This Personal Data Policy (hereinafter - the "Policy") contains information about personal data protection policy of Razoom ltd., a company Registered at Rm 301, 43, San Fung Ave. Sheung Shui, NT Hong Kong (hereinafter - the "Company"), in connection with its computer program Razoom (hereinafter - the "Program"), available for downloading on the Company’s website www.razoom.org (hereinafter – the "Company’s Website"), as well as in Apple Store and Google Play. Users can download and install the Program and start using it after registration (creation of an account). When registering users provide their personal data. This Policy regulates the issues related to the protection and processing of personal data of individuals. The terms used in this Policy, other than those defined in the preamble hereof, are defined in the End User Agreement, which is entered into by the Company and the User before he or she starts using the Program.

1. GENERAL PROVISIONS

1.1. Personal data means any information relating to a particular User, which is provided by him or her voluntarily during creation of his or her Account and / or use of the Program. The personal data may include:

1.1.1. Full name of the User;
1.1.2. E-mail address of the User;
1.1.3. Phone number of the User;
1.1.4. Information about philosophical ideas and religious beliefs, personal life, relations with others;
1.1.5. Other information, provided by the User.

1.2. In addition to the personal data listed in paragraph 1.1 of this Policy, the User authorizes the Company to receive and process the following data:

1.2.1. Visitor statistics; logs; statistics information about his or her actions on Company’s website and in the Program;
1.2.2. Technical information about the devices and operating systems used by the User;
1.2.3. IP-address and information about used browser, time of access, search requests and data from cookies;
1.2.4. Information provided by the User when he or she requests any information or technical support, purchases Modules, including the information necessary for the processing of his or her orders by payment systems, including the amount of payment;
1.2.5. Other information provided by the User when he or she participates in contests, sweepstakes, tournaments, promotions and marketing surveys.

1.3. Personal data can be collected by the Company when the User registers and afterwards (when the User edits his or her information, uses the Program, acquires Modules, gets technical support). The User hereby allows the Company to collect such personal data.
1.4. The source of information about all User’s personal data is the User himself or herself. All personal data provided by the person when he or she creates the Account and uses the Program is provided by that person voluntarily.
1.5. By filling in the registration form required to create the User’s account the latter thereby gives his or her consent to the processing of his or her personal data for the purposes specified in paragraph 2.1 of this Policy.
1.6. The Company has a policy to prevent an unauthorized use of personal data collected from the Users.

2. PURPOSES OF PROCESSING OF PERSONAL DATA

2.1. The purposes of the processing of personal data by the Company are as follows:

2.1.1. registration of the User in order to get access to the Program and his or her identification in the Program;
2.1.2. acquisition of a Module;
2.1.3. correct reflection of the User’s data and the information related to the User in the Program;
2.1.4. further development of the Program and related services;
2.1.5. marketing and statistic researches held by the Company
2.1.6. direct marketing and sales;
2.1.7. technical support, provision of the information about the Program’s fitches, sending requests about the use of the Program.

2.2. The User hereby agrees to transfer of his or her personal data, to the Company’s affiliated persons and partners for the purposes set in paragraph 2.1 of this Policy.

3. MEASURES TO ENSURE THE COMPLIANCE WITH LEGAL REQUIREMENT CONCERNING PERSONAL DATA

3.1. The Company is taking the necessary legal, organizational and technical measures to protect personal data from unauthorized, unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as other illegal actions in respect of personal data, which may include:

3.1.1. limiting and regulating the number of employees who have access to personal data;
3.1.2. familiarizing of the employees, who are directly involved in the processing of personal data, with the provisions of the Hong Kong legislation on personal data, and the present Policy;
3.1.3. password access to Users’ personal data;
3.1.4. control of access to the communication ports, input and output devices, hard disk drives and portable storage devices;
3.1.5. implementation of anti-virus control;
3.1.6. application of firewall;
3.1.7. data backup;
3.1.8. restore of personal data modified or destroyed as a result of unauthorized access.

4. SAFETY MEASURES IN RELATION TO PERSONAL DATA

4.1. When processing personal data the Company undertakes the legal, organizational and technical measures to ensure the security of personal data and to protect them from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution.

