Habr Blockchain Publishing LTD
Entered into force on 07.02.2020
By checking the box “I agree” accompanied with the link to this Policy you (hereinafter also referred to as “User”) with your own free will and for your benefit give your written consent to the processing of User’s Information for the purposes and under the terms and conditions stipulated by this Policy.
- This Policy is an integral part of the User Agreement (hereinafter referred to as the “Agreement”) posted and/or available on the Internet at: https://account.habr.com/info/agreement/, as well as other agreements entered into with the User, when it is expressly stipulated by the terms and conditions thereof. Therefore, when executing the above said agreements by methods defined therein including by visiting and using the Application you fully accept the terms of this Policy.
- Methods of processing of Personal Information include any action (operation) or a combination of actions (operations) with Personal Information including collection, recording, systematization, storage, updating (refreshment, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction in the purposes established by this Policy with/without the use of automated facilities at the discretion of Habr.
- The terms and definitions provided for by the Agreement are used herein, as well as other agreements entered into with the User, unless otherwise provided for by this Policy or follows from the merits thereof. In other cases, the terms used in the Policy shall be interpreted in accordance with the applicable laws, the business practice, or scientific doctrine.
Personal information in this Policy means as follows:
- Information that the User provides about him/her on registration or authorization, as well as during further use of the Application and/or the System, including personal data of the User.
- Data transmitted in a depersonalized form in automatic mode, depending on the settings of the User’s software.
- Habr is entitled to establish requirements for the composition of the User’s Personal Information, which are mandatory for the use of the Application and the Service based thereon. If certain information is not marked by the Habr as mandatory, it is provided or disclosed by the User at his/her discretion.
- When being registered, the User shall indicate in the mandatory manner the account name (login), e-mail address and password. When registering, Habr creates a unique identifier for each User (user_id). The User ID is linked to the User profile information.
To enter into the Agreement, the User may also provide the following personal data about himself/herself: name, title, telephone number.
If an individual acts for the benefit of an institution, the name, taxpayer identification number, tax registration reason code, primary state registration number, registration address and postal address of such institution, corporate telephone number, settlement account, service bank name, and SWIFT can additionally be provided.
The aforementioned information about the institution does not qualify as personal data.
If an individual acts as an individual entrepreneur or in his/her benefit, at will or with the direct written consent of such individual entrepreneur, the following data may be additionally provided: surname and initials of the individual entrepreneur, taxpayer identification number, primary state registration number, address for correspondence, telephone number, settlement account, the name of the serving bank, and SWIFT.
- Publicly available information. At his/her discretion, in order to fill out a profile in the System, the User can also provide the following personal data about himself/herself: surname, name, patronymic, gender, date of birth, city of residence, employer, title, and information about himself/herself in a free form. By adding information to the profile, the User makes such information available to an unlimited number of persons, i.e. makes it publicly available, taking into account the settings for displaying profile information in the System.
- Habr will not verify the reliability of the provided Personal Information and whether the User has the necessary consent for the processing thereof in accordance with this Policy, believing that the User acts in good faith, carefully and makes every effort to keep such information up to date and obtain all necessary agreements of the subjects of personal data.
- Habr collects and stores data about the User’s activities in the System, using log files. In the event that the actions are committed by an authorized User, such information is related to the User ID.
The User understands and accepts the possibility of using third party software on the Website and in the Mobile Application; as a result, such persons can receive and transmit the data in a depersonalized form as stipulated in the paragraph 2.1.2 hereof.
The aforementioned third party software includes:
- web analytics services: Google Analytics, Yandex. Metrica, Yandex AppMetrica, Fabric, Firebase; mediator (http://mediator.mail.ru)
- analytic tools (pixels) of social networks: Facebook, Vkontakte;
- advertising systems: Google DoubleClick for Publishers (DFP), Google Adsense, Yandex Advertising Network (YAN), Criteo.
The scope and conditions for collecting impersonal data by using third party software are determined directly by its titleholders and may include:
- browser data (type, version, cookie);
- operating system data (type, version, screen resolution);
- query data (time, source, IP address).
