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Effective date: May 25, 2018

This Privacy Policy (the “Policy”) describes how Cheetah Mobile Inc and its affiliates. (also referred to as “Cheetah,” “Company,” “we,” “us,” or “our”), collects, stores, uses and protects your information when you use our website at (the “Site”), any mobile applications that hyperlink to this Policy and are available for download in the Google play Store, Apple App Store or any other third party app store, or are pre-installed on third party devices (the “Apps”), or any other websites, pages, features, or content owned or operated by Cheetah (collectively, including the Site and Apps, the “Services”).

This Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Terms of Service located at ... Please read the Terms of Service carefully before you use our Services.

1. Acceptance of this Policy

By accessing, visiting or using our Services, you warrant and represent that you have read, understood and agreed to this Policy and our Terms of Service. If you disagree with anything in this Policy, you must not use or access the Services.

2. Amendments to this Policy

We may periodically make changes to this Policy as we update or expand our Services. We will notify you of any material changes to this Privacy Policy by notifying you via the email we have on file for you, or by means of a notice on our Services in advance of the effective date of the changes. If you do not agree to the changes, you should discontinue your use of the Services prior to the time the modified Policy takes effect. If you continue using the Services after the modified Policy takes effect, you will be bound by the modified Policy.

Furthermore, we may provide you with “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. These notices may provide more information about our privacy practices, or provide you with additional choices about how we process your personal information.

3. Information Collected through the Services

In this Policy, the term “personal information” includes any information that identifies or makes an individual identifiable. When you access or use our Services, we may generally collect the personal information described below.

A. Information You Directly and Voluntarily Provide to Us

When you access or use our Services, you may provide the following information to us:

    Customer Support Information: If you are a visitor to the Site, or a user of the Apps, we may collect information that you provide to us when you communicate with any of our departments such as customer service or technical services.

    Contact Information:When you sign up to create an account with some of our Apps, you will be required to provide an email address as part of the registration process. Alternatively, you can use your Facebook Account or other third party social network accounts (together, “Social Media Account”) to register for the Services.

    Social Media Account Information: When you sign up with a Social Media Account, you will be asked to choose which information you would like to share with us, such as your email address, birthday, friends list, or public profile information. When you decide to use a Social Media Account to sign up for our Services, we only require the collection of the email address associated with your Social Media Account; all other information provided by you is voluntary.

    Profile Information:When using some of our Services, you may be able to add information to your profile, such as an avatar or profile picture, birthday, nickname or username, or country. You voluntarily provide this information to us.

    Your Content:When using some of our Services, you can create, post, upload or share content by providing us with access to your photos, media and files, and your device’s camera and microphone. You voluntarily provide this information to us.

B. Information Automatically Collected Through the Services

We automatically collect information about you when you use the Services, such as:

    Device Information: If you access the Services through a mobile device, we may be able to identify the general location of your mobile device (not precise geolocation data), your mobile device's brand, model, operating system, resolution, screen size, system version, Bluetooth settings, internet connection, random-access memory (“RAM”), the application you have installed, the applications you have running in the background, mobile device "s advertising ID, other unique identifiers and other information related to device setting.

    Cookies & Similar Tracking Information : We use cookies and similar tracking technologies to collect information about your interactions with our Services. The information we collect includes, but is not limited to, account activation time, content displayed to you and whether you clicked on it, advertisements displayed to you and whether you clicked on them, URLs you have visited, notifications that have appeared on your mobile device, your Internet Protocol (“IP”) address, your mobile country code, and your user ID.

    Content Sharing:When you choose to share content with us, we automatically collect information about your Wi-Fi connection, and call information.

You may be able to limit the amount of information collected from your device (e.g., computer, phone, or tablet) with us by adjusting your device or browser settings. However, by preventing us from collecting information from you, we may not be able to provide some functions on our Services. For more information about our cookies and similar tracking technologies, and how to manage them, please read the Policy.

C. Information You Share on Third Party Websites or through Social Media Services

The Services may include links to third-party websites and social media services where you may be able to post comments, stories, reviews or other information. Your use of these third-party websites and social media services may result in the collection or sharing of information about you by these third-party websites and social media services. We encourage you to review the privacy policies and settings on the third-party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third-party websites and social media services ...

4. How We Use the Information We Collect

We use the personal information we gather through the Services for the purposes described below. If we use your personal information in any other ways, we will disclose this to you. You can choose not to share your information with third parties for marketing purposes, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your consent. If you choose to limit the ways we can use your personal information, some or all of the Services may not be available to you.

