Torrow Technologies LLC policy on the processing

and protection of personal data of Torrow.Net Platform Users

Torrow Technologies LLC, which holds the exclusive rights to the Torrow.Net computer program (hereinafter — the “Torrow.Net Platform”) available on https://torrow.net and in the Apple, Google and Huawei app stores — the “Licensor” (hereinafter — the “Torrow.Net Administration”), manages and administers the Torrow.Net Platform.

1 Terms and definitions

1.1 Torrow.Net Platform — the “Torrow.Net” computer program, available on the website https://torrow.net (including sub-levels of the specified domain, functioning both on the date of acceptance of the User Agreement by the User and launched and put into operation during the term of the User Agreement), which is available to the User through the website or mobile applications. The Torrow.Net Platform is a set of data and commands, and generated audiovisual representations (including the graphic images and the User interface), (hereinafter — data and commands) intended to operate computers and mobile devices in order to obtain a certain result in the form of organizing the functionality of the platform. The Torrow.Net platform data and commands consists of activated and non-activated data and commands.

1.2. Activated Data and Commands — data, commands and generated audiovisual displays, the rights to which are transferred by the Licensor to the User free of charge under the terms of a simple non-exclusive license defined in the User Agreement and the Torrow.Net Platform Terms of Use.

1.3 Non-activated data and commands — data, commands and generated audiovisual displays that allow increasing the functionality of the Torrow.Net Platform. The terms and conditions for granting the User the rights to use non-activated data and commands are defined in the Public Offer, the current version of which is freely available on the Internet at: https://info.torrow.net/en/publicoffer.

1.4 Torrow.Net Administration — Torrow Technologies Limited Liability Company, Tax ID number 7810705940, Primary State Registration Number 1177847300840, a legal entity incorporated under the laws of the Russian Federation and having its registered address at: 37 Kosmonavtov Ave., apt. 346, 196211, Russian Federation.

1.5. User — an individual of legal age and capacity to enter into the User Agreement who, in accordance with this Agreement, is granted the right to use the Torrow.Net Platform on the terms and conditions of this Agreement. The User under the User Agreement is a Licensee within the meaning of Article 1235 of the Civil Code of the Russian Federation under the terms of a simple non-exclusive license.

1.6 User Agreement — the text of Agreement concluded between the Licensor and the User, which is an offer addressed to a particular User by an offer that expresses the intention of the person who made the offer (to the Licensor) to consider himself to have concluded an agreement with the recipient who will accept the offer (Article 435 of the Civil Code of the Russian Federation). The User Agreement is an open and public document, the current edition of which is available on the Internet at: https://info.torrow.net/en/useragreement.

1.7 Terms of Use — the User Agreement and any special documents governing the provision of access to the use of separate or additional functionality of the Torrow.Net Platform (including its non-activated data and commands) available on the Internet at https://info.torrow.net.

1.8. Personal Account — the User's personal account created upon registration and modified while working on the Torrow.Net Platform, that allows the User to authenticate and manage his/her personal data (change information in individual items, customize their location, visibility to other Users, notification order, search for items of other Users and perform other actions provided for by Torrow.Net Platform functionality).

1.9 Data Item — a semantic data set containing Content created by the User using the Torrow.Net Platform functions and describing the contact, note, event, calendar, service, resource, comment, review, and other Torrow.Net Platform objects.

1.10. Content — information valuable content of the Torrow.Net Data Item, including attributes of various types, texts, graphics, audio, video and other content available for viewing, modifying, reproducing and downloading, which includes the results of intellectual activity, the rights to use which may belong to the Licensor, Users or other persons.

1.11 Data Item Owner — the User who directly created the Data Item and filled it with the Content, or to whom the Data Item Owner granted ownership access, thereby granting full control of the Data Item, or who inherited ownership rights from a group Data Item (community) in accordance with the functions of the Torrow.Net Platform.

1.12. Data Item Subscriber — the User who has been granted access to the Content of the Data Item and who is represented in the Data Item with the User’s Business Card selected by him.

1.13. Public Data Item — Data Item which Content is available for viewing by all Users of the Torrow.Net Platform, and which can be found in the general search using search words or other data contained in the Content.

1.14. Personal Data Item — Data Item which access to the Content is limited to a personal list of Users of the Torrow.Net Platform, to whom the Owner of the Data Item has explicitly granted access (shared the Data Item) and which can be found through an attachment to other Data Items or a unique name given by the Owner of the Data Item.

1.15. Individual Data Item — Data Item where only the Owner of the Data Item has access to the data.

1.16. Group Data Item (group, community) — Data Item which Subscribers have, in accordance with the group settings, access to other Subscribers' Business Cards and/or access to other Data Items attached to the group.

