Effective date: October 2, 2020
This Policy is an integral part of the Spotsmap.com Terms of Service (hereinafter referred to as the Terms). When applying this Policy, the definitions provided for, including, but not exclusively, section 1 of the Terms are used.
1. Scope of the Policy
1.2.When you use the Platform, Spotsmap.com protects and processes your Personal Data in strict accordance with applicable law.
2. Personal Data Processing Organization
2.1.To ensure your use of the Platform, Spotsmap.com collects and uses Personal Data, namely Private entrepreneur Kozlov Arseny Anatolyevich, TIN 590583743542, registration address of the Russian Federation, Perm, Dzerzhinsky district.
3. List of collected Personal Data
3.1.Personal data collected as you access the Platform may vary depending on whether you use your Account to access the Platform or not.
3.2.Spotsmap.com requests and collects the following Personal Data when you use the Platform. We need this information to ensure that the Platform can be used and that it is compliant with the law. Without this information, it may not be possible to provide some services.
(i)Registration information. When signing up for an account, we request certain information, including your name, surname, email address and date of birth.
(ii)Profile Information and Ads. To use some Platform features (such as booking or creating an ad) you may need to provide additional information, including address, phone number, and profile image.
(iii)Identity Verification Information. To ensure security and mutual trust, we may collect information to verify identity (including an image of a government issued ID, passport, national ID or driver's license, if permitted by applicable law) or other identification information.
(iv)Payment Information When you use some of the Platform's features, we may require you to provide certain payment information (such as bank account or card information) to ensure that payments are processed if Spotsmap.com processes them on behalf of the School. If you are a School, Spotsmap.com may request information to verify your identity (including an image of a government issued ID, passport, national ID or driver's license), as well as other identification information, your date of birth, address, email address, phone number and other information to verify your identity and to comply with legal requirements.
(v)Interaction with Spotsmap.com and other Users. When you communicate with Spotsmap.com or use the Platform to communicate with other Users, we collect information about your communication, as well as other information that you provide.
3.3.You may provide us with other Personal Data in order to improve your interaction with the Platform. The processing of such data is based on our legitimate interest or, where applicable, with your consent.
3.4.You can voluntarily provide us with other information for posting in your profile on Spotsmap.com, including gender, preferred languages of communication, city and story about yourself, as well as other information when filling out forms and surveys, updating or adding information to your Account, sending messages to community forums, participating in promotions, when interacting with the technical support team. Depending on your Account settings, some information may be displayed on the public profile page.
3.5.When you use the Platform, we automatically collect Personal Data about the services you use and how you use them, including:
Location Information. When you use certain features of the Platform, we may collect information about your exact or approximate location, including by IP address or GPS data on your mobile device, in order to improve the quality of the service. Most mobile devices allow you to control or disable location features for apps in the settings menu. If the transfer of location information from your device is enabled, Spotsmap.com may also collect such information even when you are not using the application.
Usage Statistics. We collect information about your interaction with the Platform, in particular information about the pages or content you have viewed, requests made when searching for Services, Bookings created, and other actions on the Platform.
Log Data and Device Information. We automatically collect event log data and device information when you use or access the Platform, even if you have not registered an Account or are not logged into your Account. In particular, we collect the following information: information about how you used the Platform (including the facts of clicking on links to third-party applications), IP address, time of access, information about software and hardware, information about the device, information about device events, unique identifiers, crash information, cookie data, and information about the pages that you viewed before or after using the Platform.
Information about payment transactions. In the case of making payments through Spotsmap.com, as provided by the Terms and Conditions, Spotsmap.com collects information about your payment transactions on the Platform, including information about the used means, date, time and amount of payment, expiration date of the payment method, billing address index, email address, IBAN code, your address and other information.
4. Legal basis and purposes of processing Personal Data
4.1.Due to the restriction established by applicable law in relation to the processing of Personal Data without sufficient legal basis, Spotsmap.com processes Personal Data only in the following cases:
(i)Processing is required to meet Spotsmap.com's obligations to you, including ensuring the Platform operation.
(ii)Processing is necessary to comply with statutory obligations.
(iii)When required by applicable law, processing is necessary to ensure Spotsmap.com's legitimate interests in the event that such processing does not have a significant impact on your interests, fundamental rights, and freedoms. Spotsmap.com processes Personal Data to ensure its legitimate interests, for example, in the following cases:
(a) to better understand how you interact with the Platform;
(b) to improve, change, personalize or otherwise improve the Platform;
(c) to show you ads that take into account your interests;
(iv)For specific purposes or in accordance with applicable law, we may request your specific consent to process your Personal Data. For jurisdictions where consent is recognized as a separate legal basis, the beginning of your use of the Platform represents your consent to such processing. We hereby inform you and you confirm that you have no obligation to provide us with any Personal Data when using the Platform and it is based solely on your free will. However, you understand that without providing Personal Data, we will not be able to provide you with the opportunity to use the Platform.
