Privacy Policy
Registering on SMMplanner Service, User (natural person) decides to provide his/her personal data to Administrator and gives consent to personal data processing by Administrator in accordance with principles, for the purposes and by means defined in this document (hereinafter as Policy).
If User refuses to provide requested personal data, registration on Service cannot be completed.
Terms used in Policy shall be construed in the meaning as defined in User Agreement.
If User refuses to provide requested personal data, registration on Service cannot be completed.
Terms used in Policy shall be construed in the meaning as defined in User Agreement.
General Provisions
User grants Administrator the right to process personal data with or without automation means, including Internet. Processing includes: collection, recording, systematization, accumulation, storing, specifying (updating, modification), copying, extraction, using, transfer (dissemination, provision, access), depersonalization, blocking, deleting and removing of personal data. In relation to the purposes of processing, User agrees to ensure accuracy, sufficiency and, if necessary, actuality of Personal data provided by Administrator.
Processing includes: collection, recording, systematization, accumulation, storing, specifying (updating, modification), copying, extraction, using, transfer (dissemination, provision, access), depersonalization, blocking, deleting and removing of personal data.
In relation to the purposes of processing, User agrees to ensure accuracy, sufficiency and, if necessary, actuality of Personal data provided by Administrator.
Processing includes: collection, recording, systematization, accumulation, storing, specifying (updating, modification), copying, extraction, using, transfer (dissemination, provision, access), depersonalization, blocking, deleting and removing of personal data.
In relation to the purposes of processing, User agrees to ensure accuracy, sufficiency and, if necessary, actuality of Personal data provided by Administrator.
Scope of Processed Information
Processed information includes:
Technical and statistical information:
- Personal information provided by User itself, including: name, email, payment information and other data.
Technical and statistical information:
- IP address of User's computer, location and time of access;
- Information provided by User's web-browser, including, type of device, version of the web-browser, operational system, data from referring web-site et al.;
- Information on User's actions on Service.
Purposes of Personal Data Processing
Purpose of User's personal data processing is that Administrator performs properly its obligations to User under User Agreement entered by Administrator and User.
User agrees that Administrator is entitled to use his/her personal data for the purposes to:
User agrees that Administrator is entitled to use his/her personal data for the purposes to:
- Transfer personal data to payment systems and paying agents when payment is made within Service's functions;
- Implement partner and other programs related to distribution of advertising information via email, phone and other possible means;
- Compare personal information to confirm its accuracy and to be inspected by the third parties in cases stipulated by the law;
- Prevent cases of fraud and of other abuse, and investigate these cases;
- Perform statistic and other research based on depersonalized data;
- Settle disputes, collect feedbacks and find defects;
- Improve quality of Service performance, its usability, and develop new functions.
Principles of Personal Data Processing
Administrator shall act on the basis of the following principles:
- Lawful and fair processing of personal data.
- Personal data processing in accordance with specific, pre-determined and legitimate purposes.
- No interconnection of databases with personal data processed for the purposes incompatible with each other.
- Compliance of personal data scope and volume with stated purposes of processing.
- Accuracy, sufficiency, actuality and authenticity of personal data.
- Legitimacy of technical measures to process personal data.
- Reasonable and practicable processing of personal data.
- Storage of personal data for no longer than required by the purposes of processing or during the term of User's consent.
- Processed personal data shall be removed or depersonalized after the purposes of processing are achieved or there is no need in these purposes anymore.
Processing of Personal Data
Administrator shall process personal data upon User's consent and at its own efforts and expenses or with outsourcing.
Processing of User's personal data starts from the moment of its obtaining.
Personal data are collected by the following means:
Personal data storing and using:
User's personal data are stored exclusively on duly protected electronic mediums and processed by automated systems, except cases, when non-automated processing of personal data is requied by the Russian Federation law.
During personal data processing, Administrator shall ensure using of databases located on the territory of the Russian Federation.
User's personal data are stored on Administrator's server for thirty six months months from the moment of its obtaining.
Transfer of personal data. Administrator shall not transfer personal data to the third parties without User's consent, except cases, when the information is public or transfer is required:
Removing of personal data. Administrator is entitled to remove User's personal data if:
Processing of User's personal data starts from the moment of its obtaining.
Personal data are collected by the following means:
- Subjects provide their personal data by filling corresponding fields on Service.
