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Molot Online Privacy Policy

Introduction

MOLOT ONLINE LIMITED respects your privacy and pays great attention to the protection of your personal data. When stating «Molot Online», «we», or «us», we are referring to MOLOT ONLINE LIMITED acting as controller with respect to the collection or processing of your personal data.

Our Privacy Policy applies to all personal information we collect and process about you in connection with the products and websites Molot Online offers and operates, but it excludes the products and websites that fall under relevant privacy policies that do not incorporate this Privacy Policy.

Conditions for the attention of clients and users:

Personal data processing practices of Molot Online as a data controller are set out by this Privacy Policy. Molot Online may also act as a data processor on behalf of its business clients in relation to data provided for services and/or advertising. Such data processing is covered by special instructions and terms agreed between the client and Molot Online.

This Privacy Policy helps you understand:

  • What personal data we collect
  • Why we collect it
  • What we do with it

The information below will elaborate on these three topics. Please read it carefully as it is very important. Our goal is to present the description and the handling of your personal data concisely, using clear and simple language to make this policy quick and easy to read and understand.

If you need the definition of certain terms such as «Cookie», please see our Cookie Policy . If you have a question or complaint, please contact us at info@molot.online.

1. Which types of personal data does Molot Online collect about you, and how do we collect it?

1.1. Information you give Molot Online

Registration information

Before using services you should register in our website. If you register, you will give us your personal data, including but not limited to your name, e-mail address, photo for creating your account. Providing this information will allow you to post reviews and to participate in our discussion forums.

Information for providing our products and services

When you use our services, you may send us information that may contain personal data such as name, e-mail address, etc. It is your responsibility to decide which information you want to send us and process via our products and services.

Support and request information

You send us information that may contain personal data, such as your identity or contact info, when you request our help with one of our services, or to receive information about Molot Online and/or our services.

News and marketing information

We may collect and process marketing and communications data such as your preferences in relation to receiving marketing information from us and third parties. This also applies to the way we communicate with you when you give us your data by filling in forms and by corresponding with us by post, phone, email, or otherwise when you request marketing materials. We sometimes also give you the ability to take part in surveys where we ask you to give us such information as e-mail address and your feedback about our services and websites. We may also ask you to subscribe to receive newsletters. We will only process your data for the purposes in this paragraph if we are allowed to do so under applicable law (because you consented to it or otherwise).

Information that Molot Online receives from your use of our services and websites

We collect information about our services and websites that you use and how you use them. We collect this personal data by using cookies and other methods as described below. Please see the Molot Online Cookie Policy for more details about use of cookies.

Local storage

We may collect and store information on your device using local storage of your browser or application.

Device information

We collect information about your device (such as type and version of your browser and operating system, type and model of your device, and unique identifiers about your device). We may associate your identifiers with your other information that we have collected.

Log information

When you use our services, visit our websites, or review the information we send you, we automatically collect and store certain information in server logs. This may include:

  • Information on how you used our services and websites
    • Internet Protocol (IP) address
    • Technical information about your device
    • Cookies that may uniquely identify your browser or your product account

Location information

We use your IP address and the other log information to help us understand which language to use for you and for statistical purposes to improve our services and websites.

1.2. Information that Molot Online receives from third parties

  • For some services we receive and store sign-in information.
  • We may further receive technical data from analytics providers such as Google.

Failure to provide personal data where requested

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you do not provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). As a result, we may have to cancel the contract.

2. Why and on what legal basis does Molot Online use your information?

We may use your personal data for or in connection with the following purposes and based on the following legal basis:

a. Where necessary to establish and perform your contract with us, such as where you buy services from us or to provide you information, services and technical support that you request from us.

b. Where necessary to comply with a legal obligation such as

  • To comply with laws and regulations that are applicable to us in the US and in the country located at the EEA; and
  • disclosures to law enforcement agencies or in connection with legal claims, compliance, regulatory, investigative, and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and informal requests from law enforcement or other governmental authorities.

c. Where necessary for Molot Online’s legitimate interests in connection with the purposes listed below, and where our interests are not overridden by your data protection rights:

  • To let you know about changes to our services and websites
  • To provide you information about other similar services we have
  • To support, improve, and check our websites and services
  • To monitor potentially illegal activities and security (e.g., fraud prevention)
  • To enable you take part in interactive features of our websites when you choose to do so
  • To keep our websites and services safe and secure
  • To measure or understand the effectiveness of advertising we send you and others, and to deliver relevant advertising to you
  • To make suggestions and recommendations to you and other users of our websites about our services
  • To test and analyze statistics and survey results
  • For statistical (e.g., billing and analytical) purposes
  • To provide services management and research and development (e.g., services improvement, new product features or versions).

