Privacy Policy

1. APPLICATION AND AGREEMENT

1.1. Personal data of individuals and legal entities - users of Betatransfer service are processed by CITY2010 Ltd., a person registered under the laws of the Russian Federation, located at 115193, 5th Kozhukhovskaya St., 11, Moscow, Russia (hereinafter - the Company). The Company owns the Personal Data Base of merchant.betatransfer.io users.

1.2. Personal data of merchant.betatransfer.io users is processed on secure servers located in the Netherlands.

1.3. This Privacy Policy describes the procedure established by the Company for processing personal data collected through the site.merchant.betatransfer.io (hereinafter - Site), the Betatransfer mobile application (hereinafter - the mobile application) and related services and tools that allow users to register on the Site, publish or view in real time already published ads, use another associated with the above service Betatransfer. In all of the above cases, the Company processes personal data of the users only within the framework of the requirements of the Federal Law "On Personal Data" effective on the territory of the Russian Federation and the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data. This Privacy Policy has been developed in accordance with the provisions of these documents.

1.4. By using the Site and/or the mobile application, and/or other related services and tools of Betatransfer, the User gives his/her consent to the Company to process his/her personal data, such as user name; region of residence, e-mail address, contact phone number, other contact information and at the request of user; ip-addresses, other communication data of user; messages, letters, statements transferred to the user by other users and vice versa, and also gives his/her consent to the transfer of his/her personal data to third parties, including the transfer of personal data abroad to any third country, in accordance with this Privacy Policy and the User Agreement of merchant.betatransfer.io services.

1.5. Users should be aware that when going to some links posted on the Site or in a mobile application, they may be redirected to sites (applications, etc.) of other companies outside the hosting space of the Company, where information about Users is collected outside the direct control of the Company. In this case, the Privacy Policy of the third party sites and/or applications will regulate the processing of information received from users by these third parties.

2. INFORMATION THAT THE COMPANY COLLECTS, RECEIVES AND PLACES

2.1. Account information: When you create an account on the Site, the Company may require certain information such as a valid email address and password. An account may include information about Users such as geographic location, first and last name, telephone number and related information, including photographs and/or scanned documents, computer and mobile screenshots that they may upload to their account. Users are responsible for all information they transmit to the Company.

2.2. Execution of transactions: Within the framework of the website activity, the Company may transfer information about Users: payment systems, payment agents, banks, financial institutions, currency conversion services and similar organizations with which the cooperation agreement is concluded. Including personal and contact information required to fulfill its obligations to Users and process payments. Users are responsible for all information transferred to the Company.

2.3. Advertising and Promotion: As part of the activities of its site, the Company may also process information related to the effectiveness of advertising campaigns, including which ads have been viewed on the Site and on third party sites.

2.4. Customer service: When Users contact the Customer Service Department, the Company may - as part of the operations of the website - collect personal information necessary to fulfill the request of the User and receive feedback if necessary. The Company may also contact the User using existing account contact information provided for this purpose. The Company may also collect other information about communicating with Users, such as any support requests submitted by Users or any feedback provided by Users.

2.5. Website and mobile data: The Company may automatically receive and record on the servers information from the browser of the User or any device, including IP address, software and hardware attributes, pages requested by the User, mobile identifiers, application usage information and/or other devices in use or system level information. This may happen on the Site or on a mobile application, or on third party services. For more information on how users can control and/or block such collection of information, please see section 6 of this policy below.

2.6. Information obtained as a result of surveys: The Company may collect and store information obtained as a result of surveys that may be conducted by the Company or contractors engaged by the Company - third parties, namely information on the type of activity of the User, sites, portals, mobile applications belonging to the User, financial statistics, etc.

2.7. Attached information: The Company may also add information legally obtained from business partners or third parties to existing Company data on their users.

2.8. Information available from user profiles in multi-user Internet platforms (social networks): By registering on the Site, the User gives his consent to the Company to collect and process information available from the relevant profiles in social networks, as well as to publish in the relevant social networks information about the actions of the User on the Site and/or in a mobile application.

Information that the Company does not collect or process:

The Company does not collect or process any personal data on racial or ethnic origin, political, religious or philosophical beliefs, membership of political parties or trade unions, or similar information.

3. IP-Adres, COOKIES and MOBILE IDENTIFICATORS

3.1. As part of the operations of the website, the Company may collect certain information through technologies such as cookies, pixels, and local storage (as in your browser or mobile device).

3.2. COCKIES are small text files that store information directly on the computer of users, their mobile phone or other device.

3.3. Pixels - small digital images that are part of the codes on web pages that allow another server to measure the browsability of a web page, and are often used in conjunction with cookies. The code tracks if and when (and on which page) a pixel is loaded to indicate that the user is interacting with the page or part of a page on the Site.

3.4. By using cookies, a web server can save, for example, preferences and settings on computer of User, his/her mobile phone or other device(s), which is then automatically restored on the next visit. Or, to put it differently, cookies serve, among other things, to make use of the Site more convenient, so that, for example, the User does not have to repeat the login process the next time they visit the Site. The Company uses both permanent and session cookies. Persistent cookies remain on the computer for a longer period of time and session cookies are automatically deleted when the browser window is closed.

3.5. The Company may allow third parties, such as advertising and/or analytical service providers, to collect information using these types of technologies directly from the Site web page or mobile application. The data they collect is subject to protection under the applicable privacy policies of these third parties.

