PRIVACY POLICY
This personal data protection policy (hereinafter referred to as the Privacy Policy) is developed under the Federal Law of the Russian Federation of 27 July 2006 No.152-FZ ‘On Personal Data’ and the Council of Europe Convention of 28 January 1981 No.108 on the protection of individuals with regard to automatic processing of personal data when using the MARMA mobile app (hereinafter referred to as the App).
Interregional Contact Center acts as a personal data operator (hereinafter referred to as the Operator) and shall protect users’ rights and freedoms while processing their personal data and identify personal data processing objectives, elements of personal data to be processed, and actions (operations) to be undertaken regarding personal data.
DEFINITIONS
The Personal Data shall mean any information that refers directly or indirectly to an identified or identifiable individual that is provided while using the App.
User shall mean an individual providing their personal data when using the App.
The Personal Data processing shall mean 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), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data until the data processing objectives are met or such objectives no longer apply, unless otherwise provided by federal law.
Personal data protection shall mean obligatory compliance of the Operator with the requirement of preventing its disclosure or dissemination to third parties in absence of the consent of the User or any other legal grounds.
A cookie file shall mean a piece of data that a website requests from a browser used on a computer or mobile device. Cookies allow the website to ‘remember’ the actions or preferences of the User. Cookies are stored locally on the User's computer or mobile device. The User can independently manage cookies by changing the browser settings. Changes to user preferences that block Cookies may lead to inaccessibility of certain components of the App.
The following anonymized statistical data is collected (from Cookies) when the User visits the App, including:  
type of action (click, mouseover, etc.);
date and time of action performed; 
page URL; 
IP (without the ability to work with IP-addresses in statistics); 
clientID (browser identifier by cookie file); 
screen resolution; 
class of the clicked HTML element.
General Provisions of the Personal Data Processing
Use of the App by the User shall mean acceptance of this Privacy Policy. Should the User disagree with this Privacy Policy, they must stop using the App. 
This Privacy Policy shall apply to the App. The Operator does not control, nor it is responsible for the third-party sites (and their content) to which the User can go using the links available on the App.  
The Operator processes the following Users’ personal data:
surname, first name, patronymic;
telephone number;
email address;
cookies.
The Operator processes the following Users’ devices tools:
camera;
microphone;
photo and video gallery.
The personal data processing shall be carried out automatically and nonautomatically, and include the following actions: collection, recording, systematization, accumulation, storage, clarification (update, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction;
By using the App, the User agrees that the Operator may use anonymized statistical data and Cookies for their subsequent processing by Google Analytics and Yandex.Metrics. 
The objectives of the Users’ personal data processing are:
implementation of a set of actions aimed at identifying a party within the framework of services, agreements and contracts with the Operator;
provision of personalized services to the User, as well as execution of agreements and contracts;
sending notifications, requests and information related to the use of the App, execution of agreements and contracts, as well as processing requests from the User;
improving the quality of the App, its user-friendliness, as well as development of new services; 
targeting of advertising materials;
conducting statistical and other research based on depersonalized data.
Legal ground for personal data processing is a consent for the personal data processing obtained from the User.
The User agrees to the personal data processing for the entire period necessary for the Operator to reach processing objectives, and in case such period cannot be determined – until the User withdraws the consent by submitting a request to info@mcontact.ru. The Operator shall discontinue personal data processing and destroy it within 1 (one) month from the date of receiving a withdrawal.
Transfer of the User’s personal data to third parties is allowed subject to the User’s consent or under the legislation of the Russian Federation.
RIGHTS AND OBLIGATIONS OF THE USER 
The User has the right to receive the information on their personal data processing from the Operator under Federal Law of 27 July 2006 No.152-FZ ‘On Personal Data’
The User has the right to demand the Operator to clarify, update the processed personal data of the User, block or destroy it if the personal data is incomplete, outdated, inaccurate, and also withhold the personal data processing consent by submitting a request to info@mcontact.ru. 
To exercise their rights and protect legitimate interests, the User has the right to contact the Operator. 
RIGHTS AND OBLIGATIONS OF THE OPERATOR 
The Operator shall take the necessary measures to fulfil their obligations under the legislation of the Russian Federation on personal data processing and protection.
The Operator shall consider the User’s appeals and demands, take all necessary measures to immediately eliminate any violations of the User’s rights, pursue actions against offenders and resolve disputed and conflict situations in pre-action dispute resolution procedures. 
The operator shall block the illegally processed personal data, and also discontinue personal data processing under the legislation of the Russian Federation;
The Operator shall apply appropriate physical, electronic and managerial procedures to ensure the safety and security of personal data.
CONFIDENTIALITY  
The Operator shall use the User’s personal data exclusively for the purposes specified in this Privacy policy, as well as ensure that the User’s personal data is kept under seal of secrecy, not disclose it without the User’s consent, and not sell, exchange, publish, or disclose in any way the obtained personal data of the User. Disclosure of personal data to third parties is allowed subject to the User’s consent or under the legislation of the Russian Federation.
FINAL PROVISIONS 
The security of personal data processed by the Operator shall be ensured by the implementation of legal, organizational and technical measures necessary to meet the requirements of federal legislation on personal data protection.
The Operator has the right to amend this Policy as deemed necessary, as well as in the case of relevant amendments to the current legislation of the Russian Federation on personal data. The User may at any time read and acknowledge the current version of the Policy on the Website of the app`s author. Continuing to use the App, the User agrees with the amendments to the Policy.
The Operator and Users who have violated their obligations to protect Personal Data are liable for damage arising from the unlawful use of personal data under the legislation of the Russian Federation.
Contact details
In case of questions, suggestions or intentions to exercise one or more of the User’s rights regarding the processing of personal data, the User has the right to contact the Operator using the following contact details: 
Interregional Contact Center
Moscow
Tel: +7 (495) 146 6836
St. Petersburg
Tel.: +7 (812) 213 6836
Email: info@m-contact.ru