You can obtain further information on legitimate interests balancing exercises we have carried by contacting us via the link at info@molot.online.

d. Processing for marketing and communication purposes is based on our legitimate interests or your consent as required by applicable law. You have the right to withdraw your consent at any time (to “opt out”). You can opt-out by emailing info@molot.online, or, in case of electronic direct marketing, by following the instructions in the communication.

We will not use or otherwise process your personal data for any other purposes, unless we have legal grounds to do so (e.g., you provide us with your additional consent before such use).

3. Google Analytics and other third-party analytics services

Google Analytics

Our website uses Google Analytics, a web analytics service operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics uses so-called “cookies”. These are text files that are stored on your computer and that allow an analysis of the use of the website by you. The information generated by the cookie about your use of this website is usually transmitted to a Google server in the USA and stored there.

Browser plugin

You can prevent these cookies being stored by selecting the appropriate settings in your browser. However, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of our website. You can also prevent the data generated by cookies about your use of our website (incl. your IP address) from being passed to Google, and the processing of these data by Google, by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en.

Objecting to the collection of data

You can prevent the collection of your data by Google Analytics by clicking on the Disable Google Analytics link. An opt-out cookie will be set to prevent your data from being collected on future visits to this site: Disable Google Analytics. For more information about how Google Analytics handles user data, see: https://policies.google.com/technologies/partner-sites?hl=en and https://support.google.com/analytics/answer/6004245?hl=en.

Other third-party analytics services

Some of the advertising and functionality in our website and services is provided by third parties. These third parties may use cookies, beacons, tracking pixels, and other tools to collect information about your use of these products and services. These third parties are not controlled directly by us, so we recommend that you check their privacy policies to understand how they use your data.

4. With whom does Molot Online share information collected?

We may share your personal data to comply with laws and regulations that are applicable to us for the abovementioned purposes with the following third parties, in each case always only in accordance with applicable data protection laws:

Affiliates

We may disclose your personal data to current or future affiliates, representative offices, or subsidiaries for business administration, support purposes, improvement, research and development of our products and websites, and any other abovementioned purposes.

Service providers for external processing

We may share your personal data with our service provider business partners to comply with laws and regulations that are applicable to us in your country or others that will process personal data on our behalf. Such service providers may include customer relationship management providers, telecom providers, providers of customer satisfaction surveys, billing providers, providers of support and maintenance, marketing and analytical services, etc. If we share your personal data, we will enter into a data processing agreement and give such service providers our documented instructions to ensure that they are in full compliance with our Privacy Policy. We will also use the appropriate confidentiality and technical and organizational security measures as well as audits to ensure their compliance with applicable data protection laws.

We may provide personal data to our partners for their own for marketing and promotional purposes provided that we have legal grounds to do so.

Government authorities/law enforcement officials

In some circumstances, it may become necessary for us to share your information with government authorities, law enforcement officials, or regulatory bodies as required by law or for administrative purposes and to the extent that local law allows and/or requires this:

  • To comply with applicable laws, legal actions or lawful request of state authorities
    • To protect our rights, property or safety, our users or others under the applicable laws
    • To fulfil our obligations under our agreement with you
    • To check, prevent, and investigate fraud, security, or technical issues

5. Where does Molot Online store the personal data that we collect from you?

Molot Online is a business with a global presence, therefore Molot Online may share your personal data with its service providers and partners for the purposes described in this Privacy Policy. Some of them are located in countries outside the European Economic Area (“EEA”). To learn more about transfers of personal data outside the EEA, click here.

