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Privacy Policy
Date of publication:
22 March 2019

1. What does this Privacy Policy cover

This Privacy Policy ("Policy") covers any information, about you that may include personal data as defined by applicable laws and regulations ("Personal information"), which NAÏVE Software LLC and/or NAÏVE Software, Inc. (collectively, "NAÏVE"), may obtain when you use any of the NAÏVE websites, programs, products or services, including its program, product or service (collectively, the " Services "), information about which you can find on naive.pro and other NAÏVE websites (collectively, the "Sites"), and as well as during the performance of any contract or agreement NAÏVE conclude with you in relation to your using the Services.

Please note that your using any of the Sites and/or Services may be subject to additional terms and conditions, which may amend and/or supplement this Policy.

2. Who processes your personal information

To provide you with access to the Sites and Services, your Personal information is collected and used by NAÏVE Software LLC, a company incorporated under the Russian law, with a head office registered at 74-76k1 Bakuninskaya St., office 1226, Moscow, 105082, Russia ("NAÏVE Russia"), and NAÏVE Software, Inc., a company incorporated under the laws of the State of Delaware, with a registered office at 111 Pier Avenue, Suite 100, Hermosa Beach, California 90254 ("NAÏVE USA") or their affiliates for particular Services. You can find information about the entity, which provides particular Service, in the terms of use.

3. What is the purpose of this Policy

Privacy and security of your Personal information are extremely important to us. When you use the Sites and/or Services, NAÏVE processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations.

As part of our commitment to protecting your Personal information, we use this Policy to transparently inform you about the following:

  • (a) why and how your Personal information is used (also, "processed") by NAÏVE when you access the Sites or Services;
  • (b) NAÏVE's role and responsibilities in this context as the legal entity deciding why and how your Personal information is processed;
  • (c) what instruments you may use to limit the amount of Personal information collected by NAÏVE; and
  • (d) what your rights are in relation to the above processing.
4. What type of Personal information is collected by NAIVE

Personal information collected when you use the Sites and/or Services may differ depending on whether you access the Sites or Services while logged in to your NAÏVE user account or without logging in. When you are logged in to your NAÏVE user account as you are using the Sites or Services, Personal information collected by NAÏVE may be collated and combined with other Personal information (such as your identity, contact details, age and gender, if you shared this information with us) collected by NAÏVE in your user account. NAÏVE does not verify Personal information provided by you and cannot posit if it is true and whether you have the legal capacity required. However, NAÏVE assumes that the information you provide is true, sufficiently complete and up-to-date.

Personal information collected by NAÏVE when you access, interact with or operate the Sites and/or Services includes:

  • (i) information provided by you when you register (create) a user account, such as your name, mobile phone number, address and age;
  • (ii) electronic data (http headers, IP address, cookies, web beacons/pixel tags, browser information, information about your hardware and software);
  • (iii) date and time of accessing the Sites or Services;
  • (iv) information related to your activity when using the Sites or Services (e.g. your search history, email addresses of your contacts, content of your emails together with attachments, as well as files stored in NAÏVE systems);
  • (v) (geo)location information;
  • (vi) other information about you that needs to be processed according to the terms and conditions of any specific NAÏVE Site or Service; and
  • (vii) information about you that we may receive from our Partner in accordance with an agreement you made with this Partner and an agreement between NAÏVE and this Partner.
In addition, NAÏVE uses cookies and web beacons (including pixel tags) to collect your Personal information and associate this Personal information with your device and web browser (see Section 11 below).

We do not actively collect any sensitive personal data (such as racial origins, political opinions, health or biometric data). However, you may voluntarily provide us which such data and we may process it as part of providing you with our Services (e.g. if you perform search queries related to your health). As we do not know in advance the potentially sensitive nature of the personal data you may provide to us, you must be aware that we may not be able to request your consent with such processing.

We do not perform any form of profiling which has the potential to significantly impact your rights and freedoms.

5. What are the legal basis for processing your Personal information and the purposes of it

NAÏVE is not allowed to process your Personal information if it does not have a valid legal ground. NAÏVE will therefore only process your Personal information if:

  • (i) the processing is necessary to perform our contractual obligations towards you including providing you with Sites and/or Services (i.e. providing you with the results of your search query);

  • (ii) the processing is necessary to comply with our legal or regulatory obligations; or

  • (iii) in case it is provided by applicable law, the processing is necessary for the legitimate interests of NAÏVE and does not unduly affect your interests or fundamental rights and freedoms. Please note that when we process your Personal information on this basis, we will always seek to maintain a balance between our legitimate interest and the protection of your privacy.

