Fasti.me Privacy Policy1. General terms1.1. The subject of regulation of this Privacy Policy (hereinafter - the “Policy”) are the relations between Limited Liability Company “GLS-Consulting” (INN 7717738764, Russia, 127572, Moscow, Uglichskaya St., 12, bldg. 1, room 209 ), hereinafter referred to as “GLS-Consulting” or “Company”, being the right holder of sites, services, programs and/or other products, including information, communication, advertising, educational, entertainment and other products (hereinafter referred to as “Service”), available on the Internet at
https://fasti.me and
https://app.fasti.me” (hereinafter referred to as “Site”), as well as on other domains administered by the Company, and individuals using the Internet (hereinafter referred to as “User”), regarding the processing of information about the User, including personal data, in the process of using the Service by such person (hereinafter referred to as the “Information”). This Policy is available at
https://fasti.me/privacy_policy1.2. Relationships related to information processing, including, but not limited to, collection, use, storage, distribution and protection of information about Users of the Service, are governed by this Policy, the Policy on Processing Personal Data of Users of Google API Services (
https://developers.google.com/terms/api-services-user-data-policy), the Yandex Privacy Policy
https://yandex.ru/legal/confidential/ and other rules posted within the Service (hereinafter - the “Policy”), as well as the applicable laws of the Russian Federation. Before using the Company's Service, the User shall familiarize themselves with this Policy, as well as with all applicable Rules.
1.3. This Policy is drawn up in accordance with the requirements of the Federal Law dated 27.07.2006. No. 152-FZ “On Personal Data” and defines the procedure of personal data processing and measures to ensure the security of personal data of LLC “GLS-Consulting” (hereinafter - the “Operator”). The Operator sets as its most important goal and condition of its activity the observance of human and civil rights and freedoms during the processing of personal data, including the protection of the rights to privacy, personal and family secrecy.
1.4. Upon registration, each access and/or actual use of the Service, the User agrees to the terms of this Policy, as well as the terms of agreements, regulations and rules of the Service used, as well as the User Agreement, which includes the Consent to the processing of personal data
https://www.fasti.me/agreement_policy, in the editions that were in effect at the time of actual use of the Service.
2. The basic definitions used in the Policy2.1. Automated processing of personal data - processing of personal data by means of computer technologies;
2.2. Blocking of personal data - temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data);
2.3. Site - a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address
https://fasti.me and
https://app.fasti.me ;
2.4. Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing;
2.5. Personal data depersonalization - actions, as a result of which it is impossible to determine without using additional information whether personal data belong to a particular User or other subject of personal data;
2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with the use of automation means or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
2.7. Operator - a state authority, municipal authority, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data;
2.8. Personal data - any information relating directly or indirectly to a certain or defined User of
https://fasti.me site.
2.9. User - any visitor of
https://fasti.me and
https://app.fasti.me sites;
2.10. Provision of personal data - actions aimed at disclosure of personal data to a certain person or a certain group of persons;
2.11. Dissemination of personal data - any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or familiarization of personal data to an unlimited number of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way;
2.12. Trans-border transfer of personal data - transfer of personal data to the territory of a foreign country to a foreign government authority, foreign individual or foreign legal entity;
2.13. Destruction of personal data - any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.
3. Information Content3.1. Information processed by the Company includes:
3.1.1. Account Data, which means:
(a) data about the User provided by the User to create an Account during the process of registration in the Service:
- Surname, First Name, Patronymic;
- E-mail address.
(b) additional information filled in by the User when editing their Account in the process of using the Service:
- Surname, First Name, Patronymic;
- E-mail address;
- Contact phone number;
- Links to personal accounts in social networks and messengers;
- Other personal information that the User adds / may add solely at their own volition.
(c) data additionally provided by the User at the Company's request in order to fulfill the Company's obligations to the User arising from the agreement on the provision of the respective Service, such as full name, date of birth, gender, additional e-mail address, cell phone number, etc.;
3.1.2. Other data required for the functioning of the Service, namely:
(a) data about technical means (devices), technological interaction with the Service (including, if necessary, IP address of the host, type of operating system of the User, type of browser, geographical location, Internet service provider);
(b) information that is automatically obtained when accessing the Service with the use of cookies;
(c) information obtained as a result of the User's actions in the Service, in particular, information about the addition of any content;
(d) information obtained as a result of actions of other Users in the Service;
(e) generalized analytical information about the use of Internet services.
