This Privacy Policy (hereinafter referred to as the "Policy") is an integral part of the User Agreement of the Luna Browser, available at – https://legal.loonaBrowser.ru/Browser-agreement.pdf , and regulates the relations between Innovative Development LLC (hereinafter - referred to as the "Company, We"), which is the copyright holder of the Luna Browser, and you (an individual on the Internet) (hereinafter - referred to as "User, You"), regarding the processing of User data, including personal data, during the use of the Luna Browser by such a person.
This Policy is available at - https://legal.loonaBrowser.ru/privacy-policy.pdf . Relations related to data processing are regulated by this Policy, other rules posted in the framework of the Luna Browser, as well as the applicable legislation. Before using the Luna Browser, the User must read this Policy, as well as all applicable rules and documents of the Luna Browser.
When registering, accessing and/or actually using the Luna Browser, the User agrees to the terms of this Policy, as well as to the terms of agreements and rules of the Luna Browser, which are posted on the pages (in sections) of the Luna Browser, in the versions that were valid at the time of actual use of the Luna Browser.
The protection of User Data Пользователей and ensuring their confidentiality are also a priorityи for the Company, so when using the Luna Browser, the Company protects and processes ДUserей Data in strict accordance with applicable law.
We protect the interests of our Users:
– openly explaining why and how Мwe use User data (including personal data).
– training and instructing our employees, regulating and restricting their access to User data;
– removing or reducing ДIndividual Users as they are no longer needed for the purposes stated in the Policy.
– responding to comments and incidents to prevent them from happening again.
2.1. The following is a list of "terms" and "definitions" that are used in this Policy.
2.1.1. Browser – a program for electronic computers "Luna Browser", which is a Browser, i.e. application software for viewing pages, content of web documents, computer files and their directories, managing web applications, as well as for solving other tasks.
2.1.2. Browser Partners – legal entities whose applications and / or Internet-services the User visits using the Browser and with which the Browser has a partnership agreement.
2.1.3. Company (Operator) – оa limited liability company "Innovatsionnaya Razrabotka" (OGRN / TIN 1227700160104 / 9703079836; legal address-Moscow, ext. ter. g. municipal district Airport, Krasnoarmeyskaya str., 23, sq. 61), which has all the necessary rights to grant the User the rights to use the Browser on the terms and conditions The User agreement. The Company processes User Data under the conditions stipulated in the Policy.
2.1.4. User – a legally capable individual who has reached the required age to use the Browser in accordance with the applicable legislation of the User's country of citizenship or place of residence, and who uses the Browser;
2.1.5. User Data - any information about the User (including personal data) that allows you to identify the User and distinguish him from another individual.
2.2. Before using the Browser, the User confirms that he has read the terms of this Policy and agrees to the Company's processing of User Data and their transfer to third parties providing web analytics services, under the terms of this Policy.
2.3. The Browser, with the User's prior consent, can access information about phone numbers contained in the contact lists on the User's device, which allows the User to open the Internet site of a financial organization using the Browser and, when transferring funds, select the phone number of the recipient of funds from the list of phone numbers contained in contacts on the User's device. At the same time, the Browser does not transmit or grant access to phone numbers from the contact list on the User's device to financial organizations. The User independently enters the phone number from the contact list from the User's device on the website of financial organizations and transmits it to the financial organization when transferring funds by phone number.
3.1. Users have the right to use the Browser without registration, as well as without the need to provide personal information about themselves.
However, before the User starts using the Browser, the Company considers it necessary to provide Users with detailed information about the procedure for collecting and further processing, including storing User Data (see the table below). The specified processing is performed for the purpose of executing the User Agreement, namely:
№
Purposes of processingBrowser User Data
List of processed User's data
Basis of data processing User
Note
1.
