FAMILY IT LLC

PSRN 1217700345191

TIN: 9703041303

Address: 123376, Moscow, VN.TER.G. MUNICIPAL DISTRICT PRESNENSKY, STREET ROCHDELSKAYA, D. 15, STR. 27, FLOOR 4, ROOM I/9

Tel: 8 495 540 42 66

 

Effective date 30 Nov 2022

 

PRIVACY POLICY

(PROCESSING OF PERSONAL DATA)

ELARI SAFEFAMILY 

 

1. WHO WE ARE

We are FAMILY IT Limited Liability Company, its affiliates, subsidiaries and partners (referred to as "we", "us", "our", "us", "company" and similar terms). This Privacy Policy describes how we collect, use, store, manage and disclose your information in connection with our use of https://www.familyit.ru/ (referred to as the “site”), the ELARI WEAR mobile applications (referred to as the “application” ).
We have developed applications designed for manage bluetooth watch.

  • environment of the ELARI WEAR application with bluetooth devices under the ELARI brand

This Privacy Policy applies to all visitors, users and others who use the Applications and the Site.
When you or you registers and starts using the applications, we get access to a certain set of personal data. We process this data in accordance with certain rules, which are prepared on the basis of the Federal Law of July 27, 2006 No. 152 "On Personal Data" ("Law"). These rules are described below.
We also have application terms of use located here https://familyit.ru/elariwearuseragreement ("Terms"). Please read them before using the applications.

2. WHAT PERSONAL DATA WE PROCESS

We process the following personal data:

  • When you register with ELARI WEAR, we receive the following data: (1) the nickname created by the User. We do not collect information about the first and last name, any nickname can be used as a user designation, (2) Your contact information (phone number), (3) Your email (4) account profile photo. You can use any image without identification.
  • When you start using ELARI WEAR, we collect the following data: (1) with your permission: general location information, including country, region, city information, including precise geographic location data; (2) the language set on your mobile device; (3) application usage information; (4) when making a payment, we receive information necessary to process your order, which may include the amount of the transaction, but does not include financial information / bank card data / bank card holder data, which will be transmitted directly to the payment service provider using secure protocols; You can find more information in the current data protection policies of the respective payment service providers. If you make payments on the mobile application, we do not collect or access your name and payment information, this information is collected and stored on your platform (Apple Store or Google Play) or your platform's payment service provider. (5) information about the contacts added in the ELARI WEAR application and on your phone.

When registering in the ELARI WEAR application, you can use any photo to create an avatar. Please note that we do not require this to be an actual photograph. We store the avatar image and process it.
We process personal data for the following purposes:

  1. Conclusion of Terms: we process personal data to the extent necessary to enter into an agreement on the terms of use of applications between you and us;
  2. Compliance with the Terms: fulfilling our obligations to users of our services and monitoring the fulfillment of their obligations to us. In particular, we identify you in the applications, provide the functionality of the applications stated in the Terms, arrange payment for our services.

In addition, when processing personal data, we also have the following additional purposes:

  1. Sending messages and other types of communications (SMS and other messaging services), including transactional, news, informational, advertising messages;
  2. Improving the quality of our services and application performance;
  3. Implementation of affiliate programs, including advertising campaigns, marketing research.
  4. Compliance with legal obligations.
  5. Ensuring our legitimate interests.

 

3. ON WHAT GROUNDS DO WE PROCESS PERSONAL DATA

From the point of view of the Law, the concept of processing personal data includes a wide range of actions. In essence, this includes any action (operation) or a set of actions (operations) with personal data. The processing of personal data includes, among other things, the following: collection, recording; systematization, accumulation, storage; clarification (update, change), extraction, use; transfer (distribution, provision of access), depersonalization, blocking, deletion, destruction.
We process personal data on the basis of the Terms, on the basis of the consent that you give in relation to yourself, as well as on the basis of the relevant requirements of applicable law.

Please note that you can revoke your consent to the processing of personal data by sending us an email to info@elari.net . We will need to identify you, so fill out a free-form application with your passport details, your phone number, and sign it.
An important point: the withdrawal of consent will reduce the amount of personal data processed by us, but will not stop such processing completely and will not lead to the termination of the provision of our services. You need to opt out of the Terms and stop using the applications in order for us to stop processing personal data in full.

