PRIVACY POLICY

Fodyo.com

 

"01" December 2019

 

 

   1.           GENERAL TERMS

1.1.    This Policy defines the procedure for processing and protection information about individuals (hereinafter – the User), which can be obtained by the Enterprise Tsogoev A.V. («Fodyo.Com») (hereinafter – the Enterprise) when the User uses the website Fodyo.com (Site).

1.2.           The purpose of this Policy is to ensure proper protection of personal information that the User provides about him- or herself using the Site as an online search engine for real estate data from unauthorized access and/or disclosure.

1.3.           Collection, storage, distribution and protection of information provided by the User is regulated by this Policy, other official documents of the Enterprise and the current laws of the territory where the User is located.

1.4.           By providing personal information on the Site and ticking the corresponding box on the site as well as by using the Site, the User expresses his full consent to the terms of this Policy. The User is also entitled to provide a scanned signed copy of the written consent to Personal data processing.

1.5.           If the User does not agree with the terms of this Policy, the use of the Site shall be immediately terminated.

1.6.           Should the User want to terminate receiving any information from IE, the User could unsubscribe from the newsletter by sending a request to email mail@fodyo.com . The request is processed within 24 hours. As a result, the User will be excluded from newsletters.

 

   2.           PURPOSE OF COLLECTING, PROCESSING AND STORING INFORMATION PROVIDED BY USERS OF THE SERVICES

2.1.           Processing of personal data shall be carried out in accordance with the laws in force in the country where the Service is used including, but not limited to the Federal law of the Russian Federation No. 152-FZ "On personal data", General Data Protection Regulation (GDPR), the Personal Information Protection and Electronic Documents Act (PIPEDA), and data protection laws of the United States and certain US states, as well as Australia and the UK data protection laws

The legal basis for the processing personal data is inter alia contracts concluded between the Enterprise and the User, Terms of use and the consent to Personal data processing

2.2.           The Enterprise processes the User's personal data so as to:

2.2.1.    identify a party according to agreements and contracts concluded with the Enterprise;

2.2.2.    provide access to the Website and its Services as well as to ensure compliance with the Terms of use;

2.2.3.    communicate with the User, send one-time transactional emails to the User at the time of receiving a request on the Site or receive payments from the User, if the User performs these actions, send notifications and/or requests to the User;

2.2.4.    send advertising and/or informational messages to the User;

2.2.5.    verify, research and analyse such data to support and improve the Site, as well as to develop new services and sections of the Site;

2.2.6.    conduct statistical and other research based on depersonalized data.

 

      2.3.    The Enterprise collects the following types of personal data:

2.3.1.    Personal identifying information provided at the time of the Request for information and during further interaction with the Site, as well as information about how the User uses the Site. These data may include name, surname, address (the location through your IP address), email address, gender, age, data on electronic equipment being used and the data obtained using Google Analytics and Yandex.Metrics, personal website, personal biography or image, User interactions with the Site (for example, mouse movements, locations, clicks and keystrokes).  By using the Services, the User may be requested for additional personal data by the Enterprise. The Enterprise may also collect additional personal data from the User when the User contacts the Site's support service, or communicating with the User in other ways.

The Enterprise does not request a social security number (SSN) to access the Service (unless there is a legal requirement to obtain a SSN)

2.3.2.    If the User participates in a paid service program, the Enterprise may collect financial information to process payments in the prescribed manner. This personal information may include the User's name, address, phone number, email address, bank card details and payment amount. The Enterprise uses the services of third-party payment services that possess the appropriate licenses that allow them to process payments made with payment cards or otherwise, and does not store the details of User’s bank cards.

2.3.3.    If a User connects to or logs into a Site through a third-party service (such as Facebook), the third-party service may send information such as User profile data to the Enterprise. This information may differ and is controlled by this third-party service.

2.3.4.    The Site uses log files. They store IP addresses, browser type, Internet service provider (ISP), pages visited and exit pages, platform type, date and time stamp, and the number of mouse clicks. This information is used to analyse trends, administer the Site, track user transitions and collect general demographic data for complex use. IP addresses and other data can be linked to session and device IDs.

2.3.5.    By accepting this Privacy Policy the User agrees to cross-border transfer of his or her personal data, including transfer of the User's personal information to the territory of a state other than the User's location (cross-border transfer of personal data), and if this state is not included in any of the following categories:

- is not a party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data;

- not included to the list of States providing adequate protection of personal data approved by Roskomnadzor,

The user is informed of the possible risks of such transfers due to lack of information about the adequacy of the third country's level of protection and corresponding guarantees.