Ensuring the basic functioning of the Browser
1. Technical characteristics of the User's device (device model, with information about the operating system, screen size, IP address, type and version of the operating system that the User uses);
2. Statistics related to the Browser installation (the fact of installation, the fact of launch, the fact of deletion, the fact of updating the Browser, information about features enabled/disabled, information about errors, information about diagnostic messages, the address and part of the "url" of the site added to the Browser's start page, Browser usage time, application launch speed, history of file downloads through the Browser; and history of Internet site views, files saved to the cache);
3. Information about the fact, date time of visiting network addresses, information about the fact, date, time of visiting sites and (or) pages of sites on the Internet, information entered in the search bar;
4. Information about the amount of network traffic consumed, the cookie file identifier issued to the user cookies;
5. Geographical address of the user's connection point to the Internet, a unique identifier and the user's alias;
6. information about third-party applications that the User uses when interacting with this Service;
7. Information entered on sites (including those that require authorization)
8. Saved passwords and form autofill data;
9. Information about phone numbers from the contact list on the User's device.
10. Unique identifier of the User in the Browser (s/n);
User Agreement
The Browser stores for the User the addresses of pages on the Internet that the User visited using the Browser. Information about their IP addresses can also be added to this information.
The Browser stores the cache (i.e. page elements and their copies) that the User opens through the Browser. This allows you to load pages faster.
Theм Storage location mя This isa User's device, as well as the Company's servers located on the territory of the Russian Federation.
User Data processing period – during the Browser usage period.
2.
Improving the Browser's performance and building Browser usage analytics
1. Device specifications (device model, operating system information, screen size, IP address; network information when using the Browser, ID numbers in the web analytics system);
2. Information about third-party applications that the User uses when interacting with the Browser; Information about
3. about UTM tags (tools for analyzing Browser traffic and Browser loading);
4. Search queries and information about links opened when using the Browser (applications, sites that Users view and search for when using the Browser, including ads and cookies), urls (domain) the number of pages visited;
5. Information entered by the User in the wish-list;
6. Information about the User ID assigned by the web analytics system;
7. The number of visits and the time of using the Browser.
8. A unique User Identifier in the Browser (s/n);
The User Agreement,
the User's Consent
of the Web Analytics System will function when using the Browser in order to improve the Browser's performance. This is an integral part of the Browser's operation and is necessary for the User to use the Browser.
The storage location for such data is the User's device and web analytics systems.
User Data processing period – during the Browser usage period.
We can transmit User Data to the Browser Partner so that the Browser Partner can use the Service's session analytics/the site of the Browser Partner by Users using the Browser.
3.
Ensuring the operation of the functionala Recommendation e technologies and
1. a Unique User ID in the Browser (s/n);
2. Data on the history of actions taken to view content (for example, product ID;
3. Data on possible recommendations received from Partners whose sites and applications users use using the Browser.
User Agreement
The Browser uses recommendation technologies that allow you to better understand the needs of users in order to provide users with high-quality and interesting content and products that correspond to their interests, as well as improve the Browser andго its functionality
The Browser does not act as a seller of goods or its representative.
To get information about possible recommendations that Partners recommend showing you, the Browser can send the Partner a Unique User ID in the Browser (s/n) and in response receive a recommendation for the User linked to this identifier (s/n) from the Partner.
If you do not want to receive personal recommendations, you can click togler to reject personal recommendations.
Then the Browser will generate only non-personal data for you. recommendations.
4.
Anti-advertising functionality (ad blocking in the Browser)
1. The address and / or part of the "url" of the site;
2. A site element;
3. Malicious cookies that contain an ad and the display of advertising content is restricted after the user has enabled the "Block Ads" functionality.
4. Unique User ID in the Browser (s/n);
User Agreement
The User independently decides whether to enable or disable the "Block ads" functionality.
If the "Anti-advertising" feature is enabled, the Browser will block the ability to display advertising content on those sites that are included in the Browser's lists of sites that have advertising content. The Browser independently enters and updates such lists based on open information on the Internet.
The storage location for such data is the User's device.
User Data processing period – during the Browser usage period.
5.
Functionality of using the User's contacts on sites opened through the Browser
1. Information about phone numbers from the User's contacts contained on the User's device User
User's Consent;
User Agreement
When using the Browser, the User can select phone numbers from the list of contacts on the User's device, in order to make a transfer of funds to such a phone number on the financial organization's website.