1.17. User Business Card — Data Item of the Contact type, which contains the User's data and is tied to a Personal Account, accessible to other Users in accordance with the settings that have been selected and the User’s performed actions on the Torrow.Net Platform. The User can create several User Business Cards with different data and accessibility settings for other Users.

1.18. Personal Data — a collection of data relating directly or indirectly to an identified or identifiable individual (the subject of personal data) that can be stored in a Torrow.Net Data Item.

1.19. Personal data processing — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

1.20. Distribution of personal data — actions aimed at the disclosure of personal data to an indefinite circle of persons.

1.21. Submission of personal data — actions aimed at the disclosure of personal data to a specific person or a certain circle of persons.

2 General provisions

2.1 Purpose of the document
2.1.1 This Policy is an official document of Torrow.Net Limited Liability Company, available at the address: Volhovskiy prospekt 9, office 4.1, Volhov, Leningradskaya obl., 187402, Russian Federation (hereinafter — the Torrow.Net Administration), and defines the procedure for processing and protection of information about individuals who use the services of Torrow.Net, placed on the website https://info.torrow.net and in Apple, Google and Huawei app shops, and its services (hereinafter — Users).
2.1.2 The Torrow.Net Administration is an operator of personal data processing in accordance with the Federal Law of the Russian Federation “On Personal Data” № 152-FZ from 27.07.2006.
2.1.3 The purpose of this Policy is to ensure proper protection of information about Users, including their personal data, from unauthorized access and disclosure.
2.1.4 Relationships related to the collection, storage, distribution and protection of information about Torrow.Net Platform Users are governed by this Policy, other official documents of the Torrow.Net Administration and the applicable laws of the Russian Federation.
2.1.5 The current version of the Policy, is a public document, available to any Internet User by clicking on the link https://info.torrow.net/en/personaldata.
2.1.6 the Torrow.Net Administration has the right to make changes to this Policy. When changes to the Policy are made, the Torrow.Net Administration shall notify Users by posting the new version of the Policy at the permanent address https://info.torrow.net/en/personaldata no later than 14 days before the changes come into effect. Previous versions of the Policy are stored in the documentation archive of the Torrow.Net Administration.
2.1.7 This Policy is developed and used in accordance with the User Agreement posted at https://info.torrow.net/en/useragreement. In the event of any conflict between this Policy and other official documents of the Torrow.Net Administration, this Policy shall apply.
2.2 Consent to personal data processing
2.2.1 The User expresses his/her consent to the terms of these Terms and Conditions, the User Agreement and the Terms of Use of Torrow.Net Platform (https://info.torrow.net) by checking the box indicating his/her consent to the terms and conditions of Torrow.Net when he/she authenticates.
2.2.2 By giving the consent specified in paragraph 2.2.1 of this Policy, the User confirms that he/she is acting of his/her own free will and in his/her own interest, and that the personal data specified is accurate.
2.2.3 If the User does not agree to the terms of this Policy, use of the Torrow.Net Platform and its services shall be immediately terminated and the User shall initiate the procedure for terminating the User Agreement, which is described in the User Agreement.
2.3 Terms of Use
2.3.1 By providing the Services to use the Torrow.Net Platform and its services (hereinafter referred to as the Torrow.Net Services), the Torrow.Net Administration, acting reasonably and in good faith, believes that the User
2.3.2.1 has all necessary rights enabling him/her to register and use this Torrow.Net Platform and its services;
2.3.2.2. provides accurate information about him/herself to the extent necessary to use the Torrow.Net Services;
2.3.2.3 is aware that information on the Torrow.Net Platform and its Services, posted by the User about himself or herself or others, may become available to other Users of the Website and Internet Users, may be copied and distributed by such Users in various ways;
2.3.2.4 Acknowledges that certain types of information transferred by it to other Users may not be subsequently deleted by the User;
2.3.2.5 independently determines the mode and conditions of access to the Data Items through the relevant settings of the Torrow.Net Platform;
2.3.2.6 is familiar with these Rules, expresses his/her consent to them, and assumes the rights and obligations specified therein.
2.3.2 the Torrow.Net Administration does not verify the accuracy of the received (collected) information about Users, except when such verification is necessary for the Administration of Torrow.Net to comply with Russian legislation or obligations to the User.
2.3.3 The Administration of Torrow.Net shall take technical and organizational measures to ensure functioning of the relevant tools of the Torrow.Net Platform.
2.4 Policy Limitations
2.4.1 This policy does not apply to the actions and internet resources of third parties;
2.4.2 The Torrow.Net Administration is not responsible for the actions of third parties or malicious software that, through the use of the Internet or Torrow.Net Platform features, gain access to the User's information in accordance with the User's chosen privacy level, the consequences of using information that, due to the nature of the Torrow.Net Platform, may be accessible to any Internet User;
2.4.3 The Torrow.Net Administration recommends that Users should responsibly decide on the amount of information about themselves that they post on the Website;
2.4.4 The Torrow.Net Administration is not responsible for disclosure of the User's personal data by other Users of the platform Torrow.Net or Internet Users who have access to such data in accordance with the privacy level selected by the User;
2.4.5 When removing Data Items with personal data (or other information), the content of Data Items copied by other Users and stored in other Users' Data Items is retained.

