<b>VK.COM PRIVACY POLICY</b>
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<b>1.
Who we are</b>
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<b>1.1.</b> We are LLC "V Kontakte" of 1-N, bld.
12-14, Lit.
A, Khersonskaya st., St.
Petersburg, Russia, 191024.
We are represented, for the purposes of this policy, by MGL MY.COM (CYPRUS) LIMITED of 28 Oktovriou, 365 VASHIOTIS SEAFRONT, office 402 Neapoli, 3107, Limassol, Cyprus.
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<b>1.2.</b> This Privacy Policy sets out how we collect and use your personal information when you visit https://vk.com (including through mobile version m.vk.com or our mobile apps (including our iPhone, Android and WP apps) (hereinafter the Site) and the choices available to you in connection with our use of your personal information (the Privacy Policy).
This Privacy Policy should be read alongside, and in addition to, our Site terms and conditions (accessible online at http://vk.com/terms) (Terms) and our Cookie Policy (accessible online at http://vk.com/privacy/cookies).
In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail.
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<b>2.
This Privacy Policy</b>
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<b>2.1</b> By making available the Site and its services (hereinafter the Site Services) we, acting reasonably and in good faith, believe that you: <ul>
<li>(a) have all necessary rights to register on and use this Site.
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<li>(b) provide true information about yourself to the extent necessary for use of the Site Services.
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<li>(c) understand that by the posting your personal information you have manifestly made this information public, and this information may become available to other Site users and internet users, be copied and disseminated by them.
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<li>(d) understand that some types of information transferred by you to other Site users cannot be deleted by you or us.
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<li>(e) are aware of and accept this Privacy Policy.
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<b>2.2</b> We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.
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<b>2.3</b> This Privacy Policy applies only to the European Union-based users.
If you are not a European Union-based user, please refer to the Privacy Policy applicable in the relevant jurisdiction.
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<b>3.
Information we collect about you</b>
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<b>3.1</b> In order to implement the agreement between you and us, and provide you with access to the use of the Site functionality, we will improve the Site Services, develop and implement new Site Services, and enhance available Site and services functionality.
To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organise, extract, compare, use, and supplement your data (hereinafter “processing”).
We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and section 4 of this Privacy Policy.
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<b>3.2</b> We set out in more detail the information we collect when you use our Site Services, why we collect and process it and the legal bases below.
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<br> Information Collected Purpose Legal Basis 1 Location Data We use your location data in order to generate recommendations and tailor and improve the adverts that are presented on the Site.
We also use this information in order to provide you with recommendations, community groups we feel you may be interested in, updates and information on our and selected third parties' products and services we think you may be interested in.
<ul>
<li>Consent </li>
<li>Legitimate Interests </li>
</ul>2 Data you provide for registering on the Site including your name, surname, date of birth, gender, mobile phone number and/or email We use this information in order to manage and administer the Site including providing our services to you.
We use this data to enable us to fulfill our obligations to you as part of the Site Services (e.g.
in cases where you request restoration of your page that is not linked to a mobile phone number).
See section 9.3 of this Privacy Policy for more information.
We also use this information in order to provide you with recommendations, community groups we feel you may be interested in, updates and information on our and selected third parties' products and services we think you may be interested in.
We use this information in order to generate recommendations and tailor and improve the adverts that are presented on the Site.
<ul>
<li>Legitimate interests </li>
<li>Performance of our contract with you </li>
</ul>3 Where necessary, a copy of your identity or another document containing your name, surname, photography and number of the principal identity document of you or your representative.
We may take additional verification steps where we consider reasonable in order to verify your account.
We use this data in order to verify your account and prevent abuse and infringements of your or other persons' rights.
For example, we use this information to verify your identity if you lose your credentials and wish to access your account with us.
<ul>
<li>Legitimate Interests.
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<li>Performance of our contract with you </li>
</ul>4 Additional data you provide when you edit your page via http://vk.com/edit including your family status, native city, current city, family relations, home address, education and army details, career, etc.
Additional data you provide when you edit your settings.
We use this information in order to manage and administer the Site including providing our Site Services to you.
We also use this information in order to provide you with recommendations, community groups we feel you may be interested in, updates and information on our and selected third parties' products and services we think you may be interested in.
We use this information in order to tailor and improve the adverts that are presented on the Site and measure the effectiveness of these advertisements.
