Privacy Policy of YooMoney, NBCO LLC

Version 3.0

Definitions

NBCO means “YooMoney”, NBCO LLC (Taxpayer Identification Number (INN) 7750005725, Primary State Registration Number (OGRN) 1127711000031), location address: 82 Sadovnicheskaya Street, Bld. 2, Moscow, Russian Federation.

Client means an individual, an Internet user using any services of the NBCO for his/her own purposes, as well as any other individual for whose benefit this user acts.

Counterparty means a legal entity, an individual entrepreneur who has entered or intends to enter into contractual relations with the NBCO, for which benefit the Client acts.

NBCO's Service (Services) The NBCO allows the Client to access a wide variety of services, which include utilizing electronic means of payment, transferring funds without opening a bank account, placing orders to partner-banks for making transfer (including the same with the bank cards), posting and storing diverse content, personalizing of content, etc. as well as services designed to be used by the Counterparties.

Communication with the NBCO means any interaction of the Client with the NBCO for the purposes not related to the use of the NBCO Services, including (inter alia) the participation of the Client in surveys, games, contests, promotions conducted by the NBCO on the Internet, the Client's response to the vacancies posted by the NBCO.

Preliminary

This Personal Information Privacy Policy (hereinafter referred to as the Policy) shall be applied to information about the Client the NBCO may receive. The Policy shall be applied only to the NBCO Services and Communications with the NBCO. The NBCO shall not control and shall not be responsible for the websites/services of third parties to which the Client can follow through the links available from the NBCO Services, and for the information about the Client processed by third parties.

All terms and definitions not defined but used in the text of the Policy are provided in the Agreement on the Transfer of Funds without Opening an Account Using the YooMoney Service or in other agreements on the subject of provision and use of the services of the NBCO by the Client.

Use of the NBCO's Services shall imply unconditional agreement on the part of the Client with this Policy and the terms and conditions of the processing of their personal information specified herein; should the Client disagree with these terms and conditions, they ought to refrain from using the NBCO's Services.

1. Clients' Information Obtained and Processed by the NBCO

1.1. Within this Policy, the Client's personal information means as follows:
1.1.1. Personal information that the Client provides about himself/herself independently or through a third party:
- upon registration in any of the NBCO Services,
- while using the NBCO Services,
- during the Communication with the NBCO,
- when negotiating, entering into and performing contracts with Counterparties.
The use by the Client of certain NBCO Services/Communications with the NBCO shall be possible only subject to the provision of the necessary data (for example, when creating a Wallet, sending a resume),
1.1.2. Data that are automatically transferred to the NBCO while using the NBCO Services via the software installed on the Client's device or while exchanging electronic messages with the Client, including the IP-address, cookies information (text files stored in the Client's browser), information about the Client's browser (or other program through which the NBCO Services are accessed), access time, the address of the page requested.
The collection of such information allows the NBCO to save the individual settings and parameters of the Client (including the website visitor), to improve the functional characteristics of the NBCO Services, to make them more convenient for the Clients and generally increase their efficiency, as well as to evaluate the marketing performance of the NBCO.
1.1.2.1. When browsing the NBCO websites, cookies may be automatically placed and/or the following anonymized statistical (analytical), technical and functional data types may be collected:

  • type of action performed on the site (click, mouseover, etc.);

  • date and time of the action;

  • Page URL;

  • Referer;

  • IP (without the ability to work with IP-addresses in statistics);

  • User-Agent;

  • ClientID (browser identifier based on the cookie);

  • screen resolution;

  • class of the HTML element being clicked on;

  • data on the information viewed by the Client in the Wallet interface;;

  • data on the cases of filling out forms/applications on the NBCO website, including errors when filling them out;

  • (third party) targeting and/or advertising cookies.


