MyTracker Privacy Policy

1. Who we are

1.1. We are VK LLC located at 39 bldg 79, Leningradskiy prospect, Moscow, Russia, 125167 (the Company).

1.2. We are represented, for the purposes of this policy, by MGL MY.COM (CYPRUS) LIMITED of 28 Oktovriou, 365 VASHIOTIS SEAFRONT, office 402 Neapoli, 3107, Limassol, Cyprus.

2. This Privacy Policy

2.1. This Privacy Policy accessible online at https://help.mail.ru/legal/terms/mytracker/eng/privacy; sets out how we collect and use information, that we obtain through our website https://tracker.my.com/ (tracker.my.com), as well as through our software library MyTracker (SDK) that is developed to be integrated (installed) into the Licensee’s mobile applications in order to collect data on their usage ("Services") and the choices available to you in connection with our use of this information.

The use we make of the Information, including Personal Information, collected through the website and Services, including through Licensee’s products via our SDK, may vary depending on whether you are:

(i) a licensee ("Licensee"), a person or legal entity, granted with the right to use Services, including the software library MyTracker, with whom we have a contractual relationship;

(ii) a user of our Licensee’s mobile application who interacts through such mobile applications with our Services ("End User");

(iii) a visitor of our own website ("Website Visitor"), which may include Licensees as well as prospective Licensees.

This Privacy Policy should be read alongside and in addition to, our License Agreement (accessible online at https://help.mail.ru/legal/terms/mytracker/eng/LA (License Agreement) and our Cookie Policy (accessible online at https://help.mail.ru/legal/terms/mytracker/eng/cookiepolicy. In case of any contradictions between this Privacy Policy and the License Agreement, this Privacy Policy will prevail.

2.2. The Services enable our Licensees to analyze the performance of their advertising campaigns and applications, including their effectiveness, End User’s interactions with them, installations and downloads.

2.3. By making available the Services we, acting reasonably and in good faith, believe that you:
    (a) have all necessary rights to register on and use the Services;
    (b) provide true information about yourself to the extent necessary for use of the Services;
    (c) are aware of and accept this Privacy Policy.

2.4. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.

3. Information collected via Services

3.1. In order to receive the access to the use of the Services, to improve, develop and implement new features to our Services, to enhance the available Services functionality and in compliance with applicable laws, your data will be collected, stored, aggregated, organized, extracted, compared, used, and supplemented via Services. We will receive, including through Licensees’ mobile applications, and pass this data and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.

3.2. We set out in more detail the information we collect when you use our Services, why we collect and process it and the legal bases below.