The Account and other data processed by the Company to the extent necessary and sufficient for their classification as personal data in accordance with the applicable laws of the Russian Federation shall be processed by the Company as personal data under the terms of this Policy.
3.2. The User is also given the opportunity to post any other information (if applicable) in the Service, in addition to the information specified in paragraph 2.1. of this Policy, if it does not contradict the requirements of applicable law. The Company has no purpose to process such information, as well as biometric and special categories of personal data. By posting information, the User understands that it may be available to an indefinite number of Internet users, taking into account the settings of the desired level of confidentiality.
3.3. If the functionality of the Service allows to reflect information about the User in their Account, which is available for viewing by other Users of such Service or Internet users, the User agrees to reflect information about themselves in their Account. The User agrees that the Information, including Account and other data, as well as other information may be available to other Users of the relevant Service and/or other Internet users, subject to the existing functionality of the Service (as may be changed from time to time by the Company).
3.4. The Company does not verify the Account Data provided by the User and cannot judge their reliability, as well as whether the User has sufficient legal capacity to provide the Account Data. The Company assumes that the User provides true and sufficient Account Data and updates them in a timely manner. By registering with the relevant Service or accessing it without registration, the User confirms that they have reached the legal age of use of such Service in accordance with applicable law.
3.5. Processing of cookies
Cookies are small pieces of data that websites request from the browser used on the User's computer or mobile device. Cookies are stored locally on the computer or mobile device of the Internet user. The Company collects and processes cookies with respect to Users visiting the Company's Services.
The following types of cookies are used in the Company's Services:
- strictly necessary cookies / technical cookies: these cookies are necessary for the operation of the Site and the provision of the Service to the User; they also allow the Company to identify the User's hardware and software, including browser type;
- statistical/analytical cookies: these cookies allow the Company to recognize users, to count the number of users and to collect information such as the operations performed on the sites, including information about the web pages visited and the content that the User receives;
- technical cookies that collect information about how users interact with the Site so that errors can be identified and new features can be tested to improve the performance of the Service;
- functional cookies that allow the provision of certain features to make it easier to use the sites, for example by storing preferences (such as language and location);
- (third-party) tracking / advertising cookies that collect information about traffic sources, pages visited and advertisements displayed to the User. They allow the display of advertisements that may be of interest to the User, based on an analysis of the information collected about the User. They are also used for statistical and research purposes.
Cookies are processed by the Company solely for the purpose specified in paragraph 3.2 of this Policy, under the conditions and in the manner specified in this Policy, in particular, based on the data collected through cookies, the Company develops the most useful functionality for the Service available to the User, conducts statistical studies, corrects errors in the Service and tests new features to improve the performance of the Service, personalizes them and displays the information most relevant to the User.
The information collected through cookies placed on the User's device may be transferred and made available to the Company and/or third parties specified in paragraph 3.4 of this Policy, as well as companies that own web analytics services Yandex.Metrika, Google Analytics and/or other similar services. The use of information outside the Service collected through cookies for advertising purposes, if any, may be subject to separate user agreements available on the Company's or third parties' websites. The Company and/or third parties may also provide the User with the option to opt-out of personalization of advertising, which may be subject to laws and regulations applicable to such products and offers.
The User may refuse the processing of cookies in the settings of his browser. In this case, the Service will use only those cookies that are strictly necessary for its functioning.
3.6. Processing of information about the User's location (geoposition).
The Company may receive and process information about the User's location (geoposition) as part of Other Data in order to comply with the Purpose specified in paragraph 3.2 of this Policy, namely, to continuously improve the content of the Service, to prevent and suppress any errors that may occur when using the Service, to personalize the information (including advertising) available to the User in the Service, to provide the User with relevant recommendations, as well as for statistical research.
The Company may receive and process information about the User's location (geoposition) of varying accuracy, which depends on the functionality of the Service, the settings selected by the User, the source of obtaining data about the User's location, as well as the need to process location data to provide the functionality of the Service to the User and improve the user experience.
In this case, the Company bases its assumptions about the User's location depending on the settings selected by the User in the browser or on the mobile device based on the User's IP address; information about the location of the device; and/or other information about the User's use of the Service.
The User can limit the transmission of information about their location by changing the settings of their browser and/or mobile device.
3.7. The Company has the right to send the User notifications about new products and services, special offers and various events both individually and via mailing services. The User can always opt out of receiving informational messages by sending the Company a request to the e-mail address info@fasti.me.
4. Conditions of Information processing4.1. The Company shall process Information about Users in accordance with the following principles:
4.1.1. legality of the purposes and methods of processing Information;
4.1.2. good faith;
4.1.3. compliance of the purposes of Information processing with the purposes predetermined and declared at its collection, as well as with the Company's powers;
4.1.4. compliance of the volume and nature of the Information processed and methods of its processing with the purposes of Information processing;
4.1.5. inadmissibility of combining databases containing Users' Information created for incompatible purposes.
4.2. Purposes of Information processing
The Company processes the Account Data and Other Data of the Users of the Service for the purposes of fulfillment of the agreements concluded with the Users on the use of the Service, namely for the purposes of:
- User registration in the Service;
- provision of customer support in the Service;
- receiving information about marketing events by the User;
- conducting audits and other internal research to improve the quality of services provided.
4.3. Collection of Information
The User's Account Data is collected when the User registers in the Service by filling out the registration form, as well as further when the User edits the information previously provided by the User or when the User supplements the Account Data (if applicable) on their own initiative using the tools of the Service.
The Company collects Other Data independently in the course of the User's use of the Service. In some cases, the collection of the User's Personal Data begins from the moment the User accesses the Service (e.g., when downloading an Internet page or launching an application) until the moment of registration in the Service.
4.4. Processing and Transfer of Information
Account Data and Other Data of Users are not transferred to any third parties, except as explicitly provided for in this Policy or other applicable rules, as well as applicable law.
The Company may transfer Users' Account Data and Other Data to third parties, subject to the purposes and grounds set forth in this Policy. Such third parties may include:
- persons who are involved in the provision of services related to the placement and display of information to users (including offers relevant to users' interests) about the Company's services and services in programs, products or services owned or controlled by such persons (e.g., website and application owners, advertising networks and other persons, etc.);
- persons who have legitimate grounds to process Account Data and Other Data, for example, if the transfer of Account Data and Other Data to such persons is made with the User's consent, including if the Account Data and Other Data are necessary to provide the User with the relevant service or to fulfill a specific agreement or contract entered into with the User. These persons include partners and affiliates of the Company, whose data processing is provided for by the terms of this Policy;
- third parties in respect of whom the assignment of rights or obligations or novation under the relevant agreement has been made;
- any state or local government body to which the Company is obliged to provide information in accordance with the applicable laws upon request.
In order to provide high-quality, multifunctional, convenient Service, the Company develops, improves, optimizes the current and introduces new functionality of the Service (of information, communication, advertising, educational, entertainment and other nature), including with the participation of partners and/or affiliates.
Taking into account the above, as well as taking into account the Company's compliance with the processing purposes specified in clause 3.2. of this Policy, the User agrees to and authorizes the Company to perform the following actions:
- processing, including collection, recording, systematization, accumulation, storage, clarification (update, change), comparison, extraction, use, blocking, deletion/destruction of the User's Account Data and Other Data;
- transfer of the User's Account Data and Other Data to partners and affiliates and their processing by partners and affiliates on the basis of an order from the Company (by the methods specified in this clause), as well as joint processing by partners and affiliates of the User's Account Data and Other Data with the data available to partners and affiliates;
- collection (receipt) from partners and/or affiliates of the results of processing of Account Data and Other Data together with the data at the disposal of partners and affiliates, including in the form of integer and/or text values and identifiers.
Taking into account the nature and functional features of the Service, the Company may facilitate the activities on researching the market of goods and services, including assessment of demand and offers, promotion of goods, analysis of the efficiency of information, advertising and marketing campaigns by forming impersonal analytical information based on the data on the use of the Service.
In some cases, certain functionalities of the Service may be provided not by the Company, but by third parties who act independently of the Company and do not act on behalf of the Company. In this case, Users must independently familiarize themselves with the rules of service provision and information/personal data protection policy of such third parties before using the relevant functionalities of the Service.
It is not permitted to extract and use Users' Account Data and Other Data, including for commercial purposes, without the Company's permission.
4.5. Storage of Information
User's Account Data and Other Data shall be stored on the territory of the Russian Federation, whereby storage shall be carried out exclusively on electronic media and processing shall be carried out using automated systems, except for cases when non-automated processing of Account Data and Other Data is necessary in connection with the fulfillment of the requirements of the applicable law.
Account Data and Other Data shall be stored until the purposes of their processing are achieved, namely during the entire period of the User's use of the Company's Service until the Account is deleted or until the Company receives the User's application for deletion of their Personal Data. In the latter case, the User refuses further use of the Service.