- other impersonal information about User’s activity in the Application.
- As a part of rendering certain types of services, Habr may provide Users with the opportunity to independently host a software on separate pages of the Website for collecting and processing impersonal data similar to that stipulated in paragraph 2.7 hereof, as a result of which such Users may receive the data stipulated in paragraph 2.1.2 hereof in a depersonalized form. The scope and terms of collection of such data in this case is determined by the User who placed the software to collect and process impersonal data, but cannot contradict this Policy.
- Habr shall not be held liable for using the User’s Personal Information by third parties interacting with the User within the framework of using the Application and/or the System.
Legal basis of processing of Personal information
The legal basis on which Habr relies for the use of Personal information includes:
- Processing of Personal information where User has given consent for one or more specific purposes;
- Processing of Personal information that is necessary for performing a contract to which User are party;
- Processing of Personal information that is necessary to take steps at User’s request prior to entering into a contract;
- Processing of Personal information that is necessary for Habr to comply with a legal obligation according to applicable law.
Policy with regard to children
- Habr does not intentionally collect personal data from children younger than 18, it does not request it and does not allow them to use the Application. Persons under 18 are not allowed to provide personal information including name, address, telephone number and e-mail. If Habr gets to know that the information was collected from a child under 18, Habr shall immediately delete such information. If you think we could have obtained any information from a child or about a child under 16, please, contact us through e-mail: email@example.com.
Purposes for Personal Information Processing
- Habr performs processing, including collection and storage of the Personal Information required for entering into and executing agreements with the User, and made public by the User by filling in the profile and making settings in the Personal Account.
Habr is entitled to use the Personal Information for the following purposes:
- Implementation of the functional opportunities of the System to create and display the User’s Profile in the Application. Habr stores, organizes and displays the Users’ profiles in the Application, containing the Personal Information that Users have made publicly available.
- Entering into the agreements for using the Application and the System; the Agreement shall be entered into remotely by the exchange of electronic documents signed by a basic e-signature. In this case, a pair “login – password” or an e-mail address can be used as the User’s basic e-signature key. Therefore, they are requested during the registration.
- Fulfillment of obligations under concluded agreements, including providing the User with access to the Application and the System; requests for access to the System are accepted by using the Aplication’s software and e-mail.
- Identification of the User within the fulfillment of the obligations under agreements concluded with him/her; The User’s Personal Account is linked to the User's login-password and the e-mail address.
- Providing technical support in regards to the use of the Application and the System; Calls to the support service are accepted by using the Application and e-mail.
- Providing communication with the User for the purpose of information services and improving the quality of the Service under the concluded Agreements, including by way of notification with the involvement of third parties; Communication with the User is carried out via e-mail or by the subscriber number of the phone number provided by the User at the registration or in the process of using the Application and/or the System.
- Use of depersonalized data for targeting advertising and/or informational materials by age, gender, other characteristics.
- Marketing, statistical and other research based on depersonalized data. Data from the data collection systems stipulated in the paragraph 2.7 hereof is collected and analyzed in anonymized form to find out how much time Users spend on different sections of the Application, their interests and preferences.
- Enforcement of Legal Provisions. As the organizer of the information dissemination on the Internet, the Habr stores information about the receipt, transmission, delivery and/or processing of written text, images, sounds, video or other electronic messages of Internet users and information about such users for one year upon completion of such actions.
User’s Rights to User’s Personal Information
Subject to specific provisions of applicable law, the User has the right:
- to be informed about the collection and use of his/her personal data.
- to access his/her personal data and have it corrected if it is wrong or incomplete.
- to restrict the processing of his/her personal data where the accuracy of the personal data is contested, where the processing is unlawful, and where Habr no longer needs the personal data for the purposes for which Habr has processed it.
- to object to the processing of his/her personal data and also restrict its processing in those instances where Habr undertook processing of it in carrying out a task in the public interest or where necessary for our legitimate interest where there is no compelling reason for its continued processing.
