PRIVACY POLICY 

of the LLC «Russo-Bel-Remstroi»

Effective: January 11, 2021

• Introduction

For LLC «Russo-Bel-Remstroi» ensuring of rights’ and interests’ protection of the Users is one of the most priority issues considering the peculiarities of usage of LLC «Russo-Bel-Remstroi» services. For the purpose of the General Data Protection Regulation 2016/679 and any implementing legislation (the "GDPR"), LLC «Russo-Bel-Remstroi» (referred to as “RBR Mobile”, “we”, “us”, or “our”) will be the data controller responsible for any personal data we process. Every time Services are used, data about your mobile end device are automatically collected, processed, and used. Provision of some personal identifying information is necessary for the User in order to access to RBR Mobile services receipt. In some cases, represented below non-provision of the respective personal data by the User shall result in inability for the RBR Mobile to provide services to the User. 

Within the present privacy policy of the RBR Mobile under personal data the information relating to an identified or identifiable User is understood such as your name, email address, IP address, and device identifier, among other things. Personal data do not include anonymous data that do not relate to an identified or are not identifiable in relation to concrete User as well as depersonalized data.

Purpose and legal ground for processing User’s personal data: 

• Contract with you (fulfillment of the provisions of the Terms of Use concluded between the User and the RBR Mobile, provision of the User’s access to the services provided by the RBR Mobile.
• Legitimate interest (to further our legitimate interest (incl.: providing effective and innovative Services to our users; to detect, prevent or otherwise address fraud or security issues in respect of our provision of Services; carry out research and statistical analysis; carry out marketing and business development). 
• Our use of your personal information is necessary for complying with our legal obligations.
• Consent. (to send you certain communications or where you submit certain information to us, or where required to rely upon consent by local law).

If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by sending an e-mail to the address support@rbrmobile.com with the topic “Consent withdrawal” or in the Settings menu of the application and we will stop doing so. If you withdraw your consent, this may impact the ability for us to provide some of our Services to you. If you do not understand any aspects of our Privacy Notice, please feel free to contact us at support@rbrmobile.com.

The User hereby freely gives, specific, informed and unambiguous consent to the processing of the personal data relating to him or her and mentioned above for the purposes of personal data processing indicated hereto.

• Personal Data we may collect

RBR Mobile Services can collect personal data related to users of our Services from the following sources: 

• from you directly (through the game or online forms); 
• from third parties, service providers that are assisting us in providing you with a service, or from your social networks accounts you used to sign in to our online services (for example, Facebook, Google);
• automatically.

RBR Mobile Services may collect the following categories of personal data relating to our existing or prospective Users (cases of collection are indicated):

• Information about device or browser within the access to the RBR Mobile applications that is processed by automated means, i.e. information about mobile device, including IP-address, operational system, IDFA (Identifier For Advertisers) or Apple/Android ID, technical data regarding device attributes and settings, applications, advertising opt-out signals, in-app events, device motion parameters and carrier; he hardware model, operating system and version, device identifiers set by your device operating system, and mobile network information (like your connection type, carrier and region);
• User provide to us: Name, surname, mobile phone number, registration data (login/name/e-mail address and password), feedback and survey responses in case of registration procedure conducting, participate in interactive features (like submit rating), communicate with us.
• Mobile advertising IDs, GPS location (if appropriate permission is given), application usage statistics such as launch times and duration, ad views and click-throughs, if there are advertisements in the application.
• Usage information: date and time you used Services, your interactions with the Services and with the other users or players inside the Services, subscriptions, advertising that you click on, your App progress.
• Any content User downloads into RBR Mobile applications such as User photos, place of residence etc., if such a download is possible in the application. 
• If you sign into the Services with Facebook Connect or Google Connect we will collect information that is visible via your Facebook or Google account such as: (1) your first and last name, (2) Facebook ID/Google ID (3) Profile Picture/URL

With your consent, we send promotional and other push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

• Ways of using personal data

Purpose of this Privacy Policy is fulfillment of the provisions of the Terms of Service (“Contract”) concluded between the User and Russo-Bel-Remstroi LLC. For example, we may use the Personal Data in the following ways:

• Account setup and administration: We use Registration information and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription, and Service information.
• Personalization: We use Personal Data to personalize your experience with our Services. Some of our Services will ask you to share your geolocation so we can customize your experience and increase the accuracy of the Service. If you agree to share your geolocation with us, you will be able to turn it off at any time by going to the privacy settings on your mobile device or online. For example, we may ask for age verification if we have reasonable doubts regarding your age.
• Making our service available. We use information that you submit and information that is processed automatically to provide you with all requested services.
• Providing you with interest-based (behavioural) advertising or other targeted content. We may use information that is processed automatically for marketing purposes (to show ads that may be of interest to you based on your preferences). We provide personalized content and information to you, which can include online ads or other forms of marketing.
• To communicate with you. We use the information we have to communicate with you through newsletters, i.e. to send you marketing notifications, receive your feedback about our App experience, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
• Research and development: We use Personal Data for internal research and development purposes and to improve and test the features and functions of our Services. We use information that is processed automatically to better understand user behaviour and trends, detect potential outages and technical issues, to operate, protect, improve, and optimize our App.
• Legal obligations: We may be required to use and retain Personal Data for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud.
• To post testimonials. We post testimonials on our Apps that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and testimonial. If you wish to update, or delete your testimonial, please contact us at support@rbrmobile.com and be sure to include your name, testimonial location, and contact information.
• Send you push notifications, related information, including confirmations and reminders (if you choose to allow that function)—only for users 18 years old or older and you can independently disable this anytime. 
• We may use Automatically Collected information and Cookies information to maintain and improve our Services, including to do the following things: (a) automatically update the applications on your system; (b) remember your information so that you will not have to re-enter it during your visit or the next time you access our Services; (c) provide customized third-party advertisements, content and information, unless it will include instructions on how to opt out of receiving these advertisements, content and information in the future; (d) monitor the effectiveness of third-party marketing campaigns; (e) monitor aggregate site usage metrics such as total number of visitors and pages accessed.

• Sharing information

We do not share personal information with other third parties, including people or companies, except when we have your permission and third-parties which you can find bellow. We will not rent or sell or disclose your personally identifiable information to others. We allow to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and online services, including your IP address, device identifiers, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and online services, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. If you are in the EU, please visit www.youronlinechoices.eu/. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.

The following companies are the Processors of the personal data of the applications of RBR Mobile (In case you want to learn more about the services and privacy options please consult their websites and privacy policies)::

RBR Mobile – only for the User-downloaded content and, if such download is possible in the application; registration procedure and the request for additional information.

Our Services allow in-app purchases. In-app purchases are not mandatory and it is up to you whether to pay for accessing such functionality or not. You should know that we don’t process payments directly, payments processed via Apple App Store (Apple Inc., https://www.apple.com/legal/privacy/en-ww/) and through the Google Play Store (Google LLC, https://policies.google.com/privacy). We don’t collect or store payment data, details or payments-related personal data. Payment processing takes place through a payment system, integrated into the app store, appropriate for your platform. 

We work in the international space and provide our Services to our Users around the world. We and third-party organizations that provide automatic data processing technologies for the App or our third-party advertising partners may transfer the automatically processed information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located outside Belarus and choose to provide information to us, please note that we transfer the data, including Personal Data, to Belarus and process it there. This means that your personal information can be transferred to a third country, a territory or one or more specified sectors within that third country, or to the international organization where data protection and confidentiality regulations may not provide the same level of protection of a personal data as your country does. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

• User’s rights

The User is also entitled to:

1. request the access to and rectification or erasure of personal data processed by the RBR Mobile;

2. restrict the processing of personal data concerning the User;

3. object to processing of personal data concerning the User;

4. demand for realization of the right to data portability from the RBR Mobile;

5. exercise the right to lodge a complaint with a relevant supervisory authority.

The User is empowered to request one copy of the personal data undergoing processing free of charge. Any additional copies are provided on a reimbursement basis.

RBR Mobile hereby undertakes not to conduct any disclosure or transfer of the User’s personal data to any third parties, except Processors, mentioned above, without receipt of personal consent of the User.

RBR Mobile uses the safety measures for ensuring the confidentiality of the User’s information as well as for protection of the User’s information from loss, theft, unauthorized access, misuse, amendment or destruction.

The User is obliged to ensure safety of the registration data indicated by him or her for safe usage of RBR Mobile.

• Keeping the personal information

RBR Mobile stores the personal data relating to the User for 1 (one) year after closing, termination of the Personal account or uninstalling the application. Upon termination of the mentioned term personal data relating to the User are subject to destruction or depersonalization to ensure anonymity of such information via deletion of the personal identifying information.

Data retention periods for other Processors are indicated by the links above.

