Coach365 Privacy Policy

Terms and Definitions

SMBs – small and medium-sized businesses;

Personal data – any information relating directly or indirectly to a particular or identifiable individual (data subject);

Personal data processing – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

User – an individual, including an individual entrepreneur, using the Coach365 Mobile Device Program (hereinafter referred to as the Program).

Other terms used herein are used in the meaning defined by the applicable legislation of the Russian Federation.

1. General Terms

1.1. This Privacy Policy (hereinafter referred to as the Policy) has been developed and applied by OOO RFL (INN 6316179179) in accordance with Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter referred to as the Federal Law “On Personal Data”) and defines the general terms for the processing of personal data of Users who transfer personal data to the Program for processing by OOO RFL, and outlines procedures for preventing violations of Russian legislation.

1.2. The use of the Program means the User’s acceptance of this Policy and the conditions for processing his/her personal data specified herein. In case of disagreement with these conditions, the User shall not use the Program.

1.3. Personal data obtained during the registration and use of the Program is stored and processed by OOO RFL in accordance with the requirements of the Federal Law “On Personal Data” and the requirements of the regulations of the Federal Security Service of the Russian Federation.

2. User’s Personal Data Processed by OOO RFL

2.1. This Policy applies only to the information provided by the User during the registration and use of the Program. OOO RFL does not control and is not responsible for the processing of the User’s personal data by information systems (websites) of third parties, which the User may link to while using the Program.

2.2. OOO RFL does not verify the accuracy of information containing personal data provided by the User. However, OOO RFL assumes that the User provides reliable and sufficient information containing his/her personal data, and updates this information. The consequences of providing inaccurate or insufficient information containing the User’s personal data are defined in the User Agreement.

2.3. OOO RFL processes the following personal data:

• User’s last name and/or first name and/or patronymic;

• details of the identity document;

• address;

• date of birth;

• sex;

• phone number;

• e-mail address;

• INN (taxpayer identification number);

• SNILS (individual insurance account number);

• OGRNIP (primary state registration number of an individual entrepreneur).

2.4. When the User uses the Services that are linked to in the Program, OOO RFL may transfer to the information systems through which the Service operates, the anonymized personal data of the User (user identifier and his/her role), as well as publicly available information about legal entities and individual entrepreneurs (taxpayer identification number, primary state registration number of a legal entity, primary state registration number of an individual entrepreneur) specified by the User upon registration.

2.6. OOO RFL, for statistical purposes, may collect anonymized statistical data about the Program Users.

3. Purpose of Data Processing

To organize a system of information support measures for small and medium-sized businesses and to follow the requirements of paragraph 25.1. of Federal Law No. 209-FZ dated July 24, 2007 “On the Development of Small and Medium-Sized Businesses in the Russian Federation” in order to ensure favorable conditions for the development of small and medium-sized businesses by raising awareness of available opportunities for business development, both for existing and future SMBs.

4. Term of Data Processing

The User’s personal data is processed within the period from the registration of the User in the Program and until the removal of the Program (including because the User violates the terms of the Program User Agreement or this Privacy Policy or the Terms of Use), or until the User ceases to use the Program, unless otherwise provided for by legislation of the Russian Federation.

5. Terms of Data Processing and Data Transfer to Third Parties

5.1. Processing of personal data of RFL’s Users is allowed where:

1. personal data is processed with the consent of the data subject to the processing of its personal data;

2. the processing of personal data is required to achieve the goals stipulated by the treaty of the Russian Federation or the law, to exercise and perform functions, powers and duties assigned by legislation of the Russian Federation to OOO RFL;

3. the processing of personal data is required to execute an agreement, a party to which is the data subject either as a beneficiary or a guarantor, including if OOO RFL exercises its right to assign rights (claims) under such an agreement, and to conclude an agreement initiated by the data subject or an agreement under which the data subject will be a beneficiary or a guarantor;

4. the processing of personal data is required to exercise the rights and legitimate interests of OOO RFL or third parties, or to achieve socially significant goals, provided that this violates no rights and freedoms of the data subject;

5. the personal data is processed for statistical or other research purposes, with the exception of the purposes specified in Article 15 of the Federal Law “On Personal Data”, subject to the mandatory anonymization of personal data;

5.2. OOO RFL does not disclose personal data to third parties or distribute it without the consent of the data subject, unless otherwise stipulated by the federal law of the Russian Federation.

5.3. OOO RFL has the right to entrust the processing of personal data to another person with the consent of the data subject according to an agreement signed with this person.

5.4. OOO RFL ensures the confidentiality of personal data, except where personal data is publicly available.

6. Modification and Deletion of Personal Data

6.1. The User can at any time change (update, supplement) the personal data provided or a part thereof through the functionality of the Program, except where the Program is being maintained, or
for reasons beyond the control of OOO RFL it becomes impossible to use the Program.

6.2. The User can also delete the personal data provided by sending a request for deletion to the technical support service.

7. List of Actions with Personal Data That Require Consent

OOO RFL performs with User’s personal data any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (provision, access), anonymization, blocking, deletion, and destruction of personal data.

8. Measures Used to Protect User’s Personal Data

OOO RFL takes organizational, legal and technical measures to protect the User’s personal data placed from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties in accordance with applicable legislation of the Russian Federation.

9. Changes to the Policy. Applicable Law

9.1. The current version of the Policy is constantly available at coach365.pro.

9.2. OOO RFL has the right to make changes hereto. When making changes to the current version, the date of the last update is indicated.

9.3. The new version of the Policy becomes effective upon its approval.

9.4. If OOO RFL has made changes to the Policy that the User does not agree with, the User must cease to use the Program.

9.5. Russian law is to be applied to this Policy and
the relationship between the User and OOO RFL arising in connection with the application of the Policy.

10. Cancellation of Subscription

10.1 The User can cancel a subscription by going to the subscription section in the application store (App Store or Google Play) relevant for the device and unsubscribe for the next settlement period. OOO RFL provides no refund for the remainder of the settlement period, if the User has not timely canceled a subscription before the expiration of the period.

11. Other Terms

11.1 OOO RFL strongly recommends that you consult with your doctor before starting any training program.

11.2 OOO RFL and coaches are not licensed healthcare professionals. OOO RFL and coaches are not qualified to diagnose, examine or treat illnesses of any nature, or qualified to determine the health effects of any physical exercises.

11.3 The User must understand that any exercises or training programs carry the potential for injury. If the User exercises or takes these training programs, the User agrees that he/she does it at his/her own risk, participates in this activity voluntarily, takes responsibility for injuries, and agrees to hold OOO RFL and coaches harmless from any known or unknown claims or grounds for initiating a claim related to the negligence of OOO RFL.

12. Feedback

12.1. All suggestions and questions regarding this Policy should be emailed to OOO RFL to: info@coach365.pro