These cookies can collect anonymized information about the Clients, visited pages and advertisements displayed for the Client, as well as the link through which the Client followed to the NBCO Service. They can also be used for statistical and research purposes, as well as in order to perform the following actions: display relevant and personalized advertisements; limit the number of impressions for each specific type of advertisement; determine the efficiency of an advertising campaign;
These cookies may be linked to the functionality of the NBCO websites provided by the relevant third party, which may also receive and process anonymized information obtained through the use of such files.
1.1.2.2. By using the NBCO website, the Client agrees that the NBCO may use data and cookies, except for data on the information viewed by the Client in the Wallet interface classified by the applicable law of the Russian Federation as restricted information, for their subsequent processing by systems, for example, Google Analytics, Yandex.Metrica, Google Firebase, Appmetrica, and may transfer them to a third party for research, work performance or provision of services to the NBCO. The Client may independently manage cookies by changing the settings of the browser operating on his/her equipment. Changes to user settings that block cookies may result in the inaccessibility of certain components of the NBCO website.
1.1.3. The NBCO may obtain publicly available information when the Client uses third-party resources (for example, chats / forums / social networks). These data may contain information that the Client publishes, including in the form of comments or reviews about the NBCO Services. The NBCO shall use such information in order to improve the quality of Client Servicing.
1.1.4. The NBCO may process certain data (for example, IP-address, user device identifier) in order to identify and/or prevent conditions that facilitate actions with the Wallet or a bank card that contradict the requirements of law or the agreement pursuant to which the Wallet was provided to the Client.
1.1.5. The NBCO may receive information about the Client from its counterparties. For example, when performing an agreement with a counterparty, the latter may transfer to the NBCO information that gives the counterparty the opportunity to establish a connection between such Client and his/her money transfer, information on implementation of which is transferred by the NBCO to the counterparty.
1.1.6. The NBCO may receive information in order to maintain a proper security level for online payments made by the Client using bank cards. The list of such information is defined in Clause 3.3.2.1 hereof.

1.2. Except for cases of identification/simplified identification of the Clients on the grounds and in the manner provided for by the applicable agreements between the NBCO and the Client or the counterparty of the NBCO being the user of the YooMoney service, on behalf and/or for the benefit of which the Client acts, the NBCO shall not verify the accuracy of the personal information provided by the Clients and shall not control their legal capacity. However, the NBCO shall assume that the Client provides reliable and sufficient personal information and maintains this information up to date.

2. The Purpose of Collecting and Processing the Client’s Personal Information

2.1. The NBCO shall collect and hold only this personal information which is necessary for provision of the NBCO Services, execution of agreements with the Client, or communication with the NBCO, with the exception of the cases where gathering and storing of certain personal information is prescribed by law. The personal information shall be stored no longer than it is required by the processing purposes, unless the storing period is determined by the law of Russian Federation, agreement on the use of Services by the Client of NBCO.

2.2. The NBCO may use the Client's personal information for the following purposes:
2.2.1. Entering into and performing agreements of the Client/Counterparty with the NBCO, including for the purpose of identification/simplified identification of the Client/Counterparty, creation of the Client's/Counterparty's accounts, execution of the Client's orders to transfer money and/or refund the cash balance, use of other NBCO Services by the Client/Counterparty;
2.2.2. Communicating with the Client, including sending notifications, requests and information regarding the use of the NBCO Services, as well as processing the Client's requests and applications;
2.2.3. Improving the quality of the NBCO Services, ease of their use, developing new NBCO Services, offering personalized NBCO Services to the Client;
2.2.4. Conducting statistical and other studies based on anonymized data;
2.2.5. Conducting marketing campaigns for the Clients, including for the purpose of distributing offers to participate in the campaign and receive prizes/rewards provided for by the campaign; distributing advertising and informational materials via telecommunication networks, including via telephone, facsimile, mobile radiotelephone communication, or via direct contacts; targeting advertising materials and other information brought to the attention of the Clients.
2.2.6. Identifying and/or preventing the conditions that facilitate the use of the NBCO Services for illegal purposes or for the purposes prohibited by the rules of the relevant NBCO Services.
2.2.7. Increasing the Clients' loyalty to the NBCO Services.
2.2.8. Identifying and eliminating any errors in the NBCO software.
2.2.9. Familiarizing potential Clients and employees with the NBCO Services, vacancies, working conditions in the NBCO.
2.2.10. Exchanging knowledge with the Clients and Counterparties, job candidates in order to develop the professional skills of the NBCO's employees and form professional communities in the field of the NBCO's interests.
2.2.11. Assessing the NBCO's job candidates.
2.2.12. Selecting candidates for beta testing of software, interfaces, etc. developed by the NBCO.
2.2.13. Selecting candidates in order to form an opinion on trends in demand for services, interests of different groups of the population, to conduct other research for the purpose of developing new services and improving the current ones.

3. Conditions of Processing the Client’s Personal Information and Disclosing it to Third Parties

3.1. The NBCO shall process the Clients’ personal information in accordance with this Policy, the conditions of rendering certain services, and the NBCO’s internal regulations.

3.2. The confidentiality of the Client's personal information shall be guaranteed, except for cases when such information is made publicly available by the Client. The Client shall be aware and agree that his/her actions related to personal information placement, when the Client creates or edits a userpic (avatar) in any of the NBCO Services that has the appropriate functionality, entail the public availability of the posted information.

