22 March 2019
For your information
Please note that your using any of the Sites and/or Services may be subject to additional terms and conditions, which may amend and/or supplement this Policy.
2. Who processes your personal information
3. What is the purpose of this Policy
Privacy and security of your Personal information are extremely important to us. When you use the Sites and/or Services, NAIVE processes your Personal information and ensures its protection in strict compliance with applicable laws and regulations.
As part of our commitment to protecting your Personal information, we use this Policy to transparently inform you about the following:
- (a) why and how your Personal information is used (also, “processed”) by NAIVE when you access the Sites or Services;
- (b) NAIVE’s role and responsibilities in this context as the legal entity deciding why and how your Personal information is processed;
- (c) what instruments you may use to limit the amount of Personal information collected by NAIVE; and
- (d) what your rights are in relation to the above processing.
4. What type of Personal information is collected by NAIVE
Personal information collected when you use the Sites and/or Services may differ depending on whether you access the Sites or Services while logged in to your NAIVE user account or without logging in. When you are logged in to your NAIVE user account as you are using the Sites or Services, Personal information collected by NAIVE may be collated and combined with other Personal information (such as your identity, contact details, age and gender, if you shared this information with us) collected by NAIVE in your user account. NAIVE does not verify Personal information provided by you and cannot posit if it is true and whether you have the legal capacity required. However, NAIVE assumes that the information you provide is true, sufficiently complete and up-to-date.
Personal information collected by NAIVE when you access, interact with or operate the Sites and/or Services includes:
- (i) information provided by you when you register (create) a user account, such as your name, mobile phone number, address and age;
- (ii) electronic data (http headers, IP address, cookies, web beacons/pixel tags, browser information, information about your hardware and software);
- (iii) date and time of accessing the Sites or Services;
- (iv) information related to your activity when using the Sites or Services (e.g. your search history, email addresses of your contacts, content of your emails together with attachments, as well as files stored in NAIVE systems);
- (v) (geo)location information;
- (vi) other information about you that needs to be processed according to the terms and conditions of any specific NAIVE Site or Service; and
- (vii) information about you that we may receive from our Partner in accordance with an agreement you made with this Partner and an agreement between NAIVE and this Partner.
We do not actively collect any sensitive personal data (such as racial origins, political opinions, health or biometric data). However, you may voluntarily provide us which such data and we may process it as part of providing you with our Services (e.g. if you perform search queries related to your health). As we do not know in advance the potentially sensitive nature of the personal data you may provide to us, you must be aware that we may not be able to request your consent with such processing.
We do not perform any form of profiling which has the potential to significantly impact your rights and freedoms.
5. What are the legal basis for processing your Personal information and the purposes of it
NAIVE is not allowed to process your Personal information if it does not have a valid legal ground. NAIVE will therefore only process your Personal information if:
- (i) the processing is necessary to perform our contractual obligations towards you including providing you with Sites and/or Services (i.e. providing you with the results of your search query);
- (ii) the processing is necessary to comply with our legal or regulatory obligations; or
- (iii) in case it is provided by applicable law, the processing is necessary for the legitimate interests of NAIVE and does not unduly affect your interests or fundamental rights and freedoms. Please note that when we process your Personal information on this basis, we will always seek to maintain a balance between our legitimate interest and the protection of your privacy.Examples of such ‘legitimate interests’ referred in (iii) immediately above are:(a) to better understand how you interact with our Sites and/or Services;(b) to enhance, maintaining accessibility, modify, personalize or otherwise improve the Sites and Services for the benefit of all users; and(c) to offer you other products and services from NAIVE or other companies which we think can be of interest to you (i.e. personally-targeted advertising).
- (iv) for specific purposes we may ask your consent for processing of your Personal information.
NAIVE always processes your Personal information for a specific purpose and only processes Personal information which is relevant to achieve that purpose. In particular, we process your Personal information for the following purposes:
- (i) to provide you with the Sites and/or Services (i.e. delivery of search results in response to your search queries, taking into account your preferences, search history and other Personal information about you available to NAIVE);
- (ii) to provide you with access to your user account, including your email and storage service, if you have an account on these Services;
- (iii) to contact you to notify and/or inform you or request information from you in relation to the Sites and Services, or to execute our agreements with you or process your request or application;
- (iv) to provide advertisements and/or commercial offers based on your preferences, search history and other Personal information available to NAIVE;
- (v) to improve user experience, including offering more relevant search results and more personalised Sites and/or Services, as well as improving other NAIVE products, applications and services;
- (vi) to develop new products, applications and services;
- (vii) to protect your rights and the rights of NAIVE; and
- (viii) to collect, process and present statistical data or big data, or perform other research and/or analysis of Personal information.
6. How does NAIVE protect your Personal information
In most cases, Personal information is processed automatically without access to it by our staff. However, if such access is necessary, your Personal information can be accessed only by those NAIVE employees whose professional tasks require using this information. To protect your Personal information and ensure its confidentiality, these employees must comply with internal rules and follow protocols for processing Personal information. They are also required to follow all technical and organisational security measures protecting your Personal information.
NAIVE has also implemented adequate technical and organisational measures to protect Personal information against unauthorised, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access and against all other unlawful forms of processing. These security measures have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of Personal information.
7. Who else has access to your Personal information and who is it shared with
NAIVE may also transfer Personal information to third parties outside the NAIVE Group to complete the purposes listed in Section 5 above. Such third parties may include:
- i. Partners, such as media publishers, advertising networks and other partners providing NAIVE with services related to the placement and display of advertisement on the websites, programs, products and/or services owned or operated by such Partners;
- ii. Advertisers or other Partners serving targeted advertisement on the NAIVE Sites or Services; and third parties who process Personal information, such as our (IT) systems providers and/or consultants.
NAIVE may also transfer Personal information to the following third parties outside the NAIVE Group:
- i. any third party to whom we assign or novate any of our rights or obligations under a relevant agreement;
- ii. any national or international regulatory, enforcement, exchange body, central or local government department and other statutory or public bodies or court where we are required to do so by applicable law or regulation at their request;
- iii. third parties if you expressed your consent to such transfer or transfer of your Personal information is required for your use of a certain Service or performance of a particular agreement or contract with you;
8. Where is your Personal information stored and processed
NAIVE stores Personal information in the Russian Federation.
For users in Russia: NAIVE records, systematizes, accumulates, stores, clarification (updates, changes), extracts Personal information of the citizens of the Russian Federation using databases located on the territory of the Russian Federation.
For users in the EEA or Switzerland: Russia is a jurisdiction outside the European Economic Area, which has not been recognized by the European Commission as providing an adequate level of personal data protection. Therefore, NAIVE has taken appropriate measures to ensure Personal information is handled according to applicable EU data protection rules.
In particular, NAIVE relies upon 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 can be obtained upon request.
9. For how long do we store your Personal information
NAIVE will only keep your Personal information for as long as it is necessary to fulfil the purpose for which it was collected or to comply with legal and regulatory requirements.
Unless otherwise legally required or agreed, the emails and documents, which are stored by you on our systems as part of the Service, will remain stored as long as you have an account with us, but you can delete them at any time.
If you wish to have any Personal information removed from our databases, you can have it removed via your NAIVE account or using interface of the Sites or Services (where applicable).
10. Your rights
10.1 What are your rights
If it is provided by applicable law, you have a right of access to your Personal information as processed by NAIVE under this Policy.
If you believe that any information we hold about you is incorrect or incomplete, you can log in to your user account and correct your Personal information yourself.
If it is provided by applicable law, you also have the right to:
- request erasure of your Personal information;
- request the restriction of the processing of your Personal information;
- request a copy of the Standard Contractual Clauses enabling the transfer of your Personal information to Russia, referred to in Section 8 hereof;
- object to the processing of your Personal information if it is provided by applicable law.
NAIVE will honour any such requests or objections as required under applicable law.
To the extent provided by applicable law, you may be subject to other rights not specifically mentioned herein.
10.2 How can you exercise your rights
To exercise the above rights, please log in to your user account, which will provide you with the option to do so, or in case of absence of special function in user account interface please contact NAIVE (see Section 13 hereof).
If you are not satisfied with how NAIVE processes your Personal information, please let us know and we will investigate your concern. If you are not satisfied with NAIVE’s response, you have the right to make a complaint to the competent data protection authority.
11.1 What are cookies and what does NAIVE use them for Cookies are small text files placed on the device you use to access our Sites. They contain information that is collected from your device and sent back to the Sites on each subsequent visit so as to remember your actions and preferences over time.
The following types of cookies are used on the Sites:
- strictly necessary cookies / technical cookies: these cookies are required to run the Sites and provide you with the Services and may, among other, allow NAIVE to identify your hardware and software, including your browser type;
- statistical / analytic cookies: these cookies enable us to recognise users, count the number of users and collect information such as your actions on the Sites and the Services, including the web pages you visit and the content you retrieve;
- performance cookies: these cookies collect information about how users interact with our Sites and Services, enabling us to identify errors and test new functionalities to improve the performance of the Sites and the Services;
- functionality cookies: these cookies enable us to provide specific functionalities in order to improve your experience on the Sites, for example by storing your preferences (e.g. language and location);
- (third party) tracking / advertising cookies: these cookies collect information about users, sources of traffic, page visits and advertising displayed to you and followed by you. They enable us to display advertising which may be of interest to you based on collected Personal information. These cookies are also used for statistical and research purposes.
11.2 How long are those cookies stored on your device
NAIVE only uses the information contained in the cookies for the above purposes, after which the data collected will remain stored on your device for a period that may depend on cookies type, but no longer than necessary to achieve their purpose and will be automatically removed from your system thereafter.
11.3 Who else has access to the information contained in the cookies
Personal information collected through cookies placed on your device may be transmitted to and accessed by NAIVE or the third parties referred to in Section 7 hereof. The use of Personal information outside of the Sites for advertising purposes, if any, may be subject to separate policies available on the above third parties’ websites. NAIVE or those third parties might also provide you with a possibility to opt out of receiving targeted advertising, which shall be subject to laws and regulations applicable to such products, utilities and offerings.
NAIVE may also use web beacons (pixel tags) in order to access the cookies previously placed on your computer for the following purposes:
- (i) to track your actions on the Sites and when using the Services, by accessing and interacting with the cookies stored on your computer;
- (ii) to collect statistical information related to operating the Sites, the Services or products, utilities, advertisements or other NAIVE offerings.
12. Updates to this Policy
This Policy may be subject to amendments. NAIVE shall be entitled to make such amendments at its own discretion, including, without limitation, to reflect changes in applicable legislation or amendments to the Sites and/or Services.
13. Questions and Suggestions
We welcome your questions or suggestions concerning implementation of or amendments to this Policy. To contact us please use this feedback form: [email protected]
You can also use this form to exercise your rights or report any inaccuracies in your Personal information or protest its processing.