Please note that the use of any of the Sites and / or Services may be subject to additional conditions that may make changes and / or additions to this Policy, and / or have special conditions regarding personal information posted in the relevant sections of the documents for such Sites / or Services.
2. Who processes the information
To ensure your use of the Sites and Services, your Personal Information is collected and used by Howzzthat, including including the Howzzthat company, a legal entity established under the laws of the Russian Federation and registered at 119021, Russia, Moscow, ul. Leo Tolstoy, d. 16 (HOWZZTHAT LLC), or its affiliate providing the corresponding Service in other jurisdictions. You can familiarize yourself with the information about which person provides this or that Service in the conditions for using the corresponding Service.
For users located in the European Economic Area (EEA) or Switzerland, Howzzthat is represented in the EEA and Switzerland by Howzzthat Oy, a legal entity established under the laws of Finland, registered at Moreienikatu 6, 04600 Mäntsälä, Finland (Moreenikatu 6, 04600 Mäntsälä, Suomi).
For users located in Israel, Howzzthat is represented on the territory by Howzzthat.Go Israel Ltd, a legal entity established under Israeli law, registered at 148 Menachem Begin St., Tel Aviv, Israel 6492104
3. What is the purpose of this Policy
Protecting your Personal Information and your privacy is extremely important to Howzzthat. Therefore, when you use the Sites and Services, Howzzthat protects and processes your Personal Information in strict accordance with applicable law.
Following our obligations to protect your Personal Information, in this Policy we would like to inform you most transparently about the following points:
(a) why and how Howzzthat collects and uses (“processes”) your Personal Information when you use the Sites and / or Services;
(b) what is the role and responsibilities of Howzzthat as a legal entity deciding on why and how to process your Personal Information;
(c) what tools you can use to reduce the amount of Personal Information collected by Howzzthat about you;
(d) what are your rights as part of the processing of Personal Information.
4. What personal information about you collects Howzzthat
Howzzthat may collect the following categories of Personal Information about you during your use of the Sites and Services:
(i) Personal information provided by you during registration (account creation), such as your name, phone number, address and age;
(ii) electronic data (HTTP headers, IP address, cookies, web beacons / pixel tags, browser ID information, hardware and software information);
(iii) the date and time of access to the Sites and / or Services;
(iv) information about your activity during the use of the Sites and / or Services (for example, the history of search queries; the email addresses of those with whom you correspond; the content of email and attachments, as well as files stored in Howzzthat systems);
(v) geolocation information;
(vi) other information about you necessary for processing in accordance with the conditions governing the use of specific Howzzthat Sites or Services;
(vii) information about you that we receive from our Partners in accordance with the terms of the agreements concluded between you and the relevant Partner, and the agreements concluded between Howzzthat and the Partner.
Howzzthat does not collect purposefully sensitive personal information (such as racial origin, political views, health information and biometric data), except as otherwise provided in the user agreements of certain Services. Nevertheless, you can independently provide them to Howzzthat, and in this case Howzzthat will process them as part of the provision of the Services to you (for example, if you ask for searches related to your health). At the same time, you should take into account that Howzzthat cannot request your consent to such processing, since it is not aware in advance about the potentially sensitive nature of the Personal Information that you can provide to Howzzthat.
Howzzthat does not collect data for the purpose of compiling a “portrait” of the user to the extent that it can significantly affect your rights and freedoms in accordance with applicable law.
5. What is the legal basis and purpose of processing your Personal Information
Howzzthat may not process your Personal Information without sufficient legal grounds. Therefore, Howzzthat processes your Personal Information only if:
(i) processing is necessary to fulfill Howzzthat’s contractual obligations to you, including ensuring the operation of the Sites and Services (for example, providing you with search results for your search queries);
(ii) processing is necessary to comply with legal obligations
(iii) when provided for by applicable law, processing is necessary to ensure the legitimate interests of Howzzthat in the event that such processing does not significantly affect your interests, your fundamental rights and freedoms. Please note that when processing your personal information on this basis, Howzzthat will always strive to maintain a balance between its legitimate interests and the protection of your privacy.
Howzzthat processes your Personal Information to ensure its legitimate interests, for example, in the following cases:
(a) in order to better understand how you interact with our Sites and / or Services;
(b) in order to improve, change, personalize or otherwise improve the Sites and Services for the benefit of all users;
(c) in order to offer you other products and services of Howzzthat or other companies that, in our opinion, may interest you (i.e., show you an advertisement tailored to your interests);
(iv) for specific purposes or as required by applicable law, we may request your separate consent to the processing of your Personal Information. For jurisdictions where consent is recognized as a separate legal basis, your use of the Sites and / or Services by Howzzthat expresses your consent to such processing. We hereby inform you, and you confirm that you have no obligation to provide us with any Personal Information when you use the Sites or Services and is based solely on your free will. However, you acknowledge that without the provision of Personal Information, we will not be able to provide you with the opportunity to use the Services, and your use of the Sites will be limited.
Howzzthat always processes your Personal Information for specific purposes and only that Personal Information that is relevant to the achievement of such goals. In particular, we process your Personal Information for the following purposes:
(i) providing you access to the Sites and / or Services (including the provision of search results in response to your search queries taking into account your preferences, search history and other Personal information about you available to Howzzthat);
(ii) providing access to your account, including Howzzthat e-mail and file storage, if you are registered with the relevant Services;
(iii) liaising with you to send you notifications, requests and information related to the operation of the Sites and Services, fulfill agreements with you and process your requests and applications;
(iv) personalization of advertisements and offers taking into account your preferences, search history and other Personal information about you available to Howzzthat;
(v) improving the usability of the Sites and Services, including to show the most relevant search results and provide more personalized Sites and Services, as well as to improve other Howzzthat products, applications and Services;
(vi) the creation of new Howzzthat products, utilities and offers;
(vii) protect your rights and the rights of Howzzthat;
(viii) the collection, processing and presentation of statistics, big data and other studies.
Information about the processing of your data received by Howzzthat from Google LLC (1600 Amphitheater Parkway, Mountain View, California 94043, United States) in connection with your use of Howzzthat Services containing Google API technology ( https://developers.google.com/terms ) You can find the link: https://Howzzthat.com/legal/confidential_google_api .
6. How Howzzthat protects your Personal Information
In most cases, Personal Information is processed automatically without any Howzzthat employees accessing it. If such access is needed, then it can be granted only to those Howzzthat employees who need it to perform their tasks. To protect and ensure the confidentiality of data, all employees must comply with internal rules and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect your Personal Information.
Howzzthat has also implemented sufficient technical and organizational measures to protect Personal Information from unauthorized, accidental or unlawful destruction, loss, alteration, unfair use, disclosure or access, as well as other illegal forms of processing. These security measures were implemented taking into account the current level of technology, the cost of their implementation, the risks associated with the processing and nature of Personal Information.
7. Who else has access to your Personal Information and to whom it may be transferred
7.1 Within the Howzzthat Group
Howzzthat may transfer your Personal Information to its employees (within the limits specified in section 6 of this Policy). Howzzthat may also transfer your Personal Information to its affiliates, including other companies from the group of persons to which Howzzthat belongs (Howzzthat Group). Please note that the level of protection of Personal Information in some countries may not coincide with the level established in your jurisdiction, and using the Howzzthat Services, you agree to such transfer.
when you use the Services and services of the company Howzzthat Cloud Technologies LLC (PSRN: 1167746432040), your Personal Information may be transferred to Howzzthat Cloud Technologies LLC;
7.2 Outside the Howzzthat Group
Howzzthat may also transfer Personal Information to third parties outside the Howzzthat Group to achieve the goals specified in Section 5 of this Policy. Please note that the level of protection of Personal Information in some countries may not coincide with the level established in your jurisdiction, and using the Howzzthat Services, you agree to such transfer.
Such third parties may include:
(i) Partners, such as owners of sites and applications, ad networks and other partners that provide Howzzthat with services related to the placement and display of advertising on sites, programs, products or services that are owned or controlled by such partners; companies providing transportation services (taxi);
(ii) advertisers or other Partners who display advertisements for you on the Sites and / or Howzzthat Services, as well as such Partners as information service providers or consultants.
Howzzthat may also transfer Personal Information to third parties that are not members of the Howzzthat Group:
(i) to third parties in respect of which a cession of rights or obligations has been made, or novation under an appropriate agreement;
(ii) any national and / or international regulatory authority, law enforcement authorities, central or local executive authorities, other official or state bodies or courts in respect of which Howzzthat is required to provide information in accordance with applicable law upon request;
(iii) to third parties, if you have agreed to the transfer of your Personal Information or the transfer of Personal Information is required to provide you with the relevant Service or to fulfill a specific agreement or agreement concluded with you;
(iv) to any third party in order to ensure legal protection of Howzzthat or third parties in case you violate the User Agreement for Howzzthat services ( https://Howzzthat.ru/legal/rules ), this Policy or the conditions governing the use of certain Services, or in a situation, when there is a threat of such a violation.
8. Where is your Personal Information stored and processed
Your Personal Information will be stored in the Russian Federation and / or in the EEA.
For Russian users: Howzzthat carries out recording, systematization, accumulation, storage, updating (updating, changing), extracting personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.
For users from the EEA, Switzerland or Israel: Russia is a jurisdiction outside the European Economic Area that has not been recognized by the European Commission as providing an adequate level of personal data protection. Therefore, Howzzthat has taken appropriate measures to ensure that such a transfer is carried out in accordance with the applicable EU data protection rules.
In particular, Howzzthat is guided by the Standard Contractual Terms approved by the European Commission in order to ensure an adequate level of protection for your Personal Information transmitted to Russia. A copy of these Standard Contractual Conditions is available upon request.