    Examples of such 'legitimate interests' referred in (iii) immediately above are:

    • (a) to better understand how you interact with our Sites and/or Services;
    • (b) to enhance, maintaining accessibility, modify, personalize or otherwise improve the Sites and Services for the benefit of all users; and
    • (c) to offer you other products and services from NAÏVE or other companies which we think can be of interest to you (i.e. personally-targeted advertising).
  • (iv) for specific purposes we may ask your consent for processing of your Personal information.

NAÏVE always processes your Personal information for a specific purpose and only processes Personal information which is relevant to achieve that purpose. In particular, we process your Personal information for the following purposes:

  • (i) to provide you with the Sites and/or Services (i.e. delivery of search results in response to your search queries, taking into account your preferences, search history and other Personal information about you available to NAÏVE);
  • (ii) to provide you with access to your user account, including your email and storage service, if you have an account on these Services;
  • (iii) to contact you to notify and/or inform you or request information from you in relation to the Sites and Services, or to execute our agreements with you or process your request or application;
  • (iv) to provide advertisements and/or commercial offers based on your preferences, search history and other Personal information available to NAÏVE;
  • (v) to improve user experience, including offering more relevant search results and more personalised Sites and/or Services, as well as improving other NAÏVE products, applications and services;
  • (vi) to develop new products, applications and services;
  • (vii) to protect your rights and the rights of NAÏVE; and
  • (viii) to collect, process and present statistical data or big data, or perform other research and/or analysis of Personal information.
6. How does NAÏVE protect your Personal information

In most cases, Personal information is processed automatically without access to it by our staff. However, if such access is necessary, your Personal information can be accessed only by those NAÏVE employees whose professional tasks require using this information. To protect your Personal information and ensure its confidentiality, these employees must comply with internal rules and follow protocols for processing Personal information. They are also required to follow all technical and organisational security measures protecting your Personal information.

NAÏVE has also implemented adequate technical and organisational measures to protect Personal information against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of Personal information.

7. Who else has access to your Personal information and who is it shared with

NAÏVE may also transfer Personal information to third parties outside the NAÏVE Group to complete the purposes listed in Section 5 above. Such third parties may include:

  • i. Partners, such as media publishers, advertising networks and other partners providing NAÏVE with services related to the placement and display of advertisement on the websites, programs, products and/or services owned or operated by such Partners;
  • ii. Advertisers or other Partners serving targeted advertisement on the NAÏVE Sites or Services; and third parties who process Personal information, such as our (IT) systems providers and/or consultants.
NAÏVE may also transfer Personal information to the following third parties outside the NAÏVE Group:

  • i. any third party to whom we assign or novate any of our rights or obligations under a relevant agreement;
  • ii. any national or international regulatory, enforcement, exchange body, central or local government department and other statutory or public bodies or court where we are required to do so by applicable law or regulation at their request;
  • iii. third parties if you expressed your consent to such transfer or transfer of your Personal information is required for your use of a certain Service or performance of a particular agreement or contract with you;
  • iv. any third party to ensure legal protection for NAÏVE and/or the third parties if you violate the User Agreement of any of the NAÏVE Services, this Policy or the terms of use of specific Services, or if there is a threat of such violation.
8. Where is your Personal information stored and processed

NAÏVE stores Personal information in the Russian Federation.

For users in Russia: NAÏVE records, systematizes, accumulates, stores, clarification (updates, changes), extracts Personal information of the citizens of the Russian Federation using databases located on the territory of the Russian Federation.

For users in the EEA or Switzerland: Russia is a jurisdiction outside the European Economic Area, which has not been recognized by the European Commission as providing an adequate level of personal data protection. Therefore, NAÏVE has taken appropriate measures to ensure Personal information is handled according to applicable EU data protection rules.

In particular, NAÏVE relies upon Standard Contractual Clauses approved by the European Commission to ensure an adequate level of protection for your Personal information transferred to Russia. A copy of these Standard Contractual Clauses can be obtained upon request.

9. For how long do we store your Personal information

NAÏVE will only keep your Personal information for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements.

Unless otherwise legally required or agreed, the emails and documents, which are stored by you on our systems as part of the Service, will remain stored as long as you have an account with us, but you can delete them at any time.