 

   3.           TERMS OF PROCESSING PERSONAL INFORMATION PROVIDED BY THE USER AND ITS TRANSFER TO THIRD PARTIES

      3.1.    In accordance with applicable personal data protection laws, the Enterprise will take appropriate security measures to prevent accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and other illegal processing of Personal data. The Enterprise takes seriously its safety obligation. The Enterprise uses the most appropriate physical and technical measures, including staff training and awareness, and regularly reviews these measures.

      3.2.    Upon request, the User shall be informed of presence, use and disclosure of his or her personal data and shall be given access to this information. 

      3.3.    The Enterprise provides access to the User's personal data only to those employees, contractors and affiliates who need this information to ensure the operation of the Site and to provide services.

      3.4.    The Enterprise is entitled to use information provided by User, including personal data, in order to ensure compliance with the applicable laws of the place of use of the Website (including in order to prevent and/or suppress unlawful and/or illegal actions of Users). Information provided by the User may be disclosed only in accordance with the applicable laws of the place of use of the Website at the request of the court, law enforcement agencies, as well as in other cases provided for by the law of the State where the Site is used. The Enterprise is also entitled to disclose the User's information to the third parties, including law enforcement agencies, government institutions or government agencies, as well as to private plaintiffs and defendants, whether within or outside the User's country of residence, if it is established that such disclosure is reasonably necessary to comply with the laws, including to respond to court orders or warrants, subpoenas, etc. The Enterprise can also disclose User information if it establishes that such disclosure is reasonably necessary to prevent serious physical injury or death of a person, solve national security issues or other issues of public importance, prevent or detect violations of the Website Terms of Use or fraud or abuse of the Site or its users, as well as to protect the Enterprise activities, property or other legal rights, including by disclosing information to the Enterprise lawyer or other consultants and the third parties related to an ongoing or potential lawsuit.

      3.5.    The servers hosting the Site are located in the Russian Federation and the United States. Thus, the personal data of Users using the Site and providing their data to the IP will be processed and stored in the territory of use of the Site.

      3.6.    The Enterprise is entitled to disclose the User's information if the User instructs the Enterprise to do so.

      3.7.    The User’s personal identifying information may be disclosed to the third parties in unforeseen situations that cannot be prevented even with commercially reasonable means of protection, for example, in the event of a hacker or other attack on the Website or the Enterprise.

      3.8.    Cases when a User provides his or her personal data to another User are governed by the relevant agreements between Users. Responsibility for the execution of these agreements lies solely with the parties to such agreements.

      3.9.    In order to improve the Website's usability, the Enterprise uses cookies. When one visits the Site, a cookie is created on the User's device. It means that the device has been assigned a unique number that has no meaning outside the scope of using the Services. Cookies do not contain any personal identification information and are used to personalize User interaction: after entering data when requesting information during a session on the Website, this information is stored so that the User does not have to enter it repeatedly during this session. Most web browsers accept cookies automatically. To disable collection of information via cookies or other tracking technologies, you have to configure the appropriate settings in your browser or on your mobile device. For instructions on how to delete and disable cookies and other tracking and recording tools, see the browser or mobile device reference guide. The User can also send a request to the Site's support service on how to disable the collection of cookies and other tracking and recording tools. Blocking cookies may cause certain features of the Services to become unavailable. The Enterprise can use the user's IP address to identify the user, manage the Site, and diagnose problems with the Site server.

   3.10.    The Site server logs store IP addresses, information about the browser type, Internet service provider (ISP), pages visited and exit pages, the User's platform type, date and time of Site visits, and the number of mouse clicks. This information is used to analyze trends, administer the Site, track user transitions and collect general demographic data for complex use. IP addresses and other data can be linked to session, user, and device IDs.

   3.11.    The Enterprise uses third-party analytics services to understand how the Services are used and how to improve them.

   3.12.    The Enterprise does not purposefully collect information about underage users. If there is reason to believe that the Enterprise may have accidentally collect this information, please contact the Site Administration at mail@fodyo.com immediately. Consent to data processing of a minor User shall be authorized by his or her parents (or legal representatives of a child). The general rule for parental consent requirement is set by different EU Member States differently (from 13 to 16 years), and the age of majority is defined in each country separately.

   3.13.    The Enterprise may collect personally identifiable information about the User's actions on third-party websites and online services. The Enterprise may receive additional information about the User from the third parties, such as marketers, partners, researchers, and others. The Enterprise may combine information collected from the User with information received from these third parties, as well as through the use of any other subscriptions, products or services of the Enterprise.

   3.14.    Third-party applications, plug-ins, and websites that integrate with the Website, may receive User information and content, including personal information, photos, and geolocation data. The terms of collection and processing of information by these third parties are governed by their policies. The Enterprise is not responsible for the terms or policies of those third parties.

   3.15.    The User accepts that when content is in broadcast or otherwise transmitted via third-party services, these data become available outside the Site and may be accessed by others. When exchanging information with the third parties, one should exercise caution and carefully study their methods of protecting confidential data. The User undertakes such actions at his or her own risk.

