Ster Privacy Policy

This Policy is part of the User Agreement, by accepting it (by accepting the offer), you consent to the processing of your personal data on the terms specified in the Privacy Policy below.

This Privacy Policy applies to personal data that Ster and/or its affiliates may obtain about any user (hereinafter 'User' or 'You') of the Ster mobile application (hereinafter 'App') during their use of Ster.

By registering or visiting Ster, the User expresses his/her unconditional consent to the Privacy Policy and the terms of processing his/her personal data specified therein.

Use of the App means the User’s unconditional consent to this Policy and the terms of processing of information received from the User’s device specified therein. In case of disagreement with the Policy, the User shall refrain from using the App.

1. Who processes the information

This Privacy Policy applies to the apps of Ster, LLC, located at the address: Russian Federation, Moscow, TIN: 7728427111 ('Ster' or 'We') that receive data from Users and have a link to this Privacy Policy. It does not apply to Ster websites that do not contain or link to this Privacy Policy, or to websites and applications that have their own Privacy Policy.

Ster is dedicated to protecting Your personal data while it is being processed. We encourage You to review this Privacy Policy regularly, as it may be updated in accordance with legislative amendments or changes to our internal processes. We have the right to amend this Policy by posting the revised Policy on the App and/or website. It is the responsibility of the User to get acquainted with the latest version of the Policy on his/her own.

2. Activities performed with personal data

In the course of processing Your personal data by means of automation We perform the following activities: collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.

3. Activities performed with personal data

Ster obtains data in the following ways:

3.1. Data provided by You and minimum necessary for registration with Ster:

• Cell phone number.
• Surname.
• First Name.
• Address of registration.
• Copy of passport pages.

3.2. The data You provide to replenish Your account. These data are not processed and stored in Ster, but are transmitted directly to acquiring:

• Number of the bank card from which the replenishment is made.
• Its expiration dates.
• CVV/CVC/CVP of this card.

3.3. The details You provide for refunds:

• Bank details.

3.4. Information that is transmitted automatically when interacting with Ster:

• IP address.
• Type of action performed in the App (touching the screen, flipping screens, etc.).
• Date and time when the action was carried out.
• Duration of the User’s session.
• Entry points (third-party resources, from which the User goes to the App via a link).
• Exit points (links in the App from which the User goes to third-party resources).
• Country.
• Region.
• Provider.
• List of supported languages on the device.
• OS type.
• Screen settings.

3.5. Content of information that can be obtained from the User’s device when using the App and the purpose of its obtaining:

• Information about the location of the User’s device (based on data from the cellular operator's network and GPS signals) is used to determine the availability of the App in his or her region.
• Photo images captured using the device camera and stored in the device memory are used within the scope of the services described in the App, including for use as supporting documents for making registrations and transactions.
• Mobile device information, such as mobile device model, operating system version, unique device identifiers, as well as mobile network data and cell phone number, is used to analyze possible errors in the App operation and improve the App operation.
• The information about the performed transactions, such as the place, time and amount of the performed transactions, type of payment method, data about the seller and/or service provider, as well as other information related to the performance of the above mentioned transactions, is used within the framework of the services implemented in the App.

3.6. Additional data requested by Ster in order to fulfil its obligations under the User Agreement. In particular, Ster may request a copy of Your identity document or any other document containing Your name, surname, photograph, as well as other additional information that is necessary and appropriate for identification purposes and to prevent misuse and infringement of third party rights.

4. Analysis tools

Ster uses Google Analytics to study user activity.

We use Google Analytics, which is a web analytics tool of Google Inc., Amphitheater Parkway, Mountain View, California 94043, USA ('Google') to continually improve our website. Google Analytics operates with cookies and creates pseudonymous usage profiles that allow us to analyze Your use of our website. The information stored in such cookies (e.g., browser type/version, operating system used, referrer URL, hostname of the computer accessing, time of the request to the server) is generally transmitted and stored on Google servers. You can also download and install the browser deactivation add-on from http://tools.google.com/dlpage/gaoptout?hl=ru. For more information, see 'In Google’s privacy policy': https://www.google.com/intl/ru/policies/privacy/.

5. Purposes of personal data processing

Ster processes Your personal data in order to fulfill the User Agreement. In particular, personal data is used for the following purposes:

• Provide You with access to Ster.
• Continuously develop and enhancing the quality of service in Ster.
• Communicate with You, sending notifications, requests and other information related to Ster.
• Protect the Users from fraudulent activities.
• Distribute promotional and informational materials and conduct marketing campaigns.
• Provide advertisements and offers tailored to Your preferences.
• Collect, process and present statistical data, big data and another research.
• Research the behavior of the Users of the App.
• Attract new users.
• Verify and confirm Your identity for authorization and transactions.
• Transmit Your data to the acquiring company for account replenishment.

6. Legal basis for processing Your personal data

We only process Your personal information if:

• you have consented to the processing of Your personal data in the manner provided for in the agreement we have concluded; or
• the processing of Your personal data is necessary for the performance of the agreement concluded between us; or
• the processing of Your data is required by applicable law, court order or other competent state or municipal authority.

7. Ster’s data protection principles

Ster tailors its service in such a way that the processing of personal data is minimized. In some cases, We may have to share Your personal data with third parties as required by applicable law. This happens, for example, when there is reason to suspect that a crime has been committed or that our website and mobile application are being used inappropriately.

This Policy applies only to the App. We do not control and are not responsible for information (consequences of its transfer) transferred by the User to a third party, in case such transfer was made on a third party resource, to which the User could have accessed through links from the App.

We may engage third parties to provide certain services. If such third parties need access to personal data, We will ensure that such access is limited to the extent necessary to provide the services. In addition, such external service providers must comply with all applicable data protection regulations themselves.