If you wish to have any Personal information removed from our databases, you can have it removed via your NAÏVE account or using interface of the Sites or Services (where applicable).

10. Your rights

10.1 What are your rights

If it is provided by applicable law, you have a right of access to your Personal information as processed by NAIVE under this Policy.

If you believe that any information we hold about you is incorrect or incomplete, you can log in to your user account and correct your Personal information yourself.

If it is provided by applicable law, you also have the right to:

  • request erasure of your Personal information;
  • request the restriction of the processing of your Personal information;
  • request a copy of the Standard Contractual Clauses enabling the transfer of your Personal information to Russia, referred to in Section 8 hereof;
  • object to the processing of your Personal information if it is provided by applicable law.
NAÏVE will honour any such requests or objections as required under applicable law.

To the extent provided by applicable law, you may be subject to other rights not specifically mentioned herein.

10.2 How can you exercise your rights

To exercise the above rights, please log in to your user account, which will provide you with the option to do so, or in case of absence of special function in user account interface please contact NAÏVE (see Section 13 hereof).

If you are not satisfied with how NAÏVE processes your Personal information, please let us know and we will investigate your concern. If you are not satisfied with NAÏVE's response, you have the right to make a complaint to the competent data protection authority.

11. How do we use cookies and other similar technologies on the Sites or when using the Services

11.1 What are cookies and what does NAÏVE use them for Cookies are small text files placed on the device you use to access our Sites. They contain information that is collected from your device and sent back to the Sites on each subsequent visit so as to remember your actions and preferences over time.

The following types of cookies are used on the Sites:

  • strictly necessary cookies / technical cookies: these cookies are required to run the Sites and provide you with the Services and may, among other, allow NAÏVE to identify your hardware and software, including your browser type;
  • statistical / analytic cookies: these cookies enable us to recognise users, count the number of users and collect information such as your actions on the Sites and the Services, including the web pages you visit and the content you retrieve;
  • performance cookies: these cookies collect information about how users interact with our Sites and Services, enabling us to identify errors and test new functionalities to improve the performance of the Sites and the Services;
  • functionality cookies: these cookies enable us to provide specific functionalities in order to improve your experience on the Sites, for example by storing your preferences (e.g. language and location);
  • (third party) tracking / advertising cookies: these cookies collect information about users, sources of traffic, page visits and advertising displayed to you and followed by you. They enable us to display advertising which may be of interest to you based on collected Personal information. These cookies are also used for statistical and research purposes.
11.2 How long are those cookies stored on your device

NAÏVE only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter.

11.3 Who else has access to the information contained in the cookies

Personal information collected through cookies placed on your device may be transmitted to and accessed by NAÏVE or the third parties referred to in Section 7 hereof. The use of Personal information outside of the Sites for advertising purposes, if any, may be subject to separate policies available on the above third parties' websites. NAÏVE or those third parties might also provide you with a possibility to opt out of receiving targeted advertising, which shall be subject to laws and regulations applicable to such products, utilities and offerings.

The first time that you access the Sites, your approval for the use of these cookies may be requested. If after you have approved the use of cookies you want to make another choice, you can do this by deleting the cookies stored by your browser (usually via the options in your browser's Privacy menu – please refer to your browser's manual or developer's website). The popup requesting your approval may then show up again and you can make a different choice. If you do not consent to the use of cookies, certain features of the Sites might become unavailable, which may affect your browsing experience. You may also set up your browser preferences to accept or decline by default all cookies or cookies from specific websites, including the NAÏVE Sites. If you approved the use of cookies on one of the NAÏVE Sites, we assume that the use of cookies on all Sites was approved by you.

NAÏVE may also use web beacons (pixel tags) in order to access the cookies previously placed on your computer for the following purposes:

  • (i) to track your actions on the Sites and when using the Services, by accessing and interacting with the cookies stored on your computer;
  • (ii) to collect statistical information related to operating the Sites, the Services or products, utilities, advertisements or other NAÏVE offerings.
12. Updates to this Policy

This Policy may be subject to amendments. NAÏVE shall be entitled to make such amendments at its own discretion, including, without limitation, to reflect changes in applicable legislation or amendments to the Sites and/or Services.

13. Questions and Suggestions

We welcome your questions or suggestions concerning implementation of or amendments to this Policy. To contact us please use this feedback form: [email protected]

You can also use this form to exercise your rights or report any inaccuracies in your Personal information or protest its processing.

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