Spintria

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Cookie Policy

PRIVACY POLICY

This Privacy Policy (hereinafter referred to as the 'Policy') governs the procedure for processing and protecting personal data of users registered on the website spintria-vpn.com (hereinafter referred to as the 'Service'). By using the Service, you unconditionally accept this Policy, so please read it to gain a clear understanding of what information about you we process, why we need it, and how we protect it. This Policy has been developed and is applied in accordance with the requirements of the legislation of the Russian Federation, including Federal Law No. 152-FZ 'On Personal Data,' as well as the Offer for concluding a contract for providing access to the online service [hyperlink] (hereinafter referred to as the 'Offer'). If you do not agree with the terms of this Policy, please do not provide us with your personal data and do not use the Service.

1. Definitions

Operator (hereinafter also 'Spintria,' 'we,' or 'us') – BOSCH LLC (OGRN 1250800001836), located at: Russian Federation, Republic of Kalmykia, Elista, V.I. Lenin St., 9, premises 3b. User – an individual using the Service. Services (Service) – provision of remote access to the functional capabilities of the Service (hereinafter referred to as the Service / provision of access to the Service / provision of access to the functional capabilities of the Service). Personal Data – any information relating to a directly or indirectly identified or identifiable individual (personal data subject), which the User provides to the Operator during registration on the Service or in the process of its use, as well as information collected automatically, such as data on activity on the Service. Personal Data Processing – any action (operation) or set of actions (operations) performed with personal data, including collection, recording, systematization, accumulation, storage, updating (modification, change), retrieval, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, or destruction of personal data.

2. Categories of Processed Personal Data

We collect information relating to Users, including personal data, to provide and continuously improve our Services. The data we collect can be divided into the following categories:

2.1. Data during registration on the Service (required to create an account)

  • email address
  • password

We use this information to authenticate you on the Service to provide you with the relevant services in accordance with our Offer.

2.2. Account Data (data collected during the use of Services)

  • subscription history;
  • requests to customer support that you send to us.

2.3. Technical Data

When you use the Service, additional data may be collected to improve your experience and ensure the proper functioning of the Service:

  • Internet Protocol (IP) address: including related location data.
  • Internet Service Provider (ISP): information about your provider.
  • Device and type: Device used to access the Platform, such as mobile, desktop, or tablet.
  • Browser name and version: Information about the browser used to access the Platform, such as language and time zone settings, etc.

2.4. Your personal information from other sources

We may receive information about you from other sources, such as: Service-providing partners. Payment processing service providers and other companies we collaborate with to provide you with services may collect your personal data. They are guided by their own privacy policies, for which we are not responsible.

3. Special Categories of Personal Data

We do not collect or process special categories of personal data, namely data relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, health status, or intimate life.

4. Payment Data

We do not process your payments for using the Service and do not have access to information about your credit cards. Payment providers process and store your credit card data. Although we collaborate with payment providers, they are entirely independent from Spintria. Please review their privacy policies before providing them with your data. When you make a payment, you enter your credit card details into a form provided by the service provider that will process the payment, and this information is sent directly to the provider's server. Your credit card information never reaches Spintria's servers. When you save your credit card information, it is stored on the servers of the respective payment provider, and the payment provider provides us with a token that you can use for subsequent payments. Your credit card information cannot be retrieved from the token. Since we do not process credit card data or transaction information, we are not authorized to handle complaints regarding these matters. Responsibility for any disputed payments lies with the payment providers and banks involved in the transaction.

5. Purposes and Grounds for Processing Personal Data

5.1. Personal data is processed by the Operator for the following purposes:

  • User identification on the Service;
  • Interaction with the User, including sending notifications, requests, and information related to the use of the Service and provision of services;
  • Ensuring the proper functioning of the Service;
  • Improving the quality of services provided by the Operator;
  • Conducting analytics of Service usage;
  • Exercising the Operator's rights and obligations in accordance with the legislation of the Russian Federation and international law.

5.2. The Operator processes personal data on the following grounds:

  • Consent of the personal data subject to the processing of their personal data[PD1];
  • Necessity to fulfill a contract to which the personal data subject is a party;
  • Necessity to fulfill obligations imposed on the Operator by applicable law.

6. Processing of User Information

6.1. Principles of Personal Data Processing

Personal data processing is carried out based on the following principles:

  • Legality of the purposes and methods of personal data processing;
  • Good faith and respect for the rights and freedoms of personal data subjects;
  • Compliance of the purposes of personal data processing with the purposes predefined and declared during data collection, as well as with the Operator's authority;
  • Compliance of the volume and nature of processed personal data with the purposes of processing, including their relevance and sufficiency;
  • Prohibition of combining databases containing personal data created for incompatible purposes.

6.2. Collection of Personal Data

6.2.1. The collection of the User's personal data is carried out on the Service during registration and during the User's use of the Services (Service).

