Personal Data Privacy Policy

Last updated: 07.02.2024

This Policy on the processing of personal data (hereinafter — the Policy) defines the goals and general principles of processing personal data of Personal Data Subjects, as well as the implemented measures to protect personal data when they use any of the services of the Website located at: https://happ-proxy.me (hereinafter — the Website).

The Policy is a publicly available document of the Operator and provides for the possibility of review by third parties.

This Policy applies to all personal data that the Operator may receive from the User during use of the Website and its services.

The Policy is open-ended after approval and remains in effect until replaced by a new version.

If the User does not agree with the terms of this Policy, use of the Website must be immediately discontinued.

1. General provisions

1.1. The personal data Operator is Mobness LTD (hereinafter — the Operator).

1.2. The User's personal data is processed to achieve personal data processing goals by any lawful means, including in personal data information systems using automation tools or without using such tools (mixed processing of personal data). The processing of Users' personal data is carried out in accordance with applicable data protection laws.

1.3. Consent to the processing of personal data is valid from the moment it is given to the Operator until the date the Operator loses its legal status as a legal entity, or in case such consent is withdrawn by the User.

1.4. Use of the Website's services means the User's unconditional consent to the Privacy Policy and the conditions for processing of their personal information specified therein; in case of disagreement with these conditions, the User must refrain from using the Website and its services.

1.5. The Operator may make changes to the Privacy Policy without the User's consent. The new version of the Privacy Policy takes effect from the moment it is posted on the Website, unless otherwise provided by the new version of the Privacy Policy.

Any changes to the Policy are made by the Operator independently and take effect on the day following the day of publication of such changes. The Operator notifies Users of changes to this Policy, including by publishing a new version of this Policy. The User undertakes to independently review changes made to the Policy. Actual use by the User after changes have been made to the terms of this Policy means the User's consent to the new terms.

1.6. The text of the Privacy Policy is available to Users on the Internet at: Privacy.

1.7. This Policy uses the following terms and definitions:

1.7.1. Operator — a legal entity, independently or jointly with other persons, organizing and/or carrying out processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data;

1.7.2. Personal data — any information related directly or indirectly to a determined or determinable individual (personal data subject); processing of personal data — any action (operation) or combination of actions (operations) performed using automation tools or without such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modifying), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

1.7.3. Automated processing of personal data — processing of personal data using computing equipment;

1.7.4. Distribution of personal data — actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or familiarizing an unlimited number of persons with personal data, including disclosure of personal data in mass media, posting in information and telecommunication networks or providing access to personal data by any other means;

1.7.5. Provision of personal data — actions aimed at disclosing personal data to a specific person or to a specific number of persons;

1.7.6. Blocking of personal data — temporary cessation of processing of personal data (except where processing is necessary to clarify personal data);

1.7.7. Destruction of personal data — actions resulting in the impossibility of restoring the contents of personal data in the personal data information system and/or resulting in the destruction of material carriers of personal data;

1.7.8. Personal data information system — a combination of personal data contained in databases and information technologies and technical means providing for their processing;

1.7.9. Web-site (Site) — a combination of graphic and informational materials, as well as software and databases ensuring their availability on the Internet at the network address: https://happ-proxy.me.

1.7.10. Personal data permitted by the personal data subject for distribution — personal data, access to which by an unlimited number of persons is granted by the personal data subject through giving consent to the processing of personal data permitted by the personal data subject for distribution in the manner provided by applicable data protection laws.

1.7.11. User — any visitor of the website https://happ-proxy.me who has logged in/registered on it;

1.7.12. IP address — a unique network address of a node in a computer network built using the IP protocol.

1.8. If the Policy uses terms not listed in clause 1.7, they shall be used and interpreted in accordance with applicable law and customary business practices established on the Internet.

2. Principles and conditions for processing personal data

2.1. Processing of personal data is carried out by the Operator on the basis of the following principles:

2.2. legality and fair basis;

2.2.1. limiting the processing of personal data to specific, predetermined and lawful purposes;

2.2.2. preventing the processing of personal data incompatible with the purposes of personal data collection;

2.2.3. preventing the merging of databases containing personal data whose processing is carried out for purposes incompatible with each other;

2.2.4. processing only those personal data that meet the purposes of their processing;

2.2.5. correspondence of the content and volume of processed personal data with the stated purposes of processing;

2.2.6. preventing the processing of excessive personal data with respect to the stated purposes of their processing;

2.2.7. ensuring the accuracy, sufficiency and currency of personal data with respect to the purposes of personal data processing;

2.2.8. destruction of personal data upon achievement of the purposes of their processing or in case the need to achieve those purposes is lost, where the Operator cannot remedy the personal data violations committed, unless otherwise provided by federal law.

2.3. Personal data permitted for processing under this Policy is provided by the User when using the Website:

2.3.1. The Operator may process other personal data of the User that is necessary for the use of the Website.

2.3.2. The Operator does not process special categories of personal data relating to racial, ethnic origin, political views, religious or philosophical beliefs, intimate life.

2.3.3. The processing of personal data permitted for distribution from among the special categories of personal data is allowed only if the prohibitions and conditions established by applicable data protection laws are observed.

3. Measures applied by the operator when processing personal data

3.1. When processing personal data, the Operator at its discretion takes the necessary legal, organizational and technical measures to protect them from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in respect of personal data, including:

3.2. Access to personal data processed by the Operator is granted only to persons whose job functions involve work with such information and documents. The Operator transfers personal data to its employees in the manner established by the laws of the Russian Federation, and limits this information only to those personal data necessary for the purposes of personal data processing.

3.3. The Operator may grant access to users' personal data in the following cases:

3.4. When storing personal data, the personal data operator uses databases located in the relevant jurisdiction in accordance with applicable data protection laws.

4. Rights and obligations of the parties

4.1. The personal data subject decides on the provision of their personal data and gives consent to their processing freely, by their own will and in their own interest. Consent to the processing of personal data may be given by the personal data subject or their representative in any form that allows confirmation of the fact of its receipt, unless otherwise established by federal law.

4.2. The personal data subject has the right to receive information regarding the processing of their personal data, unless such right is restricted in accordance with federal laws. The personal data subject has the right to require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated processing purpose, and to take statutory measures to protect their rights.

4.4. The User has the right to:

4.4.1. receive information regarding the processing of their personal data;

4.4.2. clarify their personal data, block or destroy them if they are incomplete, outdated, inaccurate, unlawfully obtained or cannot be considered necessary for the stated processing purpose, and take statutory measures to protect their rights;

4.4.3. protect their rights and lawful interests in court;

4.4.4. at their discretion, provide the Operator with personal data for processing under the conditions specified in the Privacy Policy;

4.4.5. on the basis of a request, receive from the Operator information regarding the processing of their personal data.

4.4.6. The User's right to access their personal data may be limited in accordance with federal laws, including if the User's access to their personal data infringes the rights and lawful interests of third parties.

4.5. The Operator is obliged to:

4.5.1. use the information received exclusively for the purposes specified in the Privacy Policy;

4.5.2. ensure that confidential information is kept secret, not disclose it without the User's prior written permission, and not sell, exchange, publish or disclose by any other means the User's transferred personal data, except as provided by the Privacy Policy;

4.5.3. take precautions to protect the User's personal data;

4.5.4. block personal data relating to the relevant User from the moment the User contacts or makes a request, or their legal representative or the authorized body for the protection of personal data subjects' rights, for the period of verification in case of detection of inaccurate personal data or unlawful actions.

4.6. The Operator may entrust the processing of personal data to another person on the basis of a contract concluded with that person, including a state or municipal contract.

The person processing personal data on behalf of the operator is required to comply with the principles and rules of personal data processing provided for by applicable data protection laws.

In addition, where necessary, the operator may transfer personal data to inquiry and investigation bodies and other authorized bodies on the grounds provided for by the applicable laws of the Russian Federation.

5. Volume and categories of processed personal data, categories of personal data subjects

5.1. The content and volume of processed personal data correspond to the stated processing purposes. The processed personal data must not be excessive in relation to the stated purposes of their processing.

5.2. Processing of personal data is permitted in the following cases:

5.3. The categories of personal data subjects include:

5.3.1. The operator's clients and counterparties (individuals) — Users of the Website;

For this category of subjects, the operator processes personal data received by the operator in connection with the conclusion of a contract to which the personal data subject is a party, and used by the operator solely for the performance of such contract and conclusion of contracts with the personal data subject:

6. Procedure for destruction and blocking of personal data

6.1. In case of detection of unlawful processing of personal data upon the Users' request, the Operator is required to block the unlawfully processed personal data relating to those Users from the moment of such request for the period of verification.

6.2. In case of detection of inaccurate personal data upon the Users' request, the Operator is required to block the personal data relating to those Users from the moment of such request for the period of verification, if blocking the personal data does not infringe the rights and lawful interests of users or third parties.

6.3. In case of confirmation of the fact of inaccuracy of personal data, the Operator, on the basis of information provided by Users or other necessary documents, is required to clarify the personal data within 7 (seven) business days from the date of submission of such information and to lift the block of personal data.

6.4. In case of detection of unlawful processing of personal data carried out by the site, the Operator, within a period not exceeding 7 (seven) business days from the date of such detection, is required to cease the unlawful processing of personal data.

6.5. If it is impossible to ensure lawful processing of personal data, the Operator, within a period not exceeding 5 (five) business days from the date of detection of unlawful processing of personal data, is required to destroy such personal data.

6.6. The Operator is required to notify Users of the elimination of the violations or of the destruction of personal data.

6.7. In case of achievement of the purpose of personal data processing, the Operator is required to cease processing personal data and destroy personal data within a period not exceeding 5 (five) days from the date of achievement of the purpose of personal data processing.

