Privacy Policy

Privacy Policy

Last update date: "26" April 2023

This Privacy Policy (hereinafter referred to as the "Policy") defines the approach of the Limited Liability Company "Interactive Video Technologies" ( hereinafter referred to as the "Administration") to the processing of personal data (hereinafter referred to as the "Personal Data") of users (hereinafter referred to as the "User") p when using sites https://movika.com, https://pro.movika.com, https://studio.movika.com , https://developer.movika.com , https://payments.movika.com (hereinafter – “Website”), mobile applications Movika or Movika PRO ( hereinafter referred to as “Mobile Application”) and use of the following products: Movika UGC, Movika Pro, Movika Studio and Movika SDK (hereinafter referred to as " Service " or "Movika").

The text of this document is an English translation of a document prepared in Russian.
Russian text shall prevail in the event of a discrepancy between the Russian and English texts of this document.

Limits of the Policy
This Policy applies to the processing of Personal Data in connection with the fulfillment by the Administration of obligations to ensure full access to:

to all functions of the Mobile application;
to provide access to all functionality of the Site;
to provide answers to the User's requests for technical support and other services (hereinafter referred to as "Requests");
to fulfill the appropriate legal obligations arising in cases where the User has given his consent to this.

The use of Movika services means the User's unconditional consent to this Policy and the conditions for processing Personal Data specified therein. If the User does not agree with this Policy, then he should not use Movika.
This Policy does not apply to software and mobile applications, as well as services of third-party developers or suppliers, social networks, services that can be accessed through the Mobile Application and the Site or integrated with them, as well as links to them (hereinafter referred to as "Third Party Services") . For example, when paying, the User may be redirected to the payment system website. Data processing in these cases is beyond the control of the Administration.

Such Third Party Services are independent data controllers (hereinafter referred to as the "Operator") in accordance with Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" (hereinafter referred to as the "Personal Data Law " ) and act on their own policies.
1.4. This Policy is inextricably linked to the User Agreement and the Rules for Publishing content posted on the Website and in the Mobile Application. A number of definitions not disclosed in this Policy are used in a certain meaning in the User Agreement and the Rules for Publishing Content.
1.5. In addition, by logging in to the Service using the VK ID tool, the User agrees and unconditionally accepts the Privacy Policy of the VK ecosystem, including the conditions for the transfer of Personal Data to third parties, which is posted on the link https://id.vk.com/privacy .
1.6. For the purposes of this Policy, Personal Data means any information provided by Movika relating directly or indirectly to a specific or identifiable individual (hereinafter referred to as the "Subject of Personal Data").

2. Legal grounds for the processing of Personal Data. Place of data processing

The processing of Personal Data is carried out in accordance with the requirements of the legislation of the Russian Federation.
The legal basis for the processing by the Administration of the Personal Data of Users is:

consent of the User;
conclusion, execution, modification or termination upon agreement between the User and the Administration ;
implementation of the rights and legitimate interests of the Administration or third parties, if the rights and freedoms of the User are not violated;
fulfillment of the duties assigned to the Administration by law.

The Administration ensures the processing of Personal Data using databases located on the territory of the Russian Federation .

3. Types of Personal Data that the Administration collects

The Administration, fulfilling its obligations in accordance with the Law on Personal Data , has the right to request from the User the following Personal Information: email address, login information for accessing the Services , as well as information that the User discloses in his profile, photo or video .
Facial expression data collection

For the avatar to work, Movika will use the TrueDepth API to collect facial expression data, but it will not be used for any other purpose than to make the avatar work, and the Administration will not store the data or share it with any third party.

In the process of using the Services by the User, the following information about the User is automatically transmitted to the Administration, which is not used to identify the person: the IP address of the User's device, information from Cookies, information about the User's Internet browser (or other application that is used to access the Service) ), the time of access to the Service, as well as technical information about the User’s device through which the Service is accessed (including the identification number of the device, the model of the device, the year of manufacture of the device, the software version installed on the device).
In the process of using the Services by the User, the Administration does not use photos or videos in order to identify the User.

4. Purposes of Personal Data Processing

By providing his Personal Data to the Administration, the User agrees to their processing in order to provide access to the Service, including for:

identification of the User in order to provide services ;
processing requests from Users by the support service of the Service;
sending information messages (for example, for sending information and service messages);
preventing and detecting fraud and illegal use of the Service;
analysis and research of the User's preferences in order to improve the Service;
carried out by the Administration or authorized mi by its third parties statistical and marketing research based on anonymized data;
improving the quality and ease of use, increasing the efficiency of the Service, developing new services of the Administration.

By using the Services, the User consents to the processing of his Personal Data for the purpose of sending information about Movika updates , promotions, other information related to Movika, including advertising, by e-mail .

