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PRIVACY POLICY
1. GENERAL PROVISION
This Privacy Policy (hereinafter referred to as the "Policy") is part of the User Agreement (hereinafter referred to as the "Agreement") establishing the terms of use of the MalibooMake application for mobile devices (hereinafter referred to as the "Application") based on the Android or iOS operating systems, with the current version of the Agreement or of this Policy can be found in the Applications menu or on the Internet at: https://maliboomake.com/en/privacy/. By accepting the terms of the Agreement, the person who installed and uses the Application agrees to the processing of data and other information in accordance with the terms of this Policy set forth in this document.
Data controller is a natural or legal person who interacts with the User, collects data and determines how to process it.
Data Operator (Processor) is a natural or legal person who receives data from the controller, stores it or processes it in some way, at the direction of the controller.
The data subject (hereinafter referred to as the "User") is an individual who uses the Application, and whose Data is processed by the Administration.
Kalinovskaya Anastasia Sergeevna (hereinafter referred to as the “Administration”) is an individual with a location address (Republic of Belarus, Minsk, Sergei Yesenin st., 22) and acts in accordance with the legislation of the Republic of Belarus. The administration is at the same time a controller, an operator (processor) as these terms are understood in the General Data Protection Regulation ("GDPR") of the European Union. The Administration independently organizes and (or) carries out the processing of the Data, and also determines the purposes of the Data processing, the composition of the data to be processed, the actions (operations) performed with the data. The Administration is the copyright holder of the Application.
This Policy defines and describes how the Administration collects, stores, transfers and uses Data and other information about Users using the Application. The administration pays great attention to the protection of data and other information provided by Users, and ensures their protection in strict accordance with applicable laws and regulations.
User data covers any information that the Administration can receive when using the Application by Users.
The Administration can change this Policy at its discretion without prior notice to the Users, if the User continues to use the Application after the publication of a new version of the Policy, the User automatically agrees to the changes. The administration recommends the User to regularly check the terms of this Policy for changes.
The administration guarantees that:
The Administration processes User Data in the following ways:
2. PURPOSE OF DATA PROCESSING
2.1.The Administration processes User Data for the following purposes:
2.1.1.Fulfillment of the obligations of the Administration to the Users of the Application for processing User photos using machine learning in order to select makeup.
2.1.2.For other purposes necessary for the functioning of the Application and the fulfillment of other obligations of the Administration to the Users of the Application in accordance with the Agreement.
3. COMPOSITION OF DATA
3.1 User data processed by the Administration includes:
3.1.1.Photos of Users in an impersonal form, namely a square of the face;
3.1.2. ID (unique identifier), or other anonymized data about the account in social networks.
3.2. The Administration also receives anonymized information:
3.2.1. Via App:
3.2.1.1. About the region, operating system version of the User's mobile device, model of the User's mobile device.
3.2.1.2. About the actions of the User within the Application (for example, but not exclusively about the use of a particular function of the Application) from the services:
Google Firebase, this information is processed on the basis of agreements (contracts) between the User and the right holders of the service, the privacy policy is available on the Internet at the following link: https://policies.google.com/privacy?hl=en, the link for sending requests: https://policies.google.com/privacy?hl=en;
Meta (Facebook Analytics), this information is processed on the basis of agreements (contracts) between the User and the right holders of the service, the privacy policy is available on the Internet at the following link: https://www.facebook.com/about/privacy, the link for sending requests: https://www.facebook.com/policies/cookies/;
Kochava, this information is processed on the basis of agreements (contracts) between the User and the right holders of the service, the privacy policy is available on the Internet at the following link: https://media-index.kochava.com/privacy, the link for sending requests: https://www.kochava.com/privacy-block/;
Google Play Console, this information is processed on the basis of agreements (contracts) between the User and the right holders of the service, the privacy policy is available on the Internet at the following link: link: https://policies.google.com/privacy?hl=en-US, link for submitting requests: https://support.google.com/websearch/troubleshooter/3111061?hl=en;
App Store Connect, this information is processed on the basis of agreements (contracts) between the User and the right holders of the service, the privacy policy is available on the Internet at the following link: https://www.apple.com/legal/privacy/, the link for sending requests: https://www.apple.com/privacy/contact/;
3.2.2. From advertising platforms that process data about user actions through third-party websites and software, using Google Advertising ID and Apple ID for Advertising. The user can independently change the settings for collecting and processing data about his actions by changing the appropriate settings on his phone.
The Google Advertising ID privacy policy is available online at the following link.
The Apple ID for Advertising privacy policy is available online at the following link.
