PRIVACY POLICY



 

 

 
 

1. What this privacy policy governs

This privacy policy (hereinafter referred to as the Policy) applies to all information, including personal data within the meaning of applicable law (hereinafter referred to as the Personal Information), that ODAK Group LLC and/or its affiliates (hereinafter referred to as FOXIZZ) may receive about you in the course of your use of any sites, programs, products and/or services of FOXIZZ (hereinafter collectively referred to as the "Services"), information about which you can find on the websites foxizz.com, foxizz.ru, foxizz.am and other websites owned by FOXIZZ (collectively, the "Sites"), as well as during the performance by FOXIZZ / its affiliates of any agreements and contracts concluded with you in connection with your use of the Services.

2. Who processes the information

To ensure your use of the Sites and Services, your Personal Information is collected and used by FOXIZZ, including including limited liability company "ODAK Group", a legal entity established under the laws of the Russian Federation and registered at: 115172, Moscow, Krasnokholmskaya embankment, d. 1/15 (ODAK Group LLC), or its affiliate providing the relevant Service in other jurisdictions. Information about which person provides a particular Service can be found in the terms of use of the relevant Service.

For users

3. What Personal Information FOXIZZ collects about you

Personal information collected in the course of operation of the Sites and / or provision of Services, as well as in the course of use of the sites, programs, products or services of Partners, may differ depending on whether you use your account to access them or not. Where you log into your account, the Personal Information collected about you by FOXIZZ during your use of the Sites and Services may be matched and linked to other Personal Information collected by FOXIZZ as part of your use of your account (for example, your identity, contact details if provided by FOXIZZ). FOXIZZ does not verify the Personal Information provided by you, except as provided in the user agreement or terms of use of individual Services, and cannot judge its accuracy, or whether you have sufficient legal capacity to provide your Personal Information. However, FOXIZZ expects you to provide true and sufficient Personal Information and keep it up to date.

FOXIZZ may collect the following categories of Personal Information about you when you use the Sites and Services:

(i) Personal information provided by you when registering (creating an account), such as your name, phone number and email;

(ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information, wi-fi network data);

(iii) the date and time of access to the Sites and/or Services;

(iv) information about your activity while using the Sites and/or Services (for example, search history, purchase data in the Services, details of the organizations visited, likes and preferences, email addresses of those with whom you correspond, telephone books, information about interactions with other users, and files and content stored on FOXIZZ systems);

(v) geolocation information;

(vi) other information about you necessary for processing in accordance with the terms governing the use of specific Sites or Services of FOXIZZ;

(vii) information about you that we receive from our Partners in accordance with the terms of agreements entered into between you and the relevant Partner and agreements entered into between FOXIZZ and the Partner;

(viii) your payment card details, other payment information provided by you, as well as received from Partners or other persons involved in the execution of a payment transaction using the FOXIZZ Sites or Services and / or in connection with the provision of paid services by FOXIZZ.

FOXIZZ also uses cookies and web beacons (including pixel tags) to collect Personal Information and associate such personal information with your device and web browser (see Section 11 of this Policy).

FOXIZZ does not collect purposefully sensitive personal information (such as racial origin, political opinions, health information, and biometric data), except as provided in the individual Services' user agreements.

FOXIZZ does not collect data for the purpose of compiling a "portrait" of the user to the extent that this may significantly affect your rights and freedoms in accordance with applicable law.

4. Legal basis and purposes of processing your Personal Information

FOXIZZ may not process your Personal Information without sufficient legal grounds. Therefore, FOXIZZ only processes your Personal Information if:

(i) processing is necessary for the performance of contracts between you and FOXIZZ, such as the User Agreement for FOXIZZ Services and the terms of certain FOXIZZ Services, which also includes operating the Sites and Services (for example, providing you with search results for your queries);

(ii) the processing is necessary for compliance with legal obligations;

(iii) where provided by applicable law, the processing is necessary for the legitimate interests of FOXIZZ in the event that such processing does not significantly affect your interests, your fundamental rights and freedoms. Please note that when processing your personal information on this basis, FOXIZZ will always strive to maintain a balance between its legitimate interests and the protection of your privacy.

FOXIZZ processes your Personal Information for its legitimate interests, for example, in the following cases:

(a) to better understand how you interact with our Sites and/or Services;

(b) to improve, change, personalize or otherwise improve the Sites and Services for the benefit of all users;

(c) to offer you other products and services of FOXIZZ or other companies that we think may be of interest to you (i.e. to show you advertisements tailored to your interests);

(iv) for specific purposes or as required by applicable law, we may require your separate consent to process your Personal Information. For jurisdictions where consent is recognized as a separate legal basis, your use of the FOXIZZ Sites and/or Services constitutes your consent to such processing. We hereby inform you, and you acknowledge that you have no obligation to provide us with any Personal Information when you use the Sites or Services, and such provision is based solely on your free will. However, you acknowledge that without providing Personal Information, we will not be able to provide you with the opportunity to use the Services, and your use of the Sites will be limited.

FOXIZZ always processes your Personal Information for specific purposes and only that Personal Information that is relevant to the achievement of such purposes. In particular, we process your Personal Information for the following purposes:

(i) providing you with access to the Sites and/or Services (including providing search results in response to your search queries based on your preferences, search history and other Personal Information about you available to FOXIZZ);

(ii) providing access to your account, including FOXIZZ's email account and file storage, if you are registered with the relevant Services;

(iii) to communicate with you to send you notices, requests and information related to the operation of the Sites and Services, to fulfill agreements with you and to process your requests and applications;

(iv) personalize advertisements and offers based on your preferences, search history and other Personal Information available to FOXIZZ about you;

(v) improve the usability of the Sites and Services, including to display the most relevant search results and provide more personalized Sites and Services, as well as to improve other FOXIZZA products, applications and Services;

(vi) creating new products, utilities and FOXIZZA offerings;

(vii) protect your rights and the rights of FOXIZZA;

(viii) collection, processing and presentation of statistical data, big data and other research;

(ix) identifying security threats to the Sites and Services, users, FOXIZZ and/or third parties, including checking your due diligence when entering into contracts using the Sites and Services;

(x) arranging the acceptance of your payments, your payment for goods and services using the Sites and Services.

The use of information received from the Google API (hereinafter referred to as the “Received Data”) in the FOXIZZa Services is carried out in accordance with the provisions of the Google API Disclosure, subject to the restrictions specified therein, namely:

The data collected is used solely for the purpose of providing you with the functions of an email client. The received data cannot be used for transfer to third parties, for displaying promotional materials and for other purposes related to illegal access to the content of your correspondence.

5. How FOXIZZ Protects Your Personal Information

In most cases, Personal Information is processed automatically without access to it by any of FOXIZZ's employees. Should such access be required, it may only be granted to those FOXIZZ employees who need it to perform their tasks. To protect and maintain data privacy, all employees must comply with internal policies and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect your Personal Information.

6. Who else has access to your Personal Information and to whom it may be shared

FOXIZZ may share your Personal Information with its employees (to the extent specified in Section 6 of this Policy). FOXIZZ may also transfer your Personal Information to its affiliates, including other companies from the group of persons to which FOXIZZ belongs (ODAK Group LLC). Please note that the level of protection of Personal Information in some countries may not match the level established in your jurisdiction, and by using the FOXIZZ Services, you consent to such transfer.

7. Where your Personal Information is stored and processed

Your Personal Information will be stored in the Russian Federation and/or the EEA.

For Russian users: FOXIZZ records, systematizes, accumulates, stores, clarifies (updates, changes), extracts personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.

For users from the EEA, Switzerland or Israel: Russia is a jurisdiction outside the European Economic Area that has not been recognized by the European Commission as providing an adequate level of personal data protection. Therefore, FOXIZZ has taken appropriate measures to ensure that such transfer is carried out in accordance with applicable EU data protection regulations.

In particular, FOXIZZ is guided by the Standard Contractual Clauses approved by the European Commission to ensure an adequate level of protection for your Personal Information transferred to Russia. A copy of these Standard Contractual Clauses is available upon request.

