Privacy Policy of the service "SandBox.Kids"

1. General Provisions

1.1. The Privacy Policy (hereinafter referred to as the Policy) is the official legal regulation of relations in the field of processing personal data (as well as other information of the user of SandBox.Kids - an online service for hosting and viewing videos) between the Administration of SandBox.Kids (IP Klincheva Zhanna Nikolaevna, INN: 552002919504, OGRNIP: 319774600025381, Legal address: Moscow, Medynskaya St., 5, bldg. 6, apt. 59, including its branches and representative offices both in the territory of the Russian Federation and abroad, as well as any other persons created as a result of the reorganization of the Company), which is the creator, copyright holder, of the SandBox.Kids video hosting service, and any user (individual) of the video hosting service (hereinafter referred to as the User).

1.2. Such relations that are directly related to the processing of information about the User (collection, storage, use, distribution and protection of information about the User) are regulated by this Policy and the current legislation of the Russian Federation. The User who will use the products of the SandBox.Kids video hosting service is obliged to familiarize themselves with this document, as well as with other legal materials that are freely available on the SandBox.Kids website.

1.3. During the registration process, using the video hosting products, the User agrees to the terms of this document, and also gives their consent to the processing of personal data.

1.4. The processing of personal data by the SandBox.Kids Administration is carried out in full compliance with the current legislation of the Russian Federation, namely: on the basis of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data", the Decree of the Government of the Russian Federation of 01.11.2012 No. 1119 "On approval of requirements for the protection of personal data when processing them in personal data information systems", the Decree of the Government of the Russian Federation of 15.09.2008 No. 687 "On approval of the Regulation on the specifics of processing personal data carried out without the use of automation tools", as well as in accordance with other regulatory legal acts in the field of personal data protection.

2. What is included in personal information

2.1. Information processed by the SandBox.Kids Administration is:

• the data that the User enters during registration, account creation (phone number, email address, country, etc.);
• other information that the User enters into his profile when editing an existing account;
• personal data that may be requested by SandBox.Kids from the User for the purpose of fulfilling the Administration's obligations to the User (based on the User Agreement posted in the link);
• electronic data (HTTP headers - a data transfer protocol with the name of a specific page; IP address - a unique numerical identifier of a device in a computer network operating on the IP protocol; cookies - a set of data sent by a web server and stored on the user's computer; browser identifier data - information about the settings and capabilities of users' browsers used to identify them; hardware and software information - programs and device drivers designed to work in a specific system; Wi-Fi network data - wireless local area network technology with devices with a specific IP address);
• statistical information about user activity on the video hosting service (any active actions of the User on the Platform, for example, downloading a video, viewing any content, adding to Favorites, marking Liked, etc.);
• financial data: information about payment cards used to conduct payment transactions;
• information that is automatically generated when accessing the video hosting service using cookies;
• any other information that is directly related to the identification of the user as an individual: full name, gender, age, date of birth, citizenship, details of the document certifying the identity of a citizen of any country, etc.

2.2. The Administration does not check the credentials provided by the User for their veracity, reliability, or whether the User has sufficient legal capacity to provide the credentials. However, the Administration assumes that the User provides reliable and sufficient credentials. By completing the registration process in the video hosting service, the User confirms that he has reached the permissible age for using such a service in accordance with the current legislation of the Russian Federation.

2.3. The Administration reserves the right to clarify, update, adapt, change, enrich and verify the personal data provided by the User, by automated processing of personal data (processing of personal data using computer technology).

2.4. Verification means checking the authenticity of the data provided. The Platform uses two types of verification: by phone number and by email address. In order for the Platform Administration to verify that it is you who is registering a profile on the service, the User will be sent an SMS message to the specified phone number (if the User has chosen to register by phone number), or an email will be sent to the email address (if the User has chosen to register by email address). In both cases, the texts of the sent messages will contain a random code that is available only to the User and which is unique to the specific User registration.

2.5. The User can make changes to his/her personal profile on the Platform at any time convenient for him/her using the editing functionality. In this case, the changes made to the profile will be updated by the SandBox.Kids Administration, subject to preliminary successful verification of the entered data.