The administration uses the following advertising platforms:
3.2.2.1. Google Admob, the privacy policy is available online at the following link: https://policies.google.com/privacy?hl=en , the link for making inquiries: https://support.google.com/websearch/troubleshooter/3111061? hl=en;
3.2.2.2. Yandex Ads, privacy policy is available on the Internet at the following link: https://yandex.ru/legal/confidential/15072019/ , link for sending requests: https://yandex.com/support/common/troubleshooting/main.html ;
3.2.2.3. Meta (Facebook Analytics), the privacy policy is available on the Internet at the following link: https://www.facebook.com/about/privacy, link for making requests: https://www.facebook.com/policies/cookies/;
3.2.2.4. Kochava, the privacy policy is available on the Internet at the following link: https://media-index.kochava.com/privacy, link for making requests: https://www.kochava.com/privacy-block/;
3.2.3. The Administration notes that the User independently applies to organizations that process his data using advertising identifiers Google Advertising ID and Apple ID for Advertising using the contact information specified in their Policies or Internet sites.
3.2.4. Even if you choose to opt out of data collection and processing, not all companies that provide online behavioral advertising are included in this list, so you may still receive some cookies and interest-based advertising from companies that are not on our list.
3.3. The Administration notes that the Administration does not collect data using Google Advertising ID and Apple ID for Advertising or when viewing advertisements, the Administration receives only anonymized statistical data.
4. STORAGE AND TRANSFER OF DATA
4.1. The Administration does not store Users' Personal Data.
4.2. The Application displays photos that are stored in the User's Gallery on the phone, if the User has granted appropriate access, or displays only photos selected by the User. The Application does not store or create a copy of the photos. The Application processes only a specific photo that the User has chosen to select and change using the Application. When using the Look or Makeup functions, only the square of the image containing the face is processed. The square with the face is processed directly in the Application on the User's device. The only device that can view the photo is the device from which the image was processed using the Application - is the User's device. The image with the face is permanently deleted from the cache as soon as the User closes the Look or Makeup section, or completely closes the Application. In the case of processing photos using other functions of the Application, the photos are processed directly in the Application without data storage. Photos of Users, including images with faces, are not transferred to third parties.
4.3. The Administration specifically notes that it does not store data (depersonalized information) specified in clause 3.2 of this Policy. The storage and processing of data is carried out by third-party organizations specified in clause 3.2 of this Policy. To get acquainted with the conditions of storage and processing of the specified data, the User should contact the indicated organizations.
4.4. If you consent to the Application tracking your actions in applications and on websites of other companies, your identifier for advertisers will be used by our advertising partners to display targeted advertising in the free version of the Application and to track the views of the Administration's advertisements and the actions of the Users after they have been viewed. . These ads are served by our advertising partners and may be targeted based on your use of the App or your online activity. You can stop tracking at any time by turning off Google Advertising ID and Apple ID for Advertising for advertising in your phone's Settings.
If you choose to opt out of targeted advertising, you will still see ads online, but it may not be relevant to you.
4.5. All collected Data is stored in impersonal electronically way. The Administration applies all necessary measures and procedures to prevent unauthorized access and maintain an appropriate level of Data protection.
4.6. By accepting this Policy, the User agrees to the Administration to store temporary a copy of the User's Personal Data in the United States, the European Union and the Russian Federation.
4.7. If the User is located in the EU, the User can contact the Administration using the contact information specified in section 12 of this Policy to obtain information on the procedure and technologies used by the Administration when transferring User Data outside the EU.
5. DATA PROTECTION
5.1. The Administration takes reasonable and appropriate administrative, technical, organizational, physical security measures in accordance with market standards and applicable law to ensure adequate protection of User Data from accidental or illegal destruction, manipulation, damage, loss, alteration, unauthorized or illegal access, disclosure, unlawful use or any other illegal form of Data processing. The Administration controls and records access to User Data. The Administration is constantly developing and improving technologies for protecting User Data. The administration regularly conducts training for employees on security, confidentiality and protection of User Data. The User understands and agrees that no technology for protecting data transmission over the Internet does not guarantee complete security, therefore the User provides the Data at his own peril and risk.
5.2. The Administration appoints Anastasia Sergeevna Kalinovskaya as the person responsible for the security of User Data and the person who interacts with Users on issues related to the processing of User Data. The user can contact Kalinovskaya A.S. according to the contact details specified in section 12 of this Policy.
5.3. The Administration notes that it is not responsible for the processing by organizations of data received using advertising identifiers Google Advertising ID and Apple ID for Advertising.
