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1. General provisions

1.1. This Policy is an official document of Mail.Ru Limited Liability Company (official state registration
number 1027739850962, Russia, 125167, Moscow, Leningradskiy prospekt 39, building 79) (hereinafter,
the «Administration of the Social Network»), and outlines the procedure for the processing and protection of
information (hereinafter, «Information») about individuals (hereinafter, «Users») using the OK social network,
including the website, mobile version of the website and application, and OK Live application (hereinafter,
«Social Network»).

1.2. The purpose of this Policy is to ensure the sufficient protection of information about Users,
including their personal data, against unauthorized access and disclosure.

1.3. Matters pertaining to the collection, storage, dissemination and protection of information about
Users of the Social Network are regulated by this Policy and the License Agreement (jointly referred to
hereinafter as the «Rules»), in addition to the current legislation of the Russian Federation.

1.4. The use of the Social Network is subject to the User's agreement to the Rules. Each instance of
accessing and/or actual use of the Social Network constitutes the User's agreement to the terms of this Policy
and the terms of the License Agreement available at https://ok.ru/regulations (hereinafter,
the «Agreement») as of their version current at the moment of actual use of the Social Network. Some terms used
in this Policy have the meaning set forth in the License Agreement.

1.5. The current version of the Policy is available to any Internet user via the http://ok.ru/privacy link. This Policy may be amended
by the Administration of the Social Network. Any amendments to this Policy are made by the Administration of the
Social Network at its own discretion, and come into effect on the day following the day of publication of such
amendments. The User is obliged to independently familiarize themselves with any amendments made to this Policy.
Actual use of the Social Network by the User after the amendment of the terms of this Policy constitute the
User's agreement to the new terms.

1.6. Should the User not agree to the terms of this Policy, they must cease their use of the Social
Network immediately.

2. Terms of use of the Social Network

2.1. The Administration of the Social Network, which provides Users with a license to use the Social
Network to the extent described in the Agreement, acting in a reasonable manner and good faith, considers that
the User:

 

2.2. The Administration of the Social Network does not check the reliability of received (collected)
information about Users, with the exception of those cases where such a check is required to fulfill the
obligations of the Administration of the Social Network to the User.

3. Purpose of information processing

The Administration processes information about Users, including but not limited to their personal data, for the
purposes of fulfilling the agreement concluded with the User (the License Agreement available at https://ok.ru/regulations).

4. Content of information about Users

4.1. Information processed by the Administration of the Social Network includes:

4.1.1. Account Data to be understood as:

(a) the User's data provided by the User for the purpose of creating an account at the time of registration with
the Social Network;

(b) additional information entered by the User for the purpose of editing their account in the course of using
the Social Network;

© data additionally provided by the User at the request of the Administration of the Social Network for the
purposes of fulfilling the Company's obligations to the User arising out of the agreement on the provision of
the Social Network functionality.

The Account Data received by the Administration of the Social Network in the amount as necessary and sufficient
for such data to be considered personal data in accordance with the current legislation of the Russian
Federation shall be processed by the Administration of the Social Network as personal data pursuant to this
 Policy.

4.1.2. Any Other Data required for the Social Network functioning that do not constitute personal data,
including but not limited to:

(a) data regarding technical equipment (devices), technological interaction with the Social Network (including
host IP address, the User's operating system, browser, geographical location, Internet Service Provider);

(b) information obtained automatically by accessing the Social Network using bookmarks (cookies);

© information created by Users on the Social Network outside of the account editing;

(d) information obtained as a result of the User's actions on the Social network, including but not limited to information about adding any content;

(e) information obtained as a result of the actions of other Users on the Social Network;

(f) summarized analytical information on the use of Internet-based services.

4.2. The below table contains a list of Account Data and Other Data processed by the Administration of the Social Network for the purposes of fulfilling the agreement concluded with the Users:

Information collected

Purpose of processing

Applicable to all platforms (web version, Android and iOS applications) when using the Social Network

Account Data (personal data), i.e.

1) the User's data provided by the User for the purpose of creating an account at the time of registration with the Social Network: first name, last name, date of birth, gender, mobile phone number;

2) additional information entered by the User for the purpose of editing their account in the course of using the Social Network: email, marital status, place of birth, current city of residence, education and career information, location of military service, images;

3) data additionally provided by the User at the request of the Administration of the Social Network (information specified by the User in the account, such as first name, last name, email, phone number, images; information on the statutory representative of the applicant (last name, first name, patronymic, grounds for statutory representation)).

To fulfill the agreement concluded with the User, including but not limited to the provision of access to, management and administration of the Social Network, verification of the Social Network account belonging to the applicant who requested to restore access to the account.

The phone number of the User is transferred to the service https://clientapi.mail.ru, the owner of which is the company for validation of the User's phone number.

Other Data (other than personal data), i.e.

4) information about the User's activities when using the Social Network, including but not limited to clicks and transitions within the Social Network interface, information about joining/leaving groups, adding other Users to friends list, participation or refusal to participate in meetings;

5) information obtained as a result of the actions of other Users on the Social Network (including but not limited to tags made on videos and photos by other Users).

(f) summarized analytical information on the use of Internet-based services.

To fulfill the agreement concluded with the User, including but not limited to management, administration, improvement and personalization of the Social Network.

Web version of the Social Network (https://ok.ru/)

Other Data (other than personal data), i.e.

6) technical data obtained by accessing the Social Network, including data regarding technical equipment (devices), technological interaction with the Social Network (including host IP address, user's operating system, browser, geographical location, Internet Service Provider, data obtained from accessing the camera, microphone, and other devices), and the subsequent User actions on the Social Network;

7) information obtained automatically by accessing the Social Network using bookmarks (cookies).

To fulfill the agreement concluded with the User, including but not limited to management, administration, improvement and personalization of the Social Network.

OK Android application

Other Data (other than personal data), i.e.

8) data accessible by the Administration of the Social Network in the course of using the application by the User, including but not limited to the device type (Smartphone/Tablet/Wear), device name, GAID, OpenUDID, OS version, device model, time zone, preferred language, list of the User's accounts, phone numbers linked to the accounts, Device ID For Vendor, Wi-Fi name, MAC of Wi-Fi access point, mobile operator name, mobile network code (MNC), User ID, OS name, application version, year of manufacture of the User's mobile device, type of Internet connection, Apps Flyer UID.

To fulfill the agreement concluded with the User, including but not limited to management, administration, improvement and personalization of the Social Network.

OK iOS application

Other Data (other than personal data), i.e.

9) data accessible by the Administration of the Social Network in the course of using the application by the User, including but not limited to the device type (Smartphone/Tablet/iPod), device name, IDFA, Open UDID, Apps Flyer UID, OS version, device model, data from address books of the User (on a mobile device and in applications), time zone, preferred language, list of the User's accounts, phone numbers linked to the accounts, Device ID For Vendor, geographical values, Wi-Fi name, MAC of Wi-Fi access point, mobile operator name, mobile network code (MNC), applications installed on the User's device.

To fulfill the agreement concluded with the User, including but not limited to management, administration, improvement and personalization of the Social Network.

Applicable to all platforms (Android and iOS applications) when using the OK Live application

Account Data (personal data), i.e.

10) the User's data provided by the User for the purpose of creating an account at the time of registration with OK Live: mobile phone number;

11) data additionally provided by the User at the request of the Administration of the Social Network (information specified by the User in the account, such as first name, last name, email, phone number, images; information on the statutory representative of the applicant (last name, first name, patronymic, grounds for statutory representation)).

To fulfill the agreement concluded with the User, including but not limited to the provision of access to, management and administration of the application, verification of the Social Network account belonging to the applicant who requested to restore access to the account.

OK Live Android application

Other Data (other than personal data), i.e.

12) data accessible by the Administration of the Social Network in the course of using the application by the User, including but not limited to the device type (Smartphone/Tablet/Wear), device name, GAID, OpenUDID, OS version, device model, time zone, preferred language, list of the User's accounts, phone numbers linked to the accounts, Device ID For Vendor, Wi-Fi name, MAC of Wi-Fi access point, mobile operator name, mobile network code (MNC), User ID, OS name, application version, year of manufacture of the User's mobile device, type of Internet connection, Apps Flyer UID.

To fulfill the agreement concluded with the User, including but not limited to management, administration, improvement and personalization of the application.

OK Live iOS application

Other Data (other than personal data), i.e.

13) data accessible by the Administration of the Social Network in the course of using the application by the User, including but not limited to the device type (Smartphone/Tablet/iPod), device name, IDFA, Open UDID, Apps Flyer UID, OS version, device model, time zone, preferred language, list of the User's accounts, phone numbers linked to the accounts, Device ID For Vendor, geographical values, Wi-Fi name, MAC of Wi-Fi access point, mobile operator name, mobile network code (MNC), applications installed on the User's device.

To fulfill the agreement concluded with the User, including but not limited to management, administration, improvement and personalization of the application.

