations to the User under the License Agreement (https://educationterra.com/tos), including ensuring the operation of the Company's Services. The beginning of the use of the Company's Services by Users in any form means that they accept all the terms of this Policy in full without any exceptions and restrictions;

3) The Policy may be changed by the company without special notice and without payment of any compensation in this regard.

1.2. By accepting the terms of this Policy, the User expresses a consent to the processing of Information by the Company for the purposes provided for in this Policy, as well as to the transfer of Information to third parties in the cases listed in this Policy.

1.3. Disabling and/or blocking by the User the option of the web browser to receive data from cookies means a ban on the collection and processing of data from cookies by the Company.

1.4. The Company's representative in accordance with the General Data Protection Regulation (GDPR) for users located in the European Economic Area (EEA) or Switzerland is Appfit Studio s.r.o. registered at: Proutěná 405/11, Újezd u Průhonic, 149 00 Praha 4

2. Amount of collected information

The Company collects and processes the following types of Personal Data:

2.1. Personal data posted by Users about themselves when registering/ using the Company's Services, which may include: name, email address, phone number, country of residence, address, age, spending and income data, account balance, etc.

Personal data provided by users voluntarily is processed by the Operator to the extent necessary to fulfill obligations.

2.2. Information about the device itself: device type, operating system type and version, model and manufacturer, screen size, screen pixel density, orientation, sound level, battery, device memory usage;

2.3. Non-personal data required for the operation of the Company's Services.

These include data automatically transmitted to the Company's Services during their use using software installed on the User's device, including IP address, User's geo-location (mobile application), advertising identifiers, OAID and others related to the User's operating system), data from cookies, information about the browser, operating system, access time, search queries, information about the location and movement of the User's device (to adapt the Company's Services to the User's current location).

3. Purposes of the collection and processing the information

3.1. The Company collects and processes only the Information that is necessary to fulfill the Company's obligations to provide the Company's Services.

3.2. The Company may use the Information to:

3.2.1. identification of the party to the agreement between the User and the Company;

3.2.2. providing services to Users using the Company's Services and further improving the Company's Services, developing new services and services based on feedback/information from Users;

3.2.3. responding to User requests to the support service, informing Users about the capabilities of the Company's Services, sending requests regarding the use of the Company's Services;

3.2.4. marketing;

3.2.5. performing statistical and other studies based on depersonalized data;

3.2.6. providing data from cookies to third parties with whom the Company has concluded contracts for the demonstration by third parties of targeted advertising and information materials on the Internet and/or for the purposes of providing other services to Users by third parties in accordance with the procedure established by law.

4. Processing of the information

4.1. The information is processed in accordance with applicable law.

4.2. The Company processes the User's personal data until the purposes for which they were collected are achieved and deletes them upon termination of use of the Services, or until the expiration of the mandatory storage of personal information provided for by applicable law.

4.3. The Operator transfers personal information to third parties to achieve the goals specified in Politics. Such third parties may include:

4.3.1. partners, such as owners of websites and applications, advertising networks and other partners providing services related to the placement and display of advertising on websites or services owned or controlled by partners;

4.3.2. any national and/or international regulatory authorities, law enforcement agencies, central or local executive authorities, other official or state bodies or courts in respect of which the Company is obliged to provide information in accordance with applicable law upon request;

4.3.3. to third parties, if the User has consented to the transfer of Personal Information or the transfer of Personal Information is required for the provision of services or the fulfillment of a certain agreement or contract concluded with the User;

4.3.4. any third party in order to ensure the legal protection of the Company or third parties in case of violation of the User Agreement of the Company's services, this Policy or the conditions governing the use of individual Services, or in a situation where there is a threat of such violation.

4.4. The Operator may exchange information obtained through tools such as cookies, registration files and device identifiers with third-party organizations that ensure the operation of automatic data processing technologies of the Services. The Operator does not control and does not influence the methods of data processing control of such third-party organizations or how they can be used.

5. Rights of the User

5.1. The User has the right to receive information about his personal data processed by the Operator.

If the information about the User is incorrect or incomplete, the User can correct and/or supplement the information himself, if the Service allows it, or contact the Company and request correction and/or addition of incorrect information.

5.2. In addition, the user has the rights to:

a) require the complete deletion of Personal Information;

b) require restrictions on the processing of Personal Information;

c) object to the processing of Personal Information;

5.3. In order to exercise any of the above rights, the User can contact the Company by e-mail support@educationterra.com. The Operator ensures the implementation of the above rights only in relation to the information to which there is access and the storage of which is carried out by the Company. To process the request, the Company must first identify the user.

5.4. When processing information for marketing purposes, the User may request the termination of data processing for such purposes. To exercise this right, you must contact the third-party service providers listed in Section 6 of the Privacy Policy.

6. Rejection to process personal data

6.1. The User may prevent and/or manage the collection and processing of data related to the use of the Services by following the instructions given below.

Google Analytics. To opt out of tracking Google Analytics data, the User can install and activate the Google Analytics Blocker. The User can also manage and/or delete «cookies» previously set by Google Analytics through the browser settings. Additional information about the practical methods of data processing and the corresponding instructions of Google Analytics can be found at the link https://support.google.com/analytics/answer/6004245 (section «Information for visitors to websites and applications where Google Analytics is used»).

6.2. Blocking cookies

Browsers that allow you to refuse to accept cookies:

a) Internet Explorer: https://support.microsoft.com/kb/278835 (this page links to additional information for different versions of IE — the mobile version is located at www.microsoft.com/windowsphone/en-us/howto/wp7/web/changing-privacy-and-other-browser-settings.aspx )

b) Chrome: https://support.google.com/chrome/answer/95647

Blocking all «cookies» can negatively affect the usability of many Services and Websites.

7. Feedback

7.1. Users have the right to send requests, including requests regarding the use of their personal data provided for in Section 5 of this Privacy Policy, in writing to the address: office 723, 4a Inzhenernaya St., Novosibirsk, Russia 630090, or in the form of an electronic document signed with a qualified electronic signature in accordance with applicable law, to the email address: support@educationterra.com.

7.2. In order to exercise the stated right, the Company may request: (1) to provide sufficient information to ensure that the user is the person about whom the Company has collected Personal Data, and (2) to describe the request in sufficient detail so that the Company can understand, evaluate and respond to it. The Company may not respond to requests that do not meet these criteria. The Company will use the Personal Data provided in the request only for verification and execution of the request. The Company will respond to the request within 30 days of its receipt.