EU PRIVACY POLICY

Last updated: March 11, 2019

1. Who we are

1.1. We are Mail.ru LLC located at 39 Leningradsky Pr., Bldg. 79, Moscow, 125167, Russian Federation. We are represented, for the purposes of this policy, by My.com B.V., Barbara Strozzilaan 201, 1083HN, Amsterdam, the Netherlands.

1.2. This Privacy Policy sets out how we collect and use your personal information when you use Disk-O application for Mac and PC ("Application" or “Services”) offered by Mail.ru LLC and the choices available to you in connection with our use of your personal information (the Privacy Policy).
This Privacy Policy should be read alongside, and in addition to, our Terms and conditions (at link https://legal.my.com/us/games/tou/), application end-user license agreement (at link https://disk-o.cloud/legal/disko_termsofuse ) and our Cookie Policy (accessible online at link https://legal.my.com/us/general/cookie/).
In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.

2. This Privacy Policy

2.1. By making available the Application we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register on and use the Application;
(b) provide true information about yourself to the extent necessary for use of the Application;
(c) are aware of and accept this Privacy Policy.

2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.

2.3. This Privacy Policy applies only to the European Union-based users. If you are not a European Union-based user, please refer to the Privacy Policy applicable in the relevant jurisdiction.

3. Information we collect about you

3.1. In order to implement the agreement between you and us, and provide you with access to the use of the Application, we will improve, develop and implement new features to our Application, and enhance the available Application functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data (hereinafter “processing”). We will also receive and pass this data and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.

3.2. We set out in more detail the information we collect when you use our Application, why we collect and process it and the legal bases below.

About Site Visitors

Information Collected

Purpose

Legal Basis

Information collected directly from you, when you send us an email asking a question, or submit a form on our website. We will also collect any other Information that you choose to provide to us, such as the contents of a message that you submit through our website.

We also use this information to communicate with you, including via email, about our Services; to respond to your inquiries or complaints;

Legitimate interests

Information automatically collected through your use of the website. Such information may include, without limitation, information about your operating system, IP address, settings and system configurations, device model, device ID and other unique device identifiers, mobile related information, the webpages you access within our website, the website that led you to our site, the website to which you go after leaving our site, the dates and times you access our website, event information (e.g., system crashes) and web log data.

We use this information to provide and manage our website and Services.

We also use this information to tailor the content and information that we may send or display to you on our website, and to otherwise personalize your experiences while using our website.

We also use this information to better understand how individuals access and use our website, both on an aggregated and individualized basis; to respond to their desires and preferences; and for other research, analytical or statistical purposes.

Legitimate interests

About Customers

We use this information to communicate with you, including via email, about our Services; send you key to the Product, to respond to your inquiries or complaints;

Legitimate interests

We use this information to provide and manage our website and Services.

We also use this information to tailor the content and information that we may send or display to you on our website, and to otherwise personalize your experiences while using our website.

Legitimate interests

Information that is received as the result of your using payment functionality on the Site

We do not keep this Data on our servers. We send this Data to a third party – our Payment Partner.

Legitimate interests

Performance of our contract with you

About Users who installed Application

1	Cloud services data	We use this information to provide and manage our website and Services.	Legitimate interests Performance of our contract with you
2	Data to activate key to the Application (such as your computer timezone, current time and hardware code).	We use this Data to provide our Services to You.	Performance of our contract with you
3	Application logs and other metrics to analyse and provide stable work for our Application. This includes IP-address, name of PC, install path of the Application, OS verison, list of processes, name of the process (for Windows)	We use this information to provide and manage our Services. We also use this Data to make our Services’ work better.	Legitimate interests
4	Application logs for the last run if You appeal to our support through Application, e-mail (which is used in first appeal to our support)	We use this to solve technical and other problems with our Application.	Performance of our contract with you

3.3. Our legitimate interests include (1) maintaining and administrating the Application; (2) providing the Application to you; (3) improving the Application and web pages; (4) ensuring your account is adequately protected; and (5) compliance with any contractual, legal or regulatory obligations under any applicable law.

3.4. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defense or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute.
It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

3.5. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Application, you may not be able to access the Application.

3.6. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.

4. Data sharing

4.1. We may share your data with Mail.ru Group LLC and other our affiliates. Sometimes we may also need to share your data with a third party in order to provide our Application to you or to administer the Application.

5. Privacy Settings

5.1. You may provide and withdraw you consent to receiving latest news about our products that we think you may be interested in via email.

6. International Transfers

6.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.

6.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standartd Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

7. Retention Periods

7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.

7.2. We may block or remove your account for violations of the terms of service or statements of end-user agreement as provided by the Terms.

8. Your Rights

8.1. You have the following rights, in certain circumstances, in relation to your personal information:
(a) Right to access your personal information.
(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
(c) Right to restrict the use of your personal information.
(d) Right to request that your personal information is erased.
(e) Right to object to processing of your personal information.
(f) Right to data portability (in certain specific circumstances).
(g) Right not to be subject to an automated decision.
(h) Right to lodge a complaint with a supervisory authority.

8.2. You also have a right to independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you.

8.3. If you would like to exercise these rights, please contact Support Service via "Support" section of the application or web site. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.

9. Security Measures

9.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

9.2. Access to the Service is authorized using your login and password.

10. Changes to this Policy

10.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.

11. Contact Us

11.1. If you have any questions, please send your inquiries to Service support via "Support" section of the application or web site. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.

11.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

11.3. The e-mail address is info@disk-o.cloud.