4.2. To ensure the security of personal data the Company:

4.2.1. identifies the threats to personal data during its processing;
4.2.2. uses technical and organizational measures to secure protection of personal data;
4.2.3. applies special measures for data protection;
4.2.4. evaluates the effectiveness of the measures taken to ensure the security of personal data;
4.2.5. reveals evidence of unauthorized access to personal data and takes the necessary measures;
4.2.6. restores personal data modified or destroyed as a result of unauthorized access to them;
4.2.7. sets rules of access to personal data, and also sets the registration and recording of all actions with personal data in the information system;
4.2.8. controls measures taken to ensure the security of personal data and the level of protection of personal data in the information systems.

5. PERSONS AUTHORISED TO DEAL WITH PERSONAL DATA

5.1. The person responsible for organization of the processing of personal data in the Company (hereinafter – the "Responsible person") is the Director General. The Responsible person fulfills the following functions:

5.1.1. monitoring of compliance by the Company and its employees with the provision of the legislation concerning personal data;
5.1.2. information of the Company’s employees about the provisions of related legislation concerning personal data, local regulations on the processing of personal data, and other set requirements for the protection of personal data;
5.1.3. organization of reception and processing of complaints and requests of the Users, monitoring their reception and processing.

6. USE AND TRANSFER OF PERSONAL DATA

6.1. The Company uses cookie files that are stored at the User’s Devices.
6.2. In accordance with applicable law, the Company is entitled to use the Users’ e-mails to provide them with information about its products and services, as well as similar products and services, if the User has not refused to receive such information.
6.3. The company can transfer the Users’ personal data only in the following cases:

6.3.1. When there is such obligation on the basis of the applicable legislation, or requirements of state law enforcement agencies, or in order to prevent crime;
6.3.2. when there is a need to transfer them in order to fulfill the provisions of the Agreement, to provide the Company’s services, to protect other users or persons, to protect the rights and the property of the Company as well as the rights and property of other users and in some other cases;
6.3.3. when there is a need to transfer them in order to provide services to the User, and in relation to his or her the acquisition of a Module.

6.4. The User hereby agrees that in the above cases his or her personal data and information about him or her can be transferred to the countries which are not parties to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data of 28 January 1981.
6.5. The Program and the Company’s Website may contain links to other persons or goods and services offered by them. The Company is not responsible for personal data collection by such persons.

7. USER RIGHTS

7.1. The User has the right to receive information about the processing of his or her personal data by the Company.
7.2. The User has the right to edit his or her personal data at any time.
7.3. The User may at any time withdraw his or her consent to the processing of personal data by sending to the Company the relevant notice.
7.4. The User has the right to require the Company to clarify personal data, to block it or destruct it if it is incomplete, outdated, inaccurate, or illegally obtained, or is not necessary for the stated purpose of their processing, as well as take legal measures to protect his or her rights.
7.5. In order to exercise his or her rights and protect his or her rights and legitimate interests the User can address the Company. The Company should examine any User’s application or grievance, investigate any alleged violation and take all necessary measures for its elimination, hold responsible any person who is guilty and settle disputes and conflicts through pre-trial negotiations.
7.6. The User has the right to protect his or her rights and legitimate interests, including claiming compensation for his or her pecuniary and / or non-pePersons guilty of violation the rules governing the processing and protection of personal data, should be held liable under the applicable law.

Version of 18.02.2016

 

 

Please read this Agreement carefully. If you download, install, copy or use program RaZOOM in any other manner, you agree and acknowledge that you have read and understood this End User License Agreement, agreed to its terms and conditions and accepted them, agreed to be bound by it, and to be responsible for any violation of any of its provisions. This End User License Agreement (hereinafter "the Agreement") governs the relationship between Company RaZOOM ltd., Registered at Rm 301, 43, San Fung Ave. Sheung Shui, NT Hong Kong (hereinafter "the Company") on one side and the user of the program RaZOOM (hereinafter "the User"), hereinafter referred to individually as "a Party" and together as "the Parties". 1. DEFINITIONS Account – an account created by the User, which contains the User’s data necessary for his or her identification (authentication) in the Program and for provision of access to his or her personal data, settings, acquired Modules, statistic indicators and other information in the Program. Frontend – the software needed for the Program’s use by the User, which should be installed on the User’s Device. Modules – additional features of the Program available for fee according to the terms of the Agreement. User – a natural person over 18 years, who has necessary legal capacity to enter into this Agreement, which is a party to this Agreement and is entitled to use the Program under this Agreement. Program – a computer program RaZoom, which includes its Modules, add-ons and updates. Website – Internet web site located at www.razoom.org. Device – a hardware system in which the Program can be installed. Elements of the Program – objects, elements and methods, available to the User in the Program. 2. SUBJECT MATTER OF THE AGREEMENT. CONDITIONS OF THE AGREEMENT 2.1. This Agreement is concluded at the moment when the User accepts it at the earliest of the following: (i) the moment of the Program installation at the User’s Device, or (ii) the moment when the User starts using the Program in case when the User gets a Devise with the Program already installed on it. 2.2. The User gets the right to use the Program free of charge in any country of the world in accordance with the provisions of this Agreement. 2.3. All rights to the Program belong to the Company. The rights to use the Program can be granted to the User only by the Company or its authorized representative. 2.4. The User can use the Program within its basic functionality for free, as well as get access to its Modules on a fee basis. 2.5. The User is fully responsible for the use of the Program on the territory on which the Program may not be used or may be used with limitations. 2.6. The User hereby acknowledges that he or she is over 18 years old and has full legal capacity to enter into this Agreement. 2.7. The User hereby acknowledges that he or she has no contraindications to use the Program and does not suffer from any diseases or disorders, due to which he or she cannot use the Program. Otherwise he or she will not use the Program. The User is fully responsible for the results of the use of the Program. The User hereby refuses from any claims related to his or her state of health, including but not limited to emotional or mental state, as well as related to possible effects on his or her health. 3. THE PROGRAM AND ITS MODULES 3.1. The Program is provided as is. The Company does not provide any warranty whatsoever in respect of the Program, other than those expressly stated in this Agreement or required by applicable law. The Company neither warrants, nor makes any commitments in respect of the Program’s compliance with the User’s requirements or expectations or his or her satisfaction from its use as well as corresponding of the Program’s functions to the Users’ requirements and smooth and error-free functioning. 3.2. The User hereby understands, accepts and agrees that he or she is fully responsible for any data or other information, which he or she provides to the Program. 3.3. Use of the Program requires an Internet connection, which should be provided by the User. 4. RIGHTS, DUTIES AND RESTRICTIONS OF THE USER 4.1. The User Has The Following Rights 4.1.1. To use the Program upon its installation on his or her Devices if the combination, components and content of the Program remain unchanged. 4.1.2. To use the Program respecting the limitations set forth in this Agreement. In order to use the Program, the User may: (a) create and delete his or her Account in accordance with the provisions of this Agreement; (b) use basic functions of the Program; (c) acquire Modules, and (d) perform other actions with the Program permitted by the Company if such actions do not affect the rights of the Company and other persons. 4.2. The User May Not 4.2.1. Copy the Program, publish, and distribute with any purpose the Program or any part thereof or its copies, rent, lease or lend the Program. 4.2.2. Translate the software into other languages; use for any purposes its audiovisual elements, images, and other Program’s content subject to protection as intellectual property. 4.2.3. Use automated scripts to interact with the Program and its Elements. 4.2.4. Use the Program by any means, which are not provided for in the Agreement, including for an impact on other persons; or for the purposes prohibited by law. 4.2.5. Hack, decompile, disassemble, decode the Program, try to bypass any restrictions in the Program, modify the Program, create other software on the basis of the Program or its Elements. 4.2.6. Provide the Program to other users through a network, install the Program on a server or a Device and provide a remote access to it. 4.2.7. Transfer to rights to the Program, including its Modules, to another persons. Transfer the Account or acquire an account of another User. 4.2.8. Use accounts of another Users. 4.3. The User Undertakes To 4.3.1. Comply with the terms of this Agreement. In case of disagreement with any provision of this Agreement, the User must terminate using the Program and uninstall the Frontend from his or her Devices. 4.3.2. Provide the exact, true and correct information when creates the Account. 4.3.3. Not violate the intellectual property rights of the Company in respect of the Program or its Elements. In particular, the User has no right to copy, transmit, publish or otherwise distribute or reproduce materials (text, image, audio or video) contained in the Program. 4.3.4. Undertake security measures for prevention of access of another persons to his or her Account. Also not to disclose to other persons personal information which allows authentication of the User in the Program. In case of an unauthorized access to the User’s Account he or she should immediately report this to the Company. 4.3.5. At the Company's request to confirm his or her personal and other data required in connection with the conclusion and execution of this Agreement and for compliance with the provisions of the applicable law. 4.3.6. To compensate to the Company and (or) other persons any losses arising out of the User’s actions, including out of the breach of this Agreement or violation of other persons’ intellectual property rights. 4.3.7. The User understands that the modification of the Program and its components is carried out through the creation and installation of new pieces of software (patches) that may lead to the removal or suspension of access to certain Elements of the Program. The User hereby acknowledges that these actions are an integral part of the process of the Program’s creation, and gives his or her consent to these actions without his or her prior notice and consent. 4.4. Beta Testing 4.4.1. When the User participates in the beta testing of the Program, he or she obtains the status of the beta-tester. The purpose of the beta testing is to assess the Program’s functionality and detect error in it. 4.4.2. During the beta testing the User is not granted any additional rights or privileges and no remuneration is paid. 4.4.3. The Company is not responsible for any events that occur in the process of the beta testing. The User hereby agrees that he or she is participating in the beta testing at his or her own risk and understands that the software may contain bugs. 4.4.4. Any information received by the User during the beta testing is confidential and shall not be disclosed. The provisions of this Agreement relating to the protection of intellectual property, as set out in Article 8 herein shall apply. The User is responsible for disclosure of any information about the Program received at the course of the beta-testing, as well as for any illegal use of intellectual property related to the Program, and shall indemnify the Company for any and all associated losses. 5. RIGHTS AND OBLIGATIONS OF THE COMPANY 5.1. The Company May 5.1.1. At any time, unilaterally limit, expand, extend, and modify in any other way the Program, including any its Elements and parts, without User’s consent or prior notice. 5.1.2. Manage the Program, its processes and technical features of its Elements and Modules upon its own discretion without User’s consent or prior notice. 5.1.3. Restrict, suspend or terminate access of the User to the Program in case of violation by the latter of the provisions of this Agreement. When doing this, the Company is not obliged to provide the User with any evidence of his or her violation of the Agreement. 5.2. The Company Undertakes To 5.2.1. Allow the User to use the Program under the conditions set forth in this Agreement, provided that he or she abides by this Agreement. 5.2.2. Allow the User to purchase (download) the Frontend at the Website, Apple Store and Google Play, or in other place approves by the Company. 5.2.3. Notify the User about the amendments to this Agreement, by publishing the respective information on the Website. 6. LIMITATION OF THE COMPANY’S LIABILITY 6.1. The Company does not bear any liability for: 6.1.1. Illegal actions of the User and (or) other persons in connection with the use of the Program. 6.1.2. Loss of User’s authentification data necessary for the access to his or her Account (loss of login, password, other information necessary to enter into the Program). 6.1.3. Incompleteness, inaccuracy or incorrectness of the User’s data provided by him or her at the moment of the creation of his or her Account. 6.1.4. Lack of Internet connection at the place where the User is using the Program or poor quality of the network connection. 6.1.5. Direct or indirect losses, as well as lost profit of the User or other persons in connection with the use of the Program or impossibility to use it; unauthorized access to the User’s personal data including those related to his or her Account. 6.1.6. In all circumstances, the Company's liability to the User is limited to an amount not exceeding the amount of payments received by the Company from the User prior to the events which entailed such liability. In case no payments were made by the User, the Company’s liability should not exceed 100 rubles. 6.1.7. The Company should not be held liable for a failure to fulfill its obligations under this Agreement fully or in part if such failure results out of force majeure, including riots, bans imposed by the authorities, natural disasters, fires, accidents, and also due to failures in telecommunication and power networks, malwares programs, as well as actions of other persons, aimed at gaining unauthorized access to, or disabling the software or hardware system. 6.2. The Company does not guarantee that: 6.2.1. The Program will satisfy personal requirements and expectations of the User. 6.2.2. The Program will work quickly and without technical failures, reliably and without errors. 6.2.3. The results that can be obtained with the Program will be correct and without errors. 6.2.4. The quality of the Program, it elements and Modules, as well as information obtained in the course of its use, will fit the User’s expectations. 6.2.5. The Program will be available for use around the clock, at a certain point in time or within a specified period. 7. PROGRAM’S MODULES 7.1. This section of the Agreement regulates the procedure and conditions for the use of the Program’s Modules. The Modules are its part, access to which is available in connection with the use of the Program. The User can acquire the Modules upon his or her personal desire and such acquisition is not compulsory. 7.2. By acquiring a Module the User gets access to advanced functionality of the Program. The Company determines the types and contents of the Modules. 7.3. The access to the Modules and their use shall be available through the duration of this Agreement, unless otherwise is provided in this Agreement or arise out of the nature of a Module. 7.4. The access to the Modules is provided by Company only at the User’s request. The User will be charged for each Module. The payment operator can charge commission in addition to the Company’s charges. The User understands and agrees that if he or she pays for a Module through a payment operator, he or she may be charged more than the charge set by the Company for a particular Module. 7.5. The User can get access to a Module only upon its payment in full. Until the Company receives a confirmation of the payment it may restrict the User’s access to the Module. 7.6. In case if due to a technical error the User gets an access to a Module which does not correspond to the one paid for by the User, he or she should immediately inform the Company and the letter will undertake all possible measures in order to provide the User an access to the correct Module which he or she paid for. 7.7. In case if due to a technical error, failure of the Program or intentional actions of the User, he or she gained access to the Module without payment, the User shall notify the Company and pay the cost of such Module. Otherwise, the Company may terminate the User's access to the Module without notice and without any compensation. 7.8. The User hereby acknowledges that he or she has the right to use the chosen method of payment for a Module which will not violate any rights of other persons and (or) the law of the country in which the Program is used or the payment is made. 7.9. Unless otherwise provided herein or set by the applicable law, the Company may unilaterally suspend or terminate the User’s access to a Module in case of suspicions of the User’s wrongful actions in connection with the payment. In such case the Company is not obliged to pay any compensation to the User including compensation for the payment made by the User. 8. INTELLECTUAL PROPERTY 8.1. The Program, its source and object code, graphics, user interface, texts, sound effects, music, photos, images, animation and video, as well as any other its Elements are (or) contain intellectual property, the exclusive right to which belongs to their rightful owners. 8.2. Any use of the Elements protected by intellectual property rights, or their parts is prohibited if not specifically allowed in this Agreement. 9. VALIDITY, AMENDMENT AND TERMINATION 9.1. This Agreement shall enter into force at the moment of acceptance of its terms by the User in accordance with Article 2.1 of this Agreement and shall remain in force during the entire period of use of the Program. 9.2. The User may unilaterally terminate the Agreement and uninstall the Program from all his or her Devices, on which the Program was installed. In this case the Company will not pay back to the User the amounts that he or she had paid and will not cover any losses. 9.3. The Company may unilaterally terminate this Agreement with termination of the User’s access to the Program in case of any violation of this Agreement. In this case the Company will not pay back to the User the amounts that he or she had paid and will not cover any losses. 9.4. The Company may amend this Agreement unilaterally. The amendments take effect from the date of their publication on the Website. 9.5. If, after the publication of amendments to the Agreement, the User continues to use the Program, he or she thereby accepts such amendments. The User is held liable for the abidance with the amended Agreement even if he or she did not familiarize himself or herself with the amendments. 9.6. The terms of this Agreement apply to all the upgrades of the Programs, which replace or complement its original version. 9.7. When a Device with the installed on it Program is transferred by the User to another person, such person accepts the terms of this Agreement as of the moment when he or she starts using the Program and becomes a party to this Agreement and gets all rights and obligations of the User. 10. FINAL PROVISIONS 10.1. If one or more provisions of this Agreement is declared invalid by a court decision, the remaining provisions of this Agreement shall remain in force, and the Parties shall fulfill their obligations out of this Agreement by a mean which is the most appropriate and close to their initial intentions existed at the moment when they entered into this Agreement. 10.2. All disputes of the Parties out of this Agreement shall be settled by negotiations and correspondence with the mandatory pre-trial settlement negotiations. Failure to reach an agreement between the Parties through negotiations within sixty (60) calendar days of the receipt by a party of a written complaint of the other, the dispute may be transferred to a court at the place of registration (place of residence) of the defendant. 10.3. The inaction of the Company in case of breach by the User of the provisions of this Agreement does not deprive the Company the right to take appropriate action later in order to defense its interests and intellectual property rights. 10.4. This Agreement and the relationship between the Parties arising out of it are regulated by the laws of the Russian Federation. 10.5. This Agreement signed by the User’s electronic signature has the same force as a document signed by the User. This Agreement exists in several language versions. In the event of any conflict between the Russian and other language versions, the Russian version shall prevail.