1.1. The Operator considers the protection of human and civil rights and freedoms during the processing of personal data, including protecting the right to privacy, personal and family secrets, as the primary goal and condition of its activities.
1.2. This Privacy Policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about users when they use the website and mobile application “Position Size Calculator” (hereinafter collectively referred to as the Services).
2.1. Automated processing of personal data — processing of personal data using computer technology.
2.2. Blocking of personal data — temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Mobile application — software for mobile devices (smartphones, tablets) developed by the Operator under the name “Position Size Calculator,” providing access to the Operator's functionalities and services.
2.4. Website — a collection of graphical and informational materials, as well as software and databases, ensuring their availability on the Internet at the network address https://yoursuper.app/.
2.5. Personal data information system — a set of personal data contained in databases and ensuring their processing using information technology and technical means.
2.6. Depersonalization of personal data — actions that make it impossible to determine, without the use of additional information, the ownership of personal data to a specific User or other subject of personal data.
2.7. Processing of personal data — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.8. Operator — a state body, municipal body, legal or natural person that independently or jointly with other persons organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data to be processed, and the actions (operations) performed with personal data.
2.9. Personal data — any information directly or indirectly related to a specific or identifiable User of the website https://yoursuper.app/ and/or the mobile application “Position Size Calculator.”
2.10. Personal data allowed by the subject of personal data for dissemination — personal data made accessible to an unlimited number of persons by the subject of personal data by giving consent for processing under the procedure established by the Law on Personal Data (hereinafter — personal data allowed for dissemination).
2.11. User — any visitor of the website https://yoursuper.app/ and/or the mobile application “Position Size Calculator.”
2.12. Provision of personal data — actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.13. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.
2.14. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state, to a foreign government body, foreign individual, or foreign legal entity.
2.15. Destruction of personal data — any actions resulting in the irrevocable destruction of personal data, making it impossible to restore the personal data's content in the personal data information system, and/or destruction of physical carriers of personal data.
3.1. The Operator has the right to:
3.2. The Operator is obliged to:
4.1. Personal data subjects have the right to:
4.2. Personal data subjects are obliged to:
4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter's consent are liable in accordance with the legislation of the Russian Federation.
5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, pre-defined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.
5.3. Combining databases containing personal data, where processing is carried out for purposes incompatible with each other, is not allowed.
5.4. Only personal data that meets the purposes of their processing is subject to processing.
5.5. The content and scope of the processed personal data correspond to the declared purposes of processing. Excessive processing of personal data in relation to the declared purposes is not allowed.
5.6. Accuracy, sufficiency, and relevance of personal data in relation to the purposes of processing are ensured during the processing of personal data. The Operator takes the necessary measures and/or ensures such measures are taken to delete or clarify incomplete or inaccurate data.
5.7. Personal data is stored in a form that allows identifying the subject of personal data no longer than required by the purposes of personal data processing unless the storage period is established by federal law or a contract to which the subject of personal data is a party, beneficiary, or guarantor. Processed personal data is destroyed or depersonalized upon achieving the processing purposes or if the need to achieve these purposes is lost, unless otherwise provided by federal law.
| Purpose of Processing | Providing the User with access to services, information, and/or materials contained on the website and/or in the mobile application “Position Size Calculator.” |
|---|---|
| Personal Data | Last name, first name, email address |
| Legal Grounds | Agreements concluded between the Operator and the subject of personal data |
| Types of Personal Data Processing | Collection, recording, systematization, accumulation, storage, destruction, and depersonalization of personal data. Sending informational emails to the email address. |
7.1. Personal data is processed with the consent of the subject of personal data for the processing of their personal data.
7.2. Personal data processing is necessary to achieve the purposes provided for by an international treaty of the Russian Federation or by law, for the execution of functions, powers, and duties imposed by the legislation of the Russian Federation on the Operator.
7.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, or an act of another authority or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. Personal data processing is necessary for the execution of a contract to which the subject of personal data is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will act as a beneficiary or guarantor.
7.5. Personal data processing is necessary for the exercise of rights and legitimate interests of the Operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. Processing of personal data accessible to an unlimited number of persons, provided by the subject of personal data or at their request (hereinafter referred to as publicly accessible personal data), is carried out.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation on the protection of personal data.
8.1. The Operator ensures the security of personal data and takes all possible measures to exclude unauthorized access to personal data.
8.2. User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the subject of personal data has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil contract.
8.3. In case of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator's email address at yoursuperapp.trade@gmail.com with the note “Updating Personal Data.”
8.4. The term of personal data processing is determined by achieving the purposes for which the personal data was collected unless another term is specified by contract or current legislation.
The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator via email at yoursuperapp.trade@gmail.com with the note “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those parties (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data must familiarize themselves with these documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Restrictions imposed by the subject of personal data on the transfer (other than access provision), as well as on processing or conditions of processing (other than access acquisition) of personal data allowed for dissemination, do not apply in cases of personal data processing for state, public, or other public interests as determined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. The Operator stores personal data in a form that allows identifying the subject of personal data no longer than is required for the purposes of personal data processing unless the storage period is established by federal law or a contract to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. The condition for terminating the processing of personal data may be the achievement of the purposes of personal data processing, the expiration of the subject's consent, the withdrawal of consent by the subject of personal data, a demand to cease personal data processing, or the identification of unlawful processing of personal data.
9.1. The Operator collects, records, systematizes, accumulates, stores, updates (modifies, changes), retrieves, uses, transfers (distributes, provides, grants access), depersonalizes, blocks, deletes, and destroys personal data.
9.2. The Operator performs automated processing of personal data, including the receipt and/or transmission of the obtained information via information and telecommunication networks or without them.
10.1. Before initiating the cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects' rights of its intention to carry out the cross-border transfer of personal data (this notification is sent separately from the notification of the intent to process personal data).
10.2. Prior to submitting the aforementioned notification, the Operator must obtain relevant information from foreign government authorities, foreign individuals, or foreign legal entities to whom the cross-border transfer of personal data is planned.
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
12.1. The User may obtain any explanations on issues of interest regarding the processing of their personal data by contacting the Operator via email at yoursuperapp.trade@gmail.com.
12.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced with a new version.
12.3. The current version of the Policy is freely available on the Internet at https://yoursuper.app/trade/app/docs/en/privacy-policy.html.