6.2.2. Personal data specified in clauses 2.1 – 2.2 of this Policy are provided directly by the User.

6.2.3. Personal data specified in clauses 2.3 – 2.4 of this Policy are collected automatically by the Operator during the User's use of the Service's Services.

6.3. Storage and Use of Personal Data

6.3.1. Users' personal data is processed exclusively using automated systems, except in cases where non-automated data processing is necessary in connection with the performance of a contract or in other cases provided by law.

6.3.2. The processing and storage of Users' personal data are carried out for the period necessary for the purposes of processing, unless there are legal grounds for further processing (e.g., if a longer storage period is established by federal law).

6.4. Transfer of Personal Data

6.4.1. Users' personal data is not transferred to third parties, except in cases provided for by this Policy or legislation.

6.4.2. The Operator may transfer Users' personal data to third parties – the Operator's counterparties – based on contracts that include obligations to ensure the confidentiality and security of the received information.

6.4.3. The provision of Users' personal data at the request of state authorities is carried out in the manner prescribed by the legislation of the Russian Federation.

6.5. Destruction of Personal Data

6.5.1. The User's personal data is destroyed in the following cases:

  • independent deletion by the User of data from their account or deletion of their account;
  • deletion of data by the Operator.

6.5.2. In case of the User deleting information from their account or deleting their account, the Operator continues to store the User's personal data on its electronic media for the period necessary and established by the applicable legislation of the Russian Federation.

7. Cross-Border Transfer of Personal Data

7.1. We do not transfer your personal data outside the Russian Federation.

8. User Rights

8.1. The User is entitled to:

  • freely access information about themselves in their account using their login and password;
  • independently make changes and corrections to information about themselves in their account, provided that such changes and corrections contain current and accurate information;
  • delete information about themselves from their account;
  • demand from the Operator the clarification of their personal data, their blocking, or destruction if such data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the stated purpose of processing, and if it is impossible to perform the actions provided for in this section independently;
  • obtain information from the Operator regarding the processing of their personal data based on a request.

9. Personal Data Security

9.1. To ensure the protection of Users' personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, or other unlawful actions, the Operator takes the necessary legal, organizational, and technical measures, including:

  • Ensuring compliance with Russian Federation legislation on personal data protection when renting servers in the Russian Federation, including compliance with data localization requirements.
  • Implementing an Information Security Management System (ISMS) that complies with Russian Federation legislation and international information protection standards.
  • Conducting internal control and audits to ensure compliance with personal data processing requirements under Russian Federation legislation.
  • Using information protection tools (antivirus software, firewalls, intrusion detection and prevention systems) and cryptographic protection of information during data transmission between servers.
  • Ensuring the physical security of data storage and processing locations on servers, including the use of access control systems, video surveillance, and alarm systems.
  • Data backup and encryption to ensure data integrity and availability, as well as the ability to restore data in case of incidents.
  • Including conditions in contracts with counterparties to ensure the confidentiality and security of personal data.

9.2. In case of interaction with third parties in the Russian Federation, the Operator ensures compliance with Russian Federation legislation on personal data protection by concluding relevant contracts and ensuring proper control over compliance with security requirements.

9.3. The Operator takes all necessary measures to protect Users' personal data in accordance with Russian Federation legislation and international information protection standards, ensuring the security of processed data within the Russian Federation.

10. Use of Cookie

We use cookie to improve the performance of our Service and provide you with more personalized services. Cookie are small text files that are stored on your device when you visit our website. These files allow us to recognize your device, save your preferences and actions on the site, and collect analytical information to improve the functionality and content of the Service.

10.1 Types of Cookie Used:

Technical Cookie: ensure the proper functioning of the website, its core functions, and security. These cookie are necessary for using the website and cannot be disabled. Analytical Cookies: help us collect information about how users interact with the website, which pages they visit, and how much time they spend on them. These cookie are used only with your consent and help us improve the website and tailor it to your needs. Functional Cookies: allow us to save your preferences, such as your region, so you can use the website more conveniently each time you visit. Advertising and Marketing Cookies: are used to show you personalized advertisements on our website and other platforms. They allow us to track the effectiveness of advertising campaigns and analyze your interests.

10.2. Managing Cookie

You can manage the use of cookie at any time through your browser settings. Depending on the browser you use, you can:

  • block the storage of all cookie;
  • delete already stored cookie;
  • receive notifications when new cookie are installed;
  • select the level of privacy.

To manage cookie in your browser, follow the instructions on the official websites of browser manufacturers. Please note that disabling technical cookie may affect the functionality of the Service and may result in the inability to use some of its features.

11. Final Provisions

11.1. This Policy is a publicly accessible document, access to which is provided to an unlimited number of persons by posting it on the Service.

11.2. The Operator reserves the right to make changes to the Policy in case of changes in legislation or conditions for processing personal data.

11.3. This Policy takes effect from the moment of its approval and remains in force indefinitely until replaced by a new version.