The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized persons from accessing personal data.
4.6. Terms of Information storage
Account and Other Data shall be stored by the Company during the term of this Agreement, and after termination of this Agreement during the period required and established by the applicable laws of the Russian Federation.
4.7. Termination of Information processing
When the purposes of Information processing are achieved, the Company shall cease processing of the Account Data and Other Data in one of the ways provided for by the Federal Law “On Personal Data”.
4.8. Trans-border transfer of personal data
Before commencing the trans-border transfer of personal data, the Operator is obliged to make sure that the foreign state, to the territory of which the transfer of personal data is supposed to be carried out, provides reliable protection of the rights of personal data subjects.
Trans-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if the personal data subject consents in writing to the trans-border transfer of their personal data and/or fulfillment of an agreement to which the personal data subject is a party.
4.9. Privacy policy for information received from Google APIs
The use of information that the Service receives from Google accounts and its disclosure to other applications is subject to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy ), including the requirements for restricted use.
5. Rights and obligations of Users when processing their Information5.1. to get free access to information about themselves by viewing the User's Account in the Service;
5.2. using the tools of the Service to set the desired level of confidentiality (conditions of access to information) with respect to information about themselves, taking into account the functionality of the Service (if applicable);
5.3. to independently make changes and corrections to the information about themselves by editing the information in the User Account, provided that such changes and corrections contain up-to-date and accurate information;
5.4. to delete information about themselves by editing the information in the User Account in the Service; in this case, the removal by the User of certain information about themselves from the User Account in the Service may lead to the inability to provide the User with access to the Service;
5.5. to demand from the Company to clarify information about the User, block or destroy it if such information is incomplete, outdated, unreliable, unreasonably obtained or is not necessary for the stated purpose of processing and if the functionality of the Service does not allow the User to delete such information independently;
5.6. on the basis of a request to receive information from the Company concerning the processing of information about the User.
5.7. to refuse to process personal data by sending a corresponding request to the Company in accordance with the procedure provided for in Section 7 of this Policy.
6. Information protection measures6.1. The Company takes technical as well as organizational and legal measures to ensure protection of Users' information from illegal or accidental access to it, destruction, modification, blocking, copying, distribution, as well as from other illegal actions.
6.2. Technical security measures are implemented by the Company taking into account the requirements of the applicable laws, the current state of the art, the nature of the information processed and the risks associated with its processing.
Information is processed mainly automatically without access to it by employees and/or contractors of the Company. If such access is granted to employees or contractors of the Company, then only to the extent necessary for such persons to perform their official duties or duties under a contract with the Company, and such persons are obliged to comply with security requirements when accessing Information. To protect and ensure the confidentiality of data, all employees/contractors shall comply with internal policies and procedures regarding the processing of information. These persons shall also comply with all technical and organizational security measures required by the applicable laws and necessary for the protection of Users' information.
7. Limitation of the Company's liability7.1. The Company is not responsible for disclosure and distribution of information about the User by other Users of the Service or other users of the Internet in the event that such persons have gained access to this information in accordance with the User's chosen settings of confidentiality level of the Service, or in the event of violation by the User of the safety of his login and/or password or other data necessary for authorization.
8. Users' requests8.1. Information about the data processed by the Company, including personal data of the User, in connection with the use of the Service is provided to the User or their representative at the time of application (request).
8.2. Requests shall be sent in writing to the Company's location address, to the Company's e-mail address info@fasti.me or in any other form provided for by the applicable laws of the Russian Federation.
8.3. The User has the right to withdraw consent to the processing of their personal data by sending a written application to the Company at its registered office or to the Company's e-mail address info@fasti.me in accordance with the requirements of the applicable laws.
9. Amendments and additions to the Policy9.1. This Policy may be changed by the Company at any time by posting a new version of the Policy on the Site without personal notice to Users. Amendments to the Policy made by the Company shall come into force on the day following the day of posting the new version of the Policy on the Site. The User undertakes to independently check this Policy for any changes made. Failure of the User to familiarize themselves with the Policy shall not serve as a basis for the User's failure to fulfill their obligations and the User's failure to comply with the restrictions set forth in this Agreement.
9.2. The User has the right to refuse to accept amendments and additions to this Policy, which means the User's refusal to use the Service and all the rights previously granted to them.
9.3. This Policy shall be regulated and interpreted in accordance with the laws of the Russian Federation. Issues not regulated by this Policy shall be resolved in accordance with the laws of the Russian Federation.