Privacy Policy of the NBCO Yandex.Money LLC

This Policy of Personal Information Privacy (hereinafter referred to as Policy) shall be effective regarding all information which might be obtained by the NBCO Yandex.Money LLC (INN 7750005725, OGRN 1127711000031, located at the following address: Russian Federation, Moscow, 82 Sadovnicheskaya ulitsa, building 2, hereinafter referred to as NBCO) about the Client during their use of the Yandex.Money service and/or any website, program, product, NBCO's service (hereinafter referred to as NBCO Services).

The Policy applies only to the services of NBCO as NBCO does not control and is not responsible for the third-party websites / services that the Client can access by following the links available at the services of NBCO including the Client information processed by third parties.

All terms and definitions not defined but used in the text of the Policy are provided in the Agreement on the Transfer of Funds without Opening an Account Using the Yandex.Money Service or in other agreements on the subject of provision and use of the services of the NBCO by the Client.

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. Clients' Information 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 (text files stored in Client's browser), 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.
1.1.2.1. When viewing NBCO's websites, some impersonal statistical data about the Client is automatically being collected from cookies (text files stored in Client's browser), including:

  • type of the action performed at the website (a click, a hover, etc.);

  • date and time of action execution;

  • Page URL;

  • Referer;

  • IP (without the ability to use the IP addresses in statistics);

  • User-Agent;

  • ClientID (browser identifier for the cookie);

  • monitor resolution;

  • class of the HTML element being clicked;

  • details about the information viewed by the Client in the wallet's interface including the information about the following sections: данные об информации просматриваемой Клиентом в интерфейсе Кошелька, включая информацию в разделах: "My transactions"; "Payment for services"; "Money transfers"; "Yandex.Money cards"; "How to collect money"; "Games and services"; "Gift cards"; "Discounts and bonuses"; "Settings";

  • information about forms/applications filled out at the NBCO's website, including any error during the process of filling out.


1.1.2.2. By using the website, the Client (including website visitors) consents to the fact that the NBCO may use statistical data and cookies, except for the details on the information viewed by the Client in the following sections of the wallet's interface: "My transactions"; "Money transfers"; "Settings", for the purpose of subsequent processing by systems including Google Analytics, Yandex.Metrica, Google Firebase, Appmetrica, and may transfer it to a third party for research or work purposes, as well as for the purpose of provision of services to NBCO. Clients (including website visitors) can independently manage cookies by configuring the settings of their browser. Changes in user settings that result in cookies being blocked can lead to the inaccessibility of individual components of the NBCO's website.
1.1.3. NBCO can obtain publicly available information when the Client uses third-party resources (for example, chats/forms/social networks). This information may contain information published by the Client, for example, in the form of comments or feedback about the NBCO Services. NBCO uses such information to improve the quality of customer service.
1.1.4. NBCO may also process certain data (for example, an IP address, a user device identifier) to identify and/or prevent conditions conducive to the carrying out of transactions that violate the requirements of the law or the Contract that the Client is supposed to comply with in order to be provided with the wallet.
1.1.5. NBCO can obtain information about the Client from its counterparties. For example, when executing a contract with a counterparty, the latter may transfer to NBCO certain information that enables the counterparty in order to establish a connection between such Client and their transfer when the information related to transfer is sent to the counterparty by NBCO.
1.1.6. NBCO can obtain information in order to maintain an adequate level of security of online payments made by the Client via bank cards. The list of such information is provided in clause 3.3.2.1. of the Policy.

1.2. 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 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 a wallet, executing the Client's orders about transfers of funds and/or balance refunds;
2.2.2. Communication. 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;
2.2.6. To prevent the conditions that allow using the Wallet to perform actions contradicting the requirements of the law or the agreement in fulfillment of which the Client is provided with the Wallet.

 

3. Conditions of Processing the Client’s Personal Information and Disclosing it to Third Parties

3.1. The NBCO shall process 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 for the use of a certain service provided by the NBCO or a partner of the NBCO, including carrying out the Client’s order.
Personal information can be passed on to third parties of the following categories in particular:
3.3.2.1. Credit organizations or other organizations partaking in the process of making money transfers.
For example, in order to maintain a proper level of security of online payments made from bank cards, the Operator can transfer information established in form of a list by the security protocols of payment systems, acquiring / issuing banks, payment systems.
The transfer of information can be mandatory, for example, in regards of the information concerning user equipment such as the IP address, OS, geographic data, ID/type of equipment, used channel: browser/app, payment authorization, identification/verification, or optional, for example, in regards of the information concerning the account in the supplier's system, address match indicators, e-mail address, mobile phone number, payment amount, risk level established by the supplier, MCC.
3.3.2.2. Marketing partners and other NBCO counterparties.
(a) NBCO can provide access to some data (for example, statistics) for conducting marketing and other studies, as well as to other data allowing to provide the Client with advertising of third parties that is relevant and may be of interest to the Client;
(b) NBCO can provide access to some of the information regarding the Client’s transactions which the partner of the NBCO can use as the basis for determining whether to provide such a Client with discounts (bonuses), incentives due to the fulfillment of certain conditions set by the partner of the NBCO, as well as regarding the Bonus Account of a Client partaking in the Yandex.Money Loyalty Program, when such access can be given due to the possibility of providing the Client with additional terms of use for Privileges;
(c) NBCO might provide access to the Client's email address allowing the partner of the NBCO to transfer a fiscal or other document as provided for by the legislation of the Russian Federation;
(d) When the Client uses the services provided by the partners of the NBCO, the information about the Client might be provided to such persons to the extent and for the purposes as required to properly provide the services to the Client or to increase their ease of use, for example, in filling out registration forms thus shortening the registration process in the services provided by the partners of the NBCO.
3.3.2.3. Data storage partners.
3.3.2.4. Partners involved in ensuring the prevention of conditions conducive to the carrying out of transactions that violate the requirements of the law or the Contract that the Client is supposed to comply with in order to be provided with the wallet.
3.3.2.5. Publicly available information. \NBCO service can include forums and/or chats where Clients can exchange ideas and communicate with each other. The Client should keep in mind that by posting a message on a forum or in a chat room, they make such information publicly available online, and each post is made by the Client at their own risk.
3.3.2.6. Transfer of control. 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;
3.3.2.7. When disclosing information is provided for by Russian or other applicable legislation within the confines of the procedure established by the law;
3.3.2.8. 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.
3.3.2.9. When the Client uses Yandex LLC (OGRN: 1027700229193) and/or its affiliated parties, the Client's personal information may be transmitted to Yandex LLC (OGRN: 1027700229193) and/or its affiliated parties for its processing in accordance with Privacy Policy of Yandex LLC, which is posted at https://yandex.com/legal/confidential/.