	Information Collected	Purpose	Legal Basis
About Licensees Licensees are granted with the right to use Services, including the software library MyTracker by implementation the software library MyTracker into own mobile applications that enable Licensees to track the performance of their advertising campaigns and applications, including their effectiveness, by receiving and analysing the information about End User’s interactions with their mobile applications.
1	Registration information including your email and/or mobile phone number	We use this information in order to manage and administer the Services provided to you. We use this data to enable us to fulfil our obligations to you as part of the Services (e.g. in cases where you request restoration of your account). We may also use this information to inform you of any updates to the Services, including new features and functionalities.	Legitimate interests Performance of our contract with you
2	Where necessary, a copy of your identity or another document containing your name, surname, photograph, number of the principal identity document of you or your representative, payment details and another additional data, with that you may provide us, including through our support service. We may take additional verification steps where we consider reasonable in order to verify your account.	We use this data in order to identify you, verify your account and prevent abuse and infringements of your or other persons' rights. For example, we use this information to verify your identity if you lose your credentials and wish to access your account with us.	Legitimate interests Performance of our contract with you
3	Additional data you provide when you edit your profile page at https://account.my.com/profile/ or on dedicated Services profile page https://tracker.my.com/user/profile via including your first and last name, nickname, gender, date of birth, avatar picture and language preferences.	We use this information in order to provide our Services to you, to manage and administer Services and as additional information to verify your account to prevent abuse and infringements of your or other persons' rights.	Legitimate interests Performance of our contract with you
4	Log data, that is received when you access the Services, including information regarding technical interaction with the Service such as your IP address, time of registration in the Service, device type, user agent (operating system used, type of browser, country and language settings), features and functions of the Services used, the dates and times you access our Services, event information (e.g., system crashes) and other similar web log data.	We use your data for internal review in order to constantly improve the content and functions of our Services and web pages, optimizing your user experience, to understand any errors you may encounter when using the Services, to notify you of changes to the Services and to personalize the use of our Services.	Legitimate interests
5	Information that is automatically received at the time of access to the website through use of cookies, pixels, redirect links, JavaScript tags and other similar technologies.	We use this information to analyse how our website is used and to tailor content that is relevant to you. It also helps us to deliver more relevant advertisements to you on our own or third party websites. For more information on such technologies, including how to manage your cookie preferences please see our Cookie Policy.	Consent on use cookies
6	Email address and contents of a message that you may submit to our Support via email support@tracker.my.com or using the special contact form https://tracker.my.com/support/.	We use this information to communicate with you, including via email, about your account; to respond to your inquiries or complaints. We may also send you information related to our products and services, such as news, best practices or other information we think may interest you, to provide you with newsletters, special offers, and promotions, including via email, and for other marketing, advertising, and promotional purposes. Such communications will be sent to you when you have chosen to receive such communication or when we have a legitimate interest to market our products and services. In any event, you will always be able to opt-out of receiving such communications.	Legitimate interests Performance of our contract with you Consent
7	Data collected via your "Main account" on the my.com and third parties, including your social network ids, nickname and email, when you register on the Services via your social accounts.	We use this information in order to manage and administer the Services provided to you (e.g. to register and authenticate you on the Services)	Performance of our contract with you
About End Users Our Services enable our Licensees to track the performance of their advertising campaigns and application downloads, including their effectiveness, by monitoring the End User’s installations and interactions with Licensee’s applications. This data is received by Licensee’s implementation of our Services (software library MyTracker) into Licensee’s own mobile products that are being used by End Users.
1	Technical information that is received when you access the Licensees’ applications, that contains our MyTracker SDK. This refers to an End User’s device information, such as: browser type, device type and model, CPU, system language, memory, OS version, screen resolution, time stamp and zone, carrier, location, app version data, installed apps, the Internet provider the dates and times an End User accesses a Licensee's application and other similar information. This also refers to various technical identifiers that generally only identify a computer, device, browser or application. For example, IP address (which may also provide general location information), User agent, network data (MAC address, Wi-Fi and other networks devices have connected to), IDFA (identifier for advertisers), Android ID (in Android devices); Google Advertiser ID, Customer issued user ID and other similar unique technical identifiers.	We use this information to provide our Services to Licensees for tracking the performance of their applications as well as their marketing and advertising campaigns. We also use this information to better understand how individuals access and use our Services, both on an aggregated and individualized basis; to respond to their desires and preferences; to improve the products of the Company, its partners and affiliates (including targeted advertising and modelling Internet user behaviour) and for other research, analytical or statistical purposes.	Legitimate interests (data is necessary for performance of the contract with our Licensees)
2	End User’s Engagement information that is related to the Licensee’s ad campaigns and End User actions, such as: clicks on ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or Application from which such ads were displayed, installations of Licensee’s applications, and other interactions, events and actions Licensee choose to measure and analyse within their Application (e.g. app installs, launches, in-app purchases made, clicks, screens transitions, engagement time etc.). Some of this information may be collected from various advertising networks and third parties that are used by the Licensee in connection with the measurement and analysis of Licensee’s marketing campaigns and that have partnered with MyTracker ("Partners").	We use this information to provide our Services to Licensees for tracking the performance of their applications as well as their marketing and advertising campaigns. We also use this information to better understand how individuals access and use our Services, both on an aggregated and individualized basis; to respond to their desires and preferences; to improve the products of the Company, its partners and affiliates (including targeted advertising and modelling Internet user behaviour) and for other research, analytical or statistical purposes. We also use this information to tailor the content and information that we may send or display to End Users; to retarget content to Users through our Services and elsewhere; and to otherwise personalize End User’s experiences while using our Services and/or the Licensees’ mobile	Legitimate interests (data is necessary for performance of the contract with our Licensees)
About Website Visitors
1	Technical Information such as browser type, operating system, device type, IP address, country and language settings and other similar information typically received when you visit our website. This may include the referring URL that led you to our website.	We use this information to operate our website, diagnose any problems and to improve the website and your navigating experience. We also use this information to tailor the content that we may send or display to you on our website, and to otherwise personalize your experiences while using our website. We also use this information to better understand how individuals access and use our Services, both on an aggregated and individualized basis; to respond to their desires and preferences; to improve the products of the Company, its partners and affiliates (including targeted advertising and modelling Internet user behaviour) and for other research, analytical or statistical purposes.	Legitimate interests
2	Usage Information collected through your use of the website, such as webpages you access, where you clicked and other similar information related to how you have used our website. This also include web log data, such as dates and times you access our website, IP addresses, event information (e.g., web server responses, system crashes etc.)	We use this information to tailor the content that we may send or display to you on our website, and to otherwise personalize your experiences while using our website. We also use this information to better understand how individuals access and use our website, both on an aggregated and individualized basis; to respond to their desires and preferences; to improve the products of the Company, its partners and affiliates (including targeted advertising and modelling Internet user behaviour) and for other research, analytical or statistical purposes.	Legitimate interests
3	Information that is automatically received at the time of access to the website through use of cookies, pixels, redirect links, JavaScript tags and other similar technologies.	We use this information to analyse how our website is used and to tailor content that is relevant to you. It also helps us to deliver more relevant advertisements to you on our own or third party websites. For more information on such technologies, including how to manage your cookie preferences please see our Cookie Policy.	Consent on use cookies
4	Information you share voluntarily with us, such as your name and email address when you send us an email asking a question, or submit a form on our website. We will also collect any other Information that you choose to provide to us, such as the contents of a message that you submit through our website.	We use this information to communicate with you, including via email, about our Services; to respond to your inquiries or complaints.	Legitimate interests
		We may also send you information related to our products and services, such as news, best practices or other information we think may interest you, to provide you with newsletters, special offers, and promotions, including via email, and for other marketing, advertising, and promotional purposes. Such communications will be sent to you when you have chosen to receive such communication or when we have a legitimate interest to market our products and services. In any event, you will always be able to opt-out of receiving such communications.	Consent