    To provide the Services to you. We require certain information from you in order to provide you with the Services you requested. Such information may include your contact and device information. We share this information with our service providers or partners to the extent necessary to continue to provide you with the Services. We cannot provide you with Services without such information.

    To provide customer service.We process your personal information when you contact us to help you with any questions, concerns, disputes or issues, or to provide us with your feedback. Without your personal information, we cannot respond to you or ensure your continued use and enjoyment of the Services.

    To enforce terms, agreements or policies. To ensure your safety and adherence to our terms, agreements or policies, we may process your personal information to: actively monitor, investigate, prevent and mitigate any alleged or actual prohibited, illicit or illegal activities on our Services; investigate, prevent, or mitigate violations of our terms and policies; enforce our agreements with third parties and partners; and, collect fees based on your use of our Services. We cannot perform our Services in accordance with our terms, agreements or policies without processing your personal information for such purposes.

    To send you Service-related communications. We use your contact information to send you administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information to you. Service-related communications are not promotional in nature. You cannot unsubscribe from such communications because you could miss important developments relating to your account or the Services that may affect how you can use our Services.

    For security purposes.We process your personal information to: improve and enforce our security measures; combat spam, malware, malicious activities or security risks; and to monitor and verify your identity so that unauthorized users do not access your account with us. We cannot ensure the security of our Services if we do not process your personal information for security purposes.

    Designated Countries:For all purposes listed above, pursuant to the EU General Data Protection Regulation (“GDPR”) or any equivalent legislation (collectively “Data Protection Laws”), we process the personal information of users located in the European Economic Area (“EEA”) , United Kingdom and Switzerland (collectively, the “Designated Countries”) based on our contract with you.

    To maintain legal and regulatory compliance. We process your personal information to pay our taxes or fulfill our other business obligations, and / or to manage risk asrequired under applicable law. We cannot perform the Services in accordance with our legal and regulatory requirements without processing your personal information for such purposes.

    Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to comply with our legal obligations.

    To personalize your experience on the Services. We allow you to personalize your experience on our Services via social media plugins on our Services (e.g., Facebook,Google, Instagram, Twitter, etc.), by keeping track of your preferences (e.g., nickname or display name, time zone, language preference, etc.), and more. Without such processing, you may not be able to access or personalize part or all of our Services.

    Designated Countries:

    To conduct research and development. We process information about the way you use and interact with our Services to: help us improve our Services; build new Services; and build customized features or Services. Such processing ensures your continued enjoyment of part or all of our Services.

    Designated Countries:Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries to satisfy our legitimate interests as described above.

    To engage in marketing activities. We may process your contact information or information about your interactions on our Services to: send you marketing communications; deliver targeted marketing; inform you about events, webinars, or other materials, including those of our partners; and, keep you up-to-date with ourrelevant products and Services. Transactional communications about your account or our Services are not considered “marketing” communications. In addition, when you share your friends' contact information with us, we may reach out to them to invite them to our Services and to continue receiving our communications. You can opt-out of our marketing activities at any time.

Designated Countries: For users located in the Designated Countries, please see section 9.C. below.

5. How We Share Your Information with Third Parties

We may share your personal information with third parties in the following circumstances:

    Employees, Third-Party Processors and Third-Party Service Providers

We disclose your personal information to our employees, contractors, affiliates, distributors, dealers, vendors and suppliers (“Service Providers”) who provide certain services to us or on our behalf, such as operating and supporting the Services, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the personal information needed to perform these limited functions on our behalf.

Designated Countries:Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on our contract with you.

B. Response to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies

To the extent permitted by law, we will disclose your personal information if:

    Required to do so by law, or in response to a subpoena or court order or similar request from judicial authority, law enforcement authorities or other competent public authorities;

    We believe, in our sole discretion, that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or

    We believe that you have abused the Services by using it to attack our systems or to gain unauthorized access to our system, to engage in spamming or otherwise to violate applicable laws.

Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on our legal obligations, in the public interest, or your vital interests.

C. Business Transfers or Bankruptcy

In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any personal information owned or controlled by us may be one of the assets transferred to third parties. We will notify you via email or a prominent notice within our Services of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information

Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred personal information will be subject to this Privacy Policy. However, any personal information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on legitimate interests described above.

D. Our Affiliates

Based on your consent, we may share some or all of your contact information with our, parent company, subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us. If you would like us to stop providing your information to our affiliates for their own marketing purposes, you may opt-out by contacting us as provided in the “How to Contact Us” section.

Designated Countries: Pursuant to the Data Protection Laws, we process the personal information of users located in the Designated Countries based on your consent.