If you are located in a territory where your consent is required to transfer your Personal Information to another jurisdiction, then using the Sites or Services, you give Howzzthat your express and unambiguous consent to such transfer or storage, and / or processing of information in other specified jurisdictions, including Russia.
9. How long do we keep your Personal Information
Howzzthat will store your Personal Information for as long as necessary to achieve the purpose for which it was collected, or to comply with legal requirements and regulations.
Unless otherwise required by law or agreement with you, emails and documents that you store in Howzzthat systems as part of the Service will be stored as long as you have an account, but they can be deleted by you at any time.
If you want any of your Personal Information to be deleted from Howzzthat databases, you can delete the necessary Personal Information yourself using your account or through the interface of the Sites and / or Services (where applicable).
10. Your rights
10.1 What rights do you have?
If this is provided for by applicable law, you have the right to access your Personal Information processed by Howzzthat in accordance with this Policy.
If you believe that any information that Howzzthat stores about you is incorrect or incomplete, you can enter your account and correct your Personal Information yourself.
If provided by applicable law, you have the right to:
- demand the removal of your Personal Information or part thereof, as well as withdraw consent to the processing of your personal information;
- require restrictions on the processing of your Personal Information;
- request a copy of the Standard Contractual Terms authorizing the transfer of your Personal Information to Russia and specified in Section 8 of this Policy;
- object to the processing of your Personal Information, if required by applicable law.
Howzzthat will fulfill these requests in accordance with applicable law.
In cases provided for by applicable law, you may also have other rights not specified above.
10.2 How you can exercise your rights
To exercise the above rights, please log in to your account, and if there is no special function in the interface, contact Howzzthat (see section 13 of this Policy).
If you are not satisfied with the way Howzzthat processes your Personal Information, please let us know and we will consider your claim. If you are not satisfied with Howzzthat’s response, you have the right to file a complaint with the competent authority.
11.1 What are cookies and why Howzzthat uses them
Cookies are small text files placed on the device that you use to access the Sites. They contain information that is collected from your device and sent back to the Sites at each subsequent visit to them in order to remember your actions and preferences after a lapse of time.
The following types of cookies are used on the Sites:
- strictly necessary cookies / technical cookies: these cookies are necessary for the operation of the Sites and the provision of Services to you; among other things, they allow Howzzthat to identify your hardware and software, including the type of your browser;
- statistical / analytical cookies: these cookies allow you to recognize users, calculate their number and collect information, such as your transactions on the Sites and Services, including information about the web pages you visit and the content that you receive;
- technical cookies: these cookies collect information about how users interact with the Sites and / or Services, which allows to detect errors and test new features to improve the performance of the Sites and Services;
- functional cookies: these cookies allow you to provide certain functions to facilitate your use of the Sites, for example, by storing your preferences (such as language and location);
- (third-party) tracking files / advertising cookies: these cookies collect information about users, traffic sources, pages visited and the ads displayed for you, as well as the one by which you clicked on the advertised page. They allow you to display ads that may interest you, based on an analysis of the Personal Information collected about you. They are also used for statistical and research purposes.
11.2 How long cookies are stored on your device
Howzzthat uses the information contained in cookies only for the above purposes, after which the collected data will be stored on your device for a period that may depend on the appropriate type of cookies, but not exceeding the time required to achieve their goal, after which they will be automatically deleted from your system.
11.3 Who else has access to the information contained in cookies
Personal information collected via cookies placed on your device may be transferred and accessible to Howzzthat and / or third parties specified in section 7 of this Policy. The use of Personal Information outside the Sites for advertising purposes, if any, may be the subject of separate user agreements available on third-party websites. Howzzthat and / or third parties may also provide you with the opportunity to opt out of the personalization of advertising, which may be subject to regulation of the law and the rules applicable to such products and offers.
Howzzthat may also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:
(i) determining your actions on the Sites and in the process of using the Services by accessing and using cookies stored on your device;
(ii) collection of statistical information related to the operation of the Sites, Services or products, utilities and offers of Howzzthat.
12. Updating this Policy
This Policy is subject to change. Howzzthat has the right to make changes at its discretion, including, but not limited to, in cases where the relevant changes are associated with changes in the applicable law, as well as when the corresponding changes are associated with changes in the operation of the Sites and Services.
Howzzthat undertakes not to make significant changes, not to impose additional burdens or restrictions on your rights established by this Policy without your notice. You will be notified of such changes. Relevant notifications can be displayed on the Site or in the Services (for example, through a pop-up window or banner) before such changes take effect, or can be sent to you through other communication channels (for example, by email, if you provided us with your Contact details).
13. Questions and suggestions
Howzzthat welcomes your questions and suggestions regarding the implementation or amendment of this Policy. Please use our feedback form at http://feedback.Howzzthat.ru . You can also use this address to send requests for the exercise of your rights or complaints regarding the incorrectness of your Personal Information or the illegality of its processing.