Privacy Policy

1. General provisions

This personal data processing policy is drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" (hereinafter referred to as the Personal Data Law) and determines the procedure for processing personal data and measures to ensure the security of personal data taken by MoosYo LLC (hereinafter referred to as the Operator).

1.1. The Operator sets compliance with the rights and freedoms of individuals as its highest goal and condition for carrying out its activities when processing their personal data, including the protection of the rights to privacy, personal, and family secrets.

1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors of the website https://en.moosyo.com.

2. Key terms used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computer technology.

2.2. Blocking of personal data means the temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website means a set of graphical and informational materials, as well as computer programs and databases that provide their availability on the Internet at the network address https://en.moosyo.com.

2.4. Personal data information system means a set of databases containing personal data and ensuring their processing through information technologies and technical means.

2.5. Depersonalization of personal data means actions that make it impossible to determine, without the use of additional information, the belonging of personal data to a specific user or another subject of personal data.

2.6. Processing of personal data means any action (operation) or a combination of actions (operations) performed with personal data, using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.7. Operator means a state authority, a municipal authority, a legal or natural person, independently or jointly with others, organizing and/or carrying out the processing of personal data, as well as determining the purposes of personal data processing, the composition of personal data subject to processing, and actions (operations) performed with personal data.

2.8. Personal data means any information relating directly or indirectly to a specific or identifiable user of the website https://en.moosyo.com.

2.9. Personal data allowed by the subject of personal data for dissemination refers to personal data for which an unlimited circle of persons is granted access by the subject of personal data by giving consent to the processing of personal data allowed for dissemination in the manner provided by the Personal Data Law (hereinafter referred to as personal data allowed for dissemination).

2.10. User means any visitor to the website https://en.moosyo.com.

2.11. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data means any actions aimed at disclosing personal data to an indefinite circle of persons (transferring personal data) or acquainting an unlimited number of persons with personal data, including making personal data publicly available in the mass media, posting in information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data means any actions as a result of which personal data are

irreversibly destroyed with the impossibility of further restoring the content of personal data in the information system of personal data and/or the physical carriers of personal data are destroyed.

3. Main rights and obligations of the Operator

3.1. The Operator has the right to:

• Obtain accurate information and/or documents containing personal data from the subject of personal data.
• In case the subject of personal data withdraws their consent to the processing of personal data or submits a request to cease the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law.
• Independently determine the scope and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• Provide the subject of personal data, upon their request, with information regarding the processing of their personal data.
• Organize the processing of personal data in accordance with the current legislation of the Russian Federation.
• Respond to inquiries and requests from the subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law.
• Provide the necessary information to the authorized body for the protection of the rights of subjects of personal data within 10 days from the date of receiving such a request.
• Publish or otherwise ensure unlimited access to this Policy regarding the processing of personal data.
• Take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions regarding personal data.
• Cease the transfer (distribution, provision, access) of personal data, terminate the processing, and destroy personal data in the manner and cases provided by the Personal Data Law.
• Fulfill other obligations provided by the Personal Data Law.

4. Main rights and obligations of the subjects of personal data

4.1. The subjects of personal data have the right to:

• Obtain information regarding the processing of their personal data, except for cases provided by federal laws. The information is provided by the Operator to the subject of personal data in an accessible form, and it should not contain personal data related to other subjects of personal data, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law.
• Request the Operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights.
• Impose a condition of preliminary consent when processing personal data for the purposes of promoting goods, works, and services on the market.
• Withdraw consent to the processing of personal data and submit a request to cease the processing of personal data.
• Challenge unlawful actions or inactions of the Operator in processing their personal data through the authorized body for the protection of the rights of subjects of personal data or in court.
• Exercise other rights provided by the legislation of the Russian Federation.

4.2. The subjects of personal data are obliged to:

• Provide the Operator with accurate information about themselves.
• Inform the Operator about the clarification (updating, changing) of their personal data.

4.3. Individuals who have provided false information about themselves to the Operator or provided information about another subject of personal data without their consent bear responsibility in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. Processing of personal data is carried out on a lawful and fair basis.

