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Privacy Policy

This privacy policy for personal data (hereinafter, the “Policy”) applies to all the information which the Limited Liability Company “DALITON” and / or its affiliates may receive about a User through his or her use of any Application created by or offered by DALITON LLC.

1. Definitions

1.1. “Site” – the website located on the Internet at http://daliton.info/

1.2. “DALITON” (DALITON LLC) – a Limited Liability Company DALITON with the office at Office 119, 56 Privolnaya Str., Moscow, Russian Federation, P.C. 109431

1.3. “Application” – any software the rights to which belong to DALITON LLC.

1.4. “User” – an individual using an Application.

2. General Provisions

2.1. The purpose of this Policy is to ensure the proper protection of information about the Users, including their personal data, from unauthorized access and disclosure.

2.2. Any relations associated with collection, storage, dissemination and protection of information about the Users are governed by this Policy, other official documents of DALITON LLC and current legislation of the Russian Federation.

2.3. By downloading (running) and / or using an Application, the User agrees to the terms of this Policy, which is recognized by the User and DALITON LLC as the User’s written consent to process the User personal data.

2.4. In case of User’s disagreement with the terms of this Policy, the User must immediately stop any use of the Application and immediately uninstall the Application.

2.5. The current version of the Policy which is a public document is compiled by DALITON LLC and available to any user of the Internet by clicking the “Privacy Policy” link on the Site.

2.6. DALITON LLC shall have the right to make changes to this Policy. DALITON LLC shall notify the Users by posting a copy of the new Policy on the Website. The changes shall come into effect from the date the new Policy is published on the Site.

2.7. User Personal Data. As used herein, “Personal Data” can include the following:

- data provided by the User as required to use the Application, including without limitation first name, last mane, gender, mobile phone number and/or e-mail address;

- additional data provided by the User as requested by DALITON LLC with the purpose of fulfilling the obligations that DALITON LLC has to the Users regarding the use of an Application. DALITON LLC may, in particular, request the User to provide a copy of their identity document or any other document containing the User’s first name, last name and photo, as well as any other information which, at the discretion of DALITON LLC will be necessary and sufficient for the purpose of identifying such User and will eliminate any abuse or violation of third persons’ rights.

- any other information about the User processed by DALITON LLC.

2.8. DALITON LLC also processes other information about the Users which includes:

- any standard data, automatically received by the http server when the User uses an Application (the User IP address, the User operating system, the UDID number of the User device, the content accessed by the User etc.);

- any information obtained as a result of the User’s actions while using an Application;

- any information obtained as a result of other Users’ actions through the Applications;

-  User personal data obtained through the Applications, with the Users’ consent, necessary to run the Applications: the first name, last name, date of birth, profile picture, friends list and other data;.

- information provided by the User while using the Applications, in particular, their nickname/

3. Terms of Applications Use

3.1. DALITON LLC, while providing services in the use of the Applications and acting reasonably and in good faith, believes that the User:

- has all the necessary rights to conduct the launch and use of the Applications;

- has provided accurate information about himself or herself to the extent required to use the Application;

- is aware that any information posted as a result of the User’s use of the Applications can be made accessible to other Users of the Applications, and may be copied and distributed by such Users;

- is aware that some certain information submitted by him or her to other Users when using the Applications cannot be removed by the User;

- is familiar with this Policy, agrees with it, and assumes the User rights and responsibilities specified herein.

3.2. DALITON LLC does not verify the accuracy of the information it collects about Users.

4. Purposes of information processing

4.1. DALITON LLC processes the information about the Users, including their Personal Data, in order to fulfill the commitments of DALITON LLC to its Users regarding the use of the Application.

4.2 DALITON LLC can use User Personal data with the following purposes:

4.2.1. To perform identification of the User within the framework of agreements and contracts with DALITON LLC;

4.2.2. To provide the User with a personalized experience when using the Applications;

4.2.3. To communicate with the User, including any notifications, requests and information regarding the use of the Applications, provision of services, or to respond to the processing of requests by the User;

4.2.4. To improve the quality of the Applications and convenience of their use, as well as to develop new Applications and services; and

4.2.5. To conduct any statistical and other studies based on anonymous data.

5. Handling Personal Data


Personal data processing is guided by the following principles:

a) the lawfulness of the purposes and methods of Personal data processing and fair practices;

b) conformity of Personal data processing purposes with the purposes determined in advance and stated while requesting Personal Data, as well as the powers and authority of DALITON LLC;

c) conformity of the scope and nature of the processed Personal Data, methods of personal data processing with the purposes of personal data processing;

g) inadmissibility of combining databases containing Personal data created for disparate purposes.

5.2. Collection of Personal Data                    

The Personal data is provided to DALITON LLC only upon the User’s consent. The User's consent to provide their Personal data to DALITON LLC shall take the form of conclusive action on the first-time download of an Application into a User’s device memory.)

5.3. Storage and use of Personal Data

The User Personal data is stored exclusively in the electronic format and processed using automated systems.

5.4. Transfer of Personal Data

The User Personal data is not transferred to any third parties, except as expressly permitted by this Policy.

Provision of User Personal data when required by government bodies (local authorities) is carried out in the manner prescribed by law.

6. User rights

The User has the following right:

Upon request, a User may receive information from DALITON LLC regarding the processing of their Personal Data.

7. Measures to protect the information about the Users

DALITON LLC takes any technical, organizational and legal measures to ensure the protection of User’s Personal data from any unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other illegal activities. The description of these technical, organizational and legal measures is contained in the by-laws of DALITON LLC.

8. Policy Limitations

The provisions of this Policy do not apply to any activities or Internet resources of any third persons.

DALITON LLC shall not be held responsible for actions of third persons that obtained through the use of the Application access to such information about the User which due to the Application’s nature is available to any Internet user.

DALITON LLC recommends Users to responsibly address the issue of the amount of information they make available about themselves.

9. Users’ Enquiries

9.1. The Users can send their enquiries to DALITON LLC, including any enquiries concerning the use of their Personal data stated in paragraph 6.4 of this Policy, in writing to the following address: p/o box 10, Privolnaya str., Moscow, Russian Federation, P.C. 109431, or as an electronic document signed by a qualified electronic signature in accordance with Russian legislation, via e-mail to e-mail@daliton.info .

9.2. An enquiry sent by a User must contain the following information:

- the number of the primary identification document of the User or his or her representative;

- the date of issue and the issuing authority of the primary identification document;

- information confirming the User’s participation in relations with DALITON LLC (in particular, information about loading the Application on the User’s Device);

- a signature of the User or his or her representative

9.3. DALITON LLC shall consider and direct a response to a User’s enquiry within thirty (30) days from the date of notification.

9.4. All correspondence received by DALITON LLC from the Users (enquiries in the written or electronic form) is regarded as restricted information and is not disclosed without a written consent of the User. Personal data and other information about the User who sent the enquiry cannot be used without the User’s consent otherwise as to respond to the received enquiry or in cases expressly provided for by law.