E. Third-Party Business Partners.

Base on you consent, we may work with and share some of your informaiton with our third-party advertising partners to provide you with advertisements or other tailored content. For more information about our own adversising practice and those of third-party partners, please visit our and our. We may share information related to users of our service with affiliates or unaffiliated third parties on a de-identified, aggregate basis. While this informaiton will not identify you personally, in some instances these parties may be able to combile these aggregate, de-identified informaiton with other data they have about you, or that they receive from other parties, in a manner that allows them to identify you personally.

Designate Countries: Pursuant to the Data Protection Laws, we process the personla informaiton of user located in the Designated Countries based on your consent.

6. Children

We do not knowingly collect personal information from children under 18 years old, unless permitted to do so by applicable law. Children are not permitted to use our Services unless they provide us with consent from their parent or guardian. If we become aware that we have unknowingly collected personal information from a child, we will make commercially reasonable efforts to delete such information in our database. If you are a parent or guardian of a child, and you believe your child has provided us with their Personal Information on our Services, please contact us immediately at .

7. Security

We are committed to ensuring the security of your personal information. We have physical, technical and administrative safeguards in place to protect the confidentiality of your personal information. In addition, we require that our service providers handling personal information also maintain appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you provide to us.

However, we cannot guarantee the security of your personal information or that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. We also have no way of protecting any of your personal information that is not in our control, such as any information transmitted via email or wireless connections.

Maintaining the security of your personal information is also your responsibility. Where we require you to register an account, you should choose a password of sufficient length and complexity and keep your password confidential. Do not leave your device unlocked so that other individuals may access it. Make sure you trust the wireless connections you are using to access or use our Services.

If you think there has been unauthorized access to or use of your account, please contact us immediately at .

8. Retention of Personal Information.

We will try to limit the storage of your personal information to the time necessary to serve the purpose (s) for which your personal information was processed, to enforce our agreement, policies or terms, to resolve disputes, or as otherwise required or permitted by law. Please contact us if you have any questions about our retention periods. While retention requirements can vary by country, we generally apply the retention periods noted below.

    Marketing.We store information used for marketing purposes indefinitely until you unsubscribe. Once you unsubscribe from marketing communications, we add your contact information to our suppression list to ensure we respect your unsubscribe request.

    Your Interactions and Content on Our Services. We may store any information about your interactions on our Services or any content created, posted or shared by you on our Services (eg, pictures, comments, support tickets, and other content) indefinitely after the closure your account for the establishment or defense of legal claims, audit and crime prevention purposes.

    Web Behavior Data.We retain any information collected via cookies, clear gifs, webpage counters and other technical or analytics tools up to one year from expiry of the cookie or the date of collection.

    Telephone Records.As required by applicable law, we will inform you that a call will be recorded before doing so. Any telephone calls with you may be kept for a period of up to six years.

9. Information for Residents in the European Economic Area, United Kingdom and Switzerland (the “Designated Countries”)

This section only applies to users of our Services that are located in the European Economic Area, United Kingdom and / or Switzerland (collectively, the "Designated Countries") at the time of data collection. We may ask you to identify which country you are located in when you use some of the Services, or we may rely on your IP address to identify which country you are located in.

Where we rely on your IP address, we cannot apply the terms of this section to any user that masks or otherwise obfuscates their location information so as not to appear located in the Designated Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to users in the Designated Countries.

A. Our Relationship to You

Cheetah Mobile Inc. and its affilates are data controllers with regard to any personal information collected from users of its Services. A “user” is an individual providing personal information to us via our Services, such as by creating an account with our Apps, signing up for our newsletter (s), or otherwise accessing or using our Services. A “data controller” is an entity that determines the purposes for which and the manner in which any personal information is processed. Any third parties that act as our service providers are “data processors” that handle your personal information in accordance with our instructions.

B. Legal bases for processing Personal Information

We describe our legal bases for processing in Section 4 (“How We Use the Information We Collect”) and Section 5 (“How We Share Your Information With Third Parties”) under headings entitled “Designated Countries.” The legal bases on which we rely on to process your personal information include: your consent to the processing; satisfaction of our legal obligations; necessity to protect your vital interests; necessity to carry out our obligations arising from any contracts we entered with you or to take steps at your request prior to entering into a contract with you; necessity to process in the public interest; or for our legitimate interests as described in those sections.

C. Marketing Activities

If you are located in the Designated Countries and are a current user, we will only contact you by electronic means (such as email or SMS) per your communication preferences and / or with information about our Services that are similar to the Services you previously purchased from us or negotiated to purchase from us.