- Information on User is collected automatically through technologies and services: web-protocols, cookie files, tags launched only when User enters his/her data.
Personal data storing and using:
User's personal data are stored exclusively on duly protected electronic mediums and processed by automated systems, except cases, when non-automated processing of personal data is requied by the Russian Federation law.
During personal data processing, Administrator shall ensure using of databases located on the territory of the Russian Federation.
User's personal data are stored on Administrator's server for thirty six months months from the moment of its obtaining.
Transfer of personal data. Administrator shall not transfer personal data to the third parties without User's consent, except cases, when the information is public or transfer is required:
- To ensure compliance with requirements of the Russian Federation law, as well as to prevent, restraint User's unlawful actions and protect legal interests of Administrator and third parties.
- By publiс authorities to comply with the Russian Federation law.
- For service providers to perform obligations under corresponding agreement, subject to they observe terms of personal data processing set forth in the Policy.
Removing of personal data. Administrator is entitled to remove User's personal data if:
- Server's security is under threat;
- User breaches provisions of User Agreement;
- User sends a request to the Administrator's email.
User's Rights
Users is entitled to obtain information on his/her personal data processing including:
User is entitled to revoke his/her consent to personal data processing, by deleting his/her Account or writing to Administrator to email: order@smmplanner.com.
- Confirmation of the personal data processing;
- Legal basis for personal data processing;
- Purposes and used by Administrator methods of personal data processing;
- Information on persons, to which personal data can be disclosed under agreement with Administrator or in accordance with the Russian Federation law;
- Other information stipulated by the Russian Federation law.
User is entitled to revoke his/her consent to personal data processing, by deleting his/her Account or writing to Administrator to email: order@smmplanner.com.
Administrator's Obligations
In accordance with requirements of Federal Law On Personal Data, Administrator shall:
Upon User's request, provide information related to his/her personal data processing or provide User with reasonable refusal.
Take measures, necessary and sufficient to ensure performance of obligations defined by Federal Law On Personal Data.
Upon User's demand, specify processed personal data, block or remove them, if personal data are incomplete, outdated, inaccurate, obtained unlawfully or are not necessary for the stated purposes of processing.
If User revokes its consent to personal data processing, stop the processing and remove personal data not later than Thirty days from the moment of receiving of said revoke, except cases, when the processing could be proceeded in accordance with the legislation.
Upon User's request, provide information related to his/her personal data processing or provide User with reasonable refusal.
Take measures, necessary and sufficient to ensure performance of obligations defined by Federal Law On Personal Data.
Upon User's demand, specify processed personal data, block or remove them, if personal data are incomplete, outdated, inaccurate, obtained unlawfully or are not necessary for the stated purposes of processing.
If User revokes its consent to personal data processing, stop the processing and remove personal data not later than Thirty days from the moment of receiving of said revoke, except cases, when the processing could be proceeded in accordance with the legislation.
Limitations on Policy's Scope
Policy covers exclusively Service and shall not be applied to other web-sites.
User shall be careful and responsible when placing his/her own personal data on Service. Administrator is not liable for the actions of the third parties that obtain access to User's personal data through the fault of the latter.
User shall be careful and responsible when placing his/her own personal data on Service. Administrator is not liable for the actions of the third parties that obtain access to User's personal data through the fault of the latter.
Final Provisions
The text of Policy is prepared in accordance with current legislation of the Russian Federation on personal data.
Administrator is entitled to change text of Policy. Date of the latest update shall be pointed in the latest edition, if any changes are made.
Policy is made in Russian language and may be provided in English for User's guidance. If there are any controversies between Russian text and the text in any other language, provisions of Policy in Russian shall prevail.
Contact information and details:
Dmitry Yurievich Bashkatov, sole proprietor
OGRNIP 315774600243562 / INN 121522926545
Address: 3 Sredny Ovchinnikovsky Lane, Office 304, 115184, Moscow, Russia
Tel.: +7 (499) 348 22 71
Administrator is entitled to change text of Policy. Date of the latest update shall be pointed in the latest edition, if any changes are made.
Policy is made in Russian language and may be provided in English for User's guidance. If there are any controversies between Russian text and the text in any other language, provisions of Policy in Russian shall prevail.