4. ADVERTISING

Please note that by agreeing to this policy, you also agree to receive advertisements in the ELARI WEAR application from us or from our customers. You can also revoke this consent if you send us an email to info@elari.net with your passport details, your phone number, and your signature.

5. HOW WE PROCESS PERSONAL DATA

We carry out automated processing of personal data. Processing is carried out by:

  • collection of your personal data when you register with ELARI WEAR;
  • collection of your activity personal data when you add an ELARI-branded bluetooth device to ELARI WEAR
  • transfer of your personal data for storage to the cloud service Yandex.Cloud or Kibana.


We process personal data based on the following principles:

  • legality of the purposes and methods of processing personal data;
  • conscientiousness;
  • compliance of the purposes of processing personal data with the purposes predetermined and declared when collecting personal data;
  • compliance of the volume and nature of the processed personal data, methods of processing personal data with the purposes of processing personal data;
  • the inadmissibility of combining databases created for mutually incompatible purposes containing personal data.

We take all necessary legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, their destruction or alteration.
In terms of Yandex.Cloud, we use this service to store personal data using cloud technologies. In Yandex.Cloud, data is stored in Russia in a form that allows you to identify the subject and no longer than required by the purposes of processing personal data. Personal data is completely destroyed after 3 (three) years from the date of termination of the use of the application.

6. HOW WE STORE PERSONAL DATA

We store all personal data contained in ELARI WEAR application, as well as third parties using the ELARI WEAR application and/or bluetooth devices under the ELARI brand, for three months. We then delete this data on our servers.
Personal data that is necessary for the fulfillment of our mutual contractual obligations, for example, data necessary for your identification, for payment for our services, etc., we store until it is necessary for the performance of the Terms. After the Terms cease to apply, we also delete the relevant data.

7. WHAT RIGHTS YOU HAVE

You have the right:

  1. Receive information regarding the processing of your personal data and the personal data of your child. We will provide this information in an accessible form;
  2. Require us to clarify your personal data and your child's personal data, block or destroy them if they are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing;
  3. Take legal measures to protect their rights;
  4. To appeal to Roskomnadzor or in court our illegal actions or omissions in the processing of personal data.

You also have other rights expressly provided for by applicable law.
If you want to exercise any of your rights, just write to us at info@elari.net . We will need to identify you, so fill out a free-form application with your passport details, your phone number, and sign it.

8. WHAT WE HAVE RIGHTS AND OBLIGATIONS

We can:

  1. Independently determine the purposes of processing personal data, the list and scope of personal data necessary to achieve the purposes of processing and providing our services;
  2. Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law;
  3. Entrust the processing of personal data to another person (such a person must comply with the principles and rules for the processing of personal data provided for by the Law);
  4. In case of withdrawal of consent to the processing of personal data, continue processing without consent if there are grounds specified in the Law.

We should:

  1. Organize the processing of personal data in accordance with the requirements of the Law;
  2. Respond to your requests and requests, as well as to requests and requests from legal representatives;
  3. Report to Roskomnadzor upon its request the necessary information within 30 calendar days from the date of receipt of such request.

9. CONFIRMATION OF THE FACT OF PROCESSING, UPDATING AND CORRECTION OF PERSONAL DATA, ANSWERS TO REQUESTS OF SUBJECTS

If you contact us, we will be able to confirm the fact of processing (including storage) of your personal data and personal data of your child, as well as inform the legal grounds and purposes of processing personal data.
You also have the right to request information regarding the processing (including storage) of personal data at any time. We will provide this information. Perhaps, in order to respond to your requests, we will ask you to send the appropriate registered letter with acknowledgment of receipt or a scanned copy (electronic image) of the signed application toinfo@elari.net _
We process your requests within 30 calendar days. If the request does not contain the necessary information or you do not have access rights to the requested information, then we will send a reasoned refusal.