For new users located in the Designated Countries, we will contact you by electronic means for marketing purposes only based on your consent or based on your friends’ consent. You can always withdraw your consent or change your marketing communication preferences at any time and free of charge. To opt out of the emails, please click the “unsubscribe” link in the footer of marketing emails or contact us at ... Marketing communications are promotional in nature and do not include transactional or Service-related communications.

D. Individual Rights

We provide you with the rights described below when you use our Services. Please contact us at if you would like to exercise your rights under applicable law. When we receive an individual rights request from you, please make sure you are ready to verify your identity. Please be advised that there are limitations to your individual rights. We may limit your individual rights in the following ways:

      Where denial of access is required or authorized by law;

      When granting access would have a negative impact on other "s privacy;

      To protect our rights and properties; and

      Where the request is frivolous or burdensome.

    Right to withdraw consent.If we rely on consent to process your personal information, you have the right to withdraw your consent at any time. A withdrawal of consent will not affect the lawfulness of our processing or the processing of any third parties based on consent before your withdrawal.

    Right of access and rectification. If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee. We may limit your access if such access would adversely affect the rights and freedoms of other individuals. You may also request to correct or update any of your personal information held by us, unless you can already do so directly via the Services.

    Right to erasure (the “Right to be Forgotten”). You may request us to erase any of your personal information held by us that: is no longer necessary in relation to the purposes for which it was collected or otherwise processed; was collected in relation to processing that you previously consented to, but later withdrew such consent; or was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.

    Right to restriction.You have the right to restrict our processing your personal information where one of the following applies:

      You contest the accuracy of your personal information that we processed. We will restrict the processing of your personal information, which may result in an interruption of some or all of the Services, during the period necessary for us to verify the accuracy of your personal information;

      The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead;

      We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims; or

      You have objected to processing, pending the verification whether the legitimate grounds of our processing override your rights.

We will only process your restricted personal information shall with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if or when the restriction is lifted.

    Right to object to processing. You may object to our processing at any time and as permitted by applicable law if we process your personal information on the legal basis of consent, contract or legitimate interests. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

    Right to data portability.If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others.

    Notification to third-parties. If we share your personal information with third parties, we will notify them of any requests for rectification, erasure or restriction of your personal information, unless this proves impossible or involves disproportionate effort. Upon your request, we will identify such third parties.

    Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, unless an exception applies under applicable law.

    Right to Lodge a Complaint.If you believe we have infringed or violated your privacy rights, please contact us at so that we can work to resolve your concerns. You also have a right to lodge a complaint with a competent supervisory authority situated in a Member State of your habitual residence, place of work, or place of alleged infringement.

You may reach our Data Protection Officer at .

E. Transfer of Personal Information

If you choose to use the Services or provide your information to us, your personal information may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. Such countries or jurisdictions may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.

Designated Countries: We transfer your personal information subject to appropriate safeguards as permitted under the Data Protection Laws. Specifically, when your personal information is transferred out of the Designated Countries, we have the required contractual provisions for transferring personal information in place with the third-parties to which your information is transferred. For such transfers, we rely on legal transfer mechanisms such as Standard Contractual Clauses or we work with U.S. based third parties that are certified under the EU-U.S. and Swiss-U.S. Privacy Shield Framework.

10. Special Information for California Residents.

California law allows users of the Services who are California residents to request and receive once a year, free of charge, a notice from us describing what categories of personal information (if any) we shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year. If you are a California resident and would like to request a copy of this notice, please contact contacting us as provided in the “How to Contact Us” section. In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least thirty (30) days for a response.

In addition, if you are a California resident under the age of 18 and are a registered user of the Services, you may request that we remove content or information that you posted on Services or stored on our servers by: submitting a request as provided in the “How to Contact Us” section and (ii) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed.

However, please note that we are not required to erase or otherwise eliminate content or information if:

    other state or federal laws require us or a third party to maintain the content or information;

    the content or information was posed, stored, or republished by another user;

    the content or information is anonymized so that the minor cannot be individually identified;

    the minor does not follow the instructions posted in this Privacy Policy on how to request removal of such content or information; and (e) the minor has received compensation or other consideration for providing the content.

Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or information.

11. How to Contact Us.

If you have any questions about this Privacy Policy, please feel free to contact us.

How to find our contact information: 1. Open the Google Play / Apple App Store; 2, Browse or Search the app you "re using; 3, Tap the app to open the detailed page; 4, Scroll down to review the contact information listed.

