Privacy Policy

• 1.1. This Policy is an official document of Matrix Platform LLC located at 125009, Moscow, Tverskaya st., 9, building 7, office 602 (hereinafter - Company Matrix), and defines the rules for processing and protection of information about individuals who use the services of Company Matrix sites http://www.TeddyID.com/ and https://www.billinger.ru/ (further - Members).
• 1.2. The purpose of this Policy is to ensure adequate protection of information about users, including their personal data from unauthorized access and disclosure.
• 1.3. Relations associated with the collection, storage, dissemination and protection of information about users, are regulated by this Policy, other official documents of Company Matrix and laws of Russian Federation.
• 1.4. The current edition of the Policy is a public document available to any Internet user at http://www.TeddyID.com/privacy.php .Company Matrix may make changes to this Policy. When making changes to the Policy, Company Matrix notifies users by posting a new version of the Policy at the above URL. Previous editions of the Policy are stored in the archive documentation of Company Matrix.
• 1.5. This Policy is developed and used in accordance with the Terms available at http://www.TeddyID.com/terms.php . In case of a conflict between this Policy and other official documents of Company Matrix, this Policy prevails.
• 1.6. By registering on the website of Company Matrix www.TeddyID.com, including using mobile applications of Company Matrix, and by using Matrix services according to the Terms, the User agrees to the terms of the Policy.
• 1.7. In case User does not agree to the terms of the Policy, use of services of Company Matrix should be discontinued immediately.

• 2.1. By providing services to users, Company Matrix, acting reasonably and in good faith believes that the User:
  • has all the necessary rights that enable him to register and use the services of Company Matrix ;
  • provides accurate information about himself to the extent necessary to use the services of Company Matrix ;
  • acknowledges that the information about himself that the user enters on the sites of Company Matrix or otherwise shares with Company Matrix may become available to other users of the services of Company and Matrix, other Internet users, and can be copied and distributed to such users ;
  • is aware that some types of information transmitted by User to other users, can not be removed by the User ;
  • is familiar with this Policy, agrees with it, and takes the rights and responsibilities that follow from it.
• 2.2. Company Matrix does not validate the received (collected) information about users, except when such inspection is essential to fulfill obligations of Company Matrix to user.

Company Matrix is processing information about users, including their personal data to meet the Company's obligations to the User specified in the Terms.

• 4.1. Personal data
  Personal data includes:
  • 4.1.1. data supplied by users that is minimally necessary to provide the services of Company Matrix: login name (username) and email address;
  • 4.1.2. data supplied by users through sites of Company Matrix (including name, mobile phone numbers, email addresses, bank account information, address, VAT number);
  • 4.1.3. data supplied by users upon request of Company Matrix for the execution of Company Matrix obligations to users arising out of the Terms. Company Matrix may, in particular, request a copy of the User's identity document or any other document containing the name, photo of the user as well as other additional information which, at the discretion of Company Matrix, will be necessary and sufficient to identify such User and would eliminate the abuses and violations of the rights of third parties.
• 4.2. Other information about the user processed by Company Matrix
  Company Matrix handles other information about the user, which includes:
  • 4.2.1. standard data automatically received by http server of Company Matrix when user accesses its sites and information about subsequent actions of User (including IP address, User's operating system, pages visited by User, information about the User's browser);
  • 4.2.2. information that is automatically obtained with use of cookies while User accesses sites of Company Matrix;
  • 4.2.3. information created by users on the sites of Company Matrix (including messages);
  • 4.2.4. information received as a result of User actions on the sites of Company Matrix (in particular, information on contracts with other Users of the Company Matrix). This information about the user may be available to some or all of the user's colleagues and counterparties ;
  • 4.2.5. information obtained as a result of the actions of other users on the sites of Company Matrix (in particular, the actions of the guardians of the User, if any);
  • 4.2.6. information that is automatically obtained when accessing servers of Company Matrix using mobile applications of Company Matrix.

• 5.1. Processing of personal data is carried out on the basis of:
  a) legitimate purposes and means of processing personal data;
  b) integrity;
  c) personal data processing solely for the purposes stated while collecting personal data, and within rights of Company Matrix as determined by the Terms;
  g) compliance of the extent and nature of the personal data and methods of personal data processing with the purposes of processing of personal data ;
  d) exclusion of association of personal data databases created for incompatible purposes.
  • 5.1.1. Terms and purposes of the processing of personal data
    Company Matrix performs the processing of personal user data to execute the Agreement between the Company Matrix and User http://www.TeddyID.com/terms.php. By virtue of Article 6 of the Federal Law of 27.07.2006 № 152-FZ "On Personal Data" separate user consent to the processing of personal data is not required. By pp 2 paragraph 2 of Article 22 of the Law, Company Matrix is entitled to exercise the processing of personal data without notifying the authorized body for the protection of personal data.
    Personal data are used for (among others) user identification, communication with the user, for statistical and other studies based on anonymous data.
  • 5.1.2. Collection of personal data
    Collection of personal data of User is performed on the sites of Company Matrix, partner sites, and mobile applications of Company Matrix during registration, as well as when user subsequently enters more information about himself using functionality of the sites of Company Matrix.
    Personal data specified in Section 4.1.1. of this Policy is provided by Users and are the minimum required data at registration.
    Personal data specified in 4.1.2. of this Policy is further provided by User on his own initiative.
  • 5.1.3. Storage and use of personal data
    Users' personal data are kept electronically and processed using both automated systems and without the use of automated systems.
  • 5.1.4. Transfer of personal data
    Personal details are not passed to any third party, except as expressly stated in this Policy.
    On User's request or with User's consent his personal information can be transferred to third parties - contractors of Company Matrix - on condition of taking by such counterparties of obligations to ensure the confidentiality of the information received, in particular, when contracting with other users of Company Matrix and using applications of Modules connected to Matrix.
    Applications used by users on third-party sites are developed, managed and maintained by third parties (developers) that act independently of Company Matrix and do not represent Company Matrix. Users are required to familiarize themselves with the terms and policies regarding protection of personal data with such third parties (developers) before using the relevant applications.
    User's personal data may be transferred to third parties to enable the protection of the rights and legitimate interests of the Company Matrix or third parties when user violates the Terms.
    Providing of personal data of Users on request of state bodies (local authorities) is carried out in the manner prescribed by law.
  • 5.1.5. Destruction of personal data
    Personal data are destroyed when:
    - User updates or replaces his data on the sites of Company Matrix;
    - Company Matrix removes information provided by Users when this information contradicts the law of Russian Federation.
    

• 6.1. Members are entitled to:
  • 6.1.1. exercise free access to information about themselves through sites of Company Matrix after proper authentication on the sites ;
  • 6.1.3. make changes and corrections to the information about yourself on the sites of Company Matrix ;
  • 6.1.4. manually delete information about themselves on sites of Company Matrix ;
  • 6.1.5. demand that Company Matrix correct, block, or delete his personal data, in cases such data are incomplete, outdated, false, unlawfully obtained or are not necessary for the stated purpose of the processing and it is impossible to perform such actions on User's own, as defined in 6.1.3. - 6.1.4. above;
• 6.2. The following information about registered users are always available to any registered user who is the counterparty of User or counterparty of the Organization the User is employed by:
  • 6.2.1. User name, as it is entered by the User himself or his supervisor ;
  • 6.2.2. User login ;

• 7.1. Company Matrix takes technical, organizational and legal measures to ensure the protection of personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other illegal actions.
• 7.2. To authenticate users online Company Matrix uses the username and password. As chosen by User, User authentication can be based on other data known to the User and the devices controlled by the User. Responsibility for the safety of this information and for access to the devices is on the User. The user may not pass his own password and device to third parties, and shall take measures to ensure the confidentiality of the password and prevent unauthorized access to his devices.
• 7.3. To ensure better protection of information about users of the company Matrix uses the binding of User's account to a mobile phone and email address. To implement this system user must provide the Company Matrix with mobile phone number and email address.
  To protect users' personal data, when User's username and password are entered from an unusual IP address, Company Matrix requests the User to provide additional information about himself or confirm the ownership of his mobile phone number or email address.

This policy does not apply to actions and Internet resources of third parties.

Company Matrix is not responsible for the actions of third parties that obtained access to User's data through the use of Internet or services of Company Matrix.

• 9.1. Members are entitled to receive information on their personal data and its use on sites of Company Matrix after proper user authentication. If the user has reason to believe that his personal data is used contrary to this Policy, the user may send an inquiry to Company Matrix through the messaging system of Company Matrix. Inquiry must be signed by an electronic signature created with the electronic signature services of Company Matrix. Company Matrix considers and sends a response to User's request within 30 days from the date of receipt of the request.

• 10.1. Company Matrix uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that Company Matrix advertises to previous visitors of its sites based on their past actions, clicks, visits, interests, demographics, location, and other factors. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Company Matrix websites. Any data collected will be used in accordance with Company Matrix' privacy policy and Google’s privacy policy.
  
  Members can set preferences for how Google advertises to them using the Google Ad Preferences page, and if Members want to they can opt out of interest-based advertising entirely by cookie settings.
  
  Company Matrix is not collecting any identifiable information through the use of Google’s or any other 3rd party remarketing system. Company Matrix does not link information that it holds about Members to data collected by Google and its partners through use of their remarketing and other tracking systems.