4.2.Spotsmap.com processes Personal Data for the following purposes:
(i)providing access to the Platform (including providing search results in response to your search queries, taking into account your preferences, search history and other Personal Data available to us);
(ii)enabling you to communicate with other Users;
(iii)ensuring the functioning, protection, improvement and optimization of the Platform and the user interface, including through the analysis of information and research;
(iv)providing access to the Account in case of registration thereof;
(v)communicating with you to send you notifications, requests and information related to the operation of the Platform, and to process your requests and applications, including in relation to the status of the Booking;
(vi)personalization of advertisements and offers based on your preferences, search history and other Personal data about you available to Spotsmap.com;
(vii)improving the usability of the Platform, including for showing the most relevant search results;
(viii)protection of the rights of Users and Spotsmap.com;
(x)sending you technical messages, support messages, updates, security alerts, and Account notifications;
(xi)collection, processing, and presentation of statistical data, big data, and other research.
(xii)detection and prevention of fraud, spam, misuse of the system, unlawful encroachments and other malicious activities;
4.3.In most cases, Personal Data is processed automatically without access to it by any of Spotsmap.com employees. If such access is required, it can be provided only to those Spotsmap.com employees who need it to complete their tasks. To protect and ensure the confidentiality of data, all employees must comply with internal policies and procedures regarding the processing of Personal Data. They must also follow all technical and organizational security measures in place to protect your Personal Data.
5. Transfer of Personal Data to third parties
5.1.Spotsmap.com may transfer Personal Data to third parties to achieve the objectives specified in section 4 of this Policy. Please note that the level of protection of Personal Data in some countries may not match the level established in your jurisdiction, and by using the Platform, you consent to such transfer.
These third parties may include:
(i)owners of sites and applications, advertising networks, and other partners providing Spotsmap.com services related to the placement and display of advertisements on sites, programs, products or services that are owned or controlled by such persons. Where permitted by applicable law, we may use certain Personal Information, including, but not limited to, your email address, hash it and transmit it to social media platforms such as Facebook or Google to generate leads, increase traffic to our website or to advertise our products and services on the Platform in other ways. You can ask Spotsmap.com at any time to stop working with your data for direct marketing purposes by writing a corresponding statement to the email address: hello@Spotsmap.com;
(ii)advertisers or other partners who display advertisements for you on the Platform, as well as information service providers or consultants.
(iii)third parties to whom the assignment of rights or obligations has been made, or novation under the relevant agreement;
(iv)any national and / or international regulatory body, law enforcement agencies, central or local executive authorities, other official or state bodies or courts in respect of which Spotsmap.com is obliged to provide information in accordance with applicable law upon request;
(v)third parties, if you have consented to the transfer of your Personal Data or the transfer of Personal Data is required to provide you with the appropriate Service or to fulfill a specific agreement or contract concluded with you;
(vi)any third party in order to provide legal protection for Spotsmap.com or third parties in case of violation by you of the Terms or this Policy or in a situation where there is a threat of such violation.
5.2.In addition, Spotsmap.com may transfer Personal Data between users to facilitate bookings and other interactions, if necessary for our adequate performance of the Terms.
5.3.In particular, when you submit a Booking request, certain information about you is shared with the School, including your profile, your full name, information about your cancellation history, and other information you agree to provide. After confirming your Booking, we will provide the School with additional information, in particular your telephone number.
5.4.In turn, upon confirmation of the Booking by the School, we will share certain information with the Student, including the profile of the School, the full name / name of the School, the telephone number and address of the School or the location of the Services.
5.5.We do not share your billing and payment information with other Users.
6. Place of storage and processing of Personal data
6.1.Your Personal Data will be stored in the Russian Federation and/or the EEA.
6.2.For Russian users: Spotsmap.com records, systematizes, accumulates, stores, clarifies (updates, changes), extracts personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.
6.3.For users in the EEA, Switzerland or Israel: Russia is a jurisdiction outside the European Economic Area, which wasn not recognized by the European Commission as providing an adequate level of personal data protection. Therefore, Spotsmap.com has taken appropriate measures to ensure that such transfers are carried out in accordance with the applicable EU data protection regulations.