3.3. The NBCO may transfer the Client's personal information to third parties in the following cases:
3.3.1. The Client has agreed to such actions;
3.3.2. The transfer is necessary to use a certain NBCO Service or the service of the NBCO partner, including for the execution of the Client's order.
In particular, the Personal Information may be transferred to third parties of the following categories:
3.3.2.1. Credit organizations and other organizations involved in making money transfers.
For example, in order to maintain a proper security level for online payments made using bank cards, the NBCO may transfer data, the list of which is established by the payment systems security protocols, to acquirer banks / issuer banks, payment systems.
The transfer of information can be mandatory, for example, in terms of information about the user equipment: IP address, OS, geographic data, ID/type of equipment, channel used: browser/application, payment authorization, identification/verification, or optional, for example, in terms of information about indicators of address coincidence, information about the account in the merchant's system, e-mail address, mobile phone number, amount of payment, risk level set by the supplier, MCC.
As part of the operation of the Faster Payments System (FPS) of the Bank of Russia payment system, the personal information of the Client shall be transferred to NSPK JSC (OGRN 1147746831352), the FPS participants, as well as to the payers (recipients) of transactions performed using the FPS.
3.3.2.2. Marketing partners and other NBCO counterparties.
(a) the NBCO may provide access to some data (for example, statistics) for marketing and other research, as well as to other data that allow the transfer of advertisements to the Client, including those of third party organizations, that are relevant and may be of interest to the Client;
(b) the NBCO may provide access to some data on the Client's payment transactions, on the basis of which the NBCO's partner determines the possibility of providing such a Client with discounts (bonuses), incentives due to the Client's fulfilling certain conditions established by the NBCO's partner, as well as on the Bonus account of the Client who is a participant of the YooMoney loyalty program, when such access is conditioned by the possibility of providing the Client with additional Privileges use conditions;
(c) the NBCO may provide access to the Client's e-mail address that allows the NBCO partner to ensure the transfer of a fiscal or other document provided for by the law of the Russian Federation;
(d) when the Client uses the services provided by the NBCO partners, information about the Client may be provided to such partners in the volume and for the purposes necessary for the proper provision of services to the Client or increasing the level of their usability, for example, for pre-filling registration forms, which accelerates the registration procedure in the services provided by the NBCO partners.
3.3.2.3. Partners providing data storage on behalf of the NBCO.
3.3.2.4. Partners involved by the NBCO for the purposes specified in Clause 2.2.6 hereof.
3.3.2.5. Publicly available information The NBCO Services may have forums and/or chat rooms where the Clients can exchange ideas and communicate with each other. When publishing a message on the forum or in the chat room, the Client shall bear in mind that such information will be publicly available online and is published by the Client at his/her own risk.
The Client acknowledges and agrees that the NBCO is not required to view any content published and/or distributed by the Client through its services, and that the NBCO has the right (but not the obligation), at its discretion, to refuse the Client to publish and/or distribute content or delete any content that is available through the NBCO Services. The Client understands and agrees that he/she shall independently assess all risks associated with the use of the content, including the assessment of the reliability, completeness or usefulness of this content, as well as that the technology of the services may require copying (reproduction) of the Client's content by the NBCO and its processing to meet the technical requirements of a particular service.
3.3.2.6. Transfer of Control The transfer shall take place as part of the sale or other transfer of business (in whole or in part), while the acquirer receives all obligations to comply with the terms of this Policy in relation to the personal information received by the acquirer.
3.3.2.7. The transfer shall be provided for by Russian or other applicable law within the procedure established by the law.
3.3.2.8. In order to ensure the possibility to protect rights and legitimate interests of the NBCO or third parties in cases where the NBCO has reasonable grounds to believe that the Client violates the terms of the applicable agreement with the NBCO and/or the requirements of the applicable law.

3.4. By entering any data in one of the NBCO Services, the Client agrees that these data will be saved to be used repeatedly or in other NBCO Services without additional re-entering.
In particular, the Client is aware and agrees that if the Client re-issues a bank card of a third-party issuer, the data of which were previously entered by the Client in any of the NBCO Services, the data of the reissued card may be used to make payments during its validity period without additional consent or confirmation of the Client.
When processing the Clients' personal data, the NBCO shall be guided by the Federal Law "On Personal Data" and other regulations governing relations in the field of personal data security.

3.5. Disclosure of anonymous data. NBCO can also disclose anonymous data (i.e. information that neither directly nor indirectly reveals the Client's identity) and aggregated data (information regarding groups and categories of Clients) to its partners, and allow partners to collect anonymous and aggregated data within the framework of allowing the Clients to use particular functions of the Services that can subsequently provide NBCO with this data.

4. Changing and Deleting of Personal Information by the Client and Gaining Access to It

4.1. Altering and deleting the Client's personal information is made as stipulated by the agreement of using the corresponding NBCO's Services. Under the NBCO Services, the Client may be granted an ability to alter (update, add) or delete the information he or she provided or its part. Use of this function is regulated by the agreements applied to this NBCO's service.
4.1.1. Within the limits established by applicable law, the NBCO reports on the alteration or deletion of personal information to each recipient to whom personal information was disclosed, excluding the cases where it's impossible or requires disproportionate effort to do so.

