This Policy of Personal Information Privacy (the
Policy) shall be effective regarding all information which might be obtained by the NBCO Yandex.Money LLC (the
NBCO) about the Client during their use of the Yandex.Money service and/or any site, program, product, NBCO's service (the
Use of the NBCO's Services shall imply unconditional agreement on the part of the Client with this Policy and the terms and conditions of the processing of their personal information specified herein; should the Client disagree with these terms and conditions, they ought to refrain from using the NBCO's Services.
1. Personal Information of the Clients Obtained and Processed by the NBCO
1.1. In this Policy the Client’s personal information shall be understood as:
1.1.1. Personal information which the Client provides about themselves during registration in any NBCO's Service (including creation of the E-wallet for the Client) or in the course of using the Service, including the Client’s personal details.
1.1.2 The details which are automatically conveyed to the NBCO in the course of using the Service via the software installed on the Client’s device, including IP-address, information from cookies, information about the Client’s browser (or another program by which access to the Service is achieved), time of access, and/or address of the requested page.
1.2. This Policy shall only be applicable for the NBCO Services. The NBCO shall not control and shall not be held responsible for third-party sites/services, which the Client might enter by following links accessible on the NBCO Services. The Client’s other personal information may be collected or requested on such sites, and other actions may be taken.
1.3. With the exception of the case of Identification/Simplified Identification of the Clients on the grounds and according to the rules set out in the Agreement, the NBCO shall not verify the authenticity of personal information provided by the Clients and shall not monitor their legal capability. However, the NBCO shall proceed from the assumption that the Client provides factual and sufficient personal information and shall keep said information current.
2. The Purpose of Collecting and Processing the Client’s Personal Information
2.1. The NBCO shall collect and hold only this personal information which is necessary for provision of the NBCO Services or execution of agreements and contracts with the Client, with the exception of the cases where storing of personal information for certain period is prescribed by law.
2.2. The NBCO may use the Client’s personal information for the following purposes:
2.2.1. To execute the NBCO's agreement including those for the purposes of completing identification/simplified identification of the Client, providing the Client with an e-payment mean, executing the Client's orders about transfers of funds and/or balance refunds;
2.2.2. To contact the Client including by sending notifications, requests, and information that relates to using the NBCO's Services, the rendering of services, as well as processing the Client’s requests and applications;
2.2.3. To improve the Service’s quality and ease of use, as well as to develop new services, offer the Client the personalized NBCO Services;
2.2.4. To carry out statistical and other research on the basis of depersonalized data;
2.2.5. To carry out marketing campaigns for Clients, including those for advertising offers to take a part in the campaign and receiving prizes/rewards provided by the campaign; to distribute advertising and informing materials via telecommunication networks, including telephone, fax, mobile phone, or direct contacts; to target advertising materials.
3. Conditions of Processing the Client’s Personal Information and Disclosing it to Third Parties
3.1. The NBCO shall hold the Clients’ personal information in accordance with this Policy, the conditions of rendering certain services, and the NBCO’s internal regulations.
3.2. The confidentiality of the Client’s personal information shall be ensured.
3.3. The NBCO shall have the right to disclose the Client’s personal information with third parties in the following instances:
3.3.1. When the Client expresses their agreement to said actions;
3.3.2. When disclosing information is necessary to carry out the Client’s order;
3.3.3. When disclosing information is provided for by Russian or other applicable legislation within the confines of the procedure established by the law;
3.3.4. When the disclosing of information takes place as part of the sale or other transfer of the business (in full or in part), whereupon the acquirer assumes all obligations to observe all of this Policy’s terms and conditions relating to the personal information they receive;
3.3.5. When ensuring the protection of the NBCO’s or third parties’ rights and legal interests in the case that the NBCO has sufficient reason to presume the Client is violating the conditions of the Agreement and/or the requirements of the applicable legislation.
3.5. When processing of the Client’s personal data by the NBCO is governed by the Federal Law On Personal Data.
4. Changing and Deleting of Personal Information by the Client
4.1. Altering and deleting the Client's personal information is made as stipulated by the agreement of using the corresponding NBCO's Services. Under the NBCO Services, the Client may be granted an ability to alter (update, add) or delete the information he or she provided or its part. Use of this function is regulated by the agreements applied to this NBCO's service.
4.2. By law, the NBCO may be induced to process/store the Clients personal information received in the course of the Service use. Such processing/storing is performed by the NBCO in the cases and within the terms stipulated by legislation.
5. Measures Taken for the Protection of the Clients’ Personal Information
5.1. The NBCO shall take necessary and sufficient organizational and technical measures to protect the Clients’ personal information from illegal or accidental access, destruction, changes, suspension, copying, distribution, as well as other illegal actions by third parties.
5.2. The NBCO secures and processes the Client's personal information in accordance with article 7.10. of the Standard of the Bank of Russia STO BR IBBS–1.0–2014 'Providing information security of the Russian bank system companies. General Provisions' of the Federal Law Concerning Personal Data and the Russian Government Regulation Concerning Establishing Personal Data Security Requirements when Processing Such Data under the Information Systems for Personal Data No. 1119 dated 1 November 2012.
5.3. When processing personal data, the NBCO provides its security and takes required measures to protect them from unauthorized or accidental accessing, erasing, altering, blocking, copying, and distribution, as well as from unlawful actions by treating such data as confidential and sticking up to it including via implementing additional security measures stipulated by Russian legislation, standards, and internal regulatory and administrative documents of the NBCO.
5.4. As a reference model of threat towards personal data security, the NBCO adopted the Industrial Partial Model of Threats Towards Personal Data Security in the Course of Its Processing by the Informational Systems for Personal Details of the Russian Banking System Companies from the BR IBBS Complex.
Date of publication: 7 March 2017