Privacy Policy

Last updated: February 25, 2021

This Privacy Policy ("Policy", "Privacy Policy") defines the rules for processing personal information that the administration of the hedgik service ("we", "Administration") may collect about Users ("User" or "you") in connection with your use of the hedgik service ("Service"). This includes determining the types of information collected, methods of information collection, purposes, measures to ensure information protection, and the rights of the User regarding their personal information ("Personal Information"), which is understood as any information about an identified or identifiable individual who is a User of the Service under the Agreement.

By this Policy, the User gives us their consent to the processing of their Personal Information under the terms of this Privacy Policy. The User’s actions aimed at using the Service constitute unconditional acceptance of the terms of this Policy and the conditions for processing their Personal Information specified in it. We strongly encourage you to read this Policy and ensure that you fully understand and agree to it before you start using our Service. If you have not read it entirely, do not understand something, or do not accept the terms of the Policy, you should immediately stop using the Service.

The User guarantees that under the User’s jurisdiction, they have reached the legal age of capacity allowing them to independently manage their personal information (but not younger than 16 years old), or the User can confirm in the appropriate manner and form the necessary permission to manage their personal information from their legal representatives.

Please note that under applicable law, you are not required to provide us with any personal information, but providing such information is a mandatory condition for using our Service. By this, you confirm, guarantee, and agree that any information you provide to us is provided of your own free will, is specific, unambiguous, and reflects your actual desire to use your data for the purposes described in the Policy.

You can withdraw your consent to the processing of your personal information at any time, and we guarantee that the procedure for withdrawing consent will be as simple as its provision. The withdrawal of consent does not affect the legality of the processing of Personal Information based on consent before its withdrawal.

1. Collected Personal Information

1.1. In our activities, we adhere to the current legislation of the Russian Federation in the field of personal data processing, as well as the standards established by the European Council Directives on the collection and storage of personal data (GDPR).

1.2. In accordance with the principle of “data minimization,” we collect Personal Information only to the extent necessary for using the Service and achieving the purposes of its collection.

1.3. While using the Service, we collect two types of Personal Information: Personal Information and Non-Personal Information.

1.3.1. Personal Information.

This information includes individual information that identifies a specific User and that the User provides to us during Registration.

Personal information is collected by the Service when linking an account from an available social network for logging in. The Service collects the following types of information from the social network account:

Name;
Email address;
Photo.

If any of the above information is not available in the social network account, the Service does not collect that information.

1.3.2. Non-Personal Information.

Non-Personal Information is information that does not identify a specific User and is collected automatically during Registration and use of the Service.

Non-Personal Information may include:

Information collected through cookies, pixel tags, web beacons, browser analysis tools, and web server logs, as well as other similar technologies and tools;
Information about the devices used by the User to access the Service, including the type of operating system, device model, browser type, system settings (such as the language used by the User's system), geolocation data (country/region determination), the User's device time zone, and carrier;
Server logs that record the IP addresses of devices used by the User to interact with the Service, access times, the sequence of User actions within the Service, session information (including response times), and loading errors;
Information from the User's social network account (depending on the privacy settings set by the User for their social network account), which may include information about your interests and preferences;
Other non-identifying information depending on the permissions you provide.

1.4. The User accepts and agrees that in some cases, we may request additional information about the User, as well as copies of documents to confirm the provided information, and make any other requests when necessary based on reasonable assumptions and legitimate interests.

2. Methods of Collecting Personal Information

2.1. The legal basis for collecting Personal Information is the User’s consent to the collection of information.

2.2. Personal Information is collected when the User registers with the Service. Registration in the Service occurs through a social network account available for logging into the Service, and Personal Information is automatically transferred from the social network account.

2.3. Non-Personal Information is collected while you are using the Service.

3. Purposes of Collecting Personal Information

3.1. We use Personal Information for the following purposes:

3.1.1. Providing access to the Service for further use.
3.1.2. Improving the Service, enhancing usability, and configuring necessary parameters based on general or individual preferences, usage experience, or difficulties encountered by Users.
3.1.3. Providing technical support and feedback, including sending notifications, requests, and information related to the use of the Service (such as update notifications, security information, changes to our terms of use).
3.1.4. Creating aggregated statistical information, including analytics and monitoring usage trends of the Service and User actions within the Service.
3.1.5. Sending promotional emails and displaying advertisements within the Service about products, services, promotions, events, and other news that we believe will interest the User. You can opt out of receiving promotional emails by using the "unsubscribe" option provided in such messages.
3.1.6. Preventing fraud or violations of applicable laws, specifically detecting, investigating, and preventing fraudulent activities and other illegal activities, and protecting our rights and property, as well as the rights and property of other users and third parties.
3.1.7. Complying with any applicable laws.

3.2. The User’s Personal Information will not be used for purposes other than those stated above.

3.3. The User confirms that the purposes of using their Personal Information align with their interests, and consent to the processing of Personal Information, expressed by the User when starting to use the Service, is given for each purpose listed in section 3.1 of the Agreement.

4. Disclosure of Personal Information

4.1. We are committed to not disclosing the User's Personal Information to third parties, except in the following cases:

4.1.1. The User has given explicit and specific consent to disclose their Personal Information.
4.1.2. Such information transfer is necessary for the User to use the Service or to comply with the User Agreement or other mandatory documents governing the relationship between us and the User.
4.1.3. When such information transfer is necessary for the operation of the Service and its functionality (such as transfer to hosting services, communications and content delivery networks, data security and cybersecurity services, billing and payment processing services, fraud detection and prevention services, web analytics, email distribution, and Service performance monitoring), third parties (recipients of Personal Information) may receive or otherwise access the User's Personal Information, either in whole or in part, depending on the role and purpose of each party in maintaining or improving the Service’s operation. Additionally, they may only use the information for the purposes stated in this Policy.
4.1.4. The transfer of Personal Information is carried out in accordance with applicable law in response to requests from authorized entities (such as court orders and law enforcement requests), where we are required to disclose such information if we believe in good faith that the law mandates such actions.
4.1.5. There is a transfer of ownership or control of all or part of the Service to a new owner.
4.1.6. The transfer of Personal Information is carried out to protect our rights and legitimate interests or the rights and interests of third parties if the User violates this Privacy Policy or other mandatory documents governing the relationship between us and the User and applicable laws. The above cases cannot be considered unauthorized disclosure of personal information, as these actions are aimed at achieving the purposes of processing Personal Information.

4.2. We will never sell Users' Personal Information to third parties.

4.3. Information may only be transferred to third parties in strict accordance with this Privacy Policy and applicable law.

5. Storage Location and Cross-Border Transfer of Personal Information

5.1. We store and process Users' Personal Information in the territory of the Russian Federation. Personal Information is stored and processed either directly by us or with the help of third parties specializing in information storage. These parties are obligated to protect and preserve Personal Information in accordance with this Privacy Policy.

5.2. If we and the User are in different jurisdictions, by accessing or using the Services, or otherwise providing us with their Personal Information, the User agrees to the processing and cross-border transfer of their Personal Information to the country of our incorporation, the Russian Federation. We guarantee that appropriate measures will be taken to protect the User's Personal Information in accordance with this Privacy Policy and applicable law.

5.3. We strive to protect and preserve Users' Personal Information in accordance with international industry standards and will not consider any lower legal requirements than those of the User's jurisdiction.

6. Use of Tracking Technologies

6.1. We use certain monitoring and tracking technologies to maintain, ensure, and improve the ongoing performance of our Service, and to provide Users with a comfortable experience while using the Service. By default, we use several of these technologies for session and User authentication, security, saving User preferences (such as default language and settings), connection stability, monitoring the performance of our Service and marketing campaigns, as well as for providing and improving our Services.

7. User Rights

7.1. Under this Privacy Policy, each User has the following rights regarding their Personal Information:

7.1.1. Right to access their Personal Information.

To ensure this right, the Service provides a dedicated section where all Personal Information we have collected about the User is displayed. The User can access this section and view the Personal Information we currently possess. Upon the User's request, we will provide a full list of the Personal Information we have collected, the legal basis and purpose of the processing, the categories of Personal Information, a list of third parties to whom the Personal Information has been or will be disclosed, the period for which the Personal Information will be stored, as well as the measures in place to protect the Personal Information. A response will be provided within a reasonable time in accordance with applicable law.

7.1.2. Right to rectification.

The User has the right to submit a request for corrections at any time, and we will make the necessary updates within a reasonable period. Taking into account the purpose of the processing, the data subject has the right to provide incomplete Personal Information, specifying only the mandatory types of Personal Information necessary for accessing the Service.