Contact information and details:
Dmitry Yurievich Bashkatov, sole proprietor
OGRNIP 315774600243562 / INN 121522926545
Address: 3 Sredny Ovchinnikovsky Lane, Office 304, 115184, Moscow, Russia
Tel.: +7 (499) 348 22 71
Publication date of current edition: 16.04.2018
SMMplanner California Resident Privacy Notice
This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under California law.
1. Personal Information Collection, Disclosure, and Sale
For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time ("CCPA").
Personal Information does not include information that is:
Personal Information does not include information that is:
- Lawfully made available from government records.
- De-identified or aggregated.
- Otherwise excluded from the scope of the CCPA.
In the preceding twelve months, we have not sold any California resident's Personal Information.
2. Use of Personal Information
We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:
- Providing Services: Providing our services.
- Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.
- Social Network Support: Updating your status on social networks, sending messages on your behalf to your social networks, and providing other features and services to you.
- Connecting Third Party Services: Facilitating the connection of third-party services or applications, such as social networks.
- Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.
- Personalization: Personalizing your experience on our services such as presenting tailored content.
- Facilitating Payments: Facilitating transactions and payments.
- De-identification and Aggregation:De-identifying and aggregating information collected through our services and using it for any lawful purpose.
- Safety Issues: Responding to trust and safety issues that may arise.
- Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
- Auditing Interactions: Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging: Debugging to identify and repair errors that impair existing intended functionality.
- Transient Use: Short-term, transient use.
- Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
- Research: Undertaking internal research for technological development and demonstration.
- Product Improvement: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.
- Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.
- Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.
3. Collection and Disclosure of Personal Information
In the preceding twelve months since this notice was last updated, we have collected Personal Information from the following categories of sources:
Pursuant to our Privacy Policy, we may share your Personal Information with the following categories of third parties:
- You/Your Devices: You or your devices directly.
- Users: Other users on our service.
- Partners: Business partners.
- Public: Publicly accessible sources.
Pursuant to our Privacy Policy, we may share your Personal Information with the following categories of third parties:
- ISPs: Internet service providers.
- Analytics Providers.
- OS/Platform Provider: Operating systems and platforms.
- Social Networks.
- Affiliates.
- Vendors: Vendors and service providers.
- Integrated Third Parties: Third parties integrated into our services.
- Third Parties as Legally Required: Third parties as required by law and similar disclosures.
- Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.
- Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.
4. Your California Privacy Rights
If you are a California resident, you may exercise the following rights.
Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you during the past twelve months.
Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please provide us with the email address associated with your SMMplanner account.
Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
Shine the Light. You may request information once per calendar year about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us in writing using the Contact Information section below.
Submit Requests. To exercise your rights under the CCPA, please contact us by email at support@smmplanner.com or write to us at the following address:
Dmitry Yurievich Bashkatov, sole proprietor
OGRNIP 315774600243562 / INN 121522926545
Address: 3 Sredny Ovchinnikovsky Lane, Office 304, 115184, Moscow, Russia
Authorizing an Agent: To authorize an agent to make a request to know or delete on your behalf, please send a written authorization signed by you and the authorized agent to us via support@smmplanner.com.
Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; and (4) specific pieces of Personal Information we have collected about you during the past twelve months.
Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.
Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. To verify your access or deletion request, please provide us with the email address associated with your SMMplanner account.
Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
Shine the Light. You may request information once per calendar year about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us in writing using the Contact Information section below.
Submit Requests. To exercise your rights under the CCPA, please contact us by email at support@smmplanner.com or write to us at the following address:
Dmitry Yurievich Bashkatov, sole proprietor
OGRNIP 315774600243562 / INN 121522926545
Address: 3 Sredny Ovchinnikovsky Lane, Office 304, 115184, Moscow, Russia
Authorizing an Agent: To authorize an agent to make a request to know or delete on your behalf, please send a written authorization signed by you and the authorized agent to us via support@smmplanner.com.
5. Do Not Track
There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.
6. Contact Information
If you have any questions, comments, or concerns about our processing activities, or you would like to exercise your privacy rights please email us at support@smmplanner.com or write to us at:
Dmitry Yurievich Bashkatov, sole proprietor
OGRNIP 315774600243562 / INN 121522926545
Address: 3 Sredny Ovchinnikovsky Lane, Office 304, 115184, Moscow, Russia
Dmitry Yurievich Bashkatov, sole proprietor
OGRNIP 315774600243562 / INN 121522926545
Address: 3 Sredny Ovchinnikovsky Lane, Office 304, 115184, Moscow, Russia
Publication date of current edition: 08.09.2018
GDPR compliance
The EU's General Data Protection Regulations (GDPR) take effect May 25, and we are fully behind the spirit of these regulations for a safe and secure Internet. We aspire to embrace privacy by design and, whenever possible, to not collect and store personally-identifiable information.
