1. Who we are

1.1. We are LLC VK located at 39 Leningradsky Pr., Bldg. 79, Moscow, 125167, Russian Federation. We are represented, for the purposes of this policy, by MGL MY.COM (CYPRUS) LIMITED of 28 Oktovriou, 365 VASHIOTIS SEAFRONT, office 402 Neapoli, 3107, Limassol, Cyprus, (hereinafter – “us”, “we”, “Administration of the Site”).

1.2. This Privacy Policy sets out how we collect and use your personal information when you visit www.ok.ru (including through mobile version m.ok.ru or our mobile apps (including our iPhone, Android and WP apps) (hereinafter the Site) and the choices available to you in connection with our use of your personal information (the Privacy Policy). This Privacy Policy should be read alongside, and in addition to, our Site terms and conditions (accessible online at https://ok.ru/regulations) (Terms) and our Cookie Policy (accessible online at https://ok.ru/cookiepolicy). In case of any contradictions between terms and conditions of processing your personal information contained in this Privacy Policy and the Terms, this Privacy Policy will prevail.

1.3. By registering and/or logging into the Service using VK ID, the User agrees to VK Ecosystem Privacy Policy which is posted at https://id.vk.com/privacy.

2. This Privacy Policy

2.1. By making available the Site and its services (hereinafter the Site Services) we, acting reasonably and in good faith, believe that you:
(a) have all necessary rights to register on and use this Site;
(b) provide true information about yourself to the extent necessary for use of the Site Services;
(c) understand that by the posting your personal information you have manifestly made this information public, and this information may become available to other Site users and internet users, be copied and disseminated by them;
(d) understand that some types of information transferred by you to other Site users cannot be deleted by you or us;
(e) are aware of and accept this Privacy Policy.

2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.

2.3. This Privacy Policy applies only to the European Union-based users. If you are not a European Union-based user, please refer to the Privacy Policy applicable in the relevant jurisdiction.

3. Information we collect about you

3.1. In order to implement the agreement between you and us, and provide you with access to the use of the Site functionality, we will improve the Site Services, develop and implement new Site Services, and enhance available Site and services functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data (hereinafter “processing”). We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy. In relation to this clause of the Privacy Policy, «affiliates and partners» mean entities, which ensure the fulfillment of Our contractual obligations to you and other users of the Site and / or entities which independently provide services to you and other users of the Site, provided that such entities represented and warranted Us, that they have legal grounds to process your and other users’ data.

3.2. We set out in more detail the information we collect when you use our Site Services, why we collect and process it and the legal bases below.

3.2.1. 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 Site;
(b) additional information entered by the User for the purpose of editing their account in the course of using the Site;
(c) data additionally provided by the User at the request of the Administration of the Site for the purposes of fulfilling the Administration of the Site's obligations to the User arising out of the agreement on the provision of the Site functionality;

3.2.2. Other data required for the Site to function, i.e.:
(a) data regarding technical equipment (devices), technological interaction with the Site (including host IP address, the User's operating system, browser, geographical location, Internet Service Provider);
(b) information obtained automatically by accessing the Site using bookmarks (cookies);
(c) information obtained as a result of the User's actions on the Site, in particular, information about adding any content;
(d) information obtained as a result of the actions of other Users on the Site;
(e) summarized analytical information on the use of Internet-based services.

3.3. We set out in more detail the information we collect when you use our Site Services, why we collect and process it:

Information collected

Purpose of processing

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

Account 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 Site, including first name, last name, date of birth, gender, mobile phone number, and other information required to fulfill the agreement with the User. During registration, the User is assigned an internal ID number that identifies the User on the Social Network;

2) additional information entered by the User for the purpose of editing their account in the course of using the Site, including email, marital status, place of birth, current city of residence, education and career information, location of military service, images, and other information required to fulfill the agreement with the User;

3) data additionally provided by the User at the request of the Administration of the Site (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, in particular, for the provision of access to, management of the Site, verification of the Site account belonging to the applicant who requested to restore access to the account to make recommendations about the User to other Users who have their phone number in their contacts.