<ul>
<li>Legitimate interests.
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<li>Performance of our contract with you </li>
</ul>5 Additional data received when you access the Site, including information regarding technical devices, technical interaction with the Site (your host IP-address, your operating system, type of a browser, geographic position, your installed apps, the Internet provider, contacts from your phonebook, data obtained accessing the camera, microphone and similar devices) and your browsing behaviour and further actions on the Site.
We use your data for internal review in order to constantly improve the content of our web page, to understand any errors you may encounter when using the Site, to notify you of changes to the Site and to personalise the use of our Site.
Information containing the Site activity history is available in the "Settings / Security" section of your page.
We use this information in order to tailor and improve the adverts that are presented on the Site and measure the effectiveness of these advertisements.
<ul>
<li>Legitimate Interests </li>
</ul>6 Information that is automatically received at the time of access to the Site or the third parties’ websites with the use of cookies and such a technology as VK Ads Pixel and VK Widgets.
Please see our cookies policy which sets out the types of cookies we use and what we use these cookies for.
We use this information in order to tailor and improve the adverts that are presented on the Site and measure the effectiveness of these advertisements and to provide you with the possibility of use the part of Site’s functionality on the third parties’ websites.
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<li>Consent </li>
</ul>7 Information that is created by you on your page outside the page edit section http://vk.com/edit and the Site ((including statuses, entries, posted on the Site, including in the microblog (“Wall”), pictures, audio recordings, video recordings, comments, entries in the group discussions).
We use this information in order to manage and administer the Site including providing our services to you.
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<li>Legitimate interests, which inter alia, include the processing of manifestly made public by you data </li>
<li>Performance of our contract with you </li>
</ul>8 Information that is created by you while placing requests to our Services support.
We use this information in order to verify your identity and to fullfil your support request.
We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.
<ul>
<li>Legitimate Interests </li>
<li>Performance of our contract with you </li>
</ul>9 Information that is received as the result of your behavioral actions on the Site (in particular, joining / leaving a group, adding other users to the friends list, posting pictures, participation / refusal to participate in meetings, your call history, adding video recordings and liking posts).
Your information can be available to all of the your friends and other users in accordance with your settings.
We use this information in order to manage and administer the Site including providing our Site Services to you.
We use this information in order to tailor and improve the adverts that are presented on the Site and measure the effectiveness of these advertisements.
We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.
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<li>Legitimate Interests </li>
</ul>10 Information that is received about you as the result of other users’ actions on the Site (in particular, notes made on the video recordings and pictures by other users).
We use this information in order to manage and administer the Site including providing our Site Services to you.
We also may use this data in order to tailor your use of the Site and your interaction with our Site Services.
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<li>Legitimate Interests </li>
</ul>11 Information that is received as the result of your using payment functionality on the Site (e.g.
first and last four digits of your card number that are needed for the option of matching these details with user’s id number).
We use this information in order to manage and administer the Site including providing our Site Services to you.
We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.
<ul>
<li>Legitimate Interests </li>
<li>Performance of our contract with you </li>
</ul>12 Data collected via third parties including your friends' information from Facebook.
We import this information into your profile.
<ul>
<li>Legitimate Interests </li>
<li>Performance of our contract with you </li>
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<b>3.3</b> Our legitimate interests include (1) maintaining and administrating the Site.
(2) providing the Site Services to you.
(3) improving the content of the Site.
(4) processing of the data that was manifestly made public by you (5) ensuring your account is adequately protected.
and (6) compliance with any contractual, legal or regulatory obligations under any applicable law.
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<b>3.4</b> Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defence or exercise of legal claims.
We will not delete personal information if it is relevant to an investigation or a dispute.
It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.
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<b>3.5</b> You may withdraw your consent the collection of location data and your apps by amending your privacy settings on the Site or mobile app/the privacy settings of your mobile device.
You may withdraw your consent the processing of your phonebook by amending your phone settings.
An option to unsubscribe will also be included in every SMS or email (as direct marketing) sent to you by us or our selected third party partners if such direct marketing is realized in fact by us or our selected third party partners with our permission.
You can also choose to hide or receive fewer some advertisement from advertisers.
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<b>3.6</b> Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data on the Site.
Once you have provided this data it will be accessible by other site users and it becomes difficult for us to remove this data.
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<b>3.7</b> Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Site, you may not be able to access or register with the Site.