3.4. When processing of the Client’s personal data by the NBCO is governed by the Federal Law On Personal Data and any other regulatory acts governing relations in the field of ensuring the security of personal data.

3.5.Disclosure of anonymous data. NBCO can also disclose anonymous data (i.e. information that neither directly nor indirectly reveals the Client's identity) and aggregated data (information regarding groups and categories of Clients) to its partners, and allow partners to collect anonymous and aggregated data within the framework of allowing the Clients to use particular functions of the Services that can subsequently provide NBCO with this data.

 

4. Changing and Deleting of Personal Information by the Client and Gaining Access to It

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.
4.1.1. Within the limits established by applicable law, the NBCO reports on the alteration or deletion of personal information to each recipient to whom personal information was disclosed, excluding the cases where it's impossible or requires disproportionate effort to do so.

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.

4.3. Access rights
4.3.1. In accordance with the applicable law, the Client has the right to access information obtained by the NBCO, i.e. you have the right to request information regarding: (a) the purpose of processing; (b) categories of processed data; (c) category of recipients who will receive or have received the Client's personal data; (d) time limits for keeping or criteria for determining it, as well as other information.
4.3.1.1. Unless other methods are implemented in the Wallet interface, the information (copy) may be provided by the NBCO in writing or via other means of communication.
4.3.1.2. If the NBCO has reasons to doubt the identity of the Client submitting the request in accordance with c. 4.3.1 of the Policy, the NBCO has the right to request the additional information necessary to confirm the identity of such Client.
4.3.1.3. The request for information (copy) shall be executed within one month (30 days) from the moment it is received by the NBCO. The NBCO has the right to extend this period by two months (60 days) due the complexity and number of requests. The NBCO shall inform the Client of such an extension indicating the reasons that led to such an extension.
4.3.1.4. If the request has no explicit justification, as well as in case of an excessive number of requests, the NBCO has the right to charge a reasonable fee for fulfilling the request (including administrative expenses) or refuse to execute the request. The NBCO can also refuse to provide the Client with the information about them posted in the manner provided for in c. 3.3.2.5. of the Policy.
4.3.1.5. The Client has the right to independently send the information received from the NBCO in the manner provided for in this section to another controller, and–if the NBCO has the technical capability–send it via the NBCO.

4.4. Dispute rights
4.4.1. Within the limits established by the applicable law, the Client may revoke any consent they previously gave or submit legal objections regarding the processing of their personal information. In some cases the withdrawal of consent will result in further unavailability of the services of NBCO to the Client.
4.4.2. In accordance with the applicable law, the Client has the right to file a complaint with the supervisory authority.

4.5. Use of the services of NBCO by children
4.5.1. Services of the NBCO are not intended for the use by children without the consent of a legal representative. NBCO might use the information regarding such individuals for the purposes of verifying the age and applying certain age restrictions.

 

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, 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 and any other regulatory acts governing relations in the field of ensuring the security of personal data

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.

 

6. Change in the Privacy Policy. Applicable Legislation

6.1. The NBCO shall have the right to make changes to this Privacy Policy by posting the Privacy Policy new version on https://money.yandex.ru/doc.xml?id=525698. When changes are made, the date of the latest version shall be specified in the current publication. Performing inferred actions of using any NBCO's Services by the User under the new conditions shall be considered as his or her consent with this offer.

6.2. This Policy and relations between the Client and the NBCO, arising in connection with the application of the Privacy Policy, shall be subject to Russian law and any other regulatory acts governing relations in the field of ensuring the security of personal data.

 

7. Interaction with Clients on the Processing of Personal Information

7.1. Questions and commentaries regarding the Policy can be forwarded to to the following email address: dpo@yamoney.ru

7.2. NBCO reserves the right not to answer any questions that are not related to the provisions of the Policy which does not deprive the Client of the opportunity to forward such questions to the NBCO at the addresses provided at the NBCO's website on the Internet in the “Contact information of NBCO Yandex.Money LLC” section.

 

Date of publication: 02 October 2018

Previous version of the document from 20.08.2018