Before using this functionality, the Browser requests a separate consent from the User. If the User provides it, the Browser will get access to phone numbers from the User's contact list, and the User will be able to open the website of a financial organization through the Browser and indicate the phone number from the list of their contacts from the User's device when transferring funds to the phone number.
However, the Browser does not transmit or grant access to phone numbers from the contact list on the User's device to the financial institution.
The user can revoke their consent by entering the Phone Settings in the "Privacy and Security" section, then "Contacts" and turning off/on the toggler.
The User's contact data is stored on the User's device.
The period of processing User Data is during the period of use of the Browser/ until the toggler is disabled.
6.
Functionality"Receiving PUSH notifications" functionality (for iOS devices)
1. Unique Пользователя Browser User ID(s/n);
2. Full name of the User;
3. User IDs in the online service of third-party companies (applicable if the User activated receiving notificationsй / PUSH notifications from such a service while using the Browser)
4. Date / time when the PUSH notification was sent PUSH notification
5. PUSH notification text1.
6. Information about the User's device
7. Information about the user's visit to the site/ app where PUSH notifications are enabled
User's Consent
This functionality is enabled only with the User's consent.
To activate this functionality, you must express separate consent in the Browser, as well as separate consent in the service of a third-party company whose notifications you want to receive through the Browser.
We inform you that after enabling this functionality, the Browser will receive the PUSH-уведомлений получать от стороннего сервиса specified information about you in the PUSH notification format from a third-party service, which is necessary to send you a PUSH notification through the Browser.
By enabling PUSH notifications, you agree that the Browser will send your unique Browser User ID (s/n) to the organization whose PUSH notifications you will receive.
To disable this functionality, go to the "notifications" section and disable PUSH notifications from the service whose notifications you no longer want to receive. After that, the Browser will stop receiving the specified information about you that was necessary for PUSH notifications from a third-party service.
Examples of information that can be contained in PUSH notifications of retail chains: Full name of the User, unique User ID in the retail network; information about discounts and product offers, information from the loyalty program, etc.
For more information about what is contained in PUSH notifications, see the terms of service of third-party companies whose PUSH notifications you enable.
Data storage location – the Company's User / server device located on the territory of the Russian Federation.
User Data processing period – during the Browser usage period/until the Функционала "Receivingя PUSH Notifications" functionality is disabled.
7.
Technical support for the User when using the Browser
1. Unique User ID (s/n);
2. Email address;
3. Information contained in the User's request.
User Agreement
The term of processing User Data is 3 years from the moment of the User's request.
User Data Storage location - Company servers located on the territory of the Russian Federation.
8.
Registration and use of the Luna ID profile(for iOS devices)
1. Last name, first name, patronymic (if any);
2. Phone number;
3. Email address;
4. Address (country / ZIP code / region / locality / district / street / house / apartment (office))
5. Avatar;
6. User's system status;
7. Favorite sites / services;
8. Browsing history;
9. Settings (filtering content, blocking dangerous sites, blocking cookies);
10. Profile ID;
11. Device ID;
12. Unique and User Identification (s/n);
13. User role;
14. Photo (photo image)
15. Type of operating system.
User Agreement
The Browser's User Agreement provides users with the opportunity to register or access services using their Mobile ID. To create a Luna ID profile, the User registers in the Browser or passes authorization via VK ID or Yandex ID.
The User's Data storage location is the Company's servers located on the territory of the Russian Federation.
Term of processing User Data during the period of using the Luna ID profile.
The User can delete their own profile and ID by using the appropriate Browser functionality.
1 The User is solely responsible and responsible for actions related to receiving PUSH notifications through the Browser from third-party services.
The browser does not participate in the formation of the text of such notifications. All PUSH notification texts are generated by a third-party company whose notifications the User has enabled. At the same time, the Browser does not perform targeted text processing of PUSH notifications and does not analyze their content.
4.1. A cookie is a small text file that is sent by a web server and stored on your computer, mobile phone, or any other device that has Internet access when you visit a website or mobile application (Service).
