Privacy Policy

• 1. Scope of Application

  • This Privacy Policy (hereinafter referred to as the “Policy”) applies to all information, including personal data within the meaning of the applicable legislation of the Russian Federation (hereinafter referred to as “Personal Information”, “personal data” or “PD”), which Limited Liability Company “Friflex” (hereinafter referred to as “Friflex”) may receive about you in the course of your use of any websites, programs, products and/or services of Friflex:

  • • friflex.com, idsport.ai, idchess.com, live.idchess.com, iddraughts.com, finchess.ru, crossconf.com, awards.crossconf.com, codebab.ai,
    • https://play.google.com/store/apps/details?id=com.idchess.idchess
    • https://appgallery.cloud.huawei.com/ag/n/app/C105818083
    • https://apps.rustore.ru/app/com.idchess.idchess
    • https://apps.apple.com/ru/app/idchess-играй-в-шахматы/id1464126978
    • https://play.google.com/store/apps/details?id=com.crossconf.mobile.android
    • https://apps.apple.com/ru/app/crossconf-главное-it-событие/id1591919846
    • https://appgallery.huawei.com/app/C109085117
    • https://www.rustore.ru/catalog/app/com.crossconf.mobile.android

  • (hereinafter collectively referred to as the “Services”), as well as in the course of Friflex’s performance of any agreements and contracts concluded with you in connection with your use of the Services. Friflex may also receive Personal Information from its Partners and Licensees (hereinafter referred to as the “Partners”) whose websites, programs, products or services you use (for example, from Friflex advertisers). Transfer of Personal Information is possible only in cases established by the applicable legislation of the Russian Federation and is carried out on the basis of special agreements between Friflex and each of the Partners.

  • Please note that the use of any of the websites and/or Services may be governed by additional terms that may amend and/or supplement this Policy and/or contain special terms regarding personal information placed in the relevant sections of documents for such Services.

• 2. General Provisions

  • To enable your use of the Services, your Personal Information is collected and used by Friflex, including LLC “Friflex”, a legal entity established under the laws of the Russian Federation, location: Russian Federation, Moscow, Tverskoy Municipal District, Sushchevskaya St., 27, bldg. 2, premises 4B/2, TIN: 7726434385, or by its Partner or Licensee providing the relevant Service in other jurisdictions.

• 3. Principles of Personal Data Processing

  • Personal data processing at Friflex is based on the principles provided for by Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data”, namely:

  • • personal data are processed on a lawful and fair basis;
    • personal data processing is limited to achieving specific, pre-defined and lawful purposes; collection of personal data that is incompatible with the purposes of personal data processing is not permitted;
    • databases containing personal data that are processed for mutually incompatible purposes shall not be combined;
    • only personal data that meet the purposes of their processing shall be processed;
    • the content and scope of processed personal data correspond to the declared purposes; the processed personal data are not excessive in relation to the declared purposes of their processing;
    • when processing personal data, Friflex ensures their accuracy and sufficiency. Friflex takes the necessary measures to delete or clarify incomplete or inaccurate data;
    • personal data are stored in a form that makes it possible to identify the personal data subject no longer than required by the purposes of personal data processing. Processed personal data shall be destroyed or depersonalized once the purposes of processing have been achieved or if the need to achieve these purposes is lost, unless otherwise provided by federal legislation;
    • for the purposes of organizing and controlling processing and ensuring the security of personal data, Friflex appoints responsible persons who form the basis of the structure in the personal data processing area.

• 4. Terms and Methods of Personal Data Processing

  Friflex:

  • Personal data are processed by Friflex only where there is a proper legal basis, for example, with the consent of the personal data subject to the processing of their personal data, or for the purpose of performing contractual obligations where the personal data subject is the beneficiary.