5.2. Processing of personal data is limited to achieving specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

5.3. The merging of databases containing personal data, the processing of which is carried out for incompatible purposes, is not allowed.

5.4. Only personal data that corresponds to the purposes of their processing shall be subject to processing.

5.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

5.6. Accuracy, sufficiency, and, if necessary, relevance of personal data in relation to the purposes of personal data processing are ensured during the processing of personal data. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.

5.7. Personal data is stored in a form that allows identifying the subject of personal data for no longer than is required by the purposes of processing personal data, unless the storage period of personal data is established by federal law, a contract, where the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the purposes of processing or in case the necessity of achieving these purposes is lost, unless otherwise provided by federal law.

6. Purposes of personal data processing

7. Terms of personal data processing

7.1. Processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.

7.2. Processing of personal data is necessary for achieving the purposes provided for by an international treaty of the Russian Federation or by law, for the performance of functions, powers, and obligations imposed by the legislation of the Russian Federation on the Operator.

7.3. Processing of personal data is necessary for the administration of justice, execution of a court decision, an act of another authority or official, subject to enforcement in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. Processing of personal data is necessary for the performance of a contract, where the personal data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the personal data subject or a contract where the personal data subject will be a beneficiary or guarantor.

7.5. Processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties, or for the achievement of socially significant objectives, provided that the rights and freedoms of the personal data subject are not violated.

7.6. Processing of personal data is carried out for personal data that has been made publicly available by the personal data subject or at their request (hereinafter referred to as publicly available personal data).

7.7. Processing of personal data is carried out for personal data that must be published or disclosed in accordance with federal law.

8. Procedure for the collection, storage, transfer, and other types of processing of personal data

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary for full compliance with the requirements of the current legislation in the field of personal data protection.

8.1. The Operator ensures the security of personal data and takes all possible measures to prevent unauthorized access to personal data.

8.2. User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the performance of the current legislation or if the personal data subject has given consent to the Operator for the transfer of data to a third party for the performance of obligations under a civil contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address feedback@moosyo.com with the subject line "Updating personal data."

8.4. The processing period of personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different period is specified in the contract or current legislation. The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at the Operator's email address feedback@moosyo.com with the subject line "Withdrawal of consent to the processing of personal data."

8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by these entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject is subject to the terms and conditions specified in these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this clause.

8.6. Prohibitions on the transfer (except for providing access) and processing or conditions for the processing (except for obtaining access) of personal data imposed by the personal data subject do not apply in cases of processing personal data for state, public, and other public interests as defined by Russian legislation.

8.7. The Operator ensures the confidentiality of personal data during its processing.

8.8. The Operator stores personal data in a form that allows identifying the personal data subject for no longer than necessary to achieve the purposes of processing, unless the storage period is established by federal law, a contract, where the personal data subject is a party, beneficiary, or guarantor.

8.9. The termination of personal data processing may occur upon the achievement of the purposes of processing personal data, expiration of the consent period given by the personal data subject, withdrawal of consent by the personal data subject, or a request to terminate the processing of personal data, as well as in case of unlawful processing of personal data.

9. List of actions performed by the Operator with the obtained personal data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the received information through information and telecommunication networks or without them.

10. Cross-border transfer of personal data

10.1. Before commencing activities related to the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of the rights of personal data subjects about their intention to carry out such cross-border transfer of personal data (this notification is sent separately from the notification of the intention to process personal data).

10.2. Prior to submitting the aforementioned notification, the Operator must obtain the relevant information from the authorities of the foreign state, foreign individuals, and foreign legal entities to whom the cross-border transfer of personal data is planned.

11. Confidentiality of personal data

The Operator and other parties who have access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final provisions

12.1. The User can obtain any clarifications regarding the processing of their personal data by contacting the Operator via email at feedback@moosyo.com.

12.2. Any changes to the policy of personal data processing by the Operator will be reflected in this document. The policy remains in effect indefinitely until it is replaced by a new version.

12.3. The current version of the Policy is publicly available on the Internet at https://en.moosyo.com/privacy-policy/.

In all other cases not described in this document, we do not take responsibility for the confidentiality of your data.