4.3. The functionality and rules of use of the Social Network may permit the User to post any information
on the Social Network (if applicable) other than that specified in Clauses 4.1 and 4.2 of this
Policy, if not contrary to current legislation requirements. The Administration of the Social Network does not
intend to process biometric and sensitive data. By posting information about themselves, the User understands
that such information may be accessible by an unspecified amount of the Internet users according to the User's
preferred level of confidentiality.

4.4. The Company does not intend to process and does not process biometric data (including but not limited
to the use of images to identify users) and sensitive data.

5. Processing of information about User

5.1. Information about Users is processed in accordance with the following principles:

a) legality of the purposes and methods of processing personal data;

b) good faith;

c) correspondence of the purpose of such data processing to the purposes defined and stated before its
collection, and to the authority of the Administration of the Social Network;

d) correspondence of the amount and nature of Account Data and Other Data processed, and the methods of their
processing to the purposes of processing Account Data and Other Data;

e) the unacceptability of unifying databases created for incompatible purposes and which contain Account Data and
Other Data.

5.1.1. Terms and purposes of Account Data and Other Data processing

The Administration of the Social network processes Account Data and Other Data of the User for the purposes of
fulfilling the Agreement between the Administration of the Social Network and the User on issuing a license for
the right to use the Social Network (Section 3 of the License Agreement, https://ok.ru/regulations).

5.1.2. Collection of Account Data and Other Data

The collection of Account Data of the User is performed during registration on the Social Network, as well as
afterwards when the User chooses to add additional information about themselves using the tools provided by the
Social Network. The collection of Other Data of the User is performed in the course of using the Social Network
by the User.

5.1.3. Storage and use of Account Data and Other Data

Account Data and Other Data of Users are processed and stored within the Russian Federation; they are stored
exclusively on electronic media and processed using automated systems, with the exception of such cases where
non-automated processing of Account Data and Other Data is necessary to comply with legislation
 requirements.

Account Data and Other Data are stored by the Administration of the Social Network until the processing purposes
have been achieved, i.e. within the effective term of the Agreement concluded with the User.

In the case of deletion of a Personal Page, the Administration of the Social Network stores the necessary Account
Data and Other Data of the User on its electronic media for the period required and established by the current
legislation of the Russian Federation. In the event of the User themselves deleting their Personal Page, the
User has the right to restore their Personal Page within 183 days of the moment of its deletion.

5.1.4. Transfer of Account Data and Other Data

Account Data and Other Data of Users is not transferred to any third parties, with the exception of the cases
directly specified by these Rules. With the consent of the User, the User's data may be transferred to
third-party co-contractors of the Administration of the Social Network under the condition that said
co-contractors accept the obligation to ensure the confidentiality of the information received. This includes
but is not limited to applications made available and supported on the Social Network by third parties
(developers) that operate independently from the Administration of the Social Network and do not represent or
act on behalf of the Administration of the Social Network. Users are obligated to independently familiarize
themselves with the terms of service and personal data protection policies of such third parties (developers)
before using the corresponding applications.

The provision of personal data of Users at the request of government bodies (and local government bodies) is
performed in accordance with the legislation.

Taking into account the aforementioned, and also taking into account the Company's compliance with the processing
purposes specified in section 3 of this Policy, the User agrees and instructs the Company to implement, as well
as instruct affiliated entities and partners to carry out processing, including collection, recording,
systematization, accumulation, storage, clarification (update, change), collation, extraction, use,
depersonalization, blocking, deletion and destruction of the User's Credentials and Other Data, instruct
affiliates and partners to process (by methods specified) the data at their disposal and necessary to achieve
the above aims, including the results of their automated processing, including in the form of integer and/or
text values and identifiers, agrees to the transfer of credentials and other data by the Company to affiliates
and/or partners in pursuance of such an order for processing, as well as with the collection (receipt) from
affiliates and/or partners and joint processing of the User's credentials and other data, as well as data
received from affiliates and partners as a result of fulfilment of the above order.

With regards to the clause of the Policy, affiliates and partners are understood to be entities ensuring
fulfillment of contractual obligations of the Company to Users and/or entities rendering independent services to
Users and providing legal grounds for processing of Users' data for the purpose of implementation of the
agreements concluded with the Company.

5.1.5. Cessation of Account Data and Other Data processing

Upon achievement of the purposes of processing Account Data and Other Data, the Administration of the Social
Network stops processing such Account Data and Other Data using one of the methods stipulated by the Federal Law
«On Personal Data».

6. Rights and responsibilities of the User

6.1. Users have the right to:

6.1.1. obtain open and free access to information about themselves by means of loading their Personal Page
on the Social Network via their username and password;

6.1.2. set their desired level of confidentiality (terms of access to information) using the tools of the
Social Network subject to the tools of the Social Network in accordance with Clause 6.3 of this Policy;

6.1.3. individually make amendments and corrections to information about themselves on their User Personal
Page on the Social Network on the condition that such amendments and corrections contain current and reliable
 information;

6.1.4. delete information about themselves from their Personal Page on the Social Network;

6.1.5. request from the Administration of the Social Network: correction, blocking or destruction of their
Account Data in the event of such data being incomplete, outdated, unreliable, illegally obtained or being
unnecessary to the stated purpose of processing, or if the User cannot individually take the measures specified
in Clauses 6.1.3. and 6.1.4. of this Policy;

6.1.6. request and receive information from the Administration of the Social Network regarding their
Account Data processing.

6.2. As the Social Network is a universal means of communication and finding people, and the main function
of the Social Network is the restoration and support of communication between old and new acquaintances, the
following information about a registered User is available to the Internet users:

6.2.1. the User's first and last names, date of birth (without year), place of birth and current city of
 residence;

6.2.2. profile picture;

6.2.3. the User's number of friends, photos, groups, games, videos and gifts.

6.3. User settings for the level of confidentiality of information about themselves:

6.3.1. The User has the right, subject to the restrictions stated in Clause 6.2 of these Rules, to
set one of the following levels of confidentiality for their Account Data:

a) information is available to all Users of the Social Network;

b) information is available only to those who are classified as friends of the User on the Social Network;

c) information is available to the User only.

6.3.2. In regard to the information recognized in Clause 6.2 of these Rules, the User has the right
to set one of the following levels of confidentiality:

a) information is available to all the Internet users and is indexed by search engines;

b) information is not available to the Internet users and is not indexed by search engines.

6.3.3. The Administration of the Social Network does not assume responsibility for the disclosure of
Users' Account Data by other Users of the Social Network that obtained access to such data in accordance with
the User's selected level of confidentiality.

6.3.4. Upon deletion of Account Data (other user information) from the Personal Page of the User, or the
deletion of a Personal Page from the Social Network by the User, information about the User copied by other
Users or stored on the pages of other Users is saved.

7. Measures to ensure the security of information about Users

7.1. The Administration of the Social Network adopts technical, organizational and legal measures to
facilitate the protection of Account Data and Other Data of Users from illegal or accidental access,
destruction, alteration, blocking, copying, dissemination and other illegal actions.

7.2. Authorized access to the Social Network requires the username (email or mobile phone number) and
password of the User. The User assumes responsibility for the security of this information. The User does not
have the right to share their username or password with third parties, and is obliged to take measures to ensure
their confidentiality.

7.3. For the purposes of ensuring more reliable protection of information about Users, the Administration
of the Social Network uses a system linking Personal Pages to mobile phones. To enable the operation of this
system, the User must provide the Administration of the Social Network with their mobile phone number. As part
of this system linking Personal Pages to mobile phones, the User may restore access to their Personal Page in
the event of the loss of their username or password using a recovery code (in a text message) sent to their
mobile phone.

For the purposes of registration of the User on the Social Network, their authorization, verification of the
current phone number linked to the Personal Page, and restoration of access to the Personal Page, the
Administration of the Social Network may also make a call to the User's phone number and hang up. Upon receipt
of such a hung-up call, the User is required to enter the code in the corresponding field, i.e. several last
digits of the phone number from which such hung-up call was received. Depending on the operating system of the
User's mobile device, the code may be imported to the corresponding field automatically. Hung-up calls are
subject to the User's preliminary consent obtained at the time of registration and use of the Social Network to
the provision of access to the call history on the User's mobile device to the Administration of the Social
Network. Such access to the call history on the User's mobile device is only used for the purpose of the code
importing when using the hung-up call function and protection from spam and mass registrations.

8. Limitation of liability of the Administration of the Social Network

8.1. The Administration of the Social Network does not assume responsibility for any actions of third
parties accessing information about the User as a result of using the Internet or the Social Network in
accordance with the User's selected level of confidentiality, or for the consequences of using information
which, as part of the Social Network, is available to any Internet user. The Administration of the Social
Network advises Users to take a responsible approach to the amount of information they share about themselves on
the Social Network.

9. User communication

9.1. The Administration of the Social Network provides the User or their representative with information
on Account Data and Other Data processed by the Administration of the Social Network, included but not limited
to the User's personal data, upon request.

9.2. Such requests shall be sent in writing to the location address of the Administration of the Social
Network or in any other form stipulated by the current legislation of the Russian Federation.

9.3. The User may revoke their consent to the processing of their personal data by sending an application
in writing to the location address of the Administration of the Social Network in accordance with current
legislation requirements.

Version dated September 8, 2020