The user can unsubscribe from this mailing at any time by following the instructions on the link in the letter or by contacting the Administration at support@movika.com with a request to remove his data from the mailing list. In this case, Movika will not attempt to contact the User until he changes his mind on this matter.
At the same time, in this case, the User undertakes to independently monitor all changes related to the operation of the Services .

The User may also be asked for Personal Data and other information by third parties, for example, when it is necessary to make a payment or add additional features using Third Party Services integrated with Movika. All Personal Data requested by third parties must be processed and stored in accordance with the User Agreement and the Privacy Policy of said third parties.
The User may transfer to the Administration certain data from third parties or the Administration may collect such data from third parties automatically when the User uses Movika. For example, the User may be given the opportunity to go through a simplified procedure for registering an account by authorizing through Third Party Services.

5. Rights of Users as Personal Data Subjects :

The subject of Personal data has the right to demand from the Administration:

clarification of his Personal Data ;
their blocking ;
destruction if the Personal Data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing.

The subject of Personal Data has the right to receive information regarding the processing of his Personal Data, including information containing:

confirmation of the fact of processing Personal data ;
legal grounds and purposes for the processing of Personal Data;
the purposes and applied methods of processing Personal data;
name and location, information about persons (except for employees of the Administration ) who have access to Personal Data or to whom Personal Data may be disclosed on the basis of an agreement or on the basis of federal law;
processed Personal data related to the relevant subject of Personal data, the source of their receipt, unless a different procedure for the provision of such data is provided by federal law;
the terms of processing of Personal data, including the terms of their storage;
the procedure for exercising with the subject of Personal Data the rights provided for by the Law on Personal Data ;
information about the performed or proposed cross-border data transfer;
the name or surname, first name, patronymic and address of the person who processes Personal Data on behalf of the Administration or another person who processes Personal Data on behalf of the Operator , if the processing is or will be entrusted to such a person;
other information provided for by the Law on Personal Data or other federal laws.

The subject of Personal data has the right to protect his rights and legitimate interests, including compensation for losses and (or) compensation for moral damage in court .
The User has the right to demand the deletion of his Personal Data if the purpose of their processing is achieved or if there are legal grounds for their deletion. The user can request the deletion of part of the data or the entire account ( hereinafter referred to as the Account). The Administration has the right not to delete Personal Data if there are legitimate and justified reasons for this, or if such deletion will affect the legitimate rights and interests of third parties. As a result of deleting the Account, the User loses access to the personal account.
The subject of Personal Data has the right to file a complaint with the supervisory authority in case of violation of his rights related to the processing of Personal Data.
also has other additional rights granted by applicable law .

6. Terms of processing , storage and protection of Users' Personal Information:

The Administration uses the Personal Information of Users solely for the purposes specified in this Policy .
The Administration undertakes to ensure the confidentiality of the Personal Information provided by the User .
The Administration will not disclose to third parties Personal Information received from Users, except at the request of authorized state and law enforcement agencies in cases provided for by applicable law and in cases where this is required for the Administration to properly fulfill its obligations and achieve the goals of processing Personal Data.
The Administration undertakes to provide all necessary technical measures to protect Users' Personal Information from unauthorized or accidental access, destruction, modification, blocking, copying and distribution.
Ensuring the security of Users' Personal Data is achieved, in particular , by implementing the following requirements by the Administration:

determination of threats to the security of the Personal Data of Users during their processing in the information systems of the Personal Data of the Administration;
application of organizational and technical measures to ensure the security of Users' Personal Data during their processing in the information systems of the Administration's Personal Data, necessary to fulfill the requirements for the protection of Personal Data, the implementation of which ensures the established levels of Personal Data security;
evaluation of the effectiveness of the measures taken by the Administration to ensure the security of the Personal Data of Users prior to the commissioning of the information system of the Personal Data of the Administration;
taking into account machine media of Users' Personal Data;
detection of facts of unauthorized access to the Personal Data of Users and taking measures, including measures to detect, prevent and eliminate the consequences of computer attacks on the information systems of the Personal Data of the Administration and to respond to computer incidents in them;
recovery of Users' Personal Data modified or destroyed due to unauthorized access to them;
establishing rules for access to the Personal Data of Users processed in the information system of the Personal Data of the Administration, as well as ensuring the registration and accounting of all actions performed with the Personal Data of Users in the information system of the Personal Data of the Administration;
control over the measures taken to ensure the security of Personal Data and the level of security of information systems of Personal Data of the Administration;
in case of loss or disclosure of Personal Data, the Administration informs the User about the loss or disclosure of Personal Data within 72 hours, the Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's Personal Data.

6. Principles and conditions of storage and processing of Personal data:

Personal data of Users collected with the help of Movika is stored and processed on the territory of the Russian Federation ;
The Administration uses all necessary reasonable measures to ensure the security of information stored and processed in the Services;
data processing is carried out on a lawful and fair basis and is limited to the achievement of specific, predetermined and legitimate purposes ;
only Personal data that meet the purposes of their processing are subject to processing ;
Since the content and scope of the processed Personal Data correspond to the stated purposes of processing, redundancy of the processed Personal Data is not allowed.

