PRIVACY POLICY

     Last updated: 28/08/2012
     
     Definitions   
     Official Website shall mean website located at http://agent.mail.ru
     Application (or the “App”) shall mean application titled “Mobile Agent” and designed for distribution through Ovi Store. 
     Company (or “We”) shall mean Mail.ru LLC, a Russian Federation legal entity.
     Current Location shall mean information about your current location available to other End-users if you allow this information to be available to public through Official Website. 
     Data shall mean information which is stored electronically, on a computer.
     End-user shall mean a registered App user. 
     Ovi Store shall mean the website currently located at http://store.ovi.com/.
     Processing shall mean any activity that involves use of the User’s Data. It includes obtaining, recording or holding the User’s Data, or carrying out any operation or set of operations on the User’s Data including organizing, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring User’s Data to third parties.
     Registration Data shall mean Data provided by you to Company at registration including the following information: (i) e-mail, (ii) nickname, (iii) first name, (iv) last name, (v) date of birth, (vi) telephone numbers, (vii) abiding-place (country and city of residence).
     User’s Data shall mean (i) your Registration Data, (ii) your message and SMS history, (iii) files sent by you through the App to other End-users, (iv) Current Location, (v) your contact-list, (vi) information about your mobile device, (vii) information about your activity in the App, (viii) your IP-addresses and other similar information.   
      
     The introduction 
      Our Application allows you to exchange instant messages, SMS, and different files with other End-users. 
      You must be a registered App user in order to use the App. You may register as an End-user and provide us with your Registration Data through the App, another Company’s application for other platforms or via the Official Website. You may change your Registration Data through Official Website or another Company’s application for other platforms (if applicable). 
      Please be aware that the App establishes a connection to the Internet when it is active in order for messages and files to be received and sent.
      Company and its subsidiaries value the privacy and security of the information that End-users share with us by using the App. The Privacy Policy describes the way that Company collects, shares, protects, or otherwise uses User’s Data. 
      In order to use the App, you will need to agree to these Privacy Policy. By using our App you fully agree and obliged to comply with the terms and conditions of this Privacy Policy and explicitly consent to using of your information in accordance with the Privacy Policy. 
      Company reserves the right to update this Privacy Policy on its sole discretion at any reasonable time by placing a new version thereof at the page of the App in Ovi Store. Therefore, Company encourages you to periodically check back and review this Privacy Policy so that you always will keep abreast and know the changes.
      If you do not agree with this Privacy Policy or with its any modified version, please do not use the App. By continuing of using the App you automatically accept the updated version of Privacy Policy. 
      
     User’s Data Processing.  Availability of User’s Data to other End-users
      Our main purpose in Processing of the User’s Data is to provide you with a safe, efficient, and customized user experience. 
      Company exercises Processing, or has third party service providers acting on Company’s behalf to exercise Processing of the User’s Data, as permitted or necessary to: (a) provide you with competitive and convenient instant messaging services and other services directly or indirectly connected with instant messaging; (b) provide you with customer support and troubleshoot problems; (c) inform you about service updates and faults; (d) customize, measure, and improve App and other Company’s software and services; and (e) organize and carry out Company’s marketing or promotional operations, games and similar events. 
      You hereby agree that the Registration Data as well as your Current Location and type of client you use may be seen by any End-user added by you to your contact-list. You understand that your message/SMS history may be instantly available to the End-users you correspond with if they opt to save the message/SMS history.   
	Company does not verify correctness and cannot be able to examine of any User’s Data. Therefore, the collected User’s Data is considered as non-personal information. 
     
     Disclosure and Transfer of User’s Data
      Company may use the collected User’s Data to analyze usage of the services, advertisement serving, managing and providing the services and products to further development of the App and other Company’s software and services. For these purposes Company may disclose User’s Data to partners which have their own specific serving technologies (“Partners”). 
      You acknowledge and agree that the analytics utilized by Company’s Partners may combine the User’s Data collected with other information they have independently collected from other services or products relating to your activities. These Partners collect and use information under their own privacy policies. They may not use your User’s Data for their own marketing purposes.
      Company may also disclose your User’s Data to third parties when Company has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Company’s (its subsidiaries) intellectual property, operations, users or others who may be harmed or may suffer loss or damage, or Company acknowledges that such disclosure is necessary to protect Company’s (its subsidiaries) rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Company or its subsidiaries.
      Company has the right to disclose User’s Data in response to legal process, for example, in response to a court order. Company may also disclose such information in response to a law enforcement agency's request or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms of use, or as otherwise required by law.
      Company may transfer User’s Data about End-users in cases Company or one of its business units are acquired by, sold to, or merged with another company. 
      
     Security measures
      Company and its subsidiaries will protect User’s Data in a manner that is consistent with this Privacy Policy by, for instance, by applying commercially reasonable technical measures and not using the information for any purpose other than to carry out the services they are performing for.
      Although we take appropriate measures to safeguard against unauthorized disclosures of User’s Data, we cannot assure you that User’s Data collected hereunder will never be disclosed in a manner that is inconsistent with this Privacy Policy.
     
     Term of User’s Data Processing
      Company processes the User’s Data collected in accordance with Privacy Policy for the period necessary to execute the purposes outlined in this Privacy Policy unless a longer processing period is required or permitted by law. Thereafter if User’s Data collected is no longer needed for purposes specified in this Privacy Policy, Company deletes all aforementioned User’s Data in its possession.
      If User’s Data is changed or deleted, Company may still retain some of the data to resolve disputes, enforce Company user agreements, and comply with technical and legal requirements and constraints related to the security service.
      
     International transfer 
      Whereas Company operates internationally, and many of our computer systems are currently based in the Russian Federation, your User’s Data will be processed by Company upon the law of the Russian Federation where data protection and privacy regulations may not offer the same level of protection as in the other countries. If you use the App as a visitor from outside the Russian Federation, you consent to the collection and/or processing of your User’s Data in the Russian Federation, which includes the use of cookies as described above.
      
     Disputes and Governing law 
      This Privacy Policy shall be governed by and construed in accordance with the laws of the Russian Federation. If any dispute shall arise in connection with this Privacy Policy, either Party may initiate the dispute resolution procedures by giving the other Party written notice of such dispute (“Dispute Notice”). Following issuance of a Dispute Notice, the Parties shall endeavor to resolve the dispute through negotiations conducted in good faith. All negotiations that take place in connection with the dispute shall be conducted in confidence and without prejudice to the rights of the Parties in any future proceedings. If the dispute cannot be resolved through good faith negotiations within thirty (30) days from the date upon which the Dispute Notice was issued, either Party may submit the dispute to be finally resolved by the courts in the Russian Federation according to procedural legislature of the Russian Federation. 
     
     Our contacts 
	Should you have any questions or concerns about Privacy Policy or its execution do not hesitate to contact Company at support@corp.mail.ru or at Mail.ru LLC site: Russian Federation, 125167, Moscow, Leningradskiy pr. 47, Build. 2.