This privacy policy regarding the processing and protection of personal data (hereinafter referred to as the Policy) applies to all information that the Limited Liability Company "Tilcher" (hereinafter referred to as the "Operator of Personal Data" or "Operator") may receive about the user (hereinafter referred to as the User) and/or about a third party, according to on behalf of and in the interests of which the User acts while using the UMA Platform (represented by the sites (hereinafter referred to as the Promo site) and (hereinafter referred to as the blogger's Personal Account, accessible via the web interface, as well as the mobile application (the blogger's Personal Account, accessible via the iOS or Android mobile application), its services, programs and products.

The Policy applies to all personal data of subjects that can be obtained by the Operator in the course of its activities. The purpose of the Policy is to provide the persons (subjects) providing their personal data with the necessary information to assess which personal data and for what purposes are processed by the Operator, which methods of ensuring their security are implemented.

The Policy protects the rights of subjects when processing their personal data with or without the use of automation tools, and also establishes the responsibility of persons with access to personal data for non-compliance with the requirements governing the processing and protection of personal data. Users of the Platform, using the Operator's services, by informing the Operator of their personal data, including through the mediation of third parties, acknowledge their consent to the processing of personal data in accordance with this Policy and the terms of processing of User's personal data.

Consent to the processing of personal data may be revoked by the subject of personal data by sending a message to the email address . If the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified by the current legislation.

Please read this Policy before using the Platform website and its services (see above). By using the UMA Platform, you consent to the collection and processing of your data in the ways set out in this Policy. If you do not agree to be bound by the terms of this Policy, you do not have the right to access the Platform and its services (see the full list above).


1.1. Within the framework of this Policy, the User's personal information is understood as:

1.1.1. Personal information that the User provides about himself/herself in the process of using feedback forms and other Platform Services, including personal data of the User (name, contact phone number, email address, etc.), as well as personal data received at the Operator's corporate email address, persons who have expressed consent to the processing of personal data, by starting using the Platform, sending information through the selected forms of the Platform's services, or sending an email to the Operator's corporate mail.

The information required for the provision of Services is marked in a special way. Other information is provided by the User at his discretion.

1.1.2. Data that is automatically transmitted to the Platform services during their use (viewing, reading texts, downloading information) using the software installed on the User's device, including IP address, cookie data, information about the User's browser (or other program that accesses the services), technical characteristics of the hardware and software used by the User, the date and time of the Site visit, the addresses of the requested pages, or other similar information.

1.1.3. Other information about the User, the processing of which is necessary for the use of the Platform.

1.2. This Privacy Policy applies only to the Platform. The Platform's Services do not control and are not responsible for third-party sites to which the User can click on links available on the Platform's sites and services.


2.1. The Platform collects and stores only the personal information that is necessary for the provision of services or the execution of agreements and contracts with the User, except in cases where the legislation provides for the mandatory storage of personal information for a period specified by law.

2.2. The Operator processes personal data for the implementation of activities, the realization of its legitimate interests and requirements.

2.3. Purposes of personal data processing:

2.3.1. Identification of the User registered on the Platform.

2.3.2. Providing the User with access to the Platform resources.

2.3.3. Establishing feedback with the User, including sending notifications, requests regarding the use of the Platform, provision of services, processing requests and requests from the User. Determining the User's location to ensure security, fraud prevention and ensuring the correct operation of the Platform functionality.

2.3.4. Confirmation of the accuracy and completeness of the personal data provided by the User.

2.3.5. Providing the User with effective customer and technical support in case of problems related to the use of the Platform. User notifications by email.

2.3.6. Notifying the User about updating the functionality and information materials of the Platform, sending notifications, special offers, newsletters and other information, and requests related to the provision of services with the consent of the User.

2.4. The Platform and its services collect typical session log information, including the IP address, browser type and language, as well as data on the time of visit and the address of the websites from which the links were clicked. In order to ensure effective management of the Platform and assist in setting up the user interface and functionality, the Operator can use cookies (small text files stored in the visitor's browser) or web beacons (web beacons - electronic images) together with tracking pixels (tracking pixels), allowing the Platform and its services to count the number of visitors who have visited a certain page or screen, and provide access to certain cookies.

2.5. The collected standard information is used exclusively for statistical purposes.

The Operator does not use personal data for the purpose of personal identification of any of the Users. However, when authorizing registered Users on the Platform, the Operator can use this information in combination with information obtained through data analysis tools and cookies in order to analyze how visitors use the Platform and its services.

2.6. Using the Platform and its services, the User agrees that the Operator can upload cookies to the User's device in accordance with the conditions described above.

2.7. The User has the ability to manage cookies by accessing the browser settings. If cookies are deleted, all data about the User's preferences will be deleted, including the preference to refuse the use of cookies. If cookies are blocked, changes may affect the user interface, and some components of the Platform and its services may become unavailable.


3.1. Confidentiality is maintained with respect to the User's personal information, except in cases where the User voluntarily provides information about himself for general access to an unlimited number of persons. In this case, the User agrees that a certain part of his personal information becomes publicly available.

3.2. The Operator does not have the right to transfer the User's personal information to third parties, with the exception of the following persons:

3.2.1. authorized state bodies within their powers;
3.2.2. persons to whom the Operator is obliged to transfer them in order to comply with the legislation of the Russian Federation;
3.2.3. persons to whom the Operator transfers personal data in order to fulfill the contract with the subject of personal data;
3.2.4. persons to whom the Operator entrusts the processing of personal data;
3.2.5. the legal successor of the Operator;
3.2.6. to other persons, with the consent of the personal data subject.

3.3. The processing of the User's personal data is carried out without time limit in any legal way, including in personal data information systems using automation tools or without the use of such tools. The processing of Users' personal data is carried out in accordance with Federal Law No. 152-FZ of 27.07.2006 "On Personal Data".

3.4. The Operator applies appropriate standards of technological and operational security to protect the information provided by the Visitors of the Platform from unauthorized access, disclosure, distortion, blocking or destruction.

3.5. The measures applied by the Operator, including, include:

3.5.1. appointment of the responsible person for the organization of personal data processing;
3.5.2. application of legal, technical and organizational measures to ensure the security of personal data;
3.5.3. assessment of the harm that may be caused to personal data subjects in case of violation of legal requirements, the ratio of harm and the security measures taken by the Operator;
3.5.4. the use of secured premises with limited access to host servers of personal data information systems, as well as the use of lockable cabinets for storing paper media of personal data;
3.5.5. familiarization of the Operator's employees directly engaged in the processing of personal data with the provisions of the legislation of the Russian Federation on personal data;
3.5.6. control over the measures taken to ensure the security of personal data.

3.6. The Operator guarantees organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions with it by third parties. The Operator, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

3.7. Processing of personal data is carried out on the territory of the Russian Federation, cross-border transfer of personal data is not carried out. The operator reserves the right to choose any channels for transmitting information about personal data, as well as the content of the transmitted information.

3.8. In case of loss or disclosure of personal data, the Operator has the right not to inform the User about the loss or disclosure of personal data.


4.1. The User is obliged to:

4.1.1. Provide information about personal data necessary for using the Platform.
4.1.2. Update, supplement the provided information about personal data in case of changes in this information.

4.2. The Operator is obliged to:

4.2.1. Use the information obtained exclusively within the stated goals.
4.2.2. To ensure the storage of confidential information in secret, not to disclose without the prior written permission of the User, as well as not to sell, exchange, publish or disclose in other possible ways the transferred personal data of the User, except as provided for in this Policy.
4.2.3. Take precautions to protect the confidentiality of the User's personal data in accordance with the procedure usually used to protect this kind of information in the existing business turnover.
4.2.4. To block personal data related to the relevant User from the moment of the User's request or request, or his legal representative or the authorized body for the protection of the rights of personal data subjects for the period of verification in case of identification of false personal data or illegal actions.

4.3. In case of loss or disclosure of personal data, the Operator is not responsible if this confidential information:

4.3.1. Became public domain before its loss or disclosure.
4.3.2. Was received from a third party before it was received by the Operator.
4.3.3. Was disclosed with the consent of the User.
4.4. The User is fully responsible for compliance with the requirements of the legislation of the Russian Federation, including the laws on advertising, on the protection of copyright and related rights, on the protection of trademarks and service marks, but not limited to the above, including full responsibility for the content and form of materials.

4.5. The User acknowledges that the responsibility for any information (including, but not limited to: data files, texts, etc.) to which he may have access as part of the Site is borne by the person who provided such information.

4.6. The User agrees that the information provided to him as part of the Platform and its services may be an object of intellectual property, the rights to which are protected and belong to other Users, partners or advertisers who post such information on the Platform.

4.7. The User is not entitled to make changes, lease, sell, distribute or create derivative works based on the content of the Platform (in whole or in part), except in cases when such actions were expressly authorized in writing by the owners of the content of the site in accordance with the terms of a separate agreement.

4.8. In relation to text materials (articles, publications that are freely available on the Platform), their distribution is allowed, provided that a link to the Platform and its services (in particular, the promo site) is given /).

4.9. The Operator is not liable to the User for any loss or damage incurred by the User as a result of the deletion, failure or inability to save any content of the Platform, its services and other communication data contained on the Platform or transmitted through it.

4.10. The Operator is not responsible for any direct or indirect losses that occurred due to: the use or inability to use the site or individual services; unauthorized access to User communications; statements or behavior of any third party on the site.

4.11. The Operator is not responsible for any information posted by the user on the Platform, including, but not limited to, copyrighted information, without the express consent of the copyright owner.


5.1. The Operator's activity in processing personal data in information systems is based on the principles of protecting the confidentiality of the information received.

5.2. The security of personal data during their processing in the Operator's information systems is ensured by the information protection system, which includes:
5.2.1. organizational measures with the use of restrictions on physical access to premises,
5.2.2. application of software and technical protection measures.

5.3. The exchange of personal data during their processing in information systems is carried out through communication channels protected by technical means of information protection.

5.4. When processing personal data in the information systems of the Organization, the following are provided::
5.4.1. carrying out measures aimed at preventing unauthorized access to personal data and (or) transferring them to persons who do not have the right to access such information;
5.4.2. timely detection of unauthorized access to personal data;
5.4.3. prevention of the impact on the technical means of automated processing of personal data, as a result of which their functioning may be disrupted;
5.4.4. the possibility of immediate recovery of personal data modified and destroyed due to unauthorized access to them;
5.4.5. constant monitoring of the level of personal data security.

5.5. In order to ensure that the level of personal data protection complies with the requirements of Federal Law No. 152-FZ of 27.07.2006 "On Personal Data" and Federal Law No. 149-FZ of 27.07.2006 "On Information, Information Technologies and Information Protection", the Operator does not disclose information about the specific means and methods used to ensure the information security of personal data.


6.1. The terms of processing of personal data are determined based on the purposes of processing in the Operator's information systems, in accordance with the term of the contract, the agreement with the Subject of personal data, the statute of limitations, as well as other legal requirements and regulatory documents of the Operator.


7.1. The Operator has the right to make changes to this Policy without the User's consent.

7.2. The new version of the Policy comes into force from the moment it is posted on the Website, unless otherwise provided by the new version of the Policy.

7.3. The current version of the Policy is posted on the page at:


8.1. All suggestions, questions and notifications regarding this Policy should be sent to .

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