Privacy Policy

This Privacy Policy (hereinafter – “Policy”) regulates processing of personal data of Users of Service by Adsup LLC (Registration Number: 6822081) (hereinafter – “the Administration”).

“Service” means web resource available in Internet at The term “Service” depending on context also includes software of Service, graphic design of Service, any part thereof, and any information published by the Administration.

User unconditionally agree with this Policy and terms of processing User`s personal data and consent to the processing of User`s personal data by continuously use of the Service. If any User does not agree with this Policy in general or any part of it, such User should withhold from using the Service. User`s personal data are processed due to fulfillment of User`s and Administration`s obligations under agreements between them.

1. Personal data processed by the Administration.

1.1 In this Agreement “personal data” means

1.1.1. Any personal information that User discretionary and voluntarily provides to the Administration during creation an Account in Service or use of the Service (including, but not limited to, google advertising ID, phone number, e-mail, geolocation,).

1.1.2. in the course of its use by the User through the software installed on the user’s device, including IP-address; cookies; information about the user’s browser (or other software through which the Service is accessed); technical characteristics of the device and software used by the User, including but not limited to root status of the device; screen size; model and producer of the device, operation system version, list of apps installed on the device; date and time of access to the Service and other similar information.

1.1.3. Other information that is necessary for duly performance of Administration`s obligation before the User.

1.2 This Policy regulates only the processing of personal data of Users collected during use of the Service. Administration does not control processing of the User`s personal data by any third parties including but not limited to third parties links on website of which are contained in Service. The User shall learn privacy policies of such third parties prior to transfer User`s personal data to such third party.

1.3 The Administration does not verify the accuracy of the personal data provided by the User, and is not able to assess its legal capacity. However, the Administration assumes that the User provides accurate and sufficient personal data and keeps this information up to date. The consequences of providing false or insufficient of such data may lead to unavailability of certain functions of the Service.

2. Purposes of processing of User`s Personal Data

2.1 The Administration collects and stores only the personal information that is necessary to provide the functionality of the Service to User or the execution of agreements with the User, or in cases where the law provides for the mandatory storage of personal data for a certain period of time.

2.2 The Administration processes the User’s personal data for the following purposes:

2.2.1. Authorization of the User in the Service, execution of agreements with the Administration;

2.2.2. Provision of personalized information and offers in Service to the User;

2.2.3. Communication with the User, including sending notifications, requests and information relating to the use of the Service, the execution of agreements, as well as processing requests and applications from the User;

2.2.4. Improving the quality of Service, ease of use, development of new service functionality;

The targeting of advertising materials;

Carrying out statistics and other researches based on anonymized data.

Collection of Personal data

3.1 The Administration collects User`s personal data in the following ways:

3.1.1. By provision of such data during registration in Service, submitting any applications, filling any forms in the Service or sending through the e-mail by the User, or contacting the support team.

3.1.2. By other means available in accordance with legislation of Russia and international legislation in area of protection of personal data.

3.1.3. The Administration starts processing of personal data after receipt of User`s consent on such processing.

3.3 The User consent to the processing of personal data by the beginning of use of the Service, including by putting marks in the boxes “I agree with the Terms of Use”, “I agree with the Privacy Policy”, through the user’s specific actions.

The User may at any time withdraw his consent to the processing of personal data. To withdraw consent to the processing of personal information, User shall submit an appropriate application to the Administration by available means of communication. In this case, the Administration must stop processing or ensure the termination of such processing and if the preservation of personal data is no longer required for the purposes of their processing, destroy personal data or ensure their destruction within a period not exceeding 30 (Thirty) days from the date of receipt of the appropriate application. In case of withdrawal of the User’s consent to the processing of personal data, the Administration is entitled to continue processing of personal data without the user’s consent only if there are any other grounds established by the Federal law of the Russian Federation of 27.07.2006 № 152-FZ “On personal data”.

3.5 The User is entitled to choose what personal data he/she will provide to the Administration. However, in case of incomplete provision of the necessary information, the Administration does not guarantee the User’s ability to use all the functions of the Service.