6. RIGHTS AND OBLIGATIONS
6.1. The Administration is obliged:
6.1.1. Arrange the processing of Data in strict accordance with applicable laws, regulations and this Policy.
6.1.2. Respond to requests and inquiries from Users and their legal representatives in strict accordance with applicable laws, regulations and this Policy.
6.1.3. Provide User Data at the legitimate request of government agencies in connection with any request, subpoena, court order, other legal or regulatory procedures in strict accordance with applicable laws and informative acts.
6.2. The User has the right to:
6.2.1. Access to its Data;
6.2.2. Receive an electronic copy of the Data processed by the Administration;
6.2.3. Delete or restrict the processing of Data;
6.2.4. Withdraw its consent to the processing of Data;
6.2.5. Provide the Application with temporary or permanent access (permission) to the camera of the mobile device and / or to the place where photos are stored. The Administration uses the access provided by the User only for the functioning of the Application;
6.2.6. Receive information from the Administration about any breaches of Data security.
6.2.7. Transfer the Data for processing to another person.
6.3. The Administration takes all reasonable measures to ensure the implementation of the User's rights in relation to the Data. The user can contact the person specified in clause 5.2 of this Policy with a request to exercise the rights specified above. The contact details of the person specified in clause 5.2 of this Policy are indicated in section 12 of these Rules. The User's request is processed within 30 (thirty) days from the date of receipt of the User's request.
7. CHILDREN
7.1. The Application is not intended for use by persons under the age of 13 (16 years for citizens of the European Economic Area), therefore the Administration does not knowingly collect the Data of underage Users. If you are the legal representative of a minor User and you know that the minor User provided the Administration with his Data without your consent, please contact the person specified in clause 5.2 of this Policy using the contact details specified in section 12 of this Policy.
7.2. Persons under the age of 13 (16 for citizens of the European Economic Area) are not entitled to use the Application.
7.3. The Administration specifically notes that it does not control the collection of data obtained when viewing advertisements on the website and in third-party programs, such data is in most cases processed by the organizations specified in section No. 3. Requests for the processing of data about minors are sent to the contact details of these organizations .
8. TRANSFER OF DATA TO THIRD PARTIES
8.1. Except as expressly specified in this Policy, the Administration does not transfer any User Data to third parties, except at the legitimate request of state authorities in connection with any request, subpoena, court order, other legal or regulatory procedures that the Administration is obliged to comply with. The Administration may also transfer Data to protect their rights, property or safety, as well as the rights, property or safety of others, or to defend against legal claims.
8.2. The Administration receives depersonalized statistical data on ad views in the free version of the Application and views from its advertising partners.
9. LIMITATION OF LIABILITY
9.1. The Application is not a public source of User Data.
9.2. The Administration informs Users that this Policy is applicable only to the processing of Data by the Application. The Administration does not control and is not responsible for the use of sites and applications of third parties to which the User can access through the advertisements shown to the User in the Application in the cases provided for by the Agreement. The user uses third-party applications and sites at his own risk.
9.3. The administration is not responsible for any leakage of data received by third parties through Google Advertising ID and Apple ID for Advertising or when viewing advertisements.
10. PROCEDURE FOR WITHDRAWAL CONSENT TO DATA PROCESSING
10.1. The user can revoke his consent to the processing of the Data or restrict the processing of the Data by contacting the person specified in clause 5.2. of this Policy with the appropriate reference.
10.2. The User's appeal is considered within 10 (ten) days from the date of receipt of the User's appeal.
11. APPLICABLE RIGHT
11.1. The interpretation of the provisions of this Policy is governed by the legislation of the Republic of Belarus and applies to claims for violation of the provisions of this Policy, regardless of the principles of conflict of laws. The User agrees to the exclusive jurisdiction and venue of the court hearings in Minsk, Republic of Belarus. This Policy is fully compliant with the provisions of the European Union General Data Protection Regulation ("GDPR"), California Consumer Privacy Act 2018 ("CCPA"), US Electronic Communications Privacy Act 1986 ("ECPA") , Email Privacy Act 2016, California Electronic Communications Privacy Act 2015 (CalECPA), Swiss Federal Data Protection Act 2016 ("FDPA"), Federal Law of the Russian Federation of July 27, 2006 N 152-FZ "On Personal Data" and other applicable regulations.
12. CONTACT DETAILS
Kalinovskaya Anastasia Sergeevna
Citizen of the Republic of Belarus
Republic of Belarus, Minsk, Sergei Yesenin st., 22
Email: maliboo.make@gmail.com