The user accepts the risks associated with the transfer of data through public communication channels without the use of cryptographic information protection tools. At the same time, the Administration uses data encryption where possible.
The Administration cannot guarantee the security of Personal Data when the security of Personal Data is beyond the control of the Administration. This also applies to Account access data, and the User is responsible for maintaining the confidentiality of this data. The user should not transfer this data to third parties, the Administration recommends that you take measures to ensure the confidentiality of this data.
The Administration applies the necessary technical and organizational measures to ensure a sufficient level of security, depending on the likelihood of any risk and the degree of threat to the rights and freedoms of the User. The administration supports these technical and organizational measures and will periodically update them to improve the overall security of the systems.
The Administration periodically includes links to the websites of partner networks, advertisers and affiliates in the mailings. If the User follows a link to any of these sites, remember that third-party sites are governed by their own data policies and that the Administration is not responsible for them. Please read these policies before submitting any information to third party sites .

7. Cookies . Push Notifications

The Administration uses cookies (hereinafter referred to as " Cookies ") to automatically collect, measure and analyze the pages the User goes to and how the User uses Movika. This is necessary to improve the user experience on the Movika service . Cookies allow us to provide certain features and functionality. By using Movika, the User agrees to the use of cookies by the Administration .
The user can disable and delete Cookies in the settings of his browser. Additional steps may be required to disable certain types of cookies . For example, due to differences in how browsers and mobile applications work, additional steps may be required to opt out of ad personalization using browser cookies and to opt out of personalized ads in the settings of the User's device or application. The User's opt-out is browser- or device-specific, so the User may need to opt-out on a browser-by-device basis. If the User chooses to disable or delete Cookies , some Movika features may stop working.
By using the Services, the User agrees to receive push notifications, which they can always disable in the application settings .

8. Period of storage of Personal data
1. The Administration stores the User's Personal Data for the period of achieving the purposes of processing, namely: for the time necessary for the provision of services, or until the receipt of the User's application for the destruction of Personal Data.
2. If the information is not necessary for the provision of services, the Administration stores it only as long as it has a legal basis for this, including when it is required to store it by law.
The Administration also stores Personal Data if, in its opinion, they are necessary or will be necessary for the presentation, execution or defense of claims.
3. Consent to the processing of Personal Data may be withdrawn by the User by sending an application for the destruction of Personal Data.
Movika undertakes to destroy Personal Data within 30 days from the date of receipt of the application, and all services to the User are automatically terminated at the moment of destruction of his Personal Data.
4. If the User revokes consent to the processing of Personal Data, Movika has the right to continue processing Personal Data without consent to processing if there are grounds specified in the legislation of the Russian Federation.

9. Usage restrictions

Movika is not intended for persons under the age of 18. By continuing to use Movika, the User confirms that he or she is over the designated age. The user is solely responsible for violation of this condition.
The Administration may set other age limits, which may be additionally indicated in legal documents or in the interface/description of the Site , Mobile Application and/or other software product.
If the User believes that the Administration could have received Personal Data from a person who has not reached the age from which he can provide independent consent to the processing or, if the consent of his legal representatives is required for the registration of such a person, the consent of legal representatives was not provided, please inform Administration, using one of the methods described in the "Contact Information" section.

10. Changes

The Administration may amend this Policy from time to time. In the event that changes are made to the Policy, the Administration will notify the User of this by updating the “last updated” date at the top of this Policy , publishing a new version of the Policy and sending any other notifications required in accordance with applicable law.
The Administration recommends that you read the Policy at least once every two weeks. In the event that the User does not agree with the changes made to the Policy, he must delete his Account and stop using Movika .

Continued use of Movika following any change to this Policy will constitute acceptance of such change.

If the User does not agree with the updated Policy, then he must stop using Movika.

11. Contact Information

The administration is: Interactive Video Technologies Limited Liability Company, an organization registered on the territory of the Russian Federation in accordance with the current legislation, TIN 1655447659, KPP 165501001, PSRN 1201600081946, location address: 420074, Kazan, st. Peterburgskaya, d. 52, office 202, email address: support@movika.com.
In order to exercise their rights and legitimate interests, the User has the right to apply to the Administration for information regarding the processing and protection of data, at the following addresses : 420074 , Kazan, st. Petersburg, d. 52, office 202 , email address: support@movika.com.
The Administration will strive to consider incoming requests as soon as possible, but in any case not more than 10 (ten) business days from the date the Administration receives the request from the User or his representative. The specified period may be extended, but not more than 5 (five) business days if the Administration sends a reasoned notice to the User, indicating the reasons for the extension of the period for providing the requested information.
The administration considers requests, provides clarifications and takes measures to protect data. The administration takes all necessary measures to eliminate possible violations, identify the perpetrators and resolve disputes out of court.