In order to counteract spam messages, the phone number of the User is transferred to the service https://clientapi.mail.ru, the owner of which is the Administration of the Site for exclusively validation of the User's phone number.

Other data, i.e.:

4) information about the User's activities when using the Site, including, but not limited to, clicks and transitions within the Site interface, information about joining/leaving groups, adding other Users to friends list, participation or refusal to participate in meetings, making/receiving donations, and other information required to fulfill the agreement with the User;

5) information obtained as a result of the actions of other Users on the Site (in particular, tags made on videos and photos by other Users, and other information required to fulfill the agreement with the User).

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

To fulfill the agreement concluded with the User, in particular, management, improvement and personalization of the Site.

7) information that is received as the result of your using payment functionality on the Site (e.g. first six and last four digits of your card number).

We use this information in order to manage and administer the Site including providing our Site Services to you. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.

8) information that is created by you on your page and the Site outside the page edit section of the Site and on the Site (including statuses, entries in the microblog, pictures, audio recordings, video recordings, comments, entries in the group discussions).

We use this information in order to manage and administer the Site including providing our services to you. We may also use this data in order to tailor and improve the adverts and recommendations that are presented on the Site and measure the effectiveness of these advertisements.

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

Other data, i.e.:

9) technical data obtained by accessing the Site, including data regarding technical equipment (devices), technological interaction with the Site (including host IP address, user's operating system, browser, geographical location, Internet Service Provider, data obtained from accessing the camera, microphone, and other information required to fulfill the agreement with the User).

10) information obtained automatically by accessing the Site using bookmarks (cookies);

To fulfill the agreement concluded with the User, in particular, management, improvement and personalization of the Site.

OK Android application

Other data, i.e.:

11) data accessible by the Administration of the Site 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, contacts from contact lists 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, 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, and other information required to fulfill the agreement with the User.

To fulfill the agreement concluded with the User, in particular, management, improvement and personalization of the Site, including to recommend to the User other Users whose contact information is contained in their phone book, as well as to provide the possibility to maintain the phone book in the Site for personal purposes.

OK iOS application

Other data, i.e.:

12) data accessible by the Administration of the Site in the course of using the application by the User, including but not limited to the device type (Smartphone/Tablet/iPod), device name, IDFA, OpenUDID, Apps Flyer UID, OS version, device model, contacts from contact lists 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, and other information required to fulfill the agreement with the User.

To fulfill the agreement concluded with the User, in particular, management, improvement and personalization of the Site, including to recommend to the User other Users whose contact information is contained in their phone book, as well as to provide the possibility to maintain the phone book in the Site for personal purposes.

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

Account Data, i.e.:

13) 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;

14) data additionally provided by the User at the request of the Administration of the Site (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), and other information required to fulfill the agreement with the User).

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

OK Live Android application

Other data, i.e.:

15) Data accessible by the Administration of the Site 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), and other information required to fulfill the agreement with the User.

To fulfill the agreement concluded with the User, in particular for management, improvement and personalization of the application.

OK Live iOS application

Other data, i.e.:

16) Data accessible by the Administration of the Site in the course of using the application by the User, including but not limited to the device type (Smartphone/Tablet/iPod), device name, IDFA, OpenUDID, 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, and other information required to fulfill the agreement with the User.

To fulfill the agreement concluded with the User, in particular for management, improvement and personalization of the application.

OK Video Android application

Other data, i.e.:

17) Data accessible by the Administration of the Site in the course of using the application by the User, including country (code) / region (code), language (code), name of the device manufacturer, type of the device product, name of the device model, time stamp of the discovered error, equipment version/OS version/application version, and other information required to fulfill the agreement with the User.

To fulfill the agreement concluded with the User, in particular for management and improvement of the application.