3 Purposes of personal data processing

3.1 General provisions
3.1.1 The Torrow.Net Administration processes information about Users, including their personal data, in order to fulfil its obligations to Users regarding the use of the Torrow.Net Platform and its services (the User Agreement https://info.torrow.net/en/useragreement).
3.1.2 Pursuant to Article 6 of Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”, the Torrow.Net Administration has the right to process publicly available personal data and data required for the performance of the agreement (User Agreement) without the consent of the User. By virtue of Article 22 par. 2, sub-par.2 of the said law, the Torrow.Net Administration has the right to process personal data without notifying the competent authority for the protection of personal data subjects.
3.1.3 After the information is deleted, the Torrow.Net Platform, as a data distributor, in accordance with Article 10.1 of the Federal Law of the Russian Federation “On Information, Information Technology and Information Protection” dated 27.07.2006 No. 149-FZ, shall store some data about the User for 1 year.
3.2 Personal data storage
3.2.1 Personal data on the Users shall be stored only on electronic media and processed using automated systems, except where non-automated processing of personal data is necessary in connection with the implementation of legal requirements.
3.3 Data transfer
3.3.1 The Torrow.Net Administration shall not transfer the User's personal data to third parties, except for cases when this obligation is provided by Russian legislation. The provision of Users' personal data at the request of state authorities (local authorities, bodies of operational and investigative activities and bodies ensuring security in the Russian Federation) is carried out in the manner prescribed by law. In addition, data is transferred by court order within the framework of the applicable laws of the Russian Federation.
3.3.2 The Torrow.Net Platform can use User data in anonymized form for the purposes of improving the performance of its services, as well as for advertising purposes. For the same purposes, the Torrow.Net Administration may transfer anonymized User data to its third-party partners, whereby the Torrow.Net Administration guarantees the security of such data transfer.
3.3.3 In order to enforce the agreement between the User and the Torrow.Net Administration and to provide the User with access to the use of the functionality of the Torrow.Net Platform, the Torrow.Net Administration develops the services and products provided, develops, and implements new services and products, optimizes the quality of services and products, improves the available functionality of the Website and services. In order to ensure the implementation of these goals, the User agrees to the implementation of the Torrow.Net Administration, in compliance with applicable legislation, collecting, storing, accumulating, systematizing, extracting, comparing, using, filling (clarifying) their data, as well as receiving and transmitting to affiliated persons and partners the results of automated processing of such data using various information evaluation models, in the form of integer and/or text values and identifiers corresponding to the evaluation criteria specified in the requests, for the processing of data by the Site Administration and /or persons specified in this paragraph.
3.3.4 At the User's instruction or with the User's consent, User personal data may be transferred to third party contractors of the Torrow.Net Administration, provided that such contractors undertake to ensure the confidentiality of the information received, when using the applications.
3.3.5 Applications and extensions used by Users on the Torrow.Net Platform are hosted and maintained by third parties (developers) who act independently of the Torrow.Net Administration and do not act for or on behalf of the Torrow.Net Administration. Users must familiarize themselves with the terms of service and the personal data protection policy of such third parties (developers) before using the relevant applications.
3.3.6 The actions of such third parties (developers) are governed by separate official documents of the Torrow.Net Administration.
3.4 Destruction of personal data
3.4.1 Personal data of the User is destroyed when
3.4.1.1 if the User independently deletes Data Items that contain personal data.
3.4.1.2 if the User independently deletes his/her accounts in the Torrow.Net Platform, which is available to the User under ”My Profile” section \ ”Accounts”.
3.4.1.3 the deletion by the Torrow.Net Administration of the information posted by the User, as well as the User's personal accounts in cases stipulated by the User Agreement.
3.4.2 In case of deletion of the User's personal accounts, the Website Administration shall keep personal and other necessary data of the User on its electronic media for the period required and established by the applicable laws of the Russian Federation.