  • • does not process biometric personal data or special categories of personal data concerning race, nationality, political opinions, religious or philosophical beliefs, or intimate life;
    • does not use personal data for decision-making based solely on automated processing that produces legal consequences or otherwise affects the rights and legitimate interests of personal data subjects;
    • does not carry out cross-border transfer of personal data;
    • does not place personal data in publicly available sources without the separate prior written consent of the personal data subject;
    • does not disclose, transfer to third parties or disseminate personal data without a proper legal basis. Friflex may entrust the processing of personal data to third parties with the consent of the personal data subject, unless otherwise provided by the legislation of the Russian Federation, on the basis of an agreement concluded with such persons (operator’s instruction for personal data processing);
    • when processing personal data, Friflex ensures their accuracy and sufficiency. Friflex takes the necessary measures to delete or clarify incomplete or inaccurate data;
    • personal data are stored in a form that makes it possible to identify the personal data subject no longer than required by the purposes of personal data processing. Processed personal data shall be destroyed or depersonalized once the purposes of processing have been achieved or if the need to achieve these purposes is lost, unless otherwise provided by federal legislation;
    • for the purposes of organizing and controlling processing and ensuring the security of personal data, Friflex appoints responsible persons who form the basis of the structure in the personal data processing area.

  Friflex processes personal data using the following methods:

  • • using automation tools, including information technologies and technical means, including computer equipment, information and technical complexes and networks, means and systems for transmitting, receiving and processing personal data, software tools (operating systems, database management systems, etc.), and information security tools used in information systems;
    • without using automation tools, where personal data processing operations, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (provision), blocking, deletion and destruction of personal data are performed manually. Processing of information concerning health status is possible only without using automation tools.

• 5. List of Processed Personal Data, Processing Purposes and Legal Grounds

  • Personal Information collected in the course of providing the Services, as well as in the course of using websites, programs, products or services of Partners and Licensees, may vary depending on whether you access them using your account or not. Where you log in to your account, Personal Information collected about you by Friflex while using the Services may be matched and linked to other Personal Information collected by Friflex as part of your use of your account. Friflex does not verify the Personal Information provided by you except in cases provided for by the user agreement or terms of use of individual Services, and cannot judge its accuracy or whether you have sufficient legal capacity to provide your Personal Information. However, Friflex proceeds on the basis that you provide accurate and sufficient Personal Information and update it in a timely manner. Friflex may collect the following categories of Personal Information about you while you use the Services:

• Personal data group	List of personal data	Purposes	Grounds
  Personal data provided directly	Personal information provided by you when applying for a vacancy or sending us your CV/resume: full name, email, phone number, CV/resume content.	Reviewing CVs/resumes and selecting candidates for vacant positions	Agreement with HeadHunter LLC (www.hh.ru); Consent of the personal data subject; cl. 1.5 of Article 6 of Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data”; cl. 1.10 of Article 6 of Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data”.
  Personal data of employees and relatives of Friflex employees	Personal information provided as part of entering into an employment agreement: full name, passport details, SNILS, information on employment history and period of employment, information on military duty, information on education, residential address and contact information (phone, email).	Conclusion, administration, amendment and termination of employment agreements; Performance by the employer of obligations provided for by federal legislation, local regulations and employment agreements; Organization of training and assistance in employees’ career growth; Assistance in obtaining social benefits; Issuing voluntary health insurance policies; Empowering employees to conclude transactions and perform other actions on behalf of Friflex.	Consent of the personal data subject; legitimate interests (cl. 1, part 1, Art. 6 of Federal Law No. 152-FZ).
  Personal data of Friflex clients; personal data of chess tournament organizers on the idSport platform	Personal information provided by you upon registration (creation of an account), such as name and email address; Technical data (HTTP headers, IP address, cookie files, browser type data, information about device type and operating system, geolocation accurate to the city); Date and time of access to the Services; Information about your activity while using the Services (for example, purchase data in the Services, information about interaction with other users, as well as files and content uploaded using the Services); User profile data that you may voluntarily provide (first name, last name, country, fields with additional information and information about yourself, photo or avatar); Tournament organizer profile data that the organizer may voluntarily make publicly available (organizer’s name or title, contact details: address, phone, email address, links to social networks, messenger contacts); Data on payment transactions and other payment information provided by you, as well as received from Partners or other persons involved in carrying out a payment transaction using Friflex Services and/or in connection with the provision of paid services, excluding payment card data; Information about you that we receive from our Partners in accordance with the terms of agreements concluded between you and the relevant Partner and agreements concluded between Friflex and the Partner.	Conclusion, administration, amendment and termination of employment agreements; Sending idSport service news and advertising offers/information about promotions/discounts; Performance of obligations provided for by contracts and agreements; Support and service for tournament participants and organizers; Sending idSport service news and advertising offers/information about promotions/discounts.	Consent of the personal data subject; User agreement.
  Personal data of users and other persons who subscribed to Friflex advertising and informational mailings	Full name (if available), first name, email address, phone number, information on consent to receive mailings, date, time, method and source of obtaining consent.	Sending advertising and informational messages, news, offers, invitations to events, information about Friflex products, services, promotions and discounts;	Consent of the personal data subject (cl. 1, part 1, Art. 6 of Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data”); consent to receive advertising mailings in accordance with part 1 of Article 18 of Federal Law No. 38-FZ dated 13 March 2006 “On Advertising”.
  Personal data of representatives of companies that are Friflex counterparties	Full name, contact information, information on power of attorney.	Conclusion, performance, amendment and termination of contracts and ensuring performance of obligations under contracts with counterparties; Legal review of documents; Business communications.	Service agreement.
  Personal data of CrossConf conference participants, speakers and award participants	Data of conference participants (full name, position, place of work, city, email address, phone).	Conclusion, performance, amendment and termination of contracts and agreements (sale of tickets, collection of an organizational fee from participating companies); Sending CrossConf news and advertising offers/information about promotions/discounts.	Consent of the personal data subject; User agreement; Service agreements.
  Personal data of Finchess tournament participants	Data of tournament participants (full name, position, place of work, city, email address, phone, chess rating).	Conclusion, performance, amendment and termination of contracts (collection of an organizational fee from teams participating in the tournament); Sending Finchess news and advertising offers/information about promotions/discounts.	Consent of the personal data subject; Service agreements.

• 6. Rights of the Personal Data Subject

  Right to Withdraw Consent to Personal Data Processing

  • You may withdraw your consent to the processing of your personal data at any time. To do so, you must send Friflex a written withdrawal of consent to personal data processing with your handwritten signature.

  • In case of withdrawal of consent, please send a scanned copy of the executed withdrawal to dpo@friflex.com. The hard-copy withdrawal may be delivered to the Friflex office in person or sent by registered mail with delivery confirmation. Within a period not exceeding 30 (thirty) days from the date of receipt of the written withdrawal, we will stop processing your personal data and send you the relevant confirmation that the processing of your personal data has been stopped.

  Right to Receive Information

  • Using automation tools, including information technologies and technical means, including computer equipment, information and technical complexes and networks, means and systems for transmitting, receiving and processing personal data, software tools (operating systems, database management systems, etc.), and information security tools used in information systems:

  • • confirmation of the fact that Friflex processes your personal data;
    • information on the legal grounds and purposes of processing your personal data;
    • information on the methods of personal data processing used by Friflex;
    • a list of personal data relating to you that are being processed and information on the source from which they were obtained, unless another procedure for providing such data is provided by law;
    • information on the personal data processing periods, including storage periods;
    • information on the completed or intended cross-border transfer of your personal data;
    • other information provided for by legislative acts of the Russian Federation;

  • In case of a request for information, please send a scanned copy of a free-form request containing your handwritten signature to dpo@friflex.com. You may deliver the hard-copy request to the Friflex office in person or send it by registered mail with delivery confirmation. Within a period not exceeding 30 (thirty) days from the date of receipt of the written request, we will provide the requested information concerning the processing of your personal data.

  Right to Clarify and Delete Personal Data

  • As a personal data subject, you have the right to:

  • • request correction of your personal data if they are inaccurate, incomplete or outdated;
    • request blocking or destruction of your personal data if they are incomplete, outdated, inaccurate, unlawfully obtained or are not necessary for the stated purpose of personal data processing;

  • In case of a request to clarify or delete personal data, please send a scanned copy of a free-form request containing your handwritten signature to dpo@friflex.com. You may deliver the hard-copy request to the Friflex office in person or send it by registered mail with delivery confirmation. Within 7 (seven) business days from the end of verification of the accuracy of the information provided, we will fulfill the request or provide a reasoned refusal to fulfill the request.

  • If the inaccuracy or incorrectness of personal data is confirmed, Friflex will notify all persons to whom the inaccurate or incorrect personal data were previously communicated of all exclusions, corrections or additions made to them.