3.4. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims. We will not delete personal information if it is relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

3.5. You may withdraw your consent the collection of location data and your apps by amending your privacy settings on the Site or mobile app/the settings of your mobile device. You may withdraw your consent the processing of your phonebook by amending your phone settings. An option to unsubscribe will also be included in every SMS or email (as direct marketing) sent to you by us or our selected third party partners if such direct marketing is realized in fact by us or our selected third party partners with our permission. You can also choose to hide or receive fewer some advertisement from advertisers.

3.6. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data on the Site. Once you have provided this data it will be accessible by other site users and it becomes difficult for us to remove this data.

3.7. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Site, you may not be able to access or register with the Site.

3.8. If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.

3.9. In order to provide the functionality of the Site, we occasionally need to send you restoration codes and other similar service notifications. For this purpose, we can use your phone number to send such notifications through SMS or through push notifications in Site application or in our other applications and applications of our partners as well. We use our own means of notifications and other applications or partners do not receive any of your data.

3.10. The Site uses the YouTube API, as provided for in clause 8.27 of the Terms. Google’s Privacy Policy is available at https://www.google.com/policies/privacy.

4. Data sharing

4.1. Your information can be available to all of "your friends" in your page and the Home page section in accordance with your settings and clause 5.1, 5.2 of this Privacy Policy. Some of your information is available to all users of the Site in your page and the Home page section in accordance with your settings and clause 5.1, 5.2 of this Privacy Policy. You can amend your settings via the Site and, subject to clause 5.1, 5.2 of this Privacy Policy, you can also determine your own confidentiality mode and conditions of access to the information mentioned at purposes 2,3,4 and 7 in the table above. We take technical and organizational measures to ensure that the appropriate Site tools are functional. Please note that by the posting your personal information you have manifestly made this information public, and this may become available to other Site users and internet users and be copied and/ or disseminated by such users. Once this data is transferred by you to other users you will not be able to delete this data.

4.2. We may share your data with MGL MY.COM (CYPRUS) LIMITED, V Kontakte LLC and other our affiliates. Sometimes we may also need to share your data with a third party (including service providers) subject to the assumption by such counterparties of obligations to ensure the confidentiality of information received in order to provide our services to you or to administer the Site, for example if you choose to share your data across other social media platforms. We may transfer Account Data and Other Data of the Users to third parties on the condition of compliance with the purpose, and if there are legal grounds, listed in this Policy. These third parties may include:

In the case of using applications in the Application Platform of the Site, your phone number and / or e-mail and / or name (depending on what minimum data is required for authorization / registration in the application), will be transferred to the owner (developer) of the corresponding application in order to provide the ability to use such an application in the Application Platform of the Site. In addition, with your consent expressed when downloading the application. We can additionally transfer your name, surname and image to the owners (developers) of applications in the Application Platform of the Site. You are obliged to read terms of use and privacy policy of such third parties (developers) before using the relevant applications in the Application Platform. Applications made available and supported on the Site by third parties (developers) that operate independently from the Administration of the Site and do not represent or act on behalf of the Administration of the Site.

For the purposes of provision of quality, multifunctional, easy-to-use Services oriented to personal needs and interests of the Users, the Administration of the Site shall develop, improve, optimize current and introduce new functionality to the Site (of an informative, communicative, advertising, educational, entertaining or other nature), including with the involvement of partners and/or affiliates.

Taking the aforementioned into account, and also taking the purposes of processing executed by Administration of the Site and listed in section 3 of this Policy into account, the User agrees and instructs the Administration of the Site to execute following actions:

Taking into account the nature and functional particularities of the Site, the operation of the information resource may enable the study of the market for goods and services, including the evaluation of supply and demand, turnover of goods, analysis of the effectiveness of informational, advertising, and marketing campaigns conducted via the creation of anonymized analytical information based on data about use of the Site.