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<b>3.8</b> If we intend to further process your data for any other purpose to those set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.
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<b>4.
Data sharing</b>
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<b>4.1</b> Your information can be available to all of "your friends" or all users of the Site in accordance with your settings and clause 5.11 of the Terms http://vk.com/terms.
You can amend your settings via the Site and, subject to clause 4.7, you can also determine your own confidentiality mode and conditions of access to the information mentioned at purposes 2,3,4 and 7 in the table above.
We take technical and organizational measures to ensure that the appropriate Site tools are functional.
Please note that when you post your personal information this may become available to other Site users and internet users and be copied and/ or disseminated by such users.
Once this data is transferred by you to other users you will not be able to delete this data.
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<b>4.2</b> We may share your data with Mail.ru Group Limited, Mail.Ru LLC and other our affiliates.
Sometimes we may also need to share your data with a third party in order to provide our services to you or to administer the Site, for example if you choose to share your data across other social media platforms.
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<b>4.3</b> We may also share your data with our third party contractors and application developers provided these third parties assume confidentiality obligations regarding your personal data collected by the Site and your use of the applications they offer.
The developers use the information provided to them in order to provide you with additional services such as games.
Data will only be shared with these developers with your consent.
You can authorise developers to access your information via the Site.
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<b>4.4</b> Our ad management and recommendation system is designed so that your information will not be shared directly with our third party advertisers.
An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age, gender or location, or to target communities according to type, e.g.
cars or fashion.
If you fall within one of the target groups you will receive an advert or recommendation.
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<b>4.5</b> An advertiser or maker of recommendations may also choose to upload a list of emails, phone numbers and vk.com identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches.
They will see the number of matches but not the matches themselves.
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<b>4.6</b> My.com B.V.
and other companies in the Mail.ru Group, using their own ad services, can show advertisements to you.
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<b>4.7</b> As the Site is an all-in-one means of communication and the key function of the Site is to restore and maintain contacts with old and new acquaintances, the following information about you is always available to any internet user and registered Site user: <ul>
<li>(a) surname and name.
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<li>(b) date of birth (if it is not hidden), profile photograph, currently city.
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</ul>
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<b>4.8</b> The Site is a Service contained in the VK Ecosystem.
Registration and/or authorization on the Site using the VK Connect tool means acceptance of the VK Ecosystem Rules, which are publicly available at https://vk.com/vk_ecosystem_terms, as well as the VK Connect User Agreement, which is publicly available at https://connect.vk.com/terms, and the VK Connect User Information Protection Rules, which are publicly available at https://connect.vk.com/privacy.
In order to use the VK Connect tool and provide services and/or provide rights to use the Services contained in the VK Ecosystem, you hereby agree and instruct us to transfer and receive personal data and other information about you to/from the Services that contained in the VK Ecosystem, for the subsequent collection, storage, accumulation, systematization, extraction, comparison, use of such data, and filling with such data of the Services contained in the VK Ecosystem, in the scope indicated in your VK Connect personal account.
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<b>5.</b> Privacy Settings <ul>
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<b>5.1</b> You may, subject to the limitations under clause 4.7, set one of the following "confidentiality levels" for your personal data submitted to us under purposes 2, 4 and 7 in the table above: <ul>
<li>(a) information available to all of the Site Users.
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<li>(b) information available to all of the Site Users, except specific Users.
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<li>(c) information available to the persons having the status of the User’s friends on the Site as well as to the persons having the status of their friends.
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<li>(d) information available only to the persons having the status of the User’s friends on the Site.
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<li>(e) information available only to some persons having the status of the User’s friends on the Site.
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<li>(f) information available to some lists of friends (in case the User has created at least one list of friends using the Create List tool in the My Friends section).
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<li>(g) information available only to the User.
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</ul>
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<b>5.2</b> For the information on your page, including mentioned in clause 4.7, you may set one of the following confidentiality levels: <ul>
<li>(a) information available to all internet users and indexed by the search systems.
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<li>(b) information available only to the Site users.
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<li>(c) information available to all internet users but not indexed by the search systems.
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<b>5.3</b> Please note, once your personal data has been copied or shared by another site user, this information will remain available to all site users and internet users even if you delete this information from your page or delete your page in its entirety.
We accept no liability for the disclosure of your personal data by other Site users who have accessed such data in accordance with the confidentiality level selected by you.
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<b>5.4</b> To make sure that the selected confidentiality level is correct, you may, using the Site tools, watch your personal page being viewed by other users.
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<b>5.5</b> The Site contains links to sites operated by third parties.
We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.
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<b>5.6</b> We bear no liability for the actions of third parties which, as the result of your use of the internet or the Site Services, obtain access to your information in accordance with the confidentiality level selected by you.
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<b>5.7</b> We bear no liability for the consequences of use of the information which, due to the Site nature, is available to any internet user.
We ask you to take a responsible approach to the scope of their information posted on the Site.
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<b>6.</b> International Transfers <ul>
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<b>6.1</b> We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in Russia.
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<b>6.2</b> The countries to which we transfer your data may not have the same data protection laws as your jurisdiction.
We take reasonable cyber security measures and/or put in place the Standartd Contractual Clauses (e.g.
Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.
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<b>7.</b> Retention Periods <ul>
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<b>7.1</b> We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.
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<b>7.2</b> You may delete your personal data by removing the data from your personal page.
alternatively, you can remove your page using the Remove My Page functionality available in the My Settings section.
You have the right to restore your personal page within 210 days after the personal page is removed.
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<b>7.3</b> We may remove your page, or the information you post if there are grounds provided for by applicable law or as provided by the Terms (e.g., sub-clauses 7.2.2 and 8.6).
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<b>8.</b> Your Rights <ul>
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<b>8.1</b> You have the following rights, in certain circumstances, in relation to your personal information: <ul>
<li>(a) Right to access your personal information.
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<li>(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing.
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<li>(c) Right to restrict the use of your personal information.
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<li>(d) Right to request that your personal information is erased.
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<li>(e) Right to object to processing of your personal information.
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<li>(f) Right to data portability (in certain specific circumstances).
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<li>(g) Right not to be subject to an automated decision.
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<li>(h) Right to lodge a complaint with a relevant supervisory authority.
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<b>8.2</b> You also have a right to independently remove your page, information on your page and make changes and corrections to your personal page on the Site, provided that such changes and corrections contain up-to-date and true information.
You can also view an overview of the information we hold about you via the Site.
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<b>8.3</b> If you would like to exercise these rights, please send your request to us in our Support Service http://vk.com/support, or in writing to: prem.
1-N, bld.
12-14, Lit.
A, Khersonskaya st., St.
Petersburg, Russia, 191024 We will aim to respond to you within 30 days from receipt of request.
We will need to verify your identity before we are able to disclose any personal data to you.
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<b>9.</b> Security Measures <ul>
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<b>9.1</b> We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.
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<b>9.2</b> Access to the Site is authorized using your login (e-mail address or mobile phone number) and password.
You are responsible for keeping this information confidential.
You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.
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<b>9.3</b> If you forget your login details, and we hold your mobile phone number, you can ask us to send you an SMS which will contain a restoration code using special tool available here http://vk.com/restore.
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<b>9.4</b> To reduce the probability of third parties gaining unauthorized access, if you login to your account from an unusual server (in particular, from a server located in a foreign country), we will block entry to your personal page.
You will then receive a message asking you to provide certain digits indicated in SMS sent to your mobile phone number.
After three unsuccessful attempts to enter these digits, we will block access from that server for 4 hours.
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<b>9.5</b> You can access information concerning the time and device from which your account was accessed using the Show activity history link in the My Settings / Security.
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<b>10.</b> Changes to this Policy <ul>
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<b>10.1</b> From time to time, we may change and/or update this Privacy Policy.
If this Privacy Policy changes in any way, we will post an updated version on this page.
We will store the previous versions of this Privacy Policy in our documentation achieve.
We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.
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<b>11.</b> Contact Us <ul>
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<b>11.1</b> If you have any questions, please send your inquiries to us, in writing to: prem.
1-N, bld.
12-14, Lit.
A, Khersonskaya st., St.
Petersburg, Russia, 191024, or to http://vk.com/support.
So we can deal with your enquiry effectively, please quote this Privacy Policy.
We will aim to respond to you within 30 days from receipt of request.
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<b>11.2</b> All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent.
The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.
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<b>11.3</b> The e-mail address of our DPO is dpo@corp.my.com.
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<li>Date of Last Revision: May 21, 2018 </li>
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