Last Updated: 19.09.2018
the “Avatan – social photo editor” Photo editor (here and after –
“Photo editor”) and a User, determines an order and conditions of
using User’s Confidential Information by Administration. The Privacy
policy is a public offer in accordance with art. 437 of Russian
Federation Civil code.
1. Terms used
1.1 Photo editor – a complex of following intellectual property objects placed on the results of intellectual activity:
a) A computer program which allows User to create personal pages, to
search an information about other Users, browse their personal pages,
send private messages to other Users, to place, copy and download photos
and other content, to use other functions;
b) A database (a totality of an information and a content placed by
Administration of Photo editor and Users, including a content from
Users personal pages;
c) Computer programs (applications) or its elements, placed in the
Photo editor by Administration or by third parties with
Administration’s permission, which could be used by Users additionally
to Photo editor main functions and created for an entertainment,
education and other purposes;
d) Other intellectual property objects.
1.2 An Administration – Individual entrepreneur Ilyaev Leonid Lvovich
(State registration code 312774610900398) and individuals authorized by
Individual entrepreneur Ilyaev Leonid Lvovich, who provides functioning
and service of the Photo editor.
1.3 A User – an individual who is a member of the Photo editor and get
a right to use the Photo editor on the grounds of this Agreement.
1.4 Content – works of science, literature and art, including photos,
graphic images, design elements, texts, videos, sound recordings and
other results of intellectual activity and any other objects.
1.5 Personal information – any information relating to an identified or
identifiable natural person (‘data subject’); an identifiable natural
person is one who can be identified, directly or indirectly, in
particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or
more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.
1.6 Personal information processing – any operation or set of operations
which is performed on personal data or on sets of personal data,
whether or not by automated means, such as collection, recording,
organization, structuring, storage, adaptation or alteration, retrieval,
consultation, use, disclosure by transmission, dissemination or
otherwise making available, alignment or combination, restriction,
erasure or destruction.
and an Administration about an order and conditions of using Users
personal information by the Administration.
information could be contained in other documents regulating conditions
of Photo editor using.
accordance with art. 435 and 438 of Russian Federation Civil Code.
2.5 Actual using of the Photo editor without registration, browsing
images or personal pages of other Users also means full acceptance of
unilaterally without notification of Users, but subject to the posting
2.8 The User agrees to the processing by the Administration of his
personal information. The consent can be withdrawn by sending a notice
in writing to the location of the Administration.
3. Objectives of collecting Personal information
3.1 The Administration has a right to use User’s personal information for the following purposes:
3.1.1 User’s identification;
3.1.2 Establishing feedback with User, including sending notifications
and requests concerning the use of the Photo editor and other
3.1.3 Confirmation of the authenticity and completeness of Personal information provided by the User;
3.1.4 Processing and receipt of payments;
3.1.5 Providing the User with support in case of problems related to the using of the Photo editor;
3.1.6 Providing the User with updates of the Photo editor, special offers, newsletters and other information;
3.1.7 Implementation of promotional activities;
3.1.8 Granting of access to the User on websites of partners of the Administration;
3.1.9 Execution of agreements and contracts concluded with the User by the Administration.
4. Methods and terms of processing of Personal information
4.1 The processing of the User's personal information is carried out by
the Administration in accordance with the current legislation of the
Russian Federation, as well as the rules of GDRP for citizens of the
4.2 The Administration takes all necessary measures to protect the
User's personal data from unauthorized or accidental access,
destruction, modification, blocking, copying, distribution, as well as
from other illegal actions of third parties. Administration shall
implement appropriate technical and organizational measures to ensure
and to be able to demonstrate that processing is performed in accordance
with the current legislation of the Russian Federation, as well as the
rules of GDRP for citizens of the European Union.
4.3 The processing of the User's personal information is carried out
during the entire period of use by the User of the Photo editor until
the moment of the removal of his account or its removal by the
Administration and no more than 1 year after that, if there are no legal
grounds for the removal of personal data, by any legal means, including
information systems of personal data using automation or without using
4.4 The User agrees that the Administration has the right to transfer
personal information to third parties for the performance of the
4.5 The Administration has the right to disclose personal information of
the User only in cases established by the legislation of the Russian
Federation (including with a view to preventing and / or suppressing
illegal actions of the User).
4.6 In case of loss or disclosure of personal information, the
Administration informs the User about the loss or disclosure of personal
data, unless otherwise provided by the current legislation of the
5. Termination of Processing of Personal information
5.1. The processing of the User's personal data is terminated after the
expiration of its processing or at the request of the User. The User has
the right to withdraw consent at any time without affecting the
legality of the processing performed prior to such withdrawal of
5.2. The User has the right to at any time send an application to the
Administration to stop processing his personal data by filling out the
feedback form on the Photo editor or by sending a request in the form
of a scanned application in free form to the email address
6. Duties of the parties
6.1. User’s duties:
6.1.1 Providing information about the personal data necessary for using the Photo editor;
6.1.2 Maintaining the relevance of the information provided on personal data in case of the Personal information changing.
6.2. Administration’s duties:
6.2.2 Ensure that Personal information is kept confidential, not
disclosed without the prior written permission of the User, except as
6.2.3 Take precautions to protect the confidentiality of the User's
Personal information in accordance with the procedure normally used to
protect this kind of information in the existing business turnover.
6.2.4. In the case of a personal data breach, without undue delay and,
where feasible, not later than 72 hours after having become aware of it,
notify the personal data breach to the supervisory authority competent
and the personal data subject.
7. Responsibility of the parties
7.1 Administration of the website is not liable for losses incurred by
the User in connection with the illegal use of personal data, except as
7.2 In case of loss or disclosure of confidential information, the
Administration is not responsible if this confidential information
became public domain before its loss or disclosure, was received from a
third party until it was received by the Administration or was disclosed
with the consent of the User.
8. Final provisions
specified in clause 2.4 and 2.5 of this agreement and shall be valid
for an indefinite period.
the Administration, may be provided to the User for familiarization in
another language. In case of a discrepancy between the provisions of the
Policy in a different language, the provisions of the Russian version of
recognized in due course by a court decision that has came into force,
recognized invalid in the prescribed manner, the parties to this
possible to the manner implied by parties when applied this Privacy
resolved through negotiations using a mandatory pre-trial (claim) order.
If it is impossible to reach consent between the parties by negotiation
within 90 (ninety) calendar days (taking into account the time of mail
delivery of correspondence) from the moment of receiving a written claim
by the other party, the dispute must be referred by the interested
party to the court at the location of the Administration.
applicable laws of the Russian Federation. If the User is a citizen of
the European Union, the General Data Protection Regulation and the
relevant acts shall apply to the rules of personal data processing.
accordance with the applicable laws of the Russian Federation and