4 Composition of the information to be processed

4.1 Data to be entered by the User at the time of registration
4.1.1 Mobile phone number and/or e-mail address, name, first name, middle name, location.
4.2 Data stored by the User in the Torrow.Net Platform
4.2.1 Content of the Data Items of the Torrow.Net Platform (notes, photos, contacts, events, services) that the User creates, modifies, and deletes.
4.2.2 User's availability information (busy or free) according to the events information in the User's personal calendar. Visibility of the User's availability information to other Users is managed in the User's business card.
4.2.3 Information about the User's personal calendar events is available to other Users according to the settings in the User's business card.
4.2.4 Information obtained because of other Users' actions on the Torrow.Net Platform (in particular, feedback and ratings made on Data Items by other Users).
4.3 Data received from the User at the request of the Torrow.Net Administration
4.3.1 to perform obligations to Users arising from the User Agreement, the Torrow.Net Administration may include copies of identity documents, or other documents containing the User's name, surname, photo, and other additional information, which, at the discretion of the Torrow.Net Administration, will be necessary and sufficient to identify such User and prevent abuse and violation of third-party rights.
4.4 System Data Automatically Sent by Devices and Services
4.4.1 Data received when accessing the Torrow.Net Platform, which includes data about the hardware (devices), technological interaction (including Host IP address, User operating system type, browser type, geographic location, Internet service provider, address book data, data resulting from access to camera, microphone, etc. devices), and subsequent User activity on the Torrow.Net Platform.
4.4.2 The Torrow.Net Platform uses third party services that may collect information used to identify the User. Links to the privacy policies of third-party service providers used by the Torrow.Net Platform:
4.4.2.1 Google — https://policies.google.com/privacy?hl=ru
4.4.2.2 Yandex — https://yandex.ru/legal/confidential
4.4.3 By using the Torrow.Net Platform you consent to the collection and processing of data specified by third party services. If you do not agree to this, please do not use the Torrow.Net Platform.
4.5 Log Data
4.5.1 Information containing the history of the User's visit to the Torrow.Net Platform.
4.5.2 Information resulting from the User's actions on the Torrow.Net Platform (in particular information about creating and deleting Data Items, access requests and access confirmations sent, participation in events, etc.).
4.6 Payment data
4.6.1 Financial transaction information (date and time of payment, payment method, transaction ID, amount) is stored in the Torrow.Net Platform when a User makes a payment using the Torrow.Net Platform services.
4.6.1.1 The Torrow.Net Platform does not collect or store bank card details.
4.7 Cookies
4.7.1 When using the Torrow.Net Platform, the mobile application or program (such as the Internet Explorer web browser, Google Chrome, etc.) used by the User may transmit a small piece of data that is stored on the User's device (computer, tablet, etc.). Such a piece of data is usually called a cookie. A cookie allows the User to remember that the User has already accessed the website, and re-authorization from the same device with the same raw data (IP address) is not required.
4.7.2 Cookies are stored on the User's technical device (computer, laptop etc.).
4.7.3 For purposes of improving the Torrow.Net Platform and for promotional purposes, the Torrow.Net Platform may collect and process cookies from Users and transfer such cookies to its partners, whereby the Torrow.Net Administration guarantees the security and anonymity of the data in such transfers.
4.7.4 By using the Torrow.Net Platform, the User consents to the collection, processing, and transfer of cookies to third parties.
4.7.5 Torrow.Net's partners can place and read identification cookies on Users' browsers or electronically tag Users' cookies when presenting advertising material on web sites.
4.7.6 The ability to provide cookies can be disabled by the User in the settings of the browser they use to work with the Torrow.Net Platform, whereby the Torrow.Net Administration does not guarantee the correct operation of the functions.
4.7.7 Instructions on how to change Cookie’s settings in different browsers are available at the following links
4.7.7.1 Chrome https://support.google.com/chrome/answer/95647?hl=en
4.7.7.2 Firefox https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
4.7.7.3 Opera https://help.opera.com/en/latest/web-preferences/
4.7.7.4 Internet Explorer https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
4.7.7.5 Safary https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac
4.7.7. 6 Edge https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy

5 User rights and obligations

5.1 Users have the right to:
5.1.1 freely access his/her information on the Torrow.Net Platform using configured personal accounts with appropriate authentication procedures (Username and password, phone number and access code, third-party authentication services, etc.)
5.1.2 manage the disclosure of its information to other Users within the available Torrow.Net Platform functionality (setting the level of access to the Data Items, confirmation of access by other Users, transfer of the Data Item to other Users, etc.).
5.1.2.1 Management of disclosure of Data Items shall be performed taking into account the specifics of the Torrow.Net Platform architecture related to the ability of other Users to always see the title and the main image of the User Data Item (only part of the content) regardless of the level of access to the item, when the item is directly referenced or when the Data Item is found amongst the sub-items.
5.1.3 change or delete Data Items owned by them.
5.1.4 demand that the Torrow.Net Administration clarify, block, or destroy their personal data, if such data is incomplete, outdated, unreliable, illegally obtained or not necessary for the stated purpose of processing and if it is impossible to independently perform the actions provided by paragraphs. 5.1.2 and 5.1.3 hereof.
5.1.5 to request from the Torrow.Net Administration the data on him, which are processed on the Torrow.Net Platform.
5.1.6 retrieve information about when and from what devices the Torrow.Net Platform has authenticated with its account, via the “My Profile” section \ “Account” \ “Active Devices” and, if necessary, close the data access session for the device selected in the list.
5.2 The User shall:
5.2.1 Set the level of access to the Data Items created, considering the content to be entered:
5.2.1.1 open — the content of the Data Item can be found in the Torrow.Net general search and can be accessed by any Internet User (not only the Torrow.Net Platform User)
5.2.1.2 closed — the content of the Data Item can be found in the general search of the Torrow.Net Platform and can only be accessed by a User of the Torrow.Net Platform upon a separate request to the owner or manager of the Data Item.
5.2.1.3 personal — the content of the Data Item cannot be found in the general search of Torrow.Net Platform, it can be accessed by a User of Torrow.Net Platform through a separate request to the owner or manager of the Data Item.
5.2.1.4 by link — the content of the Data Item cannot be found in a general Torrow.Net search, but the content of the Data Item can be accessed by any Internet User who has a link (not only a Torrow.Net Platform User).
5.2.2 assess the risks of accidental disclosure or leakage when saving personal information on the Torrow.Net Platform and refuse to save if the consequences exceed the inconvenience of not saving information on the Torrow.Net Platform.

6 Measures to protect personal data

6.1 Purpose of personal data protection
6.1.1 The Torrow.Net Administration shall take organizational, technical, and physical measures to ensure protection of personal data of the User against unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as other unlawful actions.
6.2 Organizational security measures:
6.2.1 The Torrow.Net Administration maintains a list of employees who have access to User data to avoid the possibility of unauthorized persons accessing User data.
6.2.2 The Torrow.Net Administration strictly defines the responsibilities of employees to protect data from third parties. Each employee who has access to User data is familiar with the terms of data security and is warned of responsibility for violation of such terms.
6.2.3 The Torrow.Net Administration conducts regular audits of employees' compliance with the rules and regulations for the protection of personal data of Torrow.Net Platform Users.
6.3 Technical protection measures:
6.3.1 Torrow.Net Platform data is stored in information systems with restricted access by login and password as well as access key when connected.
6.3.2 password restrictions and automatic password complexity controls for access to information systems and databases are imposed.
6.3.3 the Torrow.Net Platform uses a mobile phone page linking system to better protect User information.
6.4 Physical security measures:
6.4.1 Separate server rooms are available for the storage of Users' personal data.
6.4.2 the security of the premises where information systems are available is arranged.
6.4.3 information is stored in cloud data centers under security.

7 User requests

7.1 Users have the right to make requests to the Torrow.Net Administration, including requests regarding the use of their personal data, as follows
7.1.1 Contact Technical Support through the “My Profile” section \ “Torrow” \ “Tech Support”.
7.1.2 In writing to the address: Volhovskiy prospekt 9, office 4.1, Volhov, Leningradskaya obl., 187402, Russian Federation
7.1.3 In the form of an electronic document signed by a qualified electronic signature in accordance with the laws of the Russian Federation, at the e-mail address: support@torrow.net;
7.2 The request sent by the User must contain the following information:
7.2.1 the number of the main identification document of the User or its representative.
7.2.2 information on the date of issue of the document and the issuing authority.
7.2.3 information confirming the User's relationship with the operator (in particular, the telephone number or name of the account used to authenticate to the Torrow.Net Platform).
7.2.4 the signature of the User or its representative.
7.2.5 a description of the problem and the desired outcome of the request.
7.3 Request procedure
7.3.1 The Torrow.Net Administration undertakes to review and respond to the received request of the User within 30 days from the receipt of the request.
7.3.2 All correspondence received by the Torrow.Net Administration from Users (requests in written or electronic form) refers to restricted information and shall not be disclosed without the written consent of the User.
7.3.3 Personal data and other information about the User who submitted the request shall not be used without the User's express consent, except to respond to the subject of the received request or in cases expressly provided by law.