1. General provisions
    1.1. Definitions:
        - personal data means any information relating directly or indirectly to an identified or identifiable natural person (the personal data subject);
        - personal data operator (Operator) means the individual Namazbayev Islam Vladimirovich (Намазбаев Ислям Владимирович), whose contact email address is shown on the Support page, who independently or jointly with other persons organizes and/or performs personal data processing and determines the purposes of processing, the personal data to be processed, and the actions (operations) performed on personal data;
        - personal data processing means any action (operation) or set of actions (operations) performed on personal data, with or without automated means, including collection, recording, organization, accumulation, storage, rectification (updating or modification), retrieval, use, transfer (distribution, provision or access), anonymization, restriction, deletion and destruction;
        - automated personal data processing means personal data processing by means of computing equipment;
        - Resources means the Weexee web application and/or software owned by the Operator;
        - User means any person who uses one or more Resources;
        - Account means the personalized part of the Resources that enables electronic exchange of information and materials between Users and the Resource. A User accesses an Account by entering the User's Authentication Data;
        - Policy means this personal data processing policy (privacy policy).
    1.2. This Policy is a publicly available Operator document published in accordance with Part 2 of Article 18.1 of Federal Law No. 152-FZ. It defines the purposes and legal bases of processing, categories of data subjects and data processed, processing periods, data-subject rights, and measures taken to protect personal data.
    1.3. This Policy applies to all information that the Operator may receive about a User while the User uses the Resources.

2. Purposes of personal data collection
    2.1. The Operator collects and stores only the personal data necessary to operate the Resources and comply with legal requirements.
    2.2. The Operator processes a User's personal information for the following purposes:
        2.2.1. Identifying the User within the Resources.
        2.2.2. Providing the User with access to personalized Resource services.
        2.2.3. Communicating with the User, including sending notices related to use of the Resources and processing User inquiries and requests.
        2.2.4. Confirming the accuracy and completeness of personal data provided by the User.
        2.2.5. Providing effective technical support for problems related to use of the Resources.
    2.3. Anonymized User data obtained through Resource analytics and error-detection services is used to collect information about User activity in the Resources for the purpose of improving Resource quality.

3. Legal bases for personal data processing
    3.1. The legal bases for processing personal data are:
        - the Constitution of the Russian Federation;
        - the Civil Code of the Russian Federation;
        - Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection” dated July 27, 2006;
        - the Resource User Agreement available at https://intl.weexee.ru/user-agreement/;
        - Consent to Personal Data Processing.

4. Scope and categories of personal data processed and categories of data subjects
    4.1. The content and scope of personal data processed under this Policy correspond to the stated processing purposes and legal requirements.
    4.2. To operate the Resources, provide Users with access to their functions, and comply with legal requirements, the following personal data is processed:
        - username;
        - mobile phone number;
        - date of birth;
        - nickname;
        - gender;
        - IP address;
        - device and browser data;
        - cookies;
        - access date and time;
        - access tokens;
        - analytics data;
        - error data.

5. Personal data processing procedures and conditions
    5.1. To operate the Resources and comply with legal requirements, the Operator processes personal data by any lawful means, including automated processing.
    5.2. The Operator may transfer a User's personal information to third parties where:
        - the User has consented to the transfer;
        - the transfer is necessary for the User to use a particular service or for performance of an agreement with the User;
        - the transfer is necessary to operate Resource services;
        - the transfer is necessary to comply with legal requirements.
    5.3. If the Resources are transferred to an acquirer, all obligations to comply with this Policy in relation to personal information received by the acquirer transfer to that acquirer.
    5.4. Personal data is processed for the period necessary to achieve the processing purposes or for a period required by law. Once the purposes are achieved or consent is withdrawn, personal data is destroyed or anonymized within no more than 90 days unless otherwise provided by law.
    5.5. The Operator takes necessary organizational and technical measures to protect a User's personal information against unauthorized or accidental access, destruction, modification, restriction, copying, distribution, and other unlawful acts by third parties.
    5.6. Personal data of citizens of the Russian Federation is processed using servers and databases located in the Russian Federation, pursuant to Part 5 of Article 18 of Federal Law No. 152-FZ.
    5.7. The Resources use Google and Apple services to deliver push notifications. A technical device identifier, an internal User identifier, and notification text are transferred to those services. For registration and password changes, the User's phone number may be used to interact with telecommunications operators or telephony services located in the Russian Federation.
    5.8. User personal information remains confidential. The Operator does not publish User personal data in publicly available sources without separate consent to distribution executed in accordance with Article 10.1 of Federal Law No. 152-FZ.

6. Updating, rectifying, deleting and destroying personal data and responding to data-subject access requests
    6.1. If personal data is confirmed to be inaccurate or unlawfully processed, it must be updated or deleted in accordance with legal requirements.
    6.2. When the personal data processing purposes have been achieved, or when the data subject withdraws consent to processing, personal data must be destroyed unless:
        - otherwise provided by an agreement to which the personal data subject is a party, beneficiary or guarantor;
        - the Operator is entitled to process the data without the data subject's consent on grounds established by Federal Law “On Personal Data” or other federal laws;
        - otherwise provided by another agreement between the Operator and the personal data subject;
        - otherwise provided by law.
    6.3. The Operator processes personal data while the User's Account exists.
    6.4. Consent to personal data processing may be withdrawn by deleting the account in the app or at https://intl.weexee.ru/account-deletion/.
    6.5. Information concerning inaccurate personal data or unlawful processing may be sent to the email address identified through the Support page.