6.8. In case of withdrawal by Users of consent to the processing of their personal data, the Operator is required to cease their processing and, if storage of personal data is no longer required for the purposes of personal data processing, destroy personal data within a period not exceeding 5 (five) days from the date of receipt of the said withdrawal.

6.9. In case of impossibility to destroy personal data within the period specified in clauses 6.4–6.8 of this Policy, the Operator blocks such personal data and ensures the destruction of personal data within a period of no more than 1 month, unless another period is established by federal laws.

7. Identification files

7.1. Identification files and other technologies (hereinafter — cookies) may be used on the Website. Such technologies are used to analyze user behavior on the site and measure advertising effectiveness.

7.2. Cookies are necessary for the use of the Website, navigation of the Website and the proper operation of its services. The User can disable cookies in the settings of the web-browser or mobile device used. In doing so, certain Website functions related to the use of cookies may be limited.

7.3. Cookies may contain information about the User's actions on the Website, including information entered by them, and are used in accordance with the provisions of the Privacy Policy. The data stored in these cookies is available only to the Website and cannot be used in any way when the User visits other sites.

7.4. By using the Website, the User consents to the storage of cookies by the Website using the relevant standard mechanism in the Internet browser on their computer/smartphone.

7.5. Pop-up notifications about the collection and processing of cookies data may be shown to Website Users with a link to the Policy and buttons for accepting the processing terms or closing the pop-up notification. The User's acceptance of the cookies processing terms or closing the pop-up notification in accordance with the Policy is regarded as consent to the processing of cookies data.

8. Dispute resolution

8.1. Before going to court with a claim regarding disputes arising from the relationship between the User and the Operator, a claim (a written proposal for voluntary settlement of the dispute) is presented.

8.2. The recipient of the claim, within 10 (ten) business days from the date of receipt of the claim, notifies the claimant in writing of the results of the claim review.

8.3. If no agreement is reached, the dispute will be referred to court in accordance with the applicable laws of the Russian Federation.

8.4. The applicable laws of the Russian Federation apply to the Privacy Policy and the relations between the User and the Operator.

9. Final provisions

9.1. Other rights and obligations of the personal data Operator are determined by the laws of the Russian Federation in the area of personal data. The Operator's officials (if any), guilty of violating the rules governing the processing and protection of personal data, bear material, disciplinary, administrative, civil-law or criminal liability in the manner established by federal laws.

9.2. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the said persons (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is required to independently and timely review the said documents. The Operator is not liable for the actions of third parties, including the service providers specified in this clause.

9.3. All additional questions or suggestions regarding the Privacy Policy, as well as the processing of personal data, must be sent to the Operator's email through the channels specified in the "Help" section.

10. Provider details

Mobness LTD, Reg Number: HE444974, Адрес: Cyprus, Limassol, 16 Rigainas street, 3035, Тел.: +35795767632

E-mail: support@happ-proxy.me.

11. Consent to the processing of personal data

I hereby give my consent to Happ-Proxy.me (hereinafter — the Operator) to process my personal data on the website at https://happ-proxy.me and its subdomains in accordance with the requirements of applicable data protection laws for the purposes of conducting a survey and providing services.

1. I accept all terms of the Privacy Policy posted at: Privacy, and I give my consent to the Operator to process, including by automated means (mixed method of personal data processing), personal data in accordance with applicable data protection laws, including collection, recording, systematization, accumulation, storage, clarification (updating, modifying), retrieval, use, transfer (provision, distribution, access), blocking, depersonalization, deletion, destruction of personal data.

2. When filling in electronic forms, I warrant that my personal data is accurate and belongs to me.

3. The consent to the processing of personal data is given consciously and is unequivocal.

4. I am informed that I may withdraw this consent by submitting to the Operator a statement in simple written form in accordance with the applicable laws of the Russian Federation.

5. I undertake to take measures to ensure the security and integrity of personal data, including those necessary for the use of the Website, such as using anti-virus software, taking care to keep passwords secure and inaccessible to third parties.

6. I undertake not to use other persons' personal data when filling in electronic forms.

7. I give my consent to the processing of my personal data:

8. The purposes of processing personal data are:

9. By using the Website, I give my consent to the storage of cookies in accordance with the Privacy Policy through the relevant standard mechanism in the Internet browser on the computer/smartphone.

10. In accordance with applicable data protection laws, freely, by my own will and in my own interest, I express consent to the collection, analysis, processing, storage and use, clarification, destruction of my personal data for purposes related to the use of the website, performance of the contract, participation in promotional events.

11. I express full and unconditional consent to the use of my data to maintain communication with me by any means, including by sending emails to the specified email address for the purpose of informing about the arrival of new goods/services, notification of promotions, events, discounts, their results, conducting absentee surveys to study opinions on goods/services, trade organizations, sending news, etc.

12. This consent is valid from the date of its signing until the date of withdrawal in writing.