If you are located in a territory where your consent is required for the transfer of your Personal Information to another jurisdiction, then by using the Sites or Services, you give FOXIZZ your express and unequivocal consent to such transfer or storage and / or processing of information in other specified jurisdictions, including Russia.

8. How long do we keep your Personal Information

FOXIZZ will retain your Personal Information for as long as necessary to fulfill the purpose for which it was collected or to comply with legal and regulatory requirements.

Unless otherwise required by law or by agreement with you, emails and documents that you store on FOXIZZA's systems as part of the Service will be retained for as long as you have an account, but they may be deleted by you at any time.

If you wish to have any of your Personal Information removed from FOXIZZ's databases, you may remove the necessary Personal Information yourself through the interface of the Sites and/or Services (where applicable). The data management tool is available for users authorized in FOXIZZ services in a special section "Data Management" on the profile page in FOXIZZ ID

9. How we use cookies and other similar technologies on the Sites or when you use the Services

9.1 What cookies and why does FOXIZZ use them?

Cookies are small pieces of data that are received and processed by the device you use to access the Sites. Cookies store and send back to the Sites information that helps you navigate the Sites and allows us to remember your preferences over time, such as your browser settings or to recognize your account.

The Sites use the following types of cookies:

Strictly Necessary Cookies/Technical Cookies: These cookies are essential for the operation of the Sites and provision of the Services to you; among other things, they allow FOXIZZ to identify your hardware and software, including your browser type;

statistical/analytical cookies: these cookies allow us to recognize users, count their number and collect information such as your activities on the Sites and Services, including information about the web pages you visit and the content you receive;

technical cookies: these cookies collect information about how users interact with the Sites and/or Services, which allows us to identify errors and test new features to improve the performance of the Sites and Services;

functional cookies: these cookies allow us to provide certain features to make your use of the Sites easier, for example by storing your preferences (such as language and location);

(Third Party) Tracking / Advertising Cookies: These cookies collect information about users, traffic sources, pages visited and ads displayed to you, as well as the one that led you to the advertised page. They allow you to display advertisements that may be of interest to you based on an analysis of the Personal Information collected about you. They are also used for statistical and research purposes.

9.2 How long cookies are stored on your device

FOXIZZ uses the information contained in cookies only for the above purposes, after which the collected data will be stored on your device for a period that may depend on the type of cookie in question, but not exceeding the period necessary to achieve their purpose, after which they will be automatically removed from your system.

9.3 Who else has access to information contained in cookies

Personal information collected using cookies placed on your device may be transferred to and available to FOXIZZ and / or third parties specified in section 7 of this Policy. The use of Personal Information outside of the Sites for promotional purposes, if any, may be subject to separate user agreements available on third party websites.

When you visit the Sites for the first time, you may be asked to consent to the use of cookies. If, after you have accepted the use of cookies, you would like to change your mind, you can do so by deleting the cookies stored in your browser (usually this can be done in your browser settings - please refer to your browser manual or website its developer). After that, a pop-up window may be displayed again asking for your consent, and you can make a different choice. If you refuse the use of cookies, this may result in some features of the Sites not being available to you and may affect your ability to use the Sites. You may also change your browser settings to accept or reject by default all cookies or cookies from certain sites, including the FOXIZZ Sites. If you have approved the use of cookies on one of the FOXIZZ Sites, we will assume that the use of cookies on all Sites has been approved by you.

FOXIZZ may also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:

(i) identify your activities on the Sites and while using the Services by accessing and using cookies stored on your device;

(ii) collection of statistical information related to the operation of the Sites, Services or products, utilities and offers of FOXIZZ.

10. Updates to this Policy

This Policy may be subject to change. FOXIZZ has the right to make changes at its sole discretion, including, but not limited to, in cases where the relevant changes are related to changes in applicable law, as well as when the relevant changes are related to changes in the operation of the Sites and Services.

FOXIZZ undertakes not to make significant changes, not to impose additional encumbrances or restrictions on your rights. You will be notified of such changes. Appropriate notices may be displayed on the Site or Services (for example, through a pop-up window or banner) before such changes become effective, or may be sent to you through other communication channels (for example, by e-mail legal@foxizz.com, if you have provided us with your contact details).