Privacy Policy

Effective date: September 15, 2016
Welcome to Verb (“Verb”, “we”, “us”, “our”). Verb provides you with a fast, convenient and fun way to share content with other people.

1. INFORMATION WE COLLECT

We collect the following information.

Information you provide us directly:

  • Your username, password and email address e-mails entered when registering an account on Verb.
  • Information entered by you in the user profile (for example, first and last name, photo, phone number). With this information you and other users can be “found” on Verb.
  • User materials (for example, photos, comments and other materials) published on the Service.
  • Correspondence between you and Verb. For example, we may send Service-related messages to your e-mail (such as confirmation of registration, information about changes and updates to the Service's functions, technical notifications and security notices). Please note that you cannot unsubscribe from email newsletters related to the Service.

How to find your friends on Verb:

  • Optionally, you can use the Find Friends feature to find other people who have an account on Verb using: 1) your contact list; 2) third party social sites; 3) search by name and username on Verb.
  • If you want to find friends using (1) your device's contact list, Verb will access your contact list to determine if people on your list are using Verb.
  • If you want to find friends using (2) third party social site, then you will be asked to link to this third party service and you should understand that any information that this service may provide to us will be governed by this Privacy Policy.
  • If you would like to find friends using (3) the search function by name or username on Verb, then simply enter the appropriate name in the search form and we will search our Service.
  • Note on the Invite Friends feature: If you would like to invite someone to the Service using the Invite Friends feature, you can select that person directly from your device's contact list and send a text message or email from your personal account. You understand and agree that all costs of sending messages from your device are yours and since this invitation is sent directly from your personal account, Verb does not have access to this correspondence and cannot control it.

Analytical information:

  • We use third-party analysis tools to measure traffic and trends in the use of the Service. These tools collect information sent by your device or our Service, including data about the pages you visit, programs and other information that may help us improve the Service. We collect and use this analytical information in conjunction with analytical information about other Users in such a way that it is impossible to identify any specific User from it.

Cookies and Similar Technologies:

  • When you visit the Service, we may use cookies and other similar technologies (such as pixels, web beacons and local storage) to collect information about how you use Verb and provide you with relevant features.
  • We may ask advertisers or other partners to provide advertisements or services on your device that may use cookies or similar technologies hosted by us or by third parties.
  • For more information visit the section About Cookies

Log file information:

  • Log file information is automatically transmitted by your browser every time you make a request to access (i.e. visit) a web page or application. It can also be provided when the content of a web page or application is downloaded to your browser or device.
  • When you use the Service, our servers automatically record certain information for the log file, including data about your requests, IP address and browser type; the page from which you entered the website; the page from which you left the website; page addresses, number of clicks and interactions with links on the Service; domain names, landing pages, pages viewed, and similar information. We may also collect such information from e-mail messages sent to our Users in order to be able to track which messages were viewed and which links the recipient clicked on. This information helps to provide more accurate reports and improve the Service.

Device identifiers:

  • When you use a mobile device (such as a tablet or phone) to access our Service, we may access your device “identifier”, collect, track and store on your device and / or store one or more device identifiers remotely. Device IDs are small data files or similar data structures that are stored on (or associated with) your mobile device and uniquely identify it. A device identifier can be data that is stored in connection with the hardware of a device; data stored in connection with the operating system or other software of the device; or data that is sent by Verb to the device.
  • The Device ID may provide us or a third party partner with information about how you navigate and use the Service, which may help us or other parties compile reports or personalize advertisements and other content. Some functions of the Service may not work properly if device identifiers are partially or completely unavailable.

Metadata:

  • Metadata is generally technical data associated with User Content. For example, Metadata can describe how, when, and by whom any portion of User Content was acquired, and how that content was modified.
  • Users can add Metadata to their User Content (or it is added by another party), including a hashtag (for example, to tag keywords when a photo is posted), a geolocation tag (for example, to tag a photo's location), comments, or other information. This makes your Content more searchable and easier to interact with. If you tag a photo or tag using other APIs, the latitude and longitude of your location will be stored with the photo and will be searchable (for example, by searching by location or map), provided that you made their photo public by specifying this in their privacy settings.

2. HOW WE USE YOUR INFORMATION

In addition to some of the specific uses of information described in this Privacy Policy, we may use the information we receive to:

  • help you quickly access your information after registration;
  • remember information so that you do not have to re-enter it during the current or next visit to the Service;
  • provide you and others with personalized content and data, which may include online advertisements or other marketing materials;
  • provide, improve, test and track the effectiveness of the Service;
  • develop and test new products and functions;
  • track metrics such as total visitors, traffic, and demographics;
  • diagnose or fix technical problems;
  • automatically update the Verb app on your device;
  • Verb users or other users may organize contests, special offers, or other activities and events ("Events") within the Service. If you do not want to participate in an Event, do not use certain Metadata (such as a hashtag or geolocation tag) associated with the Event.

