Privacy Policy for FlyPenny Services

Effective Date: January 1, 2017

1. Your Privacy Rights

This Privacy Policy describes your privacy rights regarding our collection, use, storage, sharing and protection of your personal information. It applies to the FlyPenny website and all related sites, applications, services and tools regardless of how you access or use them.

2. Scope and Consent

You accept this Privacy Policy when you sign up, access, or use our products, services, content, features, technologies or functions offered on our website and all related sites, applications, and services (hereafter ‘FlyPenny Services’). This Privacy Policy is intended to govern the use of FlyPenny Services by our users (including without limitation those using FlyPenny Services in the course of charity activity), unless otherwise agreed through contract. We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective as of the published date. In addition, if the revised version includes a substantial change, we will provide you with 30-days prior notice by posting notice of the change on the ‘Policy Updates’ page of our website. After this 30-day notice period, you will be considered as having expressly consented to all amendments to this Privacy Policy.

3. Collection of Personal Information

We collect the following types of personal information in order to provide you with the FlyPenny Services, as well as to personalize and improve your experience better.

The information is collected automatically. When you use FlyPenny Services, we collect information sent to us by your computer, mobile phone or any other access device. The information sent to us includes, but is not limited to, the following: data on the pages you visit, computer IP address, device ID or its unique identifier, device type, geo-location information, computer and connection data, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad data, standard web log data, and other information. We also collect anonymous information through our use of cookies and web beacons.

3.1. Information you provide to us:
we may collect and store any information you provide when you use FlyPenny Services, including when you add information on a web form, add or update your account information, participate in community discussions, chats, dispute resolutions, or when you otherwise correspond with us regarding FlyPenny Services.

When you use FlyPenny Services, we also collect information about your transactions and activities. In addition, when you open a FlyPenny account or use FlyPenny Services, we may collect the following types of information:

We may also collect information directly from you, as well as from other sources, e.g. through your contacting us, including our Customer Support team; the survey results; through interactions with members of the FlyPenny corporate family or other companies (in respect to their privacy policies and the applicable law), and from other accounts we have reason to believe you control (both partly and totally). Additionally, for quality control and training purposes, or for the FlyPenny service protection, we have the right to monitor or record our telephone conversations with you or anyone acting on your behalf. Communicating FlyPenny, you have to be aware that such communication might be overheard, monitored, or recorded without further notice or warning.

3.2. Information from other sources:
we may also obtain information about you from third parties such as credit bureaus and identity verification services. You may choose to provide us with access to certain personal information stored by third parties such as social media sites (e.g., Facebook and Twitter). The information we may receive varies by site and is controlled by that site. By associating an account managed by a third party with your FlyPenny account and authorizing FlyPenny to have access to this information, you agree that FlyPenny may collect, store and use such information under this Privacy Policy regulations.

3.3. Authentication and Fraud Detection:
in order to help protect you from fraud and misuse of your personal information, we may collect information about you and your interactions with FlyPenny Services. We may also evaluate your computer, mobile phone or other access device to identify any malicious software or activity.

3.4. Using Your Mobile Device:
we can offer you the access to FlyPenny Services via a mobile application or a mobile optimized website. The provisions of this Privacy Policy apply to all technologies, including the mobile access and use of mobile devices.

When you download or use our mobile applications, or access one of our mobile optimized sites, we can receive information on your location and your mobile device, including the unique identifier of your device. We may use this information to provide you with location-based services, such as advertising, search results, and other personalized content. Most mobile devices allow you to control or disable location services in the device's setting menu. If you have questions about how to disable your device's location services we recommend you to contact your mobile service carrier or the manufacture of your device.

You hereby grant to ‘Double B’ Public Joint Stock Company, registered under the legislation of the Russian Federation, at the address of Russian Federation, Moscow, 121609, Krylatsky Kholmy street 7, bl. 2, office # VII, as well as its affiliates and the third parties performing identification, simplified identification or personal data verification procedures and services verification, your consent to processing (collection, recording, systematization, accumulation, storage, verification (updating and modification), extraction, use, transfer (including spread, disclosure, provision, and access), depersonalization, block of access, removal or delete) of your personal data collected by us, our affiliates or the third parties performing identification, simplified identification or personal data verification procedures and services, under this Privacy Policy. You hereby confirm that you were informed and give your direct and unconditional consent to the transfer of your personal data to foreign states territory and to the third parties, as provided under this Privacy Policy.