6.4.In particular, Spotsmap.com is guided by the Standard Contractual Clauses approved by the European Commission to ensure an adequate level of protection for your Personal Data transferred to Russia. A copy of these Standard Contractual Clauses is available upon request.
6.5.If you are located in a territory where your consent is required to transfer your Personal Data to another jurisdiction, then by using the Platform, you give Spotsmap.com your explicit and unambiguous consent to such transfer or storage and / or processing of information in other specified jurisdictions, including Russia.
7. Personal Data Storage Period
7.1.Personal data is stored by Spotsmap.com for as long as it is necessary to achieve the purpose for which it was collected, or to comply with the requirements of laws and regulations.
7.2.If you want any Personal Data to be deleted from the Platform, you can independently delete the necessary Personal Data using your Account or through the Platform interface (if applicable), or withdraw your consent by sending a relevant statement by e-mail hello@Spotsmap.com.
8. Users' rights in relation to the collected Personal Data
8.1.You can exercise any of the rights provided for by applicable law and described in this section.
8.2.You have the right to access your Personal Data and change it through your Account settings. You are responsible for keeping your Personal Data up to date.
8.3.You have the right to demand from us to correct incorrect or incomplete Personal Data if you cannot independently change it in your Account.
8.4.The laws of some jurisdictions may grant you the right to request certain copies of the Personal Data we hold about you. We may also be required by law to provide a copy of Personal Data in a standard, structured and machine-readable form and / or, if technically feasible, transfer this information to another service provider.
8.5.If we process your Personal Data on the basis of your consent, you can withdraw your consent to the processing of Personal Data at any time by changing your Account settings or by sending Spotsmap.com a corresponding statement by e-mail to hello@Spotsmap.com. Please note that the fact of withdrawal of consent does not affect the legality of the permitted data processing actions performed before the withdrawal.
8.6.The laws of some jurisdictions may give you the right to require Spotsmap.com not to use your Personal Data for certain purposes (including profiling), even if such use is lawful. If you object to such use, Spotsmap.com will stop using Personal Data for these purposes, provided that we cannot provide compelling legal evidence of the need for such use, and also provided that such use is necessary to raise claims, exercise rights or legal protection ...
8.7.Spotsmap.com will fulfill your requests in accordance with applicable law.
8.8.In cases provided for by applicable law, you may also have other rights not listed above.
8.9.To exercise the above rights, please log into your Account or, if you cannot exercise your rights on your own, contact Spotsmap.com.
9.1.Cookies are small text files placed on the device you use to access the websites that are part of the Platform. They contain information that is collected from your device and sent back to websites each time you visit them in order to remember your actions and preferences over time.
9.2.The Platform uses the following types of cookies:
(i)Strictly Necessary Cookies / Technical Cookies: These cookies are essential for the Platform to operate and to provide you with the Spotsmap.com Services; among other things, they allow Spotsmap.com to identify your hardware and software, including your browser type;
(ii)statistical / analytical cookies: these cookies allow to recognize users, count their number and collect information such as the operations you perform on the Platform, including information about the web pages you visit and the content you receive;
(iii)technical cookies: these cookies collect information about how users interact with the Platform, which allows us to identify bugs and test new features to improve the performance of the Platform;
(iv)functional cookies: these cookies enable to provide certain functions to make it easier for you to use the Platform by storing your preferences (such as language and location);
(v)(third-party) tracking / advertising cookies: These cookies collect information about users, traffic sources, pages visited and the advertisements displayed to you, as well as the one that followed you to the advertised page. They allow you to display advertisements that may interest you, based on the analysis of Personal Data collected about you. They are also used for statistical and research purposes.
9.3.Spotsmap.com 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 relevant type of cookies, but not exceeding the period necessary to achieve their purpose, after which they will be automatically removed from your system.
9.4.Personal data collected using cookies placed on your device may be transferred and available to Spotsmap.com and (or) other persons specified in section 5 of this Policy.
9.6.Spotsmap.com 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 Platform 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 Platform.
10. Updating this Policy
10.1.This Policy is subject to change. Spotsmap.com shall have the right to make changes at its sole discretion, including, but not limited to, in cases where the relevant changes are related to changes in applicable law, as well as when the relevant changes are related to changes in the Platform operation.
10.2.You will be notified of such changes. Relevant notifications may be displayed on the Platform (for example, via a pop-up window or banner) before such changes take effect, or may (but should not) be sent to you via other communication channels (for example, by email, if you have provided us your contact details).