Privacy Policy
updated: 20 October 2021
This Privacy Policy (hereinafter, the Policy) governs the collection, use, disclosure, transfer and storage of personal data of users of the instant messaging platform "Frisbee" (hereinafter, the Services).
Take a moment to find out more about our Privacy Policy and contact us if you have any questions.
1. Terms and Definitions
1.1. For the purposes hereof, the following terms and definitions are used:
You (User) — any individual that is using functional features of the Services and has reached the age of legal capacity to enter agreements in the form of our Terms of Service in accordance with the legislation of the country of their citizenship.
Messenger — instant messaging platform "Frisbee" and its web-version.
We (KLAUD ATLAS) — Klaud Atlas Limited Liability Company.
Services — website with a domain name "web.frisbee.live" and instant messaging platform "Frisbee" (including its web-version).
Chatbot — specialized program designed to automate actions and processes via the Messenger user interface.
2. Scope
2.1. This Policy shall govern any interaction between Klaud Atlas and users related to personal data when using the Services.
2.2. This Policy neither governs nor determines the rights and obligations of third parties. It also does not apply to third-party applications or software available to users for integration with the Services.
2.3. Please do not use the Services if you do not agree with the provisions and scope hereof.
3. Who determines the purposes and means of personal data collection
3.1. The purposes and means of how your personal data is collected in these Services are determined by the following legal entity:
Klaud Atlas, Limited Liability Company
8 Naberezhnaya Presnenskaya str
bldg 1, apt 8/484S/5/59A
Moscow, 123112
email (general questions): support@frisbee.live
email (personal data questions): dpo@frisbee.live
4. Personal Data We Collect
4.1. Personal data is any information that could enable direct or indirect identification of a person (e.g., their full name, cellphone number, e-mail, online identifier, etc.).
4.2. In accordance here with, personal data may be collected both directly and indirectly.
Personal data is collected directly when you provide them voluntarily (e.g. when registering in Messenger).
Indirect collection of personal data may occur automatically when accessing the Services, including the collection by third parties (for example, Branch IO SDK, which we use to configure universal hyperlinks, Crashlytics, Firebase, which we use for logging errors).
4.3. We collect the required minimum of your personal data for the purposes hereof:
1) accounting data. We collect your first and last name, email, telephone number when you are registering. You also have the opportunity to provide your photo and specify the nickname in order to improve the efficiency of using some of the functionality of the Messenger (for example, specified links to the User).
2) actions. We collect (and other users see) the information about your network status (status "online", "offline", etc.), as well as some data about incoming and outgoing messages (message sending time, chat participants), when you are using Messenger.
3) User data. All your text messages, audio and video materials will be collected and stored on our server, when you are using Messenger. Accordingly, you or your interlocutor can at any time find it available if necessary. If this information is deleted from chats and channels, it will also be deleted from our server.
4) additional info. We and our contractors may collect additional information about the IP address, the device model with which the Services are used, the device's operating system through which the Services are used, your browser, the browser language and / or the operating system. We may also collect information about your location. You can limit the collection of information about your location by changing the appropriate settings of your device through which the use of the Services is carried out.
5. Data Processing, Storage and Protection
5.1. "Processing" is understood as at least one of the following: storage, modification, retrieval, disclosure, structuring, use, destruction as well as any other action with respect to your personal data.
5.2. We process your personal data for the following purposes only:
1) ensuring the availability of the Messenger. We collect and process accounting data, as well as actions of the User and additional info in order to provide users with the possibility of proper and uninterrupted use of the functionality of the Messenger. After collecting these data, we register your account, make it visible to other users and give you the opportunity to use the functionality of the Messenger in accordance with the Terms of Service (communicate with other users, import audio and video materials, etc.).
2) feedback. We collect and process contact information that you provide when contacting technical support to provide feedback. You can make inquiries to our technical support to clarify questions regarding the technical features of the use of the Messenger, as well as the conditions of the usage of the functionality of the Messenger.
3) offense prevention. We may process your personal data in order to counter crimes, administrative offenses, violations of our Terms of Service, of the rights and legitimate interests of Klaud Atlas and/or third parties, as well as to ensure compliance with applicable law and its binding norms.
5.3. Subject to data anonymisation, your personal data may be used by Klaud Atlas for any other purposes.
5.4. Your personal data will be stored on the servers of our counterparties. We undertake that all our contractors comply with our security requirements for personal data protection and they shall not use your personal data for any purpose other than as indicated in this Policy. Employees of Klaud Atlas shall also take all necessary organisational, legal and technical measures available to us for protection of your personal data. Users of the Messenger shall also be responsible to the maximum possible extent for the provision of accurate account details, keeping passwords and any other information required for authorisation confidential and its protection from unauthorised access by third parties.