   3.16.    The Enterprise has taken a number of measures to protect the procedures of collection, transmission and storage of collected data. These steps depend on the confidentiality of the data collected, processed and stored. While the Enterprise strives to take reasonable measures to protect User information taking into account its confidentiality, the Enterprise does not guarantee complete security of the information provided by the User and the Enterprise is not responsible for theft, destruction or accidental disclosure of this information or content. The Site uses industry-standard technology, the SSL Protocol, which provides encryption of personal data and bank card numbers. In order to strengthen the security of the Site, the Enterprise uses the services of an industry leader in the field of Internet security and services verification. The Enterprise protects Site information using an advanced firewall.

The effectiveness of these measures in preventing unauthorized access to personal information depends on the security features available in the User's browser. The User is responsible for using a secure browser when sending bank card details and other personal information on the Site. Working with a browser that does not support the SSL Protocol obviously puts the confidentiality of personal data at risk.

Most browsers are able to notify you when you switch between protected and unprotected modes, about receiving incorrect website identification information, as well as about sending information via an insecure channel. In order to protect the User, the Enterprise recommends activate these alert functions. You can also look at the site URL (protected addresses start with https:// instead of http://) and the browser security symbol: this will help you determine which server you are interacting with, protected or not. Detailed information about the site’s security certificate for the sites used is also available there. The Enterprise always recommends to verify the authenticity of a secure connection certificate.

   3.17.    The Enterprise does not verify the accuracy of the information provided by the User and assumes that the User provides reliable and sufficient information in good faith, takes care of timely changes to previously provided information when necessary, including, but not limited to changing the phone number, and so on.

   3.18.    The User is entitled to correct, supplement or delete inaccurate information added to the account at any time by changing it in the account settings. All questions related to account editing should be directed to mail@fodyo.com.

   3.19.    The Enterprise stores information about the User as long as it is necessary for providing information related to real estate. Information that is no longer required will be de-identified and/or safely destroyed. In addition, the Enterprise is entitled to store information from closed accounts as required by law in order to prevent fraud, collect fees, resolve disputes, solve problems, assist in investigations, ensure compliance with the Terms of use, and perform other actions permitted by law. The stored information will be processed in accordance with this Privacy Policy.

 

   4.           PERSONAL DATA SUBJECT RIGHTS AND DATA PROCESSING CONTROL MECHANISMS

4.1.           The User is entitled at any time to revoke his consent to Personal data processing given to the Enterprise, on his own initiative, by contacting the Enterprise at mail@fodyo.com. Revocation of this Consent to personal data processing by the User does not affect the legality of the collection and processing of the User’s data on the basis of his consent before the revocation. The User has to consider that the Enterprise may have other legal grounds for processing the User’s data for purposes specified in this Privacy Policy.

4.2.           In certain cases described by the laws, the User may request for restrictions on processing his personal data. This is possible, for example, if the User disputes the correctness of his or her personal data. In this case, the Enterprise will restrict data processing until the accuracy of the data is verified.

4.3.           In certain cases specified by the laws, the User may object to the personal data processing, including the processing of his or her personal data for direct marketing purposes.

4.4.           If the User provides the data directly to the Enterprise and its processing is carried out automatically with the User's consent or for the performance of its contract with the Enterprise, the User is entitled to obtain his or her personal data to be processed in a structured common machine-readable format and to transfer that data to another service provider.

4.5.           The User is entitled to request the deletion of his or her personal data. Deleted personal data cannot be restored. The User has to consider that content published by the User through third-party services (for example, by broadcasting) or copied by third parties may be available to them even after the User's account or related content is deleted. In addition, the User may not always be able to read, correct or delete information copied by the third parties as a result of the User granting them access to this information.

4.6.           The User is entitled to challenge the Enterprise's compliance with the principles of personal data protection in accordance with the law. 

 

   5.           PRIVACY POLICY CHANGES

5.1.           If the Enterprise changes the Privacy Policy, the updated version will be published on the Site in time. If there are major changes, an explicit notification will be given. The Enterprise reserves the right to change this Privacy Policy at any time. If the User objects to any changes in the Privacy Policy, he or she could stop using the Site. By using the Site after receiving notification of changes or publishing it on the Site, the User automatically agrees to such changes.

 

   6.           DISCLAIMER OF LIABILITY

6.1.    The Enterprise makes every effort to protect the User’s personal data. However, there is no absolutely secure method of data transmission over the Internet, and therefore the Enterprise cannot guarantee the security of any information provided by the User. The transfer of personal data is performed by the User at his or her own risk.

 

   7.           CONTACTS

7.1.           Should you have any questions how the Enterprise collects, stores and uses personal data, or any questions about this Privacy Policy, please, contact the Enterprise at mail@fodyo.com.