3. Processing of data provided by the User

3.1. When collecting and processing personal data, the SandBox.Kids Administration adheres to the basic principles of legal compliance with the current legislation of the Russian Federation - this is legality, good faith, compliance of the purposes of processing personal data with the purposes previously determined and declared when collecting personal data.

3.2. The User's personal data is stored exclusively on electronic media and is processed using automated systems, except for cases where non-automated processing of personal data is necessary in connection with the fulfillment of legal requirements.

3.3. The personal data that the User provides to SandBox.Kids is not transferred to third parties, except for cases expressly provided for in this Policy. When specifying the User or with the User's consent, it is possible to transfer the User's personal data to third parties - counterparties of the SandBox.Kids Administration, subject to the assumption by such counterparties of obligations to ensure the confidentiality of the information received. The provision of Users' personal data at the request of government agencies (local government bodies) is carried out in the manner prescribed by the current legislation of the Russian Federation.

3.4. Personal data is automatically deleted when the User voluntarily deletes data from his personal profile, as well as when the User voluntarily deletes his personal profile from the Platform, or when the SandBox.Kids Administration deletes information or content of the User that violates the rules for using the SandBox.Kids video hosting service and the norms of the current legislation of the Russian Federation.

4. What is the purpose of collecting and processing personal information

4.1. The SandBox.Kids Administration collects, processes and stores only the personal information of Users necessary for the direct provision of high-quality services in the field of information technology. In this regard, the only goal pursued by the SandBox.Kids Administration when collecting and processing User data is to achieve the most clear and transparent identification of the User in the SandBox.Kids video hosting service, so that the Administration, based on recommendation and other technologies, could provide Users with the opportunity to use the service products in full.

4.2. To achieve this goal, the SandBox.Kids Administration has the full right to do the following:

• register Users on SandBox.Kids;
• provide Users with access to video hosting products, services, services for the most complete enjoyment of using SandBox.Kids;
• communicate with Users by sending notifications, mailings, requests, as well as receiving complaints and applications from Users within the Support section of the video hosting service;
• track and analyze User preferences within the framework of the use of recommendation technologies;
• carry out activities within the framework of preventing any criminal or other activity contrary to the legislation of the Russian Federation, which can be carried out on SandBox.Kids;
• organizing and conducting certain events that stimulate user interest in the Platform;
• other actions that do not directly contradict the legislation of the Russian Federation.

4.3. In order to achieve the goal, the Administration adheres to the following principles of personal data processing in accordance with the norms of the Russian Federation legislation:

• data sufficiency (do not use User data beyond the limits of achieving a specific goal);
• compliance with goals (use only such data that are suitable for the implementation of a specific goal, and not any other);
• data security (implementation of reliable digital protection of the user database);
• data confidentiality (prevention of any external activity on illegal receipt, collection, processing of personal data for their further criminal use. In other words, the confidentiality of the User's personal information is maintained);
• data relevance (timely checking of databases for the relevance of the information provided, deletion of data of Users who have stopped using the video hosting service in order to prevent their illegal distribution, use).

5. Use, processing of Cookies

5.1. Like any other service in the field of information technology, the Platform collects and processes cookies in relation to Users. SandBox.Kids uses the following types of cookies: technical cookies, analytical, functional and advertising.

5.2. Cookies are processed by the Administration only within the framework of achieving the goal specified in paragraph 4.1 of this Policy. The Platform Administration strives to improve its functionality every time, to make the service more convenient for Users, and of higher quality.

5.3. The User can at any time refuse to process cookies in the settings of their browser. In this case, SandBox.Kids services will use only those cookies that are strictly necessary for the functioning of such a service and the provision of its functionality.

6. Protection of personal data

6.1. The SandBox.Kids Administration takes all necessary measures to fully protect the personal data provided by Users in order to avoid their unauthorized distribution, access, liquidation, modification, blocking and other criminal acts.