5.5. The personal data we collect will be stored for as long as it is necessary to ensure your ability to use the Services and later for as long as it is necessary for maintaining information records and ensuring information security. Thereafter, we will store your personal data to ensure compliance with our legal obligations and agreements as well as for dispute resolution.
5.6. Any personal data collected and processed hereunder shall be properly protected unless:
1) you consent to their disclosure;
2) such personal data are anonymised;
3) such personal data are subject to disclosure under the applicable law.
5.7. We also guarantee that your personal data shall be used only for the purposes and time set hereunder and our employees and counterparties are aware of the security and privacy recommendations and shall comply with them.
5.8. We will do our best to keep your personal data protected by limiting the number of people who have access to your personal data, running regular scans to identify threats and using anti-virus software and traffic filtering for our servers that store personal data. However, despite any possible measures taken on our part, we cannot guarantee full protection of the Services against information security risks.
6. Transfer and Disclosure
6.1. Users can independently transfer their personal data to other users when using the functionality of the Services (when chatting, when importing audio and video materials, etc.). We urge you to be cautious when transferring your personal data in this way.
6.2. Additionally, your personal data may be provided to our contractors and suppliers. We guarantee that all our contractors and suppliers meet our requirements for personal data protection and that they shall not use your personal data in any way beyond the purposes stated herein.
6.3. To ensure the provision of our services, your personal data may also be transferred to a legal entity created after reorganisation of Klaud Atlas should it be necessary.
6.4. Please note that disclosure of your personal data may be required in accordance with the law and judicial procedures or at the request of public bodies of the country of your stay or other countries. Your personal data will be disclosed if it is necessary for the purposes of national security, law enforcement, protection of the rights and legitimate interests of Klaud Atlas and third parties or for other substantial public interest purposes.
7. Children's Personal Data
7.1. To the extent to which it is not prohibited by the applicable law, we do not authorise the use of our Services by individuals who have not reached the age of legal capacity to enter agreements such as our Terms of Service in accordance with the legislation of the country of their citizenship. We do not collect and process (at least knowingly) their personal data without the consent of their legal representatives.
8. Chatbots
8.1. Within our Messenger, chatbots technology is implemented, through which users can receive necessary and personalized information. Chatbots may also collect some of your personal data. Such personal data collection occurs in the following situations:
1) when you are messaging with a chatbot, download audio and video materials in a dialogue with a chatbot;
2) when you are a member of a channel where a chatbot is used;
3) when you follow the links indicated by a chatbot.
8.2. Despite the technical nature, chatbots can be considered as participants in the process of communication of Messenger users. Therefore, chatbots can collect and process almost the same amount of your personal data as regular Messenger users.
8.3. Chatbots can collect and process accounting data, actions, user information, if users themselves input such data in a dialogue or a channel with a chatbot.
8.4. Chatbots can collect and process your IP address if you follow the links indicated by chatbots.
9. Final Provisions
9.1. This Policy may be amended and (or) modified at any time of the Services operation. In this case, a notice with information about the changes accompanied by the new version of the Policy and date of its adoption will be published in the Services. The User of the Services must read and acknowledge the new version hereof.
9.2. The Policy is an agreement between us and the User about the use of the Services. Any other pre-existing written or oral agreements or arrangements with respect to such use are hereby cancelled.
9.3. If any provision hereof is invalid or unenforceable, other provisions shall remain valid and enforceable to the fullest extent permitted by applicable law.
9.4. Failure to enforce your strict compliance herewith cannot be construed as our waiver of any provision hereof or any right hereunder.
9.5. The applicable law is the law of the Republic of Belarus. The competent court at the location of Klaud Atlas has the exclusive jurisdiction over all disagreements and disputes arising out of or in connection with the Policy. The Policy is drawn up in English and in Russian. In case of any discrepancies, the Russian version of the document shall prevail.
Take a moment to find out more about our Privacy Policy and contact us if you have any questions.
1. Terms and Definitions
1.1. For the purposes hereof, the following terms and definitions are used:
You (User) — any individual that is using functional features of the Services and has reached the age of legal capacity to enter agreements in the form of our Terms of Service in accordance with the legislation of the country of their citizenship.
Messenger — instant messaging platform "Frisbee" and its web-version.
We (KLAUD ATLAS) — Klaud Atlