Privacy Policy
LLC "Wavekom"
1. Terms and Definitions
The following terms and definitions are used in this Privacy Policy:
Company — the licensor, Limited Liability Company “Wavekom”.
Abbreviated name: LLC “Wavekom” (INN: 3257062678, KPP: 168401001);
Official Website — the Company’s website on the Internet: https://corline.im/;
Policy — this Privacy Policy governing the use of the Corline platform and the Company’s Official Website;
Application User — a licensee, an individual (Client) who has reached the age of 18, installed the Application on a Device, and completed registration using a phone number;
Website Visitor — an individual or legal entity that has accessed any page of the Official Website from a Device;
Website User — an individual or legal entity that has submitted an inquiry or application to the Company via feedback forms on the Official Website;
Mailing List Subscriber — an individual or legal entity that has completed a subscription form to receive informational and promotional messages from the Company via the Official Website;
Application — a software program (web application, desktop application, mobile application) available on the Internet at https://corline.im/download/, the exclusive rights to which belong to the Company by virtue of its creation;
Device — a mobile or stationary technical device (smartphone, tablet, personal computer, laptop, etc.) with Internet access on which the Application is installed or from which access to the Official Website is performed;
Application User Information — information from the public profile of the Application User that may be obtained from the Device during registration via phone number and/or during use of the Application;
Website Visitor Information — information of a Website Visitor that may be processed by the Company when the Visitor accesses the Official Website;
Website User Information — information of a Website User that may be processed when submitting inquiries and applications via feedback forms on the Official Website, as well as during subsequent processing of such inquiries and applications;
Mailing List Subscriber Information — information provided by the Mailing List Subscriber when submitting a subscription form on the Official Website;
Content — all objects independently posted by the Application User within the Application, including design works, graphic, textual, audio, photo, and video works, as well as any other objects and compilations thereof, whether or not they are intellectual property objects, the rights (including exclusive intellectual property rights) to which belong either to the Application User or to other rights holders.
2. General Provisions
2.1. This Policy regulates the scope and conditions of processing information of Application Users, Website Visitors, Website Users, and Mailing List Subscribers (hereinafter — “data subjects”).
2.2. Use of the Application or the Official Website constitutes unconditional consent to this Policy and the information processing conditions specified herein.
2.3. This Policy applies only to the Application and the Official Website. The Company does not control and is not responsible for information (or the consequences of its transfer) transmitted by data subjects to third parties if such transmission was carried out on third-party resources accessed via links from the Application or the Official Website.
2.4. The Company does not process data of corporate profiles of Application Users. Data of corporate profiles are processed by the owners of the respective corporate servers in accordance with their internal regulations.
2.5. The Company has the right to amend this Policy unilaterally by publishing a new version on the Official Website and/or within the Application. The obligation to review the current version rests with the data subject.
2.6. If provisions of this Policy contradict the legislation of the Russian Federation, such provisions shall not apply.
2.7. The Company processes information of the following categories of individuals via the Official Website or Application:
Application Users;
Website Users;
Website Visitors;
Mailing List Subscribers.
3.Cookie Processing
3.1. The Company uses cookie data and other tracking and data storage technologies. Cookies are sent to the browser from the Company’s web servers and stored on the Device.
3.2. Cookies allow collection and tracking of data for analysis and subsequent improvement of the Application and the Official Website.
3.3. Users of the web version of the Application and Website Visitors may refuse cookie processing in accordance with browser instructions. In such cases, some features of the Official Website and web version of the Application may be unavailable.
4. Composition of Processed Information
Categories of individuals:
Application Users
Information provided during registration using a mobile phone number (e.g., user nickname, phone number).
Information provided in the personal profile settings (e.g., profile image).
Mobile phone numbers from the Device’s contact list, subject to permission granted via the operating system.
Website Users
Information provided when submitting feedback forms (e.g., phone number, email address, inquiry content).
Website Visitors
Date and time of access to the Official Website.
Activity information during use of website features.
Technical data (IP address, session duration, device type, manufacturer and model, OS version, geographic connection location, and geolocation data when voluntarily provided).
Mailing List Subscribers
Email address.
4.1. Additionally, within the scope of this Privacy Policy, the Company is entitled to process statistical information and metadata describing the content (including keywords used for document retrieval), the structure and context of other data, as well as data lifecycle management information generated during the use of the Application.
5. Purposes of Information Processing
5.1. Information is collected and processed for the following purposes:
Providing access to Application features — Application Users;
Processing inquiries and applications — Website Users;
Ensuring operation, improvement, modification, and personalization of the Application and Official Website — Application Users and Website Visitors;
Informational support for mailing list subscribers — Mailing List Subscribers;
Compliance with legal obligations — Application Users.
5.2. Only information relevant to achieving the stated purposes is processed.
6. Conditions of Information Processing
6.1. Application User information is stored during the period of Application use and for 3 (three) years after termination.
6.2. Website User and Mailing List Subscriber information is processed until purposes are achieved or consent is withdrawn, and for 3 (three) years thereafter.
6.3. Website Visitor information is processed until processing purposes are achieved or consent is withdrawn.
6.4. All data is stored in databases located within the Russian Federation.
6.5. The Company may perform the following actions: collection, recording, systematization, accumulation, storage, clarification, extraction, use, transfer, blocking, deletion, and destruction.
6.6. The transfer of information is carried out to authorized government authorities in accordance with the legislation of the Russian Federation:
Application Users
For the purpose of complying with statutory obligations imposed on the Company.
Application
For the purpose of complying with statutory obligations imposed on the Company.
7. Legal Grounds for Processing
7.1. The processing of information of an Application User, Website User, or Website Visitor is carried out on the following legal grounds:
Providing access to the functions and services of the Application:
Consent to data processing expressed by independently checking the relevant checkboxes confirming ознакомление with this Privacy Policy and consent to data processing, or by clicking a button in the Application registration/authorization window.
Processing carried out for the purpose of performing a contract (the user agreement) to which the data subject is a party.
Review and processing of inquiries and requests submitted via feedback forms:
Consent to data processing expressed by independently checking the relevant checkboxes confirming ознакомление with this Privacy Policy and consent to data processing when submitting feedback forms on the Official Website.
Ensuring the operation, improvement, modification, and personalization of the Official Website and the Application:
Consent to data processing expressed by independently clicking the “Accept” button or any other button indicating acceptance of this Privacy Policy and consent to data processing in the cookie usage notification on the Official Website.
Consent to data processing expressed by independently clicking the “Accept” button or any other button indicating acceptance of this Privacy Policy and consent to data processing in a pop-up window when starting to use the Application.
Consent to data processing expressed by independently checking the relevant checkboxes confirming ознакомление with this Privacy Policy and consent to data processing during registration/authorization in the Application.
Providing informational support to mailing list subscribers:
Consent to data processing expressed by independently checking the relevant checkboxes confirming ознакомление with this Privacy Policy and consent to data processing when submitting a subscription form for informational messages on the Official Website.
Compliance with statutory obligations imposed on the Company:
Processing is necessary to achieve purposes provided for by the legislation of the Russian Federation, and to exercise and fulfill the functions, powers, and obligations imposed on the Company by such legislation.
8. Information Security Measures
8.1. When processing information of data subjects, the Company takes all necessary legal, organizational, and technical measures to protect such information against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, as well as against other unlawful actions. Information security is ensured, in particular, by the following measures:
8.1.1. Adoption of internal documents defining the Company’s policy regarding the processing of data subjects’ information and regulating the rules for processing such data;
8.1.2. Implementation of legal, organizational, and technical measures to ensure the security of data subjects’ information when processing it in the Company’s information systems, including, in particular:
mechanisms for restoring data modified or destroyed as a result of unauthorized access;
access control mechanisms and established rules for access to data processed in the Company’s information systems;
logging and registration of events related to data processing;
antivirus protection measures;
use of firewall and network security systems;
use of secure data transmission protocols and data encryption.
9. Rights of Data Subjects
9.1. Data subjects have the right to:
1. receive information about the composition and content of the processed data;
2. request updating, correction or deletion of the data;
3. withdraw consent to data processing;
4. file complaints regarding data processing;
5. exercise other rights provided by the legislation;
6. provide an email address for submitting requests and specify the timeframe for requestconsideration;
7. update their personal data;
8. withdraw consent to data processing.
10. Access to the Policy
10.1. The current version of the Policy is available in the Application and on the Official Website: https://corline.im/legal/
10.2. The Policy may be amended by the Company unilaterally.
Notifications about changes to the Policyterms shall be published in the new version of the Application and/or on the Official Website.
Suchchanges shall enter into force as of the date of their publication, unless otherwise specified in therelevant notice.
In case of discrepancies between the versions of the Policy in the Application and on the Official Website:
for the Application User, the version provided in the Application shall prevail;
for the Website User, Website Visitor, and Newsletter Subscriber, the version published on the OfficialWebsite shall prevail.