4. PERSONAL DATA USAGE

4.1. In order to provide the services, the Company may use the information that the Company collects and publishes for the following purposes:

4.1.1. providing customer service, including for creating and managing user accounts, solving technical difficulties and access to various functions;

4.1.2. timely performance of the obligations of the Company to the User;

4.1.3. control of general and individual activity of Users, such as switching to different pages of the site, selection of services provided;

4.1.4. communication with our users, including with regard to service, customer service or permitted marketing communications through any available communication channels;

4.1.5. conducting research and analytical activities to improve our service;

4.1.6. enforcing the User Agreement of merchant.betatransfer.io services, including combating fraud and using the service for illegal purposes;

4.1.7. assessing certain factors of personal information, in particular to analyse and predict personal preferences, interests, behaviour or location.

4.2. The Company will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including any legal, accounting or reporting requirements.

To determine the appropriate retention period, the Company takes into account the volume, nature and sensitivity of personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which the Company processes your personal data and whether the Company can achieve these purposes by other means.

5. DATA INTERCHANGE

5.1. The Company may share the information it collects with affiliates located in a third country. These companies may only process and use the personal information they collect for the purposes specified in paragraph 4 of this Privacy Policy. However, the transferred data remains subject to this Privacy Policy.

5.2. The Company does not provide personal information of users to non-affiliates, except for the cases when there is a corresponding permission of users, or in the following circumstances.

5.3. The Company may use third party service providers to provide some of the services, in which case the providers have no authority to use personal data obtained through the Site, otherwise than to provide services to the Company, and the personal data itself is subject to this Privacy Policy.

5.4. The Company reserves the right, as required by law, to exchange information with individuals and public bodies for the following purposes:

  • fight against fraud and abuse on the site;
  • investigating alleged violations of the law or combating any other alleged violations of the merchant.betatransfer.io Services User Agreement by Users.

5.5. The Company may provide personal data of users to the requests of competent authorities executed in accordance with the requirements of the Criminal Code of the Russian Federation.

5.6. In accordance with the Privacy Policy, the Company undertakes not to rent or sell any personal data of the User. In the event that the business of the Company or any part of it is sold or reorganized and the Company transfers all or substantially all of its assets to the new owner, the personal data of the User may be transferred to the Buyer in order to ensure continuity of service of the Site.

5.7. The Company may transfer certain impersonal information (data that does not allow to identify Users individually) to third party service providers, trusted partners or authorized researchers in order to better understand what advertising or services may interest Users, to improve the overall quality and efficiency of services on the Site or the service, or to ensure its contribution to scientific research, which, in the opinion of the Company, may bring great social benefits.

5.8. The Company may transfer the information it collects to third parties that provide services to the Company for research purposes or to provide services to Users, and the data that is transferred is the subject of this Privacy Policy, and involved third parties have no right to use the information received otherwise than to provide services to the Company.

5.9. In cases of transfer of personal data provided by this section 5 of the Privacy Policy, it is at the discretion of the Company to inform the User about the transfer of his/her personal data.

6. USER CONTROL

6.1. Access, Fix and Delete: Users who have created an account can access, correct or delete the information they provide. The user is responsible for the accuracy of the information they provide on the Site. Posted information may be changed or deleted in the personal account of the user "My Profile" on the web page of the Site, or in the application. The Company may terminate processing of personal data of the User in case of receiving written notification of the User about withdrawal of consent to the processing of personal data.

6.2. Selection of external parties: Some external parties operating on the site, such as Google Adwords, allow users to withdraw their consent to the collection and use of their data for advertising purposes based on user activity. For more information and choices, please visit our website http://www.networkadvertising.org.

6.3. Cookies: Most major computer (desktop) and mobile web browsers (e.g. Safari, Firefox, Internet Explorer, Chrome, Opera) provide controls that allow the user to restrict or block the installation of Cookies on your systems. Please note that disabling Cookies for Category 1 domains (sites you visit) and other domains (sites linked to sites you visit) may in some cases result in limited functionality for these websites.

6.4. Other rights of Users in connection with the processing of their personal data by the Company:

6.4.1. receive information about the terms and conditions of access to personal data, including information about third parties to whom the personal data of Site users is transferred;

6.4.2. to access your personal information;

6.4.3. receive no later than thirty calendar days from the date of the request, except in cases provided by law, an answer as to whether his personal data is being processed, as well as receive the content of such personal data;

6.4.4. make a motivated demand to the owner of personal data with an objection to the processing of personal data;

6.4.5. to present the motivated demand on change or destruction of the personal data by the owner and / or the manager of the personal data, if these data are processed illegally or are unreliable;

6.4.6. protection of personal data from illegal processing and accidental loss, destruction, damage due to deliberate concealment, non-provision or untimely provision of such data, as well as protection from providing information that is unreliable or damaging to honor, dignity and business reputation;

6.4.7. to address with complaints on processing of the personal data in public authorities and officials which powers include maintenance of protection of the personal data, or in court;

6.4.8. apply legal remedies in case of violation of legislation on personal data protection;

6.4.9. withdraw consent to the processing of personal data.

7. SECURITY

7.1. All information that we collect is reasonably protected by technical and security measures to prevent unauthorized access or use of the data. Persons affiliated with the Company, trusted partners and third party service providers will use the information we collect from the Company in accordance with our security requirements and this Privacy Policy.

8. CHANGE OF POLICY

8.1. This privacy policy was last updated on 03/02/2020. The Company may update this Privacy Policy from time to time, the new version of the Privacy Policy will take effect as soon as it is posted on the Internet at the address specified in this paragraph, unless the new version of the Privacy Policy provides otherwise. The current version of the Privacy Policy is always on the page at the following address https://merchant.betatransfer.io/privacy-policy.

8.2. If the Company has made any changes to the Privacy Policy with which the User does not agree, it must stop using the services of the Site. The fact of continuation of use of the Site is the confirmation of the consent and acceptance of the corresponding edition of the Privacy Policy by the User.