Dolphin{tt} PRIVACY POLICY

WE RESPECT YOUR PRIVACY!

If you have any privacy-related concerns, please contact us at: info@dolphin.ru.com

This Privacy Policy describes how We collect and use the Personal Data you provide. It also describes the choices available to you regarding Our use of your Personal Data and how you can access the information. We respect your privacy and We take protecting it seriously.

Reading Privacy Policy is important so We hope you will give it time and attention.

This Policy applies to the following people:

• people who use the Service (for the purposes of this Policy, We define the term “User”, “you”, "your", "yours" as a person which has completed registration on our Website: https://tt.dolphin.ru.com/en).
• people who make complaints to Us by email.

We do not sell your Personal Data to third parties. A “sale” of Personal Data under the CCPA is defined broadly to include the “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” the Personal data of a Consumer to another business or third party “for monetary or other valuable consideration.” If We decide to sell the Software, We will inform you about this, so you can forbid Us to transfer your Personal Data together with our business. If so, We will delete your Data from the databases prior to a business transfer.

We adhere to the following principles in order to protect your privacy:

• principle of purposefulness - We process Personal Data fairly and in a transparent manner only for the achievement of determined and lawful objectives, and they shall not be processed in a manner not conforming to the objectives of data processing;
• principle of minimalism - We collect Personal Data only to the extent necessary for the achievement of determined purposes and do not keep Personal Data if it is no longer needed;
• principle of restricted use - We use Personal Data for other purposes only with the consent of the data subject or with the permission of a competent authority;
• principle of data quality - We update Personal Data shall be up-to-date, complete and necessary for the achievement of the purpose of data processing;
• principle of security - security measures shall be applied in order to protect Personal Data from unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical and organizational measures;
• principle of individual participation - the persons shall be notified of data collected concerning him or her, the persons shall be granted access to the data concerning him or her and the persons have the right to demand the correction of inaccurate or misleading data.

1. PERSONAL DATA THAT WE COLLECT AND PROCESS

   1. In order to fulfill our obligations on provision of a license for personal computers and laptops “Dolphin{tt}” for you and applicable terms of use, We are entitled to ask you to provide Us with your Personal Data, including (but not limited):
      1. personal email;
      2. login Telegram;
      3. IP address;
      4. OS and its interface.
   2. Personal Data collected by or transmitted to Us in the course of accessing, interacting and operating of the Software may include, without limitation, the following Personal Data:
      1. device information, which may include (but is not limited to) information about the personal computer or laptop you use to access the Service, including the hardware model, operating system and version, the web browser you use, and other device identifiers;
      2. server log information, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, your IP address, time spent at the Service;
      3. information collected by cookies and other tracking technologies. We and our providers use various technologies to collect information when you interact with the Service, including cookies and web beacons. ‘Cookies’ are small data files that are stored on your device when you visit the Software, which enables Us to collect information about your device identifiers, IP address, used to access the Service, pages or features viewed, time spent on pages and links clicked. ‘Web beacons’ are graphic images that are placed on a website or in an email that is used to monitor the behavior of the user visiting the website or sending the email. They are often used in combination with cookies.
   3. We may also receive information about you from other sources, such as when you log in to Dolphin{tt} by using your account credentials for a separate third-party Software. We will receive information from that Software as indicated in the relevant third party's authorization screen.
   4. We may collect Personal Data from you in a variety of ways and circumstances, including, but not limited to, using of Dolphin{tt}, subscription to a newsletter, filling out a form, providing Us with feedback. We shall be entitled to combine Personal Data collected in the course of your interaction with different sections of the Service with any other relevant available information.
   5. Processing of Usage Data relies on our legitimate interests. It is necessary for managing and running our business efficiently and effectively, providing quality services including Website support, developing and improving products, determining who may be interested in them.

2. USE OF COLLECTED PERSONAL DATA

   1. We may use the information collected from you for a variety of purposes, primarily, relating to providing our Software and information about our Service. We may also use the information for such other purposes as otherwise allowed by law. For example, We (or a supplier or our affiliate company acting on our behalf and only under our instructions) may use your Personal Data, including personally identifiable information, for such purposes, including, but not limited to:
      1. to provide license and access to Service “Dolphin{tt}”;
      2. to handle your orders and requests, including requests for technical support and assistance;
      3. to properly fulfill tax-related and accounting obligations imposed by applicable laws;
      4. to detect, investigate, and prevent illegal activities or conduct that may violate the Terms of Use of Service “Dolphin{tt}” and this Privacy Policy;
      5. personalize your experience with our Software;
      6. contact you in relation to, and conduct, surveys or polls you choose to take part in and to analyze the data collected for market research purposes;
      7. conduct internal research and development and to improve, test and enhance the features and functions of our Software;
      8. marketing and promotion of our Service or related products, including those of a third party’s products which are related to our Software (If you do not want Us to use your data in this way, please let Us know by contacting Us at: info@dolphin.ru.com ;
      9. meet our internal and external audit requirements, including our information security obligations;
      10. tracking purchases and usage information;
      11. any other purpose as We determine, in our sole discretion, to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, public, and/or our Software, or to comply with requirements of any applicable law.

3. CONSENT TO PERSONAL DATA PROCESSING

   1. EU Persons Consent to Personal Data processing
      1. If you are an EU Person and to process your Personal Data We need to receive your consent, as it is prescribed by GDPR, We will process your Personal Data only in the case We have received from you a freely given, specific, informed and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data (“Consent”).
      2. You may give your Consent by ticking the respective box when you register for an account with our Service. In the case you tick the respective box, you irrevocably and unconditionally consent and agree that We shall be entitled to process your Personal Data as it is indicated by your Consent.
      3. Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the processing has multiple purposes, your Consent should be deemed given for all of them.
      4. You have the right to withdraw your Consent at any time. You can submit such a request by sending Us an email to info@dolphin.ru.com. Your withdrawal of Consent shall not affect the lawfulness of your Personal Data processing based on Consent before its withdrawal.
      5. Except as required or enabled by law We will not use or disclose your Personal Data for any purpose for which you refuse Consent or later withdraw your Consent. If you withdraw Consent, you agree that in spite of this withdrawal, We may continue to use those Personal Data previously provided to Us to the extent that We are contractually or otherwise legally obliged to do so and to the extent necessary to enforce any contractual obligation you may have towards Us or in any other way permitted by law.
   2. Non-EU Persons Consent to Personal Data processing
      1. If you are not an EU Person, by transferring to Us your Personal Data via the Software or otherwise, you irrevocably and unconditionally consent and agree that We shall be entitled, in accordance with this Policy:
         1. to process in any manner, including to collect, store, use, disclose, share and transfer (including cross-border), your Personal Data so provided to Us, as well as your Personal Data collected from your use of the Service (i.e. your Personal Data which We collect automatically and/or from other sources); and
         2. to use cookies and web beacons (pixel tags) to collect your Personal Data.
      2. For Users located in the Russian Federation privacy rights are granted and all processing of Personal Data is performed in accordance with regulations and rules following the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”.

4. СOMPLIANCE WITH GENERAL DATA PROTECTION REGULATION (GDPR), CALIFORNIA CONSUMER PRIVACY ACT (CCPA) AND BRAZIL'S GENERAL DATA PROTECTION LAW (LGPD (LEI GERAL DE PROTEÇÃO DE DADOS))

   1. If you are located in the European Economic Area (EEA) privacy rights are granted and all processing of Personal Data is performed in accordance with regulations and rules following the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (“GDPR”).
   2. If you are located in California, all processing of Personal Data is performed in accordance with regulations and rules following the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq. (“CCPA”).
   3. If you are located in Brazilia, all processing of Personal Data is performed in accordance with regulations and rules following the Lei Geral de Proteção de Dados (“LGPD”).
   4. The Child Online Privacy and Protection Act (“COPPA”) regulates the online collection of information from persons under the age of 13 (covered person). Covered persons are required to obtain parental consent before providing personal data via Service. If you are a parent of a COPPA covered person, you have the option to agree to the collection and use of your COPPA covered person’s information. You may revoke your consent, review your COPPA covered person’s personal data, ask to have it deleted, and/or refuse to allow any further collection or use of your COPPA covered person’s information at any time, contact Us at info@dolphin.ru.com.
   5. We process Personal Data as a Controller, as defined in the GDPR.

5. DATA ACCESS, DATA CORRECTION, DATA DELETION, DATA PORTABILITY AND WITHDRAWAL OF THE CONSENT

   1. You can review, correct, update, delete or transfer their personally identifiable information. For that, contact Us directly at info@dolphin.ru.com. We will acknowledge your request within seventy-two (72) hours and handle it promptly and as required by law.
      1. Right to access. You may contact Us to get confirmation as to whether or not We are processing your Personal Data. When We process your personal data, We will inform you of what categories of Personal Data We process regarding you, the processing purposes, the categories of recipients to whom Personal Data have been or will be disclosed and the envisaged storage period or criteria to determine that period.
      2. Right to withdraw consent. In case our processing is based on the Consent granted, you may withdraw the Consent at any time by contacting Us or by using the functionalities of our Service. You can withdraw your Сonsent at any time by replying to the email with your withdrawal and your Personal Data will be deleted in 48 hours. Withdrawing Consent may lead to fewer possibilities to use our Service.
      3. Right to object. In case our processing is based on our legitimate interest to run, maintain and develop our business, you have the right to object at any time to our processing. We shall then no longer process your Personal Data unless for the provision of our Software or if We demonstrate other compelling legitimate grounds for our processing that override your interests, rights and freedoms or for legal claims. Notwithstanding any consent granted beforehand for direct marketing purposes, you have the right to prohibit Us from using Personal Data for direct marketing purposes, by contacting Us or by using the functionalities of the Service or unsubscribe possibilities in connection with our direct marketing messages.
      4. Right to restriction of the processing. You have the right to obtain from Us restriction of processing of your Personal Data, as foreseen by applicable data protection law, e.g. to allow our verification of accuracy of Personal Data after your contesting of accuracy or to prevent Us from erasing Personal Data when personal data are no longer necessary for the purposes but still required for your legal claims or when our processing is unlawful. Restriction of processing may lead to fewer possibilities to use our Service.
      5. Right to data portability. You have the right to receive your Personal Data from Us in a structured, commonly used and machine-readable format and to independently transmit those data to a third party, in case our processing is based on your Consent and carried out by automated means.
      6. How to use these rights. To exercise any of the above-mentioned rights, you should primarily use the functions offered by our Service. If such functions are however not sufficient for exercising such rights, you shall send Us a letter or email to the address set out below under Contact, including the following information: name, address, phone number, email address, and a copy of a valid proof of identity. We may request additional information necessary to confirm your identity. We may reject requests that are unreasonably repetitive, excessive or manifestly unfounded.