4.2. The Browser uses the following types of cookies:
– strictly necessary cookies / technical cookies: these cookies are necessary for the operation of the site and for providing the User with Browser functionality; among other things, they allow the Company to identify the User's hardware and software, including the Browser type;
– statistical / analytical cookies: these cookies allow you to recognize Users, count their number and collect information, such as the operations performed in the Browser, including information about the web pages visited and the content that the User receives.
– Technical cookies: these cookies collect information about how Users interact with the Browser, which allows you to detect errors and test new features to improve the performance of the Service.
– Functional cookies: these cookies allow you to provide certain functions to facilitate the use of sites, for example, by storing preferences (such as language and location).
– (third-party) tracking files: These cookies collect information about traffic sources, pages visited, and ads displayed by the User. They allow you to display ads that may be of interest to the User, based on the analysis of information collected about the User. They are also used for statistical and research purposes.
4.3. Cookies are processed by the Company exclusively for the purposes specified in the Table of 3.1 of this Policy, under the conditions and in accordance with the procedure defined in this Policy.
5.1. By default, the "Advanced Protection" functionality is enabled in the Browser, so that User actions are not tracked on sites by tracker scripts (i.e., programs that can monitor User actions on the Internet), as well as fraudulent sites (i.e., sites that can steal passwords and bank card data).
5.2. The user can disable "Advanced Protection", but the Company does not recommend this. Especially in cases when the User opens the websites of financial organizations using the Browser and uses their contacts contained on the User's device to transfer funds.
6.1. The Company assures Users that information about them is not shared with any third parties, except in cases expressly provided for in this Policy, other applicable Browser rules, and applicable legislation.
6.2. The Company may transfer User Data to third parties, subject to the purposes and grounds specified in this Policy. These third parties may include:
– persons who participate in the provision of services to the User; persons who assist the Company in ensuring the operability and security of the Browser, as well as in carrying out work to improve the Browser and personalize content for the User; persons who assist the Company in communicating with the User and carrying out various types of newsletters;
– persons who have legal grounds to process User Data, for example, if the transfer of User Data to third parties is carried out with the User's consent, including if the User's Data is necessary to provide the User with the relevant service or fulfill a certain agreement or contract concluded with the User, in particular, mobile operators and / or technology partners, existing agreements between the Company and mobile operators;
– any public or local authority to which the Company is required to provide information in accordance with applicable law upon request.
6.3. 6.3. The Browser uses the AppMetrica analytics service (Yandex.Metrica for Apps) provided by Yandex Limited Liability Company (registered office-16 L. Tolstogo str., Moscow, 119021, Russia) (hereinafter-Yandex) under the Terms of Use of the service.
AppMetrica analyzes data about the app's usage, including the device on which it operates, the source of installation, and compiles conversion rates and statistics of your activity for product analytics, ad campaign analysis and optimization, and error correction. The information collected in this way cannot identify you.
Information about your use of this app collected using the AppMetrica tools will be anonymized and transmitted to Yandex and stored on a Yandex server in the EU and the Russian Federation in accordance with the Yandex privacy policy. Yandex will process this information to provide statistics on your use of the app, compile reports on the app's performance for us, and provide other services.
6.4. The Browser can store your data in the cloud storage provided by the Limited Liability Company T1 Cloud (legal address - 111395, Moscow, Yunosti str., 13A, office. 8) taking into account all requirements of the applicable legislation in the field of personal data.
6.5. If you have any questions, the User can send a message to the Company's support service at support@loonabrowser.ru. At the same time, web analytics systems are inextricably linked to the operation of the Browser: if the User's consent is revoked, problems may arise when using the Browser.
7.1. All User Data is processed on the User's device, with the exception of:
– User data that is transmitted to the web analytics system.
– User data that the User provided to the Company for the purpose of providing technical support to the User when using the Browser.
7.2. The Company processes User Data by collecting, recording, organizing, accumulating, storing, clarifying (updating, changing), extracting, using, transmitting (providing, accessing), blocking, deleting, destroying. These operations are performed both with and without the use of automation tools.