In these cases, after these data transfers, your personal data may be subject to the laws of other countries, where the data protection may not be as comprehensive as your country of residence. Before we will send your personal data outside of the EEA, we ensure that the country has an adequate level of protection which is approved by the European Commission. If a country does not have adequate protection, will use the following appropriate legal safeguards to protect your personal data so that these data transfers are in full compliance with applicable data protec67tion laws:

Click on any of the items above to receive additional information. For further information or to request a copy of the aforementioned safeguards, please email info@molot.online.

6. Third-party links

Our websites may contain references and links to third-party websites that may offer information. This Privacy Policy does not apply to such websites of other parties, and we recommend reviewing privacy policies of those websites individually. We are not responsible for the information practices of such third-party websites.

Your personal data may be disclosed in response to inquiries or requests from government authorities in the countries in which we operate.

7. What do we do to protect the personal data we collect from you?

We strive to maintain the highest standards of security, and Molot Online has put in place robust technical and organizational measures for the protection of your data in accordance with the current, general state-of-the-art technologies, especially to protect the data against loss, falsification, or access by unauthorized third persons:

  • We use reasonable security measures to protect the information we have against loss, theft and unauthorized use, disclosure or modification
  • We continuously analyze and check our procedures of collection, storage, and use of information including trainings of our staff
  • We use encryption for many of our products

Please note that although we work hard to protect security of our services and websites, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our website; any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorized access. We also ask you to take every precaution to protect your personal data when you are on the Internet.

8. How long do we store your personal data?

We will keep personal data for as long as necessary to provide the products and services you have requested. Afterwards, we may retain data for an appropriate period to protect ourselves from legal claims, to administer our business, or to the extent permitted by applicable law, which may require us to hold your personal data for specific periods. We will delete your personal data when you withdraw your consent, if there is no other legal ground for further processing (e.g., a statutory obligation to retain your personal data), or when you object to the processing in accordance with “Your rights” (see below), or when we are obliged to delete it in accordance with an obligation under applicable law. For further information about our approach to data retention, please inquire at info@molot.online.

10. Your rights

Under the EEA privacy laws, you have the following individual rights related to your personal data:

Your personal data rights may be limited or subject to exceptions in some situations for example, where Molot Online demonstrates that it has a legal requirement to process your data (such as where tax authorities require us to retain it), or where it is needed for proper performance of a contract.

Where Molot Online has asked for your consent to process personal data and that consent is withdrawn, we will not process that personal data further but may not be able to continue providing the products or services for which the personal data was sought. Where Molot Online has a legal right or obligation to retain personal data or wishes to do so in connection with its legitimate interests, it may do so even if you have withdrawn consent for Molot Online to hold your personal data.

Where Molot Online requires personal data to comply with legal or contractual obligations, the provision of such data is mandatory. If such data is not provided, Molot Online will not be able to manage the engagement relationship, or to meet obligations placed on it. In all other cases, provision of requested personal data is optional.

11. Molot Online and CCPA

Advertisers and partners should ensure that use of Molot Online services, including restricted data processing, meets their CCPA compliance requirements.

Restricted data processing does not extend to the sending or disclosure of data to third parties that you may have enabled in our services, and you should ensure that you’ve taken all measures with respect to such third parties as required to meet your CCPA compliance needs

Molot Online complies with all laws and regulations applicable to its provision of services, which would include the CCPA.

12. How can you contact us?

To request information about how we use or share your personal data, exert any other right under applicable data protection law, or to raise a complaint or ask a general question related to data processing by us, you can contact us at:

Legal Address: Room 5003, Floor 5, Yau Lee Centre, 45 Hoi Yuen Road, Kwun Tong, Hong Kong

_________________

Email:  info@molot.online

Data Protection Officer

Email: bachinin@molot.online

13. How and when does Molot Online change this Policy?

We reserve the right to change this Privacy Policy from time to time. Any changes to our Privacy Policy will be posted on this page. Where changes to this Privacy Policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice by notifying you by email or by a pop-up banner on our website as required by applicable law so that you have the opportunity to exercise your rights.

«01» October 2022


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