6. STORING AND DELETION OF INFORMATION

   1. We store your Personal Data for as long as needed to provide you with our Software. We may store Data longer, but only in a way that it cannot be tracked back to you. When Personal Data is no longer needed, We delete it using reasonable measures to protect the Data from unauthorized access or use.
   2. EU Territory. We store Personal Data as long as it is needed for the provision of our Software. Traffic information is erased or made anonymous when it is no longer needed for the purpose of the transmission or, in the case of payable Software, up to the end of the period during which the bill may lawfully be challenged or payment pursued. Direct marketing and provision of value-added Software information (including traffic information used for these purposes) are stored as long as the same is necessary for the provision of these activities, or up to the time when a User opts out from such use in accordance with this Privacy Policy. Other information is stored for as long as We consider it to be necessary for the provision of our Service. This Section shall not prevent any technical storage or access to information for the sole purpose of carrying out the transmission of a communication or as strictly necessary in order for Us to provide the Software you requested.
   3. As explained in the GDPR statement, We strive to anonymize the data when possible. If you decide to exercise your right to erasure, We will also inform our providers to delete all your data.
   4. US Territory. We will retain collected information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by applicable legislation.
   5. Storing might be different depending on the territory of collecting the information and the applicable legislation, but We always strive to store the information only as long as it is needed for the purposes of providing, improving or personalizing our Software.
   6. We do not use Software to knowingly solicit information from or market to children under the age of 13. In the event that We learn that We have collected personal data from a child under 13 years of age, We will delete that information as quickly as possible. If you believe that We might have any information from or about a child under 13 years of age please contact Us at info@dolphin.ru.com.

7. INFORMATION SECURITY

   1. We care to ensure the security of Personal Data. We follow generally accepted industry standards to protect the information submitted to Us, both during transmission and once We receive it. We maintain technical, physical, and administrative security measures to provide reasonable protection for your Personal Data. When We or our contractors process your information, We also make sure that your information is protected from unauthorized access, loss, manipulation, falsification, destruction or unauthorized disclosure. This is done through appropriate administrative, technical and physical measures.
   2. There is no 100% secure method of transmission over the Internet or method of electronic storage. Therefore, We cannot guarantee its absolute security.
   3. We never process any kind of sensitive data and criminal offense data. Also, We never undertake to profile personal data.

8. CONTRACTORS

   1. We work with third-party services providers, who provide website, application development, hosting, maintenance, and other services for us. They may be located outside of the EEA. These contractors may have access to, or process Personal Data on behalf of Us as part of providing those services for Us. We limit the information provided to these providers to that which is reasonably necessary for them to perform their functions.
   2. All data transfers are performed in accordance with the highest security regulations. Transfer of Personal Data to countries outside of the European Economic Area may be possible only in the case when We have obtained your Consent for it.
   3. All data processed by Us is stored exclusively in secure hosting facilities provided by mcs.mail.ru, Yandex.Cloud and aws.Amazon.
   4. We use Amplitude Analytics for analyzing User’s behavior and understand how Users are navigating through Software and which features engage the most. For more information on the privacy practices of Amplitude Analytics, please visit the Privacy Policy: https://amplitude.com/privacy.
   5. We use Yandex Metrika to evaluate website traffic and analyze User’s behavior. For more information on the privacy practices of Yandex Metrika, please visit the Privacy Policy: https://metrica.yandex.com/about/info/privacy-policy.
   6. We use Google Analytics to create detailed statistics of website visitors. The statistics are collected on Google's server; the User only places JS code on the pages of his or her site. The tracking code is triggered when the User opens the page in his or her web browser. For more information on the privacy practices of Google Analytics, please visit the Privacy Policy: https://policies.google.com/privacy?hl=en-US s-privacy-policy/.

9. APPLICATION OF THIS PRIVACY POLICY

   1. This Privacy Policy is applicable to our Software. Once redirected to another website or App, this Policy is no longer applicable.

10. ACCEPTANCE OF THESE CONDITIONS

    1. We assume that all Users have carefully read this document and agree to its content. If one does not agree with this Privacy policy, they should refrain from using Service.

11. CHANGES AND UPDATES TO OUR PRIVACY POLICY

    1. From time to time, We may update this Privacy Policy. We encourage you to periodically check back and review this Policy so that you always will know what information We collect, how We use it, and with whom We share it.

12. CONTACT US!

If you have any questions please contact Us at info@dolphin.ru.com.