10. DATA COLLECTED AUTOMATICALLY USING

COOKIES AND SIMILAR TECHNOLOGIES

When you use our mobile applications and/or website, we may collect certain information about your computer or device using technologies such as cookies, web beacons, log files or other tracking/recording tools. The information we collect using tracking technologies includes, but is not limited to, IP address, browser information, links to/outputs and URLs, traffic data, and information about how you interact with links on the website , mobile application or Service, domain names, landing pages, page views, cookie data that allows us to uniquely identify your browser and track your browser behavior on our site, mobile device type, mobile device identifiers or other persistent identifiers.
When you access our Service through a mobile device, we may receive or collect and store unique identification numbers associated with your device or our mobile application (including, for example, UDID, Unique Identifier for Advertisers (“IDFA”), device type, model and the manufacturer, make and model of the mobile operating system, phone number and, depending on your mobile device settings
We may use our own cookies, which are owned by us and which we place on your device, and third-party cookies, which otherwise party places on your device
Cookies or similar technologies stored on your device through which you use the Service perform the following functions:
Authentication. If you are logged in to our resources, cookies help us show you the correct information and personalize your experience.
Safety. We use cookies to enable and maintain our security features and to help us detect malicious activity.
preferences and settings. Cookies or similar technologies may tell us which language you prefer and what your communication preferences are. They will help you fill out the forms on our resources more easily. They also provide you with functionality and personalized settings.
Marketing.We may use cookies or similar technologies to deliver marketing campaigns and track their effectiveness. Similarly, our partners may use cookies to provide us with information about your interactions with their services and action tags to measure the effectiveness of advertising and provide more targeted advertising, the use of these third party cookies will be subject to the privacy policies of the advertising service providers.
Performance, analytics and research.Cookies or similar technologies help us understand how well our apps and Service are performing, diagnose and fix technical issues reported by users or our developers. We may also use cookies or similar technologies to understand, improve and research products, features and services, including creating logs and records when you access our applications and resources from different devices, such as your mobile device.
We may use the services of third party analytics software providers to better understand the functionality of our software on the device, including, but not limited to, Google Analytics, Yandex.Metrica, Firebase, (collectively , "Third Party Analytics Services"). This software may record information about how often you use the Service; events that occur within the Service, aggregated usage and performance data; information about where our software is downloaded from. These partners may use cookies, web beacons and other tracking technologies to collect or receive data about you and may act as a data controller with respect to information about you. We do not link the information we store in the analytics software to the personal information you submit to us.
This policy does not cover the use of third party tools, to learn more about their privacy practices please follow the links below.
AppMetrica (Russia)

We use AppMetrica to better understand how you use our products. For more information about AppMetrica's privacy practices, see https://yandex.com/legal/metrica_termsofuse. Find out more in their Terms of Use and Privacy Policy. Refusal of processing: visit the page "Yandex" Metrica.
Firebase (The country in which the legal entity providing the service is located depends on the country in which the User is located)

Firebase helps us to clearly understand how users behave, which allows us to make informed decisions regarding application marketing and performance optimization. For more information about Firebase security rules, see Firebase Security Rules.https://firebase.google.com/terms/analytics.
Google Analytics (USA)

Google Analytics collects information about how often users visit our site, which pages they visit, when they do so, and which other sites they visited prior to coming to our site. Google's ability to use and share the information collected by Google Analytics about your visits to our properties is limited by the Google Analytics Terms of Use and Google's Privacy Policy. You can prevent Google Analytics from recognizing you when you return to our site by disabling cookies on your browser or mobile device. For more information about Google Analytics, please see the Google Privacy Policy ( https://policies.google.com/privacy?hl=en). To prevent Google Analytics from using your data through a web browser, you can install a Google Analytics opt-out blocker ( https://tools.google.com/dlpage/gaoptout/ ).

11. CHANGES TO OUR POLICY

This policy is subject to change. We do this at our sole discretion, including when the relevant changes are related to changes in the law or in the operation of application.
We will notify you in advance of any significant changes using the functionality of the application or on the website. Appropriate notifications may be displayed in the application (for example, via a pop-up window or banner) before such changes take effect, or may be sent to you through other communication channels (for example, by email or push notifications).