We process personal information to the extent specified in clause 3.3. of this Privacy Policy, together with the personal information about you received from the Company's partners, and provided by the Company's partners with legal grounds for such processing, to the extent specified in the Privacy Policy of the Company's partner, which you use, in order to improve the quality of the services provided by the Site, namely: to satisfy the your interests by showing information relevant to your interests, targeting of accurate advertising (showing information relevant to your interests), the formation of generalized statistical/analytical information based on the use of the Site and Partner service(s).

The Administration of the Site may perform transborder transfer of Information in the minimum amount necessary for the purposes specified in this Policy to the third parties specified in clauses 4.2 and 4.3 of this Policy.

Some web resources and applications of the third parties may present an opportunity to use their functions via authorization with the use of data from the User's profile on the Site. During such authorization, the web resource or application of the third party requests consent or permission from the User to use data from the User's profile on the Site. Said consent must indicate the volume of data used upon authorization and the procedure for their processing. In agreeing with the authorization to use data from the profile on the Site, the User gives consent to the transmission of data from his or her profile on the Site to the third party which owns the web resource or application within which said authorization takes place in the amount specified in the consent/permission and requested by said web resource or application.

4.3. Processing of Other Data in the use of the OK and OK Live mobile applications

Other Data on the operation of the OK application may be sent to myTarget (VK LLC), VK Ads (VK LLC), or Yandex Ad (Yandex), for the personalization of advertisements displayed to the User on the Site and also to Google CrashLytics (Google) for the analysis of errors in the operation of the application, to myTracker (VK LLC), Google Analytics (Google), or Google Firebase Analytics (Google) for the receipt of aggregated analytical information on the operation of the application.

Other Data necessary to support the operation of several functional capabilities of the Site are sent to Google Tag Manager (Google) and VKontakte SDK (V Kontakte LLC).

Other Data on the operation of the OK Live application are sent to myTarget (VK LLC) for the personalization of advertisements displayed to the User in the application, and also to Google CrashLytics (Google) for the analysis of errors in the operation of the application and to myTracker (VK LLC), Google Analytics (Google), and Google Firebase Analytics (Google) for the receipt of aggregated analytical information on the operation of the application.

Other Data necessary to support the operation of several functional capabilities of the application are sent to VKontakte SDK (V Kontakte LLC).

4.4. Our ad management and recommendation system is designed so that your information will not be shared directly with our third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age, gender or location, or to target communities according to type, e.g. cars or fashion. If you fall within one of the target groups you will receive an advert or recommendation.

4.5. An advertiser or maker of recommendations may also choose to upload e.g. a list of emails, phone numbers and identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches. They will see the number of matches but not the matches themselves.

4.6. We, LLC VK, other companies in the VK or our selected third party partners with our permission, using their own ad services, can show advertisements to you.
For the purpose of displaying a cookie banner and using cookies, including for displaying ads to users, we cooperate with Jaohawi AB (Håltegelvägen 1b, 72348 Västerås, Sweden) in full accordance with applicable law and IAB Europe Transparency & Consent Framework Policies Version 2019-04-02.2c.

4.7. As the Site is an all-in-one means of communication and the key function of the Site is to restore and maintain contacts with old and new acquaintances, the following information about you is always available to Internet users:
surname and name;
date of birth (without year if it is hidden), profile photograph, city of birth, city of residence;
number of your friends, photos, groups, games, notes, videos and gifts.