4. Using of the Collected Personal Data

The main purpose of the personal data collecting is to provide you with a secure, smooth, efficient, and customized service. Your personal data might be used as follows:

We may contact you by electronic communication or by mail to notify you of your account, to troubleshoot problems with your account, to resolve disputes, to collect fees, to poll your opinions through surveys or questionnaires, or in other ways in order to serve your account. Additionally, we may contact you to offer coupons, discounts and promotions, and inform you about FlyPenny Services. At least, we may contact you as due necessity to enforce our policy, applicable law, or any agreement we might sign with you. When contacting you by phone, to improve service quality, we can use autodialed or prerecorded calls and text messages, and you give your consent to receive them. You can decline to receive certain communication modes, where it’s applicable and permitted by the law.

5. Marketing

We do not sell nor disclose your personal data to the third parties for marketing purposes without your explicit consent. In order to optimize and personalize FlyPenny Services, the content and advertising, we may combine your data with the information collected from other companies. In case you do not wish to receive promotional messages from us and to join the customized promotion programs, indicate your preferences in the ‘Notifications’ section by editing your settings, or follow the instructions in the message or advertisement.

We respect your communication preferences. If you do not wish to receive notifications via our application, you can edit your preferences on the settings page of the application.

6. How We Use Cookies and Similar Technologies

When you access our website or use FlyPenny Services, we (including companies we cooperate with) may place small data files on your computer or other device. These data files may be cookies, pixel tags, e-tags, flash cookies, or other storage supported by your browser or associated applications (hereafter named ‘cookies’). We use these technologies to recognize you as a customer; to customize FlyPenny Services, content, and advertising; to measure promotional effectiveness; to provide security for your account; to mitigate risks and prevent fraud; to promote trust and safety for our websites and FlyPenny Services.

You have the right to decline our cookies if your browser or browser add-on permits, unless our cookies are required to prevent fraud or ensure the security of websites we control. However, declining our cookies may interfere with your use of our websites and FlyPenny Services.

7. Protection and Storage of Personal Data

In this Privacy Policy regulations, the term ‘personal data’ is used to describe information associated with a specific person and allows to identify such person. We do not consider personal data information received anonymously since it does not allow identifying a specific user.

Your personal data is being stored and processed in our computers in North America, Asia, Europe and elsewhere in the world where our storage and processing facilities are located. We protect your information using physical, technical, and administrative security means to reduce the risks of loss, misuse, unauthorized access, disclosure and personal data alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centers, and information access authorization control.

8. Share of Personal Information with Other FlyPenny Users

When transacting with others, we may provide those parties with information necessary to complete the transaction, such as your first name, family name, account ID, contact details, shipping and billing addresses, or other information needed to promote the reliability and security of the transaction. If a transaction is blocked, fails, or is later invalidated, we may also provide details of the unsuccessful transaction. Communication with users for providing them with unwanted or threatening messages is against our policy and constitutes a violation of our User Agreement.

When you send Thanks to the mobile phone number or email address of the recipient we provide them with your first and family names registered in your account, so that the recipient can verify the person sending them Thanks.

When Thanks are received from your mobile phone number or email address we provide the other party with your first and family names registered in the account, so that the sender can verify that Thanks were sent properly.

We shall not provide your bank card number or bank account to the other party in the FlyPenny system or to any third party offering or using FlyPenny Services, unless you explicitly agree to it, or when we are forced to do so in order to follow the bank cards using regulations, in case of a judicial inquiry, or other events within legal proceedings.

9. Sharing Personal Data with Someone Else

We may share your personal data with the following parties:

Please note that these third parties may be located in other countries where the laws on processing personal data may be less stringent than in your country.

When you open a FlyPenny account on a different website or via a different application, any information that you enter on that website or application (and not directly on the FlyPenny website) will be given to the owner of such website or application. These sites are governed by their own privacy policies that you are encouraged to review before providing them you’re your personal information. FlyPenny is not responsible for the content published by the third parties or data using principles they practice.

10. Cross-border Transfer of Personal Data

The Company is committed to the protection of your personal data, regardless of where they are located, as well as to ensure an adequate protection of your personal data when transferring abroad, including outside the European Economic Area.

11. Access to Your Personal Data or Change

You can review and edit your personal data at any time by logging in to your account and reviewing your account settings and profile. You can also close your account at the FlyPenny website. If you close your FlyPenny account we will mark your account in our database as ‘closed’, though reserve the right to store personal data from your account for a certain period of time to resolve disputes, troubleshoot problems, assist any kind of investigation to prevent fraud, ensure compliance with the User Agreement, as well as to perform other activities, provided or permitted under the present legislation.

12. Requirements Concerning Privacy of Personal Data

If you have questions regarding this Privacy Policy contact us by e-mail: