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Privacy Policy and User Data Protection

1. Introduction and General Provisions

  • 1.1. In order to comply with international legal requirements, respect the rights of Service Users, and maintain its business reputation, ZNA LLC (the "Administration") has developed and put into effect this Privacy Policy and User Data Protection Policy (the "Privacy Policy").
  • 1.2. The Administration states that lawful and fair processing of Service User data, confidentiality of data, and security of data-processing operations are among its most important tasks when providing access to the Service.
  • 1.3. This Privacy Policy is developed and applied on the basis of international law and local regulations that support the purposes of processing and protecting Service User data.
  • 1.4. The requirements of this Policy imposed on the Administration are mandatory for all employees of the Administration.

2. Terms and Definitions

  • 2.1. Data confidentiality means the mandatory requirement for the Administration or persons authorized by it who have obtained access to data not to disclose such data without the subject's consent or another lawful basis.
  • 2.2. Data processing means any action or set of actions performed with data, including collection, recording, systematization, accumulation, storage, clarification, updating, modification, extraction, use, transfer, distribution, provision, access, depersonalization, blocking, deletion, or destruction of data.
  • 2.3. Administration means ZNA LLC.
  • 2.4. Service User means an individual who is a party to the user agreement with the Administration regarding access to and use of the Service through the itlove website, mobile applications, social-network applications, or any other method provided by the User Agreement.
  • 2.5. User Agreement means the agreement between the Administration and the User on the terms of using the Service. The terms of the User Agreement are available at: http://itlove.in/agreement.
  • 2.6. Service means an Internet resource consisting of information and software contained in a hardware-and-software system that makes such information available on the Internet at http://itlove.in.

3. Data Processed by the Administration

  • 3.1. The User data processed by the Administration includes the following information about Service Users: name, date of birth, city of residence, marital status, gender, e-mail address, photo, and other information that Service Users voluntarily provide about themselves or make available for processing in the scope chosen by them. This may also include IP address, cookie information, information about the User's browser or other program used to access the Service, access time, and address of the requested page, if such processing is not prohibited by international law. The Service User may configure their device to minimize the transfer of data to the Administration, for example by disabling cookies, while complying with this Privacy Policy.
  • 3.2. The Administration collects and stores only the data necessary to provide access to the Service and render services in accordance with the User Agreement.

4. Purpose of User Data Processing

  • 4.1. The Administration processes User data exclusively for the following purposes:
  • 4.1.1. Providing access to the Service and enabling Service Users to use it, including User identification, information services, targeting advertising materials, improving the Service, and developing new services.
  • 4.1.2. Entering into other transactions with Service Users that are not prohibited by international law and taking actions aimed at or related to the performance of such transactions.
  • 4.1.3. Advertising and promoting goods, works, and services offered by the Administration through the Service.
  • 4.1.4. Complying with international law.

5. Procedure for User Data Processing

  • 5.1. User data is processed in the following cases:
  • 5.1.1. Processing is carried out with the Service User's consent to the processing of their data.
  • 5.1.2. Processing is necessary to conclude and perform an agreement to which the Service User is a party.
  • 5.1.3. Processing is carried out for User data to which access by an unlimited number of persons was provided by the Service User or at the Service User's request.
  • 5.1.4. In other cases provided by international law.
  • 5.2. The Administration enables use of the Service only if the Service User first provides voluntary and informed consent to the processing of their data in accordance with this Privacy Policy.
  • 5.3. When using the Service, the User undertakes to act in good faith. The good faith of the Service User is presumed under international law. The Service User must provide only reliable information about themselves. The Service User is responsible for the reliability, relevance, and legal compliance of the information provided and bears the risk of violating third-party rights by their actions.
  • 5.4. The Service User agrees that the Administration may send informational, financial, system, and other notifications to the e-mail address specified by the Service User during registration. After registration, the Service User may independently configure the list of information they wish to receive from the Administration by editing the relevant section of the Service.
  • 5.5. The Service User may withdraw consent to the processing of their data by requesting deletion of their account in the Service and ceasing use of the Service.
  • 5.6. If the Service User withdraws consent to data processing, the Administration stops processing the specified data and destroys it within no more than 180 days from receiving the withdrawal, in the manner and on the terms provided by international law and the User Agreement.

6. Rights of Service Users

  • 6.1. Service Users have the right:
  • 6.1.1. To free access to their data within the procedure and limits provided by international law.
  • 6.1.2. To receive information about their data and its processing in the scope and manner established by international law.
  • 6.1.3. To require exclusion or correction of inaccurate and incomplete data, as well as data processed in violation of international law, provided that the Service User or their authorized representative submits information confirming that the relevant data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated processing purpose.
  • 6.1.4. To challenge in court, in the established manner, any unlawful actions or inaction of persons authorized to process data and responsible for organizing data protection.
  • 6.1.5. To exercise other rights regarding their data provided by international law.

7. Data Security

  • 7.1. The Administration takes the necessary legal, organizational, and technical measures to protect Service User data against accidental or unauthorized access, destruction, modification, blocking of access, and other unlawful actions involving Service User data.
  • 7.2. To coordinate actions for ensuring the security of Service User data, the Administration:
  • 7.2.1. Adopts local regulations aimed at planning, organizing, and implementing legal, organizational, and technical measures to ensure the security of Service User data, and fully implements those measures.
  • 7.2.2. Appoints a person responsible for data security.

8. Final Provisions

  • 8.1. This Privacy Policy is a publicly available document that declares the conceptual basis of the Administration's activity when processing Service User data.
  • 8.2. The Administration may amend this Privacy Policy. A new version of the Privacy Policy takes effect when it is posted online at http://itlove.in/agreement/privacy, unless otherwise provided by the Administration. The current version of the Privacy Policy is always available at http://itlove.in/agreement/privacy.
  • 8.3. The Administration informs Service Users that this Privacy Policy applies only to the Service. The Administration does not control and is not responsible for third-party websites that the User may access, at their discretion and risk, through links posted in the Service by other Service Users.
  • 8.4. International law applies to relations between Service Users and the Administration arising in connection with this Privacy Policy.
  • 8.5. If the Administration provides a translation of this Privacy Policy into another language for User convenience, the Russian version of the Privacy Policy prevails, and relations between the User and the Administration are governed by the Russian version.

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