Xabo Network Developer Privacy
Standard Confidentiality Policy
1. Basic Terms
- 1.1. Site — site in the Internet at http://xabo.net/.
- 1.2. Developer — individual or legal entity that places an Application on the Site and uses it according to the Terms for Application Placement and Rules for Application Placement on the Site. Name, last name and patronymic or company name of the Developer and other related information are specified in "About Developer" section in the Application start window and also in Application settings.
- 1.3. Site Administration — Xabo Network LLC.
- 1.4. Application — software service placed by the Developer on the Site in "Applications" section, which had been moderated by the Site Administration and included into the application catalog.
- 1.5. User — duly registered Site user who utilizes the Application.
- 1.6. Policy — this Standard Confidentiality Policy of Application Developers for the Site.
2. General Provisions
- 2.1. This Policy is the official standard document of Developers and regulates processing and protection of information about individuals who use Applications. This Policy does not cover Developers that have published and use its own document defining policy for users' private information processing.
- 2.2. The purpose of this Policy is to ensure proper protection of information about users, including their private information, against unauthorized access and disclosure.
- 2.3. Activities related to collection, storage, distribution and protection of information about users shall be regulated by this Policy, other official documents of Developers and existing legislation.
- 2.4. Existing revision of the Policy which is a public document has been developed by the Site Administration and is available for all users in the Internet when they click "Confidentiality Policy of Application Developer" hyperlink.
- Site Administration has the right to amend the Policy. When amending the Policy, the Site Administration notifies users by publishing a new revision of the Policy on the Site at permanent address https://xabo.net/dev/uprivacy not later than 10 days prior to coming into effect of such amendments. Previous revisions of the Policy are stored in the document archive of the Site Administration.
- 2.5. This Policy has been developed and is used according to the Xabo Network Terms of Service generally accessible on the Site at http://xabo.net/policies/terms, and Rules for User Information Protection on the Site at http://xabo.net/policies/privacy.
- 2.6. When using Applications, user accepts the terms of the Policy.
- 2.7. If user does not accept the terms of this Policy, he/she shall immediately stop to use Applications.
3. Terms of Application Use
- 3.1. By provision of services for Application use, the Developer acting reasonably and in good faith considers that the user:
- — has all required rights that allow him/her to start and use Applications.
- — specifies reliable information about himself/herself in the scope required to use Applications;
- — understands that all information published as a result of Application use by the user can be available for other users of Applications, can be copied and distributed by such users;
- — understands that some kinds of information, the user rendered to other users when using Applications, cannot be deleted by user himself/herself;
- — has read this Policy, accepts it and assumes its rights and responsibilities.
- 3.2. The Developer does not check reliability of the received (collected) information about users.
4. Information Processing Purposes
The developer processes information about users including their private information in order to fulfill own obligations to users concerning Application use.
5. Composition of Information about Users
The developer processes information about users that includes:
- 5.1. Users' private information provided by the Site Administration with consent of users and required for Application use: name, last name, date of birth, profile photo, list of friends, and information the user publishes on "Edit" tab in "My Page" section on the Site;
- 5.2. Additional information about users provided by the Site Administration with consent of users, particularly: photos, status, notes, audios, videos, offers, questions, communities the user is member of;
- 5.3. Information provided by users when they utilize applications, nickname in particular.
- 5.4. Information the Developer receives as a result of users actions when they utilize Applications.
6. Users' Private Information Processing
- 6.1. Private information is processed based on the following principles:
- a) legality of purposes and means of private information processing and due care;
- b) purposes of private information processing comply with the purposes previously defined and claimed at private information collection, and also with Developers' authority;
- c) scope and nature of processed private information, methods of private information processing comply with the purposes of private information processing;
- d) databases with private information created for incompatible purposes shall not be combined.
- 6.1.1. Terms and purposes of private information processing
- The Developer processes user's private information with his/her consent in order to provide the user with services for Application use.
- 6.1.2. Private information collection
- User's private information shall be provided to the Developer by the Site Administration with user consent, according to Item 5.1 of this Policy. User consent to provide his/her private information to the Developer shall be given as implicative action when the user loads the Application onto his/her personal page for the first time.
- In case of change and/or removal of information specified in Items 5.1 and 5.2 of the Policy, the Site Administration shall notify the developer thereof.
- 6.1.3. Private information storage and use
- Users' private information shall be stored solely on electronic media and processed using automated systems.
- 6.1.4. Private information transfer
- Users' private information shall not be transferred to any third party, except of cases directly stipulated by the Policy.
- Users' private information shall be provided upon request of government authorities (local government bodies) in manner required by legislation.
- 6.1.5. Private information deletion
- User's private information shall be deleted when:
- — user himself/herself deletes information from his/her personal page on the Site;
- — user himself/herself deletes his/her personal page on the Site using "Delete my page" function in "My Settings" section;
- — user himself/herself deletes the Application from his/her personal page on the Site;
- — Site Administration deletes information published by the user and user's personal page in cases stipulated by the Xabo Network Terms of Service at http://xabo.net/policies/terms (Items 6.2.2 and 7.6).
- 6.2. Because Applications are a means of communication and relations with old and new friends, the following information can be available for other users of the Application:
- 6.2.1. name and last name of the user,
- 6.2.2. user's profile photo,
- 6.2.3. information on how the user utilizes the Application, and on user's actions when he/she utilizes the Application.
- Users with the friend status of a specific user on the Site are provided with information about the fact that such user utilizes the Application.
7. Users' Rights and Responsibilities
- 7.1. Users have the right to:
- 7.1.1. freely and free of charge access to the information about themselves by loading Applications on the Site they use;
- 7.1.2. change and correct information about themselves using functionality of user's page on the Site, assuming that such changes and corrections contain actual and reliable information;
- 7.1.3. delete information about themselves using functionality of user's personal page on the Site;
- 7.1.4. obtain information about their private information processing from the Developer upon request.
8. Means for Protection of Users' Information
The developer shall take technical, organizational and legal measures to protect user's private information against unauthorized or accidental access to it, deletion, change, block, copy, distribution and other illegal actions. Description of respective technical, organizational and legal measures can be found in local regulations of the Developer.
9. Policy Constraints
This Policy does not cover actions and Internet resources of third parties. The Developer shall not be responsible for actions of third parties that through the use of the Application gained access to information about the user when such information can be found by any Internet user due to the Site nature. The Developer recommends users to use well-thought approach when choosing private information to be accessible through the Internet.
10. Users' Requests
- 10.1. Users can request the Developer concerning use of their private information according to Item 7.1.4 of the Policy in written form at the address specified in "Settings" section of the Application or in electronic form signed with a registered electronic signature as per the legislation at the email address specified in "Settings" section of the Application.
- 10.2. User's request shall contain the following information:
- — number of the main document that certifies identity of the user or his/her representative;
- — information about when such document was issued, and authority that issued it;
- — information that proves user's relations with the Developer (particularly, information on Application load onto the personal page, nickname the user used when utilizing the Application);
- — signature of the user or his/her representative.
- 10.3. The Developer shall review and reply to user's request within 30 days from the date such request was received.
- 10.4. All correspondence the Developer receives from users (written or electronic appeals) shall be considered as limited access information and shall not be disclosed without written consent of the user. Private information and other information about the user who sent a request shall be used only for reply to the received request or in cases directly stipulated by the law, other use of such information is allowed only with user's special consent.