7.3. At the same time, the User should pay attention to the fact that the term of processing the User's Data is until the purposes of data processing are achieved, unless otherwise provided for by the legislation of the Russian Federation.
8.1. The Browser's functionality for auto-filling in User Data supports working with the device's infrastructure in the form of a local secure KeyChain storage and its API, which use asymmetric encryption to protect the User's stored Data.
This allows the User to securely store User Data that is necessary for authorization on websites (including those websites that may store important information that is sensitive to the User, such as applications of financial organizations).
8.2. When a User navigates to the above-mentioned websites via the Browser, the "Auto-complete" function, requesting data from the local secure storage, KeyChain fills in the corresponding site fields using the KeyChain API. The request for data from the local secure storage is accompanied by confirmation from the User through authentication using Face ID / Touch ID / Passcode when the device security option is configured.
8.3. The exchange and storage of this User Data on the User's device must be carried out with the User's consent, which the User will provide to the organization and the website to which the User enters their Data.
9.1. To delete cookies from your Browser, use the following guide:
"Home Screen" → "History" → "• • •" at the bottom of the screen → "History" → Swipe left on the deleted item → Hold down the deleted item → "Delete" → Click "Clear" → Select a time range
Home Screen → "Settings" → "Clear History and data" → "Search History" → Select a time range.
9.2. The Company will ensure that all User Data is deleted if:
– The User independently deleted the Data in the Browser using the Browser's functionality.
– The user deleted the Browser from their device.
– With respect to User Data that is processed on the Company's servers - if the User exercises his right to withdraw consent to the processing of personal data by sending a message about Data deletion to the email address - support@loonabrowser.ru. In this case, the Company will ensure the deletion of User Data that was processed on the Company's servers based on the User's consent.
10.1. The Company takes all necessary technical, organizational and legal measures to ensure the protection of Users ' Data from unauthorized or accidental access to them, destruction, modification, blocking, copying, distribution, as well as from other illegal actions.
10.2. Technical security measures are implemented by the Company taking into account the requirements of applicable legislation, state - of-the-art technology, the nature of the processed information and the risks associated with its processing.
10.3. Information is mostly processed automatically without access to it by the Company's employees and/ or contractors. If such access is granted to employees or contractors of the Company, then only to the extent necessary for such persons to perform their official duties or obligations under the contract with the Company, while such persons are required to comply with security requirements when accessing User Data. To protect and protect the confidentiality of data, all employees / contractors comply with internal rules and procedures regarding the processing of information. These individuals also comply with all technical and organizational security measures provided for by applicable law and necessary to protect User information.
10.4. The user must ensure that their device is protected independently. The Company recommends that the User always enable the "Advanced Protection" functionality when using the Browser, as well as additionally install antivirus software on their device and regularly check their device for malicious software.
11.1. Users have the right to:
– get free access to your personal information via the Browser.
– independently make changes and corrections to the information about yourself by editing it, provided that such changes and corrections contain up-to-date and reliable information;
– delete information about yourself by editing Data in the Browser, and deleting certain information about yourself from the Browser by the User may make it impossible for the User to access the Browser's functionality.
– require the Company to clarify the User's Data, block it or destroy it if such information is incomplete, outdated, unreliable, unreasonably obtained or is not necessary for the stated purpose of processing and if the Browser functionality does not allow the User to delete such information independently;
– revoke consent to the processing of User Data.
– on the basis of a request, receive information from the Company regarding the processing of User Data by the Company;
– appeal the Company's actions or omissions to the authorized bodies, in accordance with the procedure provided for by applicable law.
11.2. The User has the right to apply to the following email address: support@loonabrowser.ru monitor the exercise of their rights, including those provided for in this Policy.
12.1. By accepting the User Agreement, the User also accepts this Policy, which is an integral part of it. The User confirms that they have read the Policy and agree to the terms of processing the User's Data.
12.2. The Company has the right to make changes to the Policy without prior notice. We recommend that you review the Policy regularly, especially if new features appear in the Browser.
12.3. The new version of the Policy takes effect from the moment it is posted for unlimited access, unless otherwise provided by the new version of the Policy.