6.2. On SandBox.Kids, personal information is mostly processed automatically without access to it by employees and/or contractors of the Administration. If such access is granted to employees or contractors of the SandBox.Kids Administration, then only to the extent necessary for such persons to perform their official duties or duties under an agreement with the Administration, while such persons are obliged to comply with all technical and organizational security measures when accessing the Information in accordance with the law.

6.3. We strive to constantly develop and implement new advanced technological and organizational measures to protect the personal information of our Users in order to prevent any unauthorized, illegal modification, destruction of User data, as well as their further criminal distribution and use for personal fraudulent purposes to extract benefits. However, even with this level of protection, the SandBox.Kids Administration notifies its Users that in the era of rapidly developing levels of criminal activity in the digital technology sphere, it cannot guarantee the security of the data transmitted by the User to SandBox.Kids, unauthorized access to which may be obtained by other persons through illegal actions. In other words, the transfer of data is carried out by Users at their own risk. 6.4. To protect SandBox.Kids data, a system of linking the User's personal mobile phone number, which he/she enters in the account registration window, is used. Therefore, in case of loss of login/password data, the User will be able to restore access to his/her account using the phone number.

6.5. The SandBox.Kids administration has developed measures for the most high-quality and comprehensive protection of Users' personal data:

• intermediate monitoring of the security system is carried out to identify the most vulnerable points in the service;
• immediate recovery work is carried out in cases of detection of unauthorized destruction of data, its modification;
• our own system for protecting the personal data of Users has been created;
• a working group in the field of security has been formed, the core activity of which consists only of debugging the process of protecting the personal data of Users, improving its comprehensive measures, predicting possible actions of intruders to gain access to the personal data of our Users.

6.6. Recording, systematization, accumulation, storage, clarification, extraction of personal data of SandBox.Kids Users is carried out by the Administration exclusively on server capacities located on the territory of the Russian Federation.

7. Rights and obligations of the SandBox.Kids User

7.1. In cases stipulated by the current legislation of the Russian Federation, the SandBox.Kids User has the full right of access to his personal information, which is located on SandBox.Kids and processed by the SandBox.Kids Administration.

7.2. Based on the Russian Federation law, Users have the rights to:

• view information through their own account, the content of which the Platform stores in its databases;
• delete their information from SandBox.Kids, as well as demand the complete deletion of any personal information directly related to the User;
• revoke their own consent to the processing of personal data (in this case, the User will not be able to use SandBox.Kids products due to a temporary ban on authorization by the Administration);
• express a demand for another restriction on the processing of their own personal information;
• raise objections regarding the personal data processing policy, even in cases where this is provided for by the Russian Federation law;
• notify the SandBox.Kids Administration of facts of violation of personal data processing;
• periodically send a request to determine the status of the correctness of the processing of their personal data;
• demand that corrections be made to the current personal data, if an inaccuracy is found in the composition of personal data that was not completed by the User himself;
• draw up and file a complaint with the relevant subordinate authorities in the event of detection of a violation by the SandBox.Kids Administration of the Users' rights in the field of personal data processing.

7.3. The SandBox.Kids Administration will fulfill the specified requirements, requests from Users on the basis of applicable law.

7.4. Users can send requests, complaints, suggestions, demands, and other written clarifications via the contact us link specified in the User Agreement.

8. Other terms, amendments and additions to the Privacy Policy

8.1. This Policy may be amended in the future at the discretion of the SandBox.Kids Administration with mass notification of this to Users. This notification will also include a link to the new version of this Policy. Upon receipt of such notification, the User undertakes to once again independently familiarize themselves with the new provisions of the Policy. Failure of the User to familiarize themselves with the new provisions of the Policy shall not be grounds for the User's failure to fulfill their obligations within the framework of using the SandBox.Kids video hosting service.

8.2. The User has the right to refuse to accept amendments and additions to this Policy, which means the User's refusal to use all rights previously granted to them.

8.3. This document is regulated in accordance with the legislation of the Russian Federation. Issues not regulated by this Policy shall be resolved in accordance with the legislation of the Russian Federation.

8.4. The SandBox.Kids administration is not responsible for third-party websites and services that the User can access via links/buttons available on SandBox.Kids.