For the purposes outlined in this Policy, We may engage partners with whom We have appropriate confidentiality agreements to process User Information. The transfer of anonymized data about the use of the App to partners for the purposes of improving the App is carried out on the basis of agreements with partners.

In order to verify and confirm Your identity, as well as for the purpose of issuing a virtual card, Your personal data may be transferred to third parties solely for the purpose of performing services within the framework of the User agreement defining the subject matter in accordance with the User agreement signed between Ster and the User.

We take all organizational and technical measures within our control to protect User Information from unauthorized access, use, copying and distribution by third parties.

User’s information may be provided to state authorities in accordance with the requirements of the applicable law.

8. Recipients and legal basis for data transfer

We only disclose information with access restrictions in the following ways:

• Within Ster. Your personal data will be used by our staff and other employees as necessary for the purposes described above.
• We may also share Your data with Third Parties who help us provide services. They will process Your personal data as data processors (Article 28 GDPR) solely on our behalf. Categories of such recipients include: web analytics, data processing, advertising, email newsletters, payment processing and other services. In such cases, these third parties must comply with our privacy and data security requirements and may not use the personal data they receive from us for other purposes. When we disclose Your information outside the European Economic Area, we do so based on the standards set out in the European Commission-approved standard contractual clauses on transfers of personal data, as well as our own high standards of data security and respect for Your privacy.

9. Where Your Personal Information is stored and processed

Your Personal Information will be stored in the Russian Federation and/or the EEA.

For Russian users: Ster records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves personal data of citizens of the Russian Federation using databases located in the Russian Federation.

FOR USERS IN THE EEU OR SWITZERLAND: RUSSIA IS A JURISDICTION OUTSIDE THE EUROPEAN ECONOMIC AREA THAT HAS NOT BEEN RECOGNIZED BY THE EUROPEAN COMMISSION AS PROVIDING AN ADEQUATE LEVEL OF PROTECTION FOR PERSONAL DATA. THEREFORE, STER HAS TAKEN APPROPRIATE MEASURES TO ENSURE THAT SUCH TRANSFERS ARE CONDUCTED IN COMPLIANCE WITH APPLICABLE EU DATA PROTECTION REGULATIONS. IN PARTICULAR, STER RELIES ON THE STANDARD CONTRACTUAL CLAUSES APPROVED BY THE EUROPEAN COMMISSION TO ENSURE AN ADEQUATE LEVEL OF PROTECTION FOR YOUR PERSONAL INFORMATION TRANSMITTED TO RUSSIA. A COPY OF THESE STANDARD CONTRACTUAL CLAUSES IS AVAILABLE UPON REQUEST.

According to Regulation N 2016/679 of the European Parliament and of the Council of the European Union 'On the protection of natural persons with regard to the processing of personal data and on the free circulation of such data and repealing Directive 95/46/EC'. It also defines the term 'personal data' as any information relating to an identified natural person, but this term is disclosed in detail:

'An identifiable person is a person who can be identified, directly or indirectly, in particular through identifiers such as name, identification number, location information, online identifier or through one or more features characteristic of the physical, psychological, genetic, mental, economic, cultural or social identity of the said natural person.'

10. Storage period for Your personal data

Ster will store Your personal data for as long as is necessary to fulfill the purpose for which it was collected or to comply with legal and regulatory requirements.

11. Your rights and how to exercise them in relation to personal data

You have the following rights in relation to Your personal data:

The right to information obtain. You have the right to receive clear, transparent and understandable information about how We use Your personal data and about Your rights.

The right of access. This right allows You to obtain a copy of the personal data We process and to verify that We are processing it in accordance with the applicable law.

The right to make changes. You can submit a request to modify Your personal data in the 'My Profile' section.

The right to limit processing. This right allows You to ask us to suspend the processing of Your personal data, for example, if You want us to establish its accuracy or the reason for processing.

The right to data portability. You may ask us to transfer Your personal data. We will provide You or a third party You choose with Your personal data in a structured standardized machine-readable format.

The right to object. You may object to the processing of Your personal data at any time if such processing is in our legitimate interests.

The right to withdraw consent to data protection. If You withdraw Your consent, we may not be able to provide You with access to certain features of our website. We will notify You if and when You withdraw Your consent.

The right to lodge a complaint. You have the right to contact Your country's data protection authority to complain about our data protection and privacy practices.

The right to deactivate cookies. If You wish to restrict or block all cookies set by our websites, use the tool available on the relevant website or refer to Your browser’s help to learn how to manage Your browser settings.

The right to be forgotten. This right allows You to contact support to delete Your data from Ster if, for any reason, Your data could cause You harm. This applies to outdated, irrelevant, incomplete, inaccurate or redundant data or information whose legitimate grounds for storage have disappeared over time. This right is exercisable under certain conditions, and in turn Ster will do everything necessary to ensure that Your data is only used as necessary in accordance with the stated purposes.

If You want to exercise these rights, You can write to support@ster.me at any time. We will respond to all legitimate requests within 30 days.

HOWEVER, WITHDRAWING YOUR CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA OR EXERCISING YOUR RIGHT TO BE FORGOTTEN WILL RESULT IN THE DELETION OF YOUR ACCOUNT, MAKING IT IMPOSSIBLE FOR YOU TO USE STER. The rights provided above may be restricted as required by law.

12. Making changes to the privacy policy

Ster has the right to make changes to this Privacy Policy. The new version of the Privacy Policy shall come into effect from the moment of its posting, unless otherwise provided by the new version of the Policy.

13. Feedback

Questions or comments regarding the Policy can be sent to the email address: support@ster.me