4.2. By law, the NBCO may be induced to process/store the Clients personal information received in the course of the Service use. Such processing/storing is performed by the NBCO in the cases and within the terms stipulated by legislation.

4.3. Access rights
4.3.1. In accordance with the applicable law, the Client has the right to access information obtained by the NBCO, i.e. you have the right to request information regarding: (a) the purpose of processing; (b) categories of processed data; (c) category of recipients who will receive or have received the Client's personal data; (d) time limits for keeping or criteria for determining it, as well as other information.
4.3.1.1. Unless other methods are implemented in the Wallet interface, the information (copy) may be provided by the NBCO in writing or via other means of communication.
4.3.1.2. If the NBCO has reasons to doubt the identity of the Client submitting the request in accordance with c. 4.3.1 of the Policy, the NBCO has the right to request the additional information necessary to confirm the identity of such Client.
4.3.1.3. The request for information (copy) shall be executed within one month (30 days) from the moment it is received by the NBCO. The NBCO has the right to extend this period by two months (60 days) due the complexity and number of requests. The NBCO shall inform the Client of such an extension indicating the reasons that led to such an extension.
4.3.1.4. If the request has no explicit justification, as well as in case of an excessive number of requests, the NBCO has the right to charge a reasonable fee for fulfilling the request (including administrative expenses) or refuse to execute the request. The NBCO can also refuse to provide the Client with the information about them posted in the manner provided for in c. 3.3.2.5. of the Policy.
4.3.1.5. The Client has the right to independently send the information received from the NBCO in the manner provided for in this section to another controller, and, if the NBCO has the technical capability, send it via the NBCO.

4.4. Dispute rights
4.4.1. Within the limits established by the applicable law, the Client may revoke any consent they previously gave or submit legal objections regarding the processing of their personal information. In some cases the withdrawal of consent will result in further unavailability of the services of NBCO to the Client.
4.4.2. In accordance with the applicable law, the Client has the right to file a complaint with the supervisory authority.

4.5. Use of the services of NBCO by children
4.5.1. Services of the NBCO are not intended for the use by children without the consent of a legal representative. NBCO might use the information regarding such individuals for the purposes of verifying the age and applying certain age restrictions.

5. Measures Taken for the Protection of the Clients’ Personal Information

5.1. The NBCO shall take necessary and sufficient organizational and technical measures to protect the Clients’ personal information from illegal or accidental access, destruction, changes, suspension, copying, distribution, as well as other illegal actions by third parties.

5.2. The NBCO secures and processes the Client's personal information in accordance with article 7.10. of the Standard of the Bank of Russia STO BR IBBS–1.0–2014 'Providing information security of the Russian bank system companies. General Provisions' of the Federal Law Concerning Personal Data and the Russian Government Regulation Concerning Establishing Personal Data Security Requirements when Processing Such Data under the Information Systems for Personal Data No. 1119 dated 1 November 2012 and other regulations concerning the relations in the field of providing personal data security.

5.3. When processing personal data, the NBCO provides its security and takes required measures to protect them from unauthorized or accidental accessing, erasing, altering, blocking, copying, and distribution, as well as from unlawful actions by treating such data as confidential and sticking up to it including via implementing additional security measures stipulated by Russian legislation, standards, and internal regulatory and administrative documents of the NBCO.

5.4. As a reference model of threat towards personal data security, the NBCO adopted the Industrial Partial Model of Threats Towards Personal Data Security in the Course of Its Processing by the Informational Systems for Personal Details of the Russian Banking System Companies from the BR IBBS Complex.

6. Change in the Privacy Policy. Applicable Legislation

6.1. The NBCO shall have the right to make changes to this Privacy Policy by posting the Privacy Policy new version on https://yoomoney.ru/page?id=527708. Performing inferred actions of using any NBCO's Services by the User under the new conditions shall be considered as his or her consent with this offer.

6.2. This Policy and relations between the Client and the NBCO, arising in connection with the application of the Privacy Policy, shall be subject to Russian law and any other regulatory acts governing relations in the field of ensuring the security of personal data.

7. Interaction with Clients on the Processing of Personal Information

7.1. Questions and commentaries regarding the Policy can be forwarded to to the following email address: dpo@yoomoney.ru

7.2. NBCO reserves the right not to answer any questions that are not related to the provisions of the Policy which does not deprive the Client of the opportunity to forward such questions to the NBCO at the addresses provided at the NBCO's website on the Internet in the “Contact information of NBCO YooMoney LLC” section.

Publication date: 5 November 2020

Previous version dated 19 October 2020