3.3. Our legitimate interests include:

(1) maintaining and administrating the Services;

(2) providing the Services to you;

(3) improving the content of the Services;

(4) processing of the information that you choose to provide to us via email or submitting on our website or Service;

(5) preventing fraud or harm to us or to any third party, ensuring your account is adequately protected, ensuring the overall security of our network and services;

(6) compliance with any contractual, legal or regulatory obligations under any applicable law.

3.4. As part of maintaining and administrating the Services, we may use the information to analyze user activity and ensure that rules and terms of use for the Services are not violated.

3.5. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defense or exercise of legal claims.

3.6. You may withdraw your consent the collection of location data and your apps by amending your privacy settings of your mobile device.

3.7. Please note that if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to send this information to us.

3.8. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access or register or proper use the Services.

3.9. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.

4. Data sharing

4.1. We do not share or disclose your data with any third party, except for the cases described below in this section.

4.2. We may share certain data upon our Licensee’s request (e.g. to Licensee’s marketing or advertising Partners).

4.3. We may share your data with MGL MY.COM (CYPRUS) LIMITED and other our affiliates.

4.4. Sometimes we may also need to share your data with a third party in order to provide our Services to you or to administer the Services, for example, if you choose to share your data across other social media platforms.

4.5. We may use certain third-party analytical services and marketing and advertising networks to help us market our own products on our own website and on third-party websites (e.g. for remarking ads across the internet).

4.6. We may use third-party’s (HubSpot, Inc.) CRM service to perform the License Agreement, namely to automate interaction with you.

4.7. We may share certain data when legally required (e.g. court orders or other lawful requests by public authorities).

4.8. We may share certain data to respond to, or prevent, fraud or to protect the safety of the company, Licensee, End Users or the public.