3. TRANSFER OF YOUR INFORMATION

We do not share or sell your information to third parties outside of Verb (or the Verb group of companies) without your consent, except as described in this Privacy Policy.

Parties with whom we may share your information:

  • We may share User Content and information about you (including, but not limited to, information obtained through cookies, log files, device identifiers, website usage and location data) to companies that are legally part of a group companies that Verb is a member of, or become part of this group ("Affiliated Companies"). Affiliated Companies may use this information to help provide, study and improve the Service (including by providing statistical data) and Affiliated Companies' own services (including by improving the quality and relevance of materials). However, these Affiliates will respect your privacy settings.
  • In addition, we may share your information, as well as information obtained through tools such as cookies, log files, device identifiers and location data, to third parties that help us provide you with the Service ("Service Providers") ... Our Service Providers access your information to the extent reasonably necessary to provide the Service based on reasonable confidentiality terms.
  • We may also share certain information (such as data from cookies) with third party advertising partners. This information will allow third-party advertising organizations, among other things, to offer you advertisements that they believe will be of most interest to you.
  • We may delete some of the data that can be used to identify you and transfer anonymous data to third parties. In addition, we may combine your information with other information in such a way that it cannot be associated with you, and transfer this aggregated information to third parties.

Parties to whom you may wish to provide access to your User Materials:

  • Any information or materials that you voluntarily open access to when posting on the Service (for example, User Content) becomes publicly available in accordance with your chosen privacy settings. To change your privacy settings on the Service, change your profile settings. Once you post or make your User Content available to the public, others will be able to share your User Content.
  • Depending on your profile and privacy settings, any User Content you make publicly available may appear searchable by other Users or be used by the Verb API.
  • If you delete information posted by you on the Service, copies of it may remain available in cached and archived pages of the Service or if other Users or third parties have used the Verb API to copy or save this information.

What happens when the owner changes:

  • If we sell or otherwise transfer Verb or our assets to another organization, in part or in whole (for example, as a result of a merger, acquisition, bankruptcy, liquidation, dissolution), then your information (for example, name, email address, User Content and any other information collected through the Service) may be sold or transferred along with the rest of the property. In doing so, you remain the owner of your User Materials. The buyer or acquirer will be required to comply with the obligations we have made in this Privacy Policy.

Responding to formal inquiries and preventing damage:

  • We may access, store, and share your information in response to a formal request (such as a search warrant, court order, or subpoena) by making sure in good faith that the request is lawful. In particular, we may respond to official requests from government agencies in countries other than the United States if we have reasonable grounds to believe that the response should be provided under the laws of that country or territory, affects users in that country or territory, and does not contradict internationally recognized standards. ... We may also access, store and transmit information if we have reasonable grounds to believe that it is necessary to detect, prevent or suppress fraud or other illegal activity; to protect yourself, you and others, including during an investigation; or to prevent death or imminent harm to health. We may access the information we receive about you, process and store it for a longer period of time if it is the subject of a formal request or legal obligation, government investigation or investigation for possible violations of our terms or policies, or in other cases. to prevent harm.

4. HOW WE STORE YOUR INFORMATION

Storage and handling:

  • Your information collected through the Service may be stored and processed in the United States or any other country where Verb equipment, its Affiliates or Service Providers are located.
  • Verb, its Affiliated Companies or Service Providers may transfer information collected about you (including personal information) outside your country or territory to other countries or territories around the world. If you are located in the European Union or other regions where data collection and use laws differ from those in the United States, please note that we may transfer information (including personal information) to a country or territory where data protection laws are not. provide the same level of protection as the laws of your country or territory.
  • By registering and using the Service, you consent to the transfer of information to the United States or any other country where Verb's equipment, its Affiliated Companies or Service Providers are located, and to the use and disclosure of information about you in accordance with the provisions of this Privacy Policy.
  • We use commercially reasonable safeguards to maintain the security of information collected through the Service and take reasonable steps (such as asking for a unique password) to identify you before granting you access to your account. However, Verb cannot ensure the complete security of any information you transmit to Verb, or guarantee that information on the Service will not be disclosed, made public, altered or destroyed.
  • Please take precautions on your part to help us. You are responsible for maintaining the confidentiality of your unique password and account information, and for controlling access to email communications between you and Verb. Your privacy settings may also change based on changes to the social services you connect to Verb. We are not responsible for the functionality, privacy or security measures of any other organization.

