This Privacy Policy applies to all users of the Company's information systems and applications (Products).

Users explicitly agree to the processing of their personal data as described in this Policy. Processing includes any operation with personal data, regardless of the means and procedures used, including collection, recording, systematization, accumulation, storage, clarification, updating, modification, and extraction of personal data, as well as their use, transmission, distribution, provision, access, blocking, deletion, and destruction.

The service is provided by "638mm." The Company is the data controller responsible for the purposes of processing users' personal data and may transfer personal data or delegate their processing to any affiliated companies in accordance with the law.

Collection of personal data

In order to provide its Products, the Company requires information about users' contact details. The Company requests the minimum amount of information from users to maintain communication with them:

• User's name,

• Mobile phone number,

• Email address.

During the order processing, the Company may collect and store the following personal information, including personal data:

• Address and other contact information (depending on the Products used); when paying through the service, financial information such as credit card numbers and bank account information;

• Messages sent using the Products and messages sent to the Company;

• Other information about the user's interaction with the Company's information systems and its partners, including information about online user actions, results of collecting application statistics, and publicly available information about the programs and devices used to access them, including geolocation data.

The Company processes your personal data for the purpose of fulfilling the contract between you and the Company. Users have the right to send requests regarding the processing, deletion, and clarification of personal data, as well as inappropriate content, to the address [email protected].

Use

The main purpose of the Company in collecting personal data is to provide users with safe and effective Products. Users agree that the Company may also use their personal data for:

• Providing services and customer support upon users' request,

• Performing agreements with users,

• Resolving disputes, collecting feedback, and identifying malfunctions,

• Customizing, analyzing, and improving services, informational content, and advertising of the Products,

• Informing users about Products, targeted marketing, service updates, and promotional offers based on users' preferences,

• Comparing personal data to confirm their accuracy and verifying them by third parties in cases provided by law.

Marketing

The company does not sell or provide users' personal data to third parties for marketing purposes. The company may combine anonymized data with other information obtained from third parties to improve and personalize services, content, and advertising.

The company may also disclose users' personal data to:

Service providers who assist in providing products (e.g., fraud investigation, payment collection, customer service, consulting services) as agreed upon in the agreements.

Law enforcement agencies, government authorities, or third parties in response to information requests related to criminal investigations, illegal activities, or any activities that may result in the company or its users being held liable.

Respecting users' personal information, the company will not disclose personal data to any party, including authorized government agencies, without a legally compliant request.

Location Information

When using the "638mm" application with user permission, the company may collect and store device location information in the background. This information is solely used to improve order matching algorithms and enhance product efficiency. Data collection and storage comply with applicable personal data legislation.

Security

Users' personal data is stored in the company's information systems and protected through various means (encryption, passwords, restricted access for affiliated companies, employees, and contractors, physical security, etc.) to prevent unauthorized access and disclosure.

The use, transfer, distribution, provision, access, blocking, deletion, and destruction of users' personal data are carried out solely based on decisions made by authorized representatives of the company in accordance with applicable legislation and the legitimate interests of users.

The company does not make decisions affecting users' rights and legitimate interests solely based on automated processing of personal data, except when providing information in response to a user-initiated request using automated systems.

For legally significant decisions, interactions with users by third parties at the company's request, and in compliance with user agreements or user requests, non-automated processing of personal data is carried out to the extent required for such interactions and in accordance with security requirements for other non-processed data.

Prohibitions and Restrictions

Users agree:

Not to use the service and/or other company products for criminal activities, disclosure of information classified as state secrets or other legally protected secrets, dissemination of materials (including images, comments, reviews, etc.) containing public appeals for terrorism or public justification of terrorism, other extremist materials, as well as materials promoting pornography, violence, and cruelty, containing profanity, offensive, indecent content, promoting violence, extremist views, discrimination, incitement of religious, racial, political, or ethnic hatred, violating the rights of authors or right holders, containing personal data of other users without their consent, and any other user-generated content prohibited by law or infringing upon the rights and interests of third parties.

Not to distribute information using the service and/or other company products to defame individuals or specific categories of citizens based on gender, age, race, national origin, language, religion, profession, place of residence and work, as well as their political beliefs.

To comply with prohibitions and restrictions, respect the rights and legitimate interests of citizens and organizations, including the honor, dignity, and business reputation of individuals and the business reputation of organizations when using the service and/or other company products.

Third Parties

Unless otherwise specified in this Policy, this document applies only to the company's use of personal data provided by users. If users disclose their personal data to other individuals (e.g., at the request of specialists or third-party agents), different rules may apply to such use and disclosure of personal data. The company advises users to clarify the purposes of use before providing their personal data to others.

Changes

The company continuously improves its methods of data collection, storage, and processing, including security measures. Therefore, and in the event of changes in personal data legislation, the company may modify.