Our Privacy Policy contains mentions of the few instances where personally-identifiable information is required. Typically this will include an email address in order to log in to SMMplanner or a social network username in order to manage your account.
Overall, we aim for privacy by default: if data collection is not integral to the way our product works, then we won't collect it. This approach has felt very much in line with the spirit of GDPR, and we're fortunate that a lot of these data collection practices have been in place at SMMplanner for some time. As such, you may see few banners or forms requesting consent for us to collect personally-identifiable information for tracking or other purposes. We don't deem this information necessary to provide SMMplanner's service to you, and we choose not to engage in activities and strategies that make this data relevant.
At any time, you may request your information to be exported and sent to you for review, and we promptly honor any requests by you to have your information deleted and forgotten.
Our Privacy Policy contains mentions of the few instances where personally-identifiable information is required. Typically this will include an email address in order to log in to SMMplanner or a social network username in order to manage your account.
Overall, we aim for privacy by default: if data collection is not integral to the way our product works, then we won't collect it. This approach has felt very much in line with the spirit of GDPR, and we're fortunate that a lot of these data collection practices have been in place at SMMplanner for some time. As such, you may see few banners or forms requesting consent for us to collect personally-identifiable information for tracking or other purposes. We don't deem this information necessary to provide SMMplanner's service to you, and we choose not to engage in activities and strategies that make this data relevant.
At any time, you may request your information to be exported and sent to you for review, and we promptly honor any requests by you to have your information deleted and forgotten.
Here is what we've done for GDPR compliance:
Data Mapping
We are auditing all areas of SMMplanner to determine what personal data we collect and for what purpose. In a case where collecting personal data is not essential, we are removing that collection process.
Privacy Policy
We're working with a legal consultant to ensure that our policy contains the proper language, that it's easy to understand, and that it communicates clearly any instances of personal data collection.
Cookies
We have added a cookie notice to all marketing pages and blogs in order to comply with the E-Privacy Directive. We do not collect personally-identifiable information with our cookies, but we do want to acknowledge the use of cookie technology on our website.
Deletion
A user has the right to request that we delete all of their personal data. Users who wish to inquire about the right to be forgotten will be able to reach out to us at any time. If you want to delete all data please send us support@smmplanner.com.
Delete my data
A user can request access to a copy of the personal data that we have collected. Users who wish to request portability can reach out to us at any time. You can send a request to support@smmplanner.com.
Data Protection Agreement
Within Section 7 of our DPA, we commit to displaying a list of all current sub-processors in use by SMMplanner. A sub-processor includes any third party that we share personally identifiable info with.
Here is that list: Google, Intercom, Facebook, Yandex, VK, myTarget, Carrotquest, HotJar.
Here is that list: Google, Intercom, Facebook, Yandex, VK, myTarget, Carrotquest, HotJar.
Cookie Statement
Like many websites, we also use "cookie" technology to collect additional website usage data and to improve the Site and our Service. A cookie is a small data file that we transfer to your computer's hard disk. A session cookie enables certain features of the Site and our service and is deleted from your computer when you disconnect from or leave the Site. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Site. Persistent cookies can be removed by following your web browser help file directions. Most Internet browsers automatically accept cookies. SMMplanner may use both session cookies and persistent cookies to better understand how you interact with the Site and our Service, to monitor aggregate usage by our users and web traffic routing on the Site, and to improve the Site and our Service.
We may also automatically record certain information from your device by using various types of technology, including "clear gifs" or "web beacons." This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Service, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message, to the extent permitted under applicable law.
You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Please note that if you delete, or choose not to accept, cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
We may also automatically record certain information from your device by using various types of technology, including "clear gifs" or "web beacons." This automatically collected information may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Service, the pages or other content you view or otherwise interact with on the Service, and the dates and times that you visit, access, or use the Service. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message, to the extent permitted under applicable law.
You can instruct your browser, by editing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Please note that if you delete, or choose not to accept, cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
Publication date of current edition: 08.09.2018