4.9. As part of any merger or acquisition, in which case End User Data may be transferred to the surviving or acquiring entity.

5. International Transfers

5.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.

In particular, We may transfer your personal data (Licensees’ personal data) namely: surname, name, email address, telephone number, name, surname, legal form of the Licensee and (if You accepted the Cookie Policy) information that is automatically received at the time of access to the website through use of cookies, pixels, redirect links, JavaScript tags and other similar technologies to our partner providing us with access to the CRM system, HubSpot, Inc. (25 First Street, 2nd Floor, Cambridge, MA 02141, United States) (hereinafter referred to as "HubSpot") and its affiliates and contractors (hereinafter referred to as "Sub-Processors") for the purposes of for performance of the contract with you, namely to automate interaction with you. As part of such transfer, transfer to the following countries is possible: Australia, Ireland, Colombia, Singapore, USA, France, Germany, Sweden, Japan. The list of Sub-Processors is available on the Internet at: https://legal.hubspot.com/dpa (see “Annex 4 - List of Sub-Processors”).

5.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

6. Retention Periods

6.1. We will retain collected information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.

7. Your Rights

7.1. Under the laws of certain jurisdictions, when processing End User Data in connection with the provision of Services to a Licensee, MyTracker is deemed a ‘data processor’ while its Licensees are deemed ‘data controllers’.

7.2. Therefore, End Users should closely review the Privacy Policies of the Applications and websites they use in order to learn about the privacy practices of our Licensees.

7.3. Where MyTracker may be deemed a data controller under the laws of certain jurisdictions (e.g. in connection with certain purposes of processing of End User data, Log data or Registration Information), MyTracker shall comply with all applicable laws related to its status as a data controller and shall only use the data as described in this Privacy Policy.

7.4. We provide users with choices on how we may use information in connection with: (i) our marketing activities; and (ii) our use of cookies and similar technologies to serve your interest-based advertisements and to analyze usage of our website.

7.5. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in an every such email.

7.6. You can manage your preferences related to our use of cookies and similar technologies that we use, among other things, to provide you with targeted interest-based advertisements and to analyze your use of our website – please see our Cookie Policy for instructions.

7.7. In addition, the laws of some jurisdictions (e.g. GDPR in EU) may provide you with various rights in connection with our processing of certain information. Please note these rights may be limited in certain circumstances as provided by applicable law. Such rights may include:
(a) Right to access your personal information;

(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing;

(d) Right to request that your personal information is erased;

(e) Right to object to processing of your personal information;

(f) Right to data portability (in certain specific circumstances);

(g) Right not to be subject to an automated decision;

(h) Right to lodge a complaint with a supervisory authority.

7.8. Where MyTracker is deemed a data processor, End Users should contact our Licensees to pursue any such legal data subject rights. MyTracker will cooperate with its Licensees to support and comply with any such valid data subject rights requests.

7.9. Where MyTracker is deemed a data controller, to exercise these rights, please send your request to us at support@tracker.my.com, or in writing to: 39 bldg 79, Leningradskiy prospect, Moscow, Russia, 125167. We will aim to respond to you within 30 days from receipt of the request. We will need to verify your identity before we are able to disclose any personal data to you.

8. Protecting your information

8.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

8.2. Access to the Services is authorized using your login (email address or mobile phone number) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.

8.3. If you forget your login details, you can request us to send you an SMS or email, which will contain a restoration code.

8.4. To reduce the probability of third parties gaining unauthorized access, if you login to your account from an unusual place or aft

9. Changes to this Policy

9.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation archive. We recommend you to regularly review this page to ensure that you are always aware of our information practices and any changes to such.

10. Contact Us

10.1. If you have any questions, please send your inquiries to us, in writing to 39 bldg 79, Leningradskiy prospect, Moscow, Russia, 125167, or to support@tracker.my.com. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of the request.

10.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

10.3. The email address of our DPO is dpo@corp.my.com.

Last updated: March 2, 2022

Обновлено 6 апреля 2022 г.