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TamTam Messenger Confidentiality Policy

1. General Provisions

1.1. Mail.Ru Limited Liability Company (Primary State Registration Number (OGRN) 1027739850962, address: 39 Leningradsky Prospekt, bld. 79, Moscow, 125167, Russia), hereinafter referred to as the Company or the Licensor, hereby undertakes to keep confidential any data and information provided by the users (hereinafter referred to as the Licensee or the User) during their use of the computer program of the TamTam application for mobile devices on Android and iOS platforms (hereinafter referred to as the Messenger).

1.2. This Policy sets the rules that the Company adheres to when collecting and/or processing any data and information provided by the Licensee or made available to the Company during the use of the Messenger by the Licensee.

1.3. The use of the Messenger is subject to the Licensee’s consent to this Policy published on the Company Website at: https://help.mail.ru/legal/terms/tamtam/eng/privacy. Each time when accessing and/or actually using the Messenger, the Licensee agrees to comply with this Policy and with the terms and conditions of the License Agreement made available at https://help.mail.ru/legal/terms/tamtam/eng/LA (hereinafter referred to as the ‘Agreement’) and Regulation of using channels made available at https://help.mail.ru/legal/terms/tamtam/eng/regulations ( hereinafter referred to as the ‘Regulation’) as amended as of the time of the actual use of the Messenger.

Some terms used in this Policy are defined in the Agreement.

2. Data and other information processed by the Company

2.1. Account data and other data relating to the Licensee shall be processed by the Licensor for the purposes of the proper performance of the Agreement.

2.2. The account data are understood to mean information provided independently by the Licensee during the registration in the Messenger by means of completing a registration form (in case of registration by phone number) and some of the information provided during the use of the Messenger.

2.3. The registration in the Messenger is possible via other services of the Licensor or third parties, such as OK or Google (hereinafter referred to as the Social Network Account). When using this feature, the Licensee agrees that the Licensor may have access to certain information of the Licensee contained in the Social Network Account and may publish such information and store it in the Messenger.

2.4. Other data are understood to mean data relating to the Licensee that become accessible to the Licensor in the course of the Licensee’s use of the Messenger and/or the services of affiliated parties and/or partners. Such data may include without limitation information about the hardware (devices) and means of technical interaction with the Messenger and/or the services of affiliated parties and/or partners (including host IP address, the Licensee’s operating system, browser type, geographical location, information about the provider etc.), about the Licensee’s activity, and other data obtained by the means specified, as well as photos and images uploaded by the Licensee in public chats and channels of the Messenger, which according to the AI-systems may contain the content that violates the terms of the Agreement and/or the Rules, as well as photos and images which the Licensor received complaints from the  other users of the Messenger.

2.5. For the purposes of performance of this License Agreement and providing the Licensee with access to the Messenger’s functionality, the Licensor shall develop, improve, optimize and introduce new functionality to the Messenger (including services and products of an informative, advertising, educational, entertaining or other nature), including with the involvement of affiliated parties and/or partners. To ensure that the stated purposes can be achieved, the Licensee agrees to and delegates to the Licensor, in accordance with the applicable laws, the processing (including collection, recording, systematization, retention, storage, clarification (updating, amending), comparison, extraction, use, anonymization, blocking, deletion and destruction) of account data and other data relating to the Licensee, including the results of automated processing of such data, which may, among other things, be in the form of integer and/or textual values and identifiers, as well as the transfer of such data to affiliated parties and/or partners in fulfillment of said delegation to process the data, and the collection (receipt) of account data and other data pertaining to the Licensee from affiliated parties and/or partners.

2.6. The Licensor may have access to other information relating to the Licensee and provided by the Licensee at the latter’s discretion in the course of using the Messenger, which is not processed by the Licensor, including for achieving the purposes indicated above.

2.7. Processing of the Licensee’s account and other data shall be performed during the whole period from the registration in until the deletion of the Messenger, unless otherwise stipulated by the applicable laws. The Licensee may recall its consent to the processing of its account and/or other data, having notified the Licensor to this end at the address stated in Section 5 of this Policy. In such a case, the Licensee shall stop using the Messenger.

2.8. For the purposes of properly fulfilling the conditions of the License Agreement, the Licensor shall take safety measures. To ensure fulfilling the stated purposes, the Licensee agrees that account data and other data may be passed to third parties, including in instances covered by the applicable laws, in a volume required to identify, investigate and suppress illegal activities.

2.9. The Licensee agrees to the display of its account and other data, as well as additional information, on its profile within the scope of the Messenger functionality, and also agrees that such data will be considered publically accessible, unless the Licensee has chosen an alternative mode for access to said data within the scope of the Messenger’s functionality. The Licensee agrees that information, including account data and other data, may be accessible to other Internet users, taking into account the existing functionality of the Messenger (that may be changed from time to time by the Licensor). The Licensor may restrict the use of information from the Messenger by third parties, in particular for commercial purposes. The use of information by the Licensor is governed by the Agreement.

3. Applicable Law

The Users’ data shall be processed in accordance with the laws of the Russian Federation.

4. Policy Application

The Company reserves the right to introduce amendments to this Policy. A new version of the Policy shall be effective from the time of its publication on the website at: https://help.mail.ru/legal/terms/tamtam/eng/privacy. The Licensee shall regularly familiarize itself with new versions of the Policy.

5. Feedback

The Licensee may provide its opinion on the confidentiality principles of the Company by e-mail to [email protected].