• Our policy towards children

Our Services usually have a minimum age requirement of users and are not directed to children, and we do not knowingly collect Personal Data relating to children. Children should never disclose their name, address or phone number, or any personal information, without their parents’ prior permission. We consider a user to be a child if they are under the age of 13, unless more stringent regulation applies in their country of residence. In EU countries, users under the age of 16 are considered children, unless the data protection regulation of their country of residence specifies another age. If you become aware that your child has provided us with Personal information without your consent, please contact us and we will take the required steps to delete such information.

• Amendment to privacy policy

Conditions of the present privacy policy of the RBR Mobile may be unilaterally changed by the RBR Mobile if required under the applicable laws or in other relevant cases with obligatory notification of the Users. New version of the privacy policy enters into force and is subject to observance by the User after the User has expressly agreed to its applicability. If the User does not agree to the applicability of the new version of the privacy policy of the RBR Mobile, the User will discontinue the usage of the RBR Mobile and will be not allowed to use its Personal account without provision of an unambiguous consent to the applicability of the new version of the PRIVACY POLICY.

• Information for Individuals in Switzerland, UK and the EEA

Legal Basis for Processing

When we process your personal data we will only do so in the following situations:

As necessary to perform our responsibilities under our contract with you (like providing the services you have requested);

When we have a legitimate interest in processing your personal data, including to communicate with you about changes to our Services, to help secure and improve our Services (including to prevent fraud) and to analyze use of our Services;

As necessary to comply with our legal obligations; 

When we have your consent to do so.

You should know that we retain personal data for no longer than is necessary for the purposes for which it is processed, unless applicable law requires storage for a longer period of time.

Data Subject Requests

Subject to certain limits and conditions provided under law, you have the following rights:

You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or made available in a portable form.

You also have the right to object to certain processing (like receiving direct marketing), or request that we restrict processing in certain circumstances (like to retain but not further process pending resolution of a claim).

When we ask for your consent, you may withdraw that consent at any time.

You have the right to file a complaint regarding our data protection practices with a supervisory authority. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en. If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

If you would like to exercise any of these rights and can’t do so directly via the Services or your device, you may contact us as indicated below.

• Specific provisions applicable under california privacy law

This is additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). We adopted this paragraph to comply with CCPA and any terms defined in the CCPA have the same meaning when used in this notice.

California law requires us to disclose information about the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in this policy. In particular, our Services have collected the following categories of personal information from its consumers within the last twelve (12) months:

We do not sell your personal information to third parties. We do share personal information with the Processors of the Personal Data of the Services of RBR Mobile mentioned before.

As a California resident, you have the rights listed below:

• You can request information about how we have collected and used your personal information during the past 12 months including the categories of personal information collected, the sources from which we collected personal information, the business or commercial purpose for collecting personal information, and the third parties with whom we shared personal information.
• You can request a copy of the personal information that we have collected about you during the past 12 months. Also, according to the California “Shine the Light” law users who are California residents have the right to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. To make such a request from us, if entitled, please use the contact information listed below.
• You can ask us to delete personal information we have collected from you. We may need certain types of information so that we can provide our Services to you. If you ask us to delete some or all of your information, you may no longer be able to access or use the Services.
• You have the right to be Free from Discrimination. We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data.
• You have the right to opt out of the sale of Personal Information, which is defined in a way that may include the transfer of data to third parties to personalize ads for you. Please note that the CCPA defines the term “sale” very broadly to include any exchange of data for consideration of any kind, not simply selling your data for monetary compensation. Depending upon the circumstances, the term “sale” could include a company providing a resident’s data to another entity to assist the company with targeted advertising. We do not sell to third parties, and within the last 12 months have not sold, any of your personal information. If you opt out of the ‘sale’ of your information, we will not sell your information, including to our advertising partners, but you may continue to receive ads from our Services, which may not be as tailored to your interests.

You may exercise your California privacy rights described above by emailing us. We will need to confirm your identity (e.g. first name, last name, account name, email address, state of residence, etc.) and California residency to process your requests to exercise your information, access or deletion rights. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

• Additional information and contact details

If you have any questions relating to the present privacy policy of the RBR Mobile or claims arising out of its application, please, refer them to the RBR Mobile Support service via the e-mail: support@rbrmobile.com. We shall contact you back as soon as possible.

In case of your personal data breach, please, immediately contact the RBR Mobile Support service via the e-mail: support@rbrmobile.com (mentioning topic “Personal data breach” in your notice with description of the accident occurred).

Contact details of the RBR Mobile:

RBR Mobile

Belarus, Minsk

ul. Krasnozviozdnaya, 18B

of. 202, 2200343 (zip code)

support@rbrmobile.com