The User can view, update or delete any personal information specified in the Account at any time. To do this, User can edit his/her Account online or send an email to

4. Terms of processing of personal data. Transfer to third parties

4.1 The Administration collects, stores and process User`s personal data in accordance with legislation of Russian Federation, this Policy and Administration`s internal policies

4.2 Confidentiality of the User’s personal data is maintained by the Administration, except in cases of voluntary provision by the User of such data for public access to an unlimited number of persons.

4.3 The Administration is entitled to transfer User`s personal data to third parties in the following ways:

4.3.1 The User consent to such transfer:

4.3.2 Such transfer is necessary to provide Service or services to the User, or execution of any agreement with User, including but not limited to, accrual of remuneration to the User.

4.3.3. Such transfer is established by Russian or other applicable law.

4.3.4. Such transfer takes place as part of the sale or other transfer of business (in whole or in part), and the purchaser shall assume all obligations to comply with the terms of this Policy in relation to the personal information received by him;

4.3.5. In order to ensure the possibility of protecting the rights and legitimate interests of the Administration or third parties in cases where the User violates the Terms of Use of Service, this Policy, or there is a threat of such violation.

4.3.6. Transfer of anonymized User`s personal data to the third parties for carrying out statistical researches, performance of works or rendering services on behalf of the Administration.

4.4 In cases permitted by law, the Administration may transfer your personal information to third parties and government agencies outside the Russian Federation, including to FRG. Personal information may be processed by an employee of the Administration or the Administration’s counterparty working outside the Russian Federation, including to FRG. Such employees may participate, among other things, in the provision of services to the User, the processing of payment orders and the provision of technical support services. By providing User`s personal data, the User agree to such transfer, storage or processing. The Administration will take all necessary measures to ensure the reliable processing of such information in accordance with this privacy Policy.

4.5 The Administration is guided by the Federal law of the Russian Federation of 27.07.2006 № 152-FZ “On personal data”.

5. Right to change or delete personal data. Mandatory retention of personal data

5.1 The User may request to stop the processing of his/her personal data in the Service by sending a message indicating the Account id to the e-mail specified in section 9 of the Policy.

5.2 The rights provided for in this Policy may be restricted in accordance with applicable legislation. In particular, such restrictions may include the obligation of the Administration to retain the information changed or deleted by the User for a period established by law and to transmit such information in accordance with the legally established procedure to the state body.

5.3 User`s personal data is processed by the Administration throughout the period of use of the Service by the User and/or the validity of agreements with the User in accordance with the legislation of the Russian Federation.

6. Processing of cookies

6.1 Cookies transferred from the Administration to User`s equipment and vice versa are used to personalize Service and services and offers for User, statistic research, and for improvement of Service.

6.2 The structure of the cookies, its content and technical parameters are determined by the Administration and are subject to change without prior notice to the User.

6.3 Markers placed by the Administration in the Service can be used to analyze the User’s cookies, to collect and process statistical information about the use of the Service, as well as to ensure the efficiency of the Service in general or its individual functions in particular. The technical parameters of the counters are determined by the Administration and are subject to change without prior notice to the User.

6.4 More information about cookies used in the Service can be found in the Cookies Notice.

7. Security Measures

7.1 The Administration use relevant electronic and procedural safeguards to protect the privacy of the information the User provide to the Administration from loss, misuse, disclosure, alteration and destruction

8. Modifications of Privacy Policy. Applicable law.

8.1 The Administration is entitled to make changes to this privacy Policy. The new version of the Policy shall enter into force upon its publication, unless otherwise provided by the new version of the Policy. The current version shall be available at

8.2 This Policy and the relationship between the User and the Administration arising in connection with the application of this Policy shall be subject to the law of the Russian Federation.

9. Feedback.

9.1 The User is entitled to send by e-mail all requests and notifications, related to personal data and this Policy, that set by the Federal law of the Russian Federation of 27.07.2006 № 152-FZ “On personal data”.

This Policy is effective as of 17.09, 2020.