Privacy Policy

This Privacy Policy (hereinafter – «Policy») covers any information about users that may include personal data as defined by applicable laws and regulations (hereinafter – «Personal information»), which Sole Proprietor Ordin Ilya Yuryevich, PSRNSP (Primary State Registration Number of the Sole Proprietor) 313370219700017 (hereinafter – «Administration») may obtain when you use website, which is available at https://englika.com (hereinafter – the «Site») and/or the Englika mobile application, which is available in the App Store and Google Play (hereinafter – the «App»), and as well as during the performance of any contract or agreement Administration concludes with you in relation to your using the Site and/or the App.

The use of the Site and/or the App is also shall be regulated by Google Privacy Policy, which is available at https://policies.google.com/privacy.

To provide you with access to the Site and/or the App, your Personal information is collected and used by Administration.

1. Purpose of this Policy

Privacy and security of your Personal information are extremely important to Administration. When you use the Site and/or the App, Administration 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:

Why and how your Personal information is collected and used (processed) by Administration when you access the Site and/or the App.
Administration’s role and responsibilities in this context as the legal entity deciding why and how your Personal information is processed.
What instruments you may use to limit the amount of Personal information collected by Administration.
What your rights are in relation to the processing of Personal information.

2. What type of Personal information is collected by Administration

Personal information collected when you use the Site and/or the App may differ depending on whether you access the Site and/or the App while logged in to your user account or without logging in.

Administration does not verify Personal information provided by you unless otherwise provided in the User Agreement or Terms of Use, and does not decide the its credibility or whether you have the legal capacity required. Administration assumes that the information you provide is true, sufficiently complete and up-to-date.

Personal information collected by Administration when you access, interact with or operate the Site and/or the App includes:

Information provided by you when you register a user account (email address, first name, last name, etc).
Electronic data: HTTP headers, IP address, cookies, web beacons/pixel tags, browser information, information about your hardware and software.
Date and time of accessing the Site and/or the App.
Information related to your activity when using the Site and/or the App.

Administration uses cookies and web beacons/pixel tags to collect your Personal information and associate this Personal information with your device and web browser.

Administration does not actively collect any sensitive personal data, such as racial origins, political opinions, health or biometric data.

3. Legal basis and purposes of Personal information processing

Administration will therefore only process your Personal information if:

The processing is necessary to perform our contractual obligations towards you including providing you with the Site and/or the App.
The processing is necessary to comply with our legal or regulatory obligations.
The processing is necessary for the legitimate interests of Administration and does not unduly affect your interests or fundamental rights and freedoms.

Examples of such «legitimate interests» referred in immediately above are:

To better understand how you interact with the Site and/or the App.
To enhance, maintaining accessibility, modify, personalize or otherwise improve the Site and/or the App for the benefit of all users.
For specific purposes or if consent is required under the applicable laws and regulations, we may ask your consent for processing of your Personal information. In those jurisdictions in which consent is the legal basis, you provide such consent by agreeing to use the Site and/or the App. We hereby inform you, and you hereby acknowledge, that you have no legal obligation to provide us with any Personal Information when you use the Site and/or the App, and the provision of it is solely based on your free will. However, you are aware that without the provision of Personal Information, we will not be able to provide you with the App and your use of the Site will be limited.

Administration 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:

To provide you with the Site and/or the App.
To provide you with access to your user account.
To contact you to notify and/or inform you or request information from you in relation to the Site and/or the App, or to execute our agreements with you or process your request or application.
To improve user experience of the Site and/or the App.
To protect your rights and the rights of Administration.

4. How Administration protects your Personal information

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 Administration 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.

5. Who has access to your Personal information and who is it shared with

Administration may transfer your Personal information with its employees (within the limits set out in Section 4 this Policy). Administration may also transfer Personal information to third parties to complete the purposes listed in Section 3 this Policy.

Please note that the level of protection of Personal Information in some countries may not be identical to the level in your jurisdiction and by using the Site and/or the App you consent to such transfer.

Such third parties may include:

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.
Third parties if you expressed your consent to such transfer or transfer of your Personal information is required for the Site and/or the App to work or performance of a particular agreement or contract with you.
Any third party to ensure legal protection for Administration and/or the third parties if you violate the User Agreement, this Policy or the Terms of Use, or if there is a threat of such violation.

6. Where your Personal information is stored and processed

Administration stores Personal information in the Russian Federation and/or in the European Economic Area.

If you are located in a jurisdiction where transfer of your Personal Information to another jurisdiction requires your consent, then by using the Site and/or the App you provide Administration with your express and unambiguous consent to such transfer, storage, and processing of the information in other jurisdictions, including Russia.

7. How long we store your Personal information

Administration 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.

If you wish to have any Personal information removed from our databases, you can have it removed using interface of the Site and/or the App.

8. What are your rights

If it is provided by applicable law, you have a right of access to your Personal information as processed by Administration 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 or certain parts of it. Administration will honour any such requests or objections as required under applicable law.

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 Administration (see Section 11 hereof).

9. How we use cookies

9.1. What are cookies and what does Administration use them for

A cookie is a small piece of data stored on the user's computer by the web browser while browsing a website. Cookies were designed to be a reliable mechanism for websites to remember stateful information (such as what language do you prefer to view the website in).

The following types of cookies are used on the Site:

Strictly necessary cookies / technical cookies. These cookies are required to run the Site and may, among other, allow Administration 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 Site, including the web pages you visit and the content you retrieve.
Performance cookies. These cookies collect information about how users interact with the Site, enabling us to identify errors and test new functionalities to improve the performance of the Site.
Functionality cookies. These cookies enable us to provide specific functionalities in order to improve your experience on the Site. For example by storing your preferences, such as your language.
Tracking cookies (third party). These cookies collect information about users, sources of traffic, page visits, etc. These cookies used for statistical and research purposes.

9.2. How long are those cookies stored on your device

Administration 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, and will be automatically removed from your system thereafter.

9.3. Who 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 Administration or the third parties referred to in Section 5 hereof.

The first time that you access the Site, your approval for the use of these cookies may be requested. If after you have approved the use of cookies you want to make another choice, you can do this by deleting the cookies stored by your browser. The popup requesting your approval may then show up again and you can make a different choice. If you do not consent to the use of cookies, certain features of the Site might become unavailable, which may affect your browsing experience.

Administration may also use web beacons/pixel tags in order to access the cookies previously placed on your computer for the following purposes:

To track your actions on the Site, by accessing and interacting with the cookies stored on your computer.
To collect statistical information related to operating the Site.

10. Updates to this Policy

This Policy may be subject to amendments. Administration shall be entitled to make such amendments at its own discretion, including, without limitation, to reflect changes in applicable legislation or amendments to the Site and/or the App.

11. Contacts

If you have any questions related to this Policy, please contact us by email support@englika.com. You can also use this email address to exercise your rights or report any inaccuracies in your Personal information or protest its processing.