5. PERSONAL SETTINGS RELATING TO YOUR INFORMATION

Account information and profile and privacy settings:

  • You can update your account information at any time by logging into our website and changing your profile settings.
  • You can also opt out of receiving our communications by e-mail by clicking on the “Unsubscribe” link that is contained in each message. As already mentioned, there is no way for you to opt out of receiving communications related to the Service (for example, account verification, confirmation and reminder of purchases and bills, changes and updates to the Service's functions, security and technical notifications).

Retention period for User Materials:

  • Upon deletion or deactivation of your Verb account, its Affiliates or its Service Providers may retain information (including your profile information) and User Content for a commercially reasonable period of time for the purpose of backing up, archiving, and auditing purposes.

6. PRIVACY POLICY FOR CHILDREN

Verb does not knowingly collect or request any information from people under the age of 13, and also does not allow such persons to register on the Service. The Service and the materials posted on it are not intended for persons under the age of 13. If we become aware of our receiving personal information about a child under the age of 13 without parental consent, we will delete that information as soon as possible. If you believe we may have information about or from a child under the age of 13, please contact us.

7. OTHER WEBSITES AND SERVICES

We are not responsible for the operation of other websites or services that contain links to our Service or links to which are contained in our Service, including for the information or materials posted on them. When you follow a link from our Service to another website or service, remember that our Privacy Policy does not apply to those third party websites or services. When you visit or use any third party website or service, including those linked to from our website, the terms and policies of that third party website or service apply to you. In addition, you agree that we have no responsibility or control over any third parties to whom you provide access to your User Materials. If you use a third party website or service and give them access to your User Materials, then you do so at your own risk.

8. HOW TO CONTACT US IN CASE OF USER DEATH

Contact us in case of death of a Verb user. We usually correspond by email. If you need more information, we will contact you by email. mail specified in your request.

9. HOW TO CONTACT US

If you have any questions about the Privacy Policy or the Service, please search the Help Center for a suitable channel to contact us.

10. CHANGES TO PRIVACY POLICY

Verb may change or update this Privacy Policy from time to time, so we ask that you review it periodically. We may provide you with additional forms of notification of changes or updates as appropriate. If you continue to use Verb or the Service following the posting of changes to the Privacy Policy, this will mean that you agree to such changes.

1.1. This Policy is carried out by IE Melentiev K.I. (hereinafter referred to as the "Organization") in relation to the processing and protection of personal data of individuals (subjects of personal data) on the basis of Article 24 of the Constitution of the Russian Federation and Federal Law No. 152-FZ "On Personal Data".

1.2. The policy applies to all personal data (subjects) that can be obtained by the Organization in the course of its activities, including the clients of the Organization.

1.3. The purpose of the Policy is to inform the persons who provide their personal data with the necessary information to assess what personal data and for what purposes are processed by the Organization, what methods of ensuring their security are implemented.

1.4. The policy ensures the protection of the rights and freedoms of subjects when processing their personal data using automation tools or without using such means, and also establishes the responsibility of persons who have access to personal data for failure to comply with the requirements governing the processing and protection of personal data.

1.5. Clients, using the services and services of the Organization, informing the Organization of their personal data, including through the mediation of third parties, acknowledge their consent to the processing of personal data in accordance with this Policy.

1.6. Consent to the processing of personal data can be revoked by the subject of personal data. If the subject of personal data withdraws consent to the processing of personal data, the operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified by the current legislation or, otherwise, to refuse to provide the service, if personal data is necessary to provide such services.

1.7. This Policy is subject to change by the Organization.

2. Concept and composition of personal data

2.1. For the purposes of this Policy, personal data means any information relating directly or indirectly to a specific individual (subject of personal data).

2.2. Depending on the subject of personal data, the Organization, in order to carry out its activities and to fulfill its obligations, may process personal data of the following categories of subjects:

  • personal data of an employee of the Organization - information required by the Organization in connection with labor relations and relating to a specific employee.
  • Client data - information necessary for the Organization to fulfill its obligations under the contractual relationship with the Client and to comply with legal requirements Russian Federation.
  • personal data of the Client provided when registering on the website, including when the Client places Orders.
  • data that is automatically transmitted to the Services in the course of their use using the software installed on the user's device, including the IP address, information from the cookie, information about the user's browser (or other program with which the Services are accessed), access time , the address of the requested page.