- to withdraw consent that User had given to the collection and processing of his/her personal data at any time. If User does withdraw his/her consent to the collection and processing of personal data, that withdrawal shall not affect the lawfulness of any processing by Habr that is based on the consent User had given before he/she withdrew it.
- to obtain the deletion of his/her personal data when it is no longer relevant to the purposes for which it was collected or processed, when User has withdrawn consent and there is no basis for us to continue processing, when User has objected to further processing and there is no compelling interest for continued processing, and when the data was unlawfully processed.
- not to be a subject to a decision based solely on automated processing, including profiling, which produces legal affects concerning User or similarly affecting User, except where there is a lawful basis for continued processing.
- to receive personal data in a structured, commonly used, and machine readable form for the purpose of data portability in those instances where Habr processes by automated means personal data that User has provided.
- These rights may be exercised by using the tools Habr offers in the Application or by contacting Habr with specific request through the methods described below. Habr will address any such requests in a timely manner and according to applicable law. In certain cases, Habr may ask User to verify identity before acting on User’s request. If User is unsatisfied with Habr’s response, User may refer his/her complaint to the relevant supervisory authority in User’s jurisdiction.
Personal Information Storage Retention
- All Personal Information that is collected will be stored only as long as is necessary to accomplish the purpose for which it is collected, or as long as is permitted or required by applicable law. Periodically, Habr will review its data processing systems to determine whether or not the purposes for the collection and processing of User’s personal data remain valid. That determination will be based on factors that include, but are not limited to, whether or not you are still in contact with Habr, whether or not any requests made by User from Habr have been fulfilled (including any follow-up tasks), whether or not there is a contractual relationship between User and Habr, and whether or not there is a contractual or legal basis for continuing to retain User’s personal data. Based on that review and any notifications received from data subjects, Habr will update its systems.
- To improve the quality of the System and to ensure the possibility of legal protection, Habr is entitled to keep log files about actions taken by the User in the context of using the Application and/or System, as well as in regards to the conclusion and execution by the User of the Agreement and other agreements on its part, within 1 (one) year upon their commission.
Requirements for the Personal Information Protection
- Habr stores the Personal Information and provides its protection against unauthorized access and distribution in accordance with internal terms and regulations.
- With regard to the User’s Personal Information, its confidentiality is protected, except for publicly available information (paragraph 2.4 hereof) and in other cases when the technology of the Application or the Service provided on its basis or the configuration of the User’s software provides for an open exchange of information with other Users of the Application or with any Internet users.
Transfer of the Personal Information
Habr is entitled to transfer Personal Information to third parties in the following cases:
- The User expressed his/her consent to such actions, including when the User applies the settings of the used software that do not limit the provision of certain information;
- The transfer is necessary in the context of the User’s use of the Application’s functionality and/or the specificity of the Service based on it;
- Due to the transfer of the Application to the possession, use or property of such third party, including the assignment of rights under contracts concluded with the User in benefit of such third party;
- Upon request of a court or other state authority within the procedure established by law;
- To protect the rights and legitimate interests of Habr in connection with failure to comply with the agreements entered into with the User.
Amendments to and deletion of the Personal Information
- The User is entitled at any time to independently edit the Personal Information in his/her Personal Account provided by himself/herself during registration or authorization.
- The User is entitled to delete his/her own account or to exercise the right to withdraw consent to the processing of his/her personal data by sending to Habr a request to delete his/her account at the address: firstname.lastname@example.org.
- This Policy may be amended or terminated unilaterally by Habr without prior notice to the User. The new version of the Policy becomes effective after posting on the Habr’s Website, unless otherwise provided for by the new version of the Policy.
- The current version of the Policy is on the Habr’s Website at: https://account.habr.com/info/confidential/.
Habr Blockchain Publishing LTD
Registration Number: НЕ 289873
Address: Diagorou 4, KERMIA BUILDING, 6th floor, flat / office 601, 1097, Nicosia, Cyprus
Any questions related to this Policy can be mailed to email@example.com
The wording of the Policy dated December 25, 2018