7.1.3. Right to withdraw consent to the processing of Personal Information.

The User has the right to withdraw their consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. The Service provides the ability to withdraw consent as easily as it was granted. The User can request the deletion of their account at any time, and we will delete the account within a reasonable time after receiving such a request.

Please note that you can correct, update, or delete certain parts of your Personal Information yourself.

When Personal Information is corrected or consent is withdrawn by the User, we will notify all third parties who have access to the User's Personal Information.

7.1.4. Right to erasure ("right to be forgotten").

The User has the right to request, and we are obligated to delete, the User's Personal Information without undue delay if:

The Personal Information is no longer needed for the purposes for which it was collected;
The data subject withdraws their consent to the processing of their Personal Information, which was the basis for its collection;
The Personal Information was unlawfully processed;
The Personal Information must be erased to comply with the law.

7.1.5. Right to data portability.

The User has the right to receive their Personal Information in a structured, commonly used, and machine-readable format. To receive all Personal Information ever collected by us in a structured format, the User can send a request to our technical support service. The User also has the right to transmit their Personal Information directly from one controller to another, where technically feasible.

8. Retention Period of Personal Information

8.1. We store your Personal Information for as long as you use the Service (while your account is active), or until we no longer need this data to provide the Service, or for a longer period if required by applicable law or to resolve disputes with our Users, prevent fraud and abuse, and/or protect our legitimate interests.

9. Information Security

9.1. We hereby guarantee that we take all necessary and sufficient organizational and technical measures to protect the User's Personal Information from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, and other unlawful actions by third parties, in accordance with applicable law. In our operations, we use industry-standard security measures to protect the User's Personal Information and strive to ensure the utmost protection and confidentiality of Personal Information. Security measures are embedded by default at the structural level of the Service during its development. Security measures include firewall protection, pseudonymization, data encryption, data minimization, system resilience to failures, the ability to promptly restore access to Personal Information in the event of a physical or technical incident, physical access control to data processing centers, and control over access authorization to data. We regularly monitor our systems for potential vulnerabilities and attacks, assess the effectiveness of technical and organizational measures to ensure the security of Personal Information, and continually seek new ways and service providers to further enhance the security of our Service and protect our Users' privacy. All third parties with access to Personal Information and involved in providing the Service to the User adhere to equally strict Personal Information security measures.

9.2. However, we cannot guarantee absolute security, and we therefore urge you to exercise caution, set a strong password for your account, and avoid providing any sensitive information whose disclosure could cause significant harm.

9.3. In the event of any breach of Personal Information confidentiality, we will take all measures within our power to eliminate or minimize possible negative consequences, and will promptly notify the relevant supervisory authorities and the User, providing all available information about the breach. Such incidents are recorded in a special register of incidents, which we are required to maintain in accordance with applicable law.

9.4. A breach of Personal Information confidentiality, as referred to in this Policy, means a security breach that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to transmitted or processed Personal Information.

10. Changes and Interpretation of the Privacy Policy

10.1. This Privacy Policy, its interpretation, and any claims or disputes related to it are governed by, construed, and enforced exclusively in accordance with the laws of the Russian Federation, without regard to any principles of conflict of laws.

10.2. You hereby agree that any disputes arising from or relating to this Policy shall be subject to the exclusive jurisdiction of the courts in the Russian Federation, at our location.

10.3. We reserve the right to make changes to the Privacy Policy at any time. If we believe the changes are material (at our sole discretion and in good faith), we will notify you before the changes take effect. Otherwise, we are under no obligation to provide such notification.

10.4. We encourage you to periodically review this page to stay informed about our current Privacy Policy. Unless otherwise expressly stated, our latest version of the Privacy Policy applies to all information we have about you.

11. Interaction with Us and Responses to Your Requests

11.1. If you have any questions or notifications regarding this Privacy Policy and the use of your Personal Information, please contact us at team@hedgik.

11.2. We will respond to your request within a reasonable period of time or within the period required by applicable law.

11.3. In cases where this Policy or applicable law requires us to provide you with copies of information or any documents, we will provide them in a single copy, subject to reimbursement of the costs of making and sending such documents. If you make a request electronically, and unless you request otherwise, we will provide the response in a commonly used electronic format at our discretion.

11.4. If the User's requests are clearly unfounded or excessive, particularly due to their repetitive nature, we reserve the right to refuse to act on the request.

11.5. If we have reasonable doubts about the identity of the person making the request, we may request additional information necessary to verify the User's identity.