4. Terms of processing personal data

4.1. The terms for processing personal data are determined based on the purposes of processing in the information systems of the Organization, in accordance with the term of the contract, agreement with the subject of personal data.

5. The circle of persons admitted to the processing of personal data

5.1. To achieve the goals of Article 3 of this Policy, only those employees of the Organization who are entrusted with such a duty in accordance with their official (labor) duties are allowed to process personal data. Access of other employees may be granted only in cases provided by law. The organization requires its employees to maintain confidentiality and ensure the security of personal data during their processing.

5.2. The organization has the right to transfer personal data to third parties in the following cases:

  • The personal data subject has clearly expressed his consent to such actions, including:
    when providing services to Clients - accepted the terms of the public offer agreement;
  • The transfer is provided for by Russian or other applicable law within the framework of the procedure established by law;

At the same time, all obligations to comply with the conditions for ensuring the security of personal data in accordance with the current legislation of the Russian Federation and international agreements in relation to the data received by him are transferred to the acquirer.

6. Methods of processing personal data

6.1. In the process of providing services, in the implementation of on-farm activities, the Organization uses automated and non-automated processing of personal data.

7. Implementation of personal data protection

7.1. The activities of the Organization for the processing of personal data in information systems are inextricably linked with the protection of the confidentiality of the information received by the Organization. All employees of the Organization are obliged to ensure the confidentiality of personal data, as well as other confidential information established by the Organization, if this does not contradict the current legislation of the Russian Federation.

7.2. The security of personal data during their processing in the information systems of the Organization is ensured using the information security system.

7.3. The exchange of personal data during their processing in the personal data information system is carried out through secure communication channels.

7.4. When processing personal data in the personal data information system of the Organization, the following are provided:

  • taking measures aimed at preventing unauthorized access to personal data and (or) transferring them to persons who do not have the right to access such information;
  • application of firewalling;
  • physical protection of premises and technical means that allow the processing of personal data;
  • timely detection of facts of unauthorized access to personal data;
  • prevention of physical impact on the technical means of automated workstations, as a result of which their functioning may be disrupted;
  • the possibility of immediate recovery of personal data modified and destroyed due to unauthorized access to them;
  • constant antivirus control;
  • constant analysis of the security of personal data;
  • use of security attributes;
  • control of the integrity of the software environment for processing personal data;
  • other means and measures in accordance with applicable law.

(General Data Protection Regulation) - a general regulation on the protection of personal data, which is about to enter into force in the EU and which Ukrainian entrepreneurs will have to comply with if they want to do business with European citizens.

Juscutum lawyer Vladislav Nekrutenko in his column spoke about what the GDPR actually changes, what it should be and what information should be disclosed to Internet users.

Probably, every person at least once gave consent to the processing of personal data when registering on the website. At the same time, it is indicated that the processing will be carried out in accordance with the "Privacy Policy" of the site. What does it mean?

In recent years, personal data has become an effective economic asset. Their competent use brings companies a commercial advantage and profit.

On the other hand, the abuse of benefits from personal data and the ignorance of users about this lead to government restrictions in this area. Therefore, the legislation of developed countries requires that a company:


  • fully informed the user about the nature and details of the use of his data;

  • after which she received consent from him for their collection and processing.

Do I need a Privacy Policy for this? Definitely as this is the best way to inform users about the collection of personal data on the website.

Privacy Policy is an internal document that sets out the rules for the collection and processing of personal data of users on a specific web resource.

The user should read the Privacy Policy during the first visit to the site or when registering. In addition, this document is posted publicly on the site with permanent access to it. Before consenting to the processing of data, the user must read the Privacy Policy (or at least tick the box that he has read). Today it is one of the most common practices for informing on web resources.

GDPR requirements for informing the user
The very requirement to inform website users about the use of their data is not new. However, problems arise in its implementation.

You can often find long versions of the Privacy Policy resources, written in an incomprehensible language, which describe only certain aspects of the processing of personal data. This policy does not serve as an informational function for users, but rather serves as a formal compliance with the law. Accordingly, the user is not able to understand what he agrees to.

Because of this and other misleading users, the European Union has adopted a new personal data protection act - the General Data Protection Regulation (GDPR). The GDPR sets requirements for the processing of personal data in the European Union. In addition, the document applies to companies outside the EU, if they process personal information European citizens.

The main innovations are the openness and transparency of the collection of personal data, the awareness of the subject, as well as the freedom of consent to their collection and processing. In this regard, the GDPR sets higher requirements for the volume and quality of informing users about the processing of their data.