1. General provisions
1.1. This Personal Data Processing Policy (the "Policy") is drawn up in accordance with Federal Law of the Russian Federation No. 152-FZ "On Personal Data" and defines the position of Sole Proprietor Vladimir Leonidovich Rabchanov, OGRNIP 317470400018418, INN 471009214205 (the "Operator"), regarding the processing and protection of personal data and the rights of data subjects.
1.2. The Policy applies to all personal data that the Operator receives from data subjects using the website https://upmob.ru (the "Website"), including the user dashboard, contact forms, order placement and payment processes.
1.3. The Policy is a public document available at https://upmob.ru/en/personal-data. Details of how user data is handled on the Website are additionally described in the Privacy Policy.
2. Processing principles
2.1. The Operator processes personal data based on the principles of lawfulness and fairness; limitation of processing to specific, pre-defined and legitimate purposes; adequacy and relevance of the data to the stated purposes; accuracy and currency of the data; and storage in a form that allows identification of the subject no longer than the purposes of processing require. Upon achievement of the purposes, the data is destroyed or anonymized.
3. Purposes of processing
3.1. Personal data is processed for the following purposes:
· registration and identification of Users on the Website, providing access to the dashboard;
· conclusion and performance of service agreements for app promotion and other services offered on the Website (orders, settlements, refunds);
· handling enquiries received via contact forms, email and messengers;
· sending notifications related to the performance of the agreement (order statuses, document changes, maintenance);
· sending marketing communications — only with the subject's separate consent;
· improving the Website and service quality based on anonymized statistics;
· compliance with obligations imposed on the Operator by the laws of the Russian Federation.
4. Legal grounds
4.1. The legal grounds for processing are: the data subject's consent; the necessity to perform an agreement to which the data subject is a party — the Public Offer and the Terms of Use; compliance with legal obligations of the Operator; and the legitimate interests of the Operator, provided the rights and freedoms of data subjects are not violated.
5. Categories of data processed
5.1. The Operator processes: name (if provided); email address; messenger contact (if provided); payment details (processed by payment providers — the Operator does not store full card data); links to promotion objects (app pages, websites, accounts); automatically collected data (IP address, browser and OS information, cookies, on-site activity); order history and dashboard transactions.
5.2. Special categories of personal data and biometric data are not processed.
5.3. The Operator does not carry out cross-border transfers of personal data. Data is stored on servers located in the Russian Federation.
6. Processing procedure and retention
6.1. Processing is carried out with and without automation tools. Access to personal data is limited to persons authorized by the Operator and bound by confidentiality obligations.
6.2. Data may be shared with third parties only as described in the Privacy Policy: payment providers for settlements, technical contractors under confidentiality obligations, and state authorities upon lawful requests.
6.3. Retention periods: data related to the performance of agreements — 5 years from the last interaction; contact data — until consent is withdrawn; automatically collected data — 1 year. Upon expiry, data is destroyed or anonymized.
7. Data protection measures
7.1. The Operator applies legal, organizational and technical measures to protect personal data, including: appointment of a person responsible for data processing; internal regulations on data protection; TLS/SSL encryption; restricted and personalized access to information systems; backups and anti-virus protection; and internal compliance audits.
8. Data subject rights
8.1. A data subject has the right to: obtain information about the processing of their personal data; demand rectification, blocking or destruction of data that is incomplete, outdated, inaccurate or unlawfully obtained; withdraw consent at any time; and appeal against the Operator's actions to the supervisory authority (Roskomnadzor) or in court.
8.2. To exercise these rights, send a request to admin@upmob.ru. The Operator responds within 10 business days. Upon withdrawal of consent, the data is destroyed within 30 days, except where further processing is required by law.
9. Final provisions
9.1. The Operator may amend this Policy; the new version takes effect upon publication on the Website. Matters not covered by this Policy are governed by the laws of the Russian Federation, the Privacy Policy, the Terms of Use and the Public Offer.
10. Operator details
Sole Proprietor Vladimir Leonidovich Rabchanov
OGRNIP 317470400018418
INN 471009214205
Email for personal data requests: admin@upmob.ru