4.8. If you use VK ID, we can transfer your information to third parties when using VK Ecosystem Services and other Services using the VK ID tool as well as we may receive from the specified Services your information in the amount specified in your personal VK Ecosystem account in order to fulfill agreement with you as User of VK Ecosystem.
We may share your information with VK Ecosystem Services, as well as with external Services using the VK Ecosystem tools, to provide you with accesses, capabilities and benefits of the VK Ecosystem, for example, if you decide to log in to the Service using the VK ID tool. By starting the usage of such Service/tool/its functions, you agree to such transfer of information to the extent necessary for the operation of the Service/tool. You also agree and accept the User documentation of such VK Ecosystem Service and/or its tool in full, without any reservations or exceptions. If you do not agree with any of the provisions of the User documentation of the Service/tool, you are not entitled to use such Service / tool. The list of VK Ecosystem Services is available at https://vk.com/vk_ecosystem_services. The list of VK Ecosystem Tools is available at https://vk.com/vk_ecosystem_tools.

5. Privacy Settings

5.1. You may, subject to the limitations under clause 4.7, set one of the "confidentiality levels" for your personal data in the settings available at https://ok.ru/settings/privacy.

5.2. For the information on your page, including mentioned in clause 4.7, you may set one of the following confidentiality levels:
information available to all internet users and indexed by the search systems, or;
information not indexed by the search systems.

5.3. Please note, once your personal data has been copied or shared by another site user, this information will remain available to all site users and internet users even if you delete this information from your page or delete your page in its entirety. We accept no liability for the disclosure of your personal data by other Site users who have accessed such data in accordance with the confidentiality level selected by you.

5.4. The Site contains links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.

5.5. We bear no liability for the actions of third parties which, as the result of your use of the internet or the Site Services, obtain access to your information in accordance with the confidentiality level selected by you.

5.6. We bear no liability for the consequences of use of the information which, due to the Site nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted on the Site.

5.7. We respect your privacy as a user, and you can change or revoke your consent to processing your personal data for targeted advertising from our advertisers by using settings on the page at https://ok.ru/cmpChangeConsent.

6. International Transfers

6.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.

6.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standartd Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

7. Retention Periods

7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.

7.2. You may delete your personal data by removing the data from your personal page; alternatively, you can remove your page using the Delete profile functionality available in the end License Agreement section. You have the right to restore your personal page within 183 days after the personal page is removed.

7.3. We may remove your page, or the information you post if there are grounds provided for by applicable law or by the Terms.

8. Your Rights

8.1. You have the following rights, in certain circumstances, in relation to your personal information:
Right to access your personal information.
Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
Right to restrict the use of your personal information.
Right to request that your personal information is erased.
Right to object to processing of your personal information.
Right to data portability (in certain specific circumstances).
Right not to be subject to an automated decision.
Right to lodge a complaint with a supervisory authority.

8.2. You also have a right to independently remove your page, information on your page and make changes and corrections to your personal page on the Site, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you via the Site.

8.3. If you would like to exercise these rights, please send your request to us in our Support Service, or in writing to: 39 Leningradsky Pr., Bldg. 79, Moscow, 125167, Russian Federation. We will aim to respond to you within 30 days from receipt of request. We will need to verify your identity before we are able to disclose any personal data to you.

9. Security Measures

We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

Access to the Site is authorized using your login (e-mail address or mobile phone number) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.

If you need to reset password, you can provide us with your mobile phone number or e-mail address associated with your profile. If you forget mobile phone number or e-mail address associated with your account, you can type your personal information (first name, surname, age and city) specified in your profile or the link to your profile and we will try to find your profile. We will send you a restoration code to your mobile phone number or e-mail associated with your profile. You can create a new password using such code on the restoration page.

To reduce the probability of third parties gaining unauthorized access, if you login to your account from an unusual server (in particular, from a server located in a foreign country), we will block entry to your personal page. You will then receive a message asking you to provide digits indicated in SMS

You can access information concerning the time and IP-address from which your account was accessed using "Settings / Location History" link in the Site.

10. Changes to this Policy

10.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.

11. Contact Us

11.1. If you have any questions, please send your inquiries to us, in writing to 39 Leningradsky Pr., Bldg. 79, Moscow, 125167, Russian Federation, or to our support. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.

11.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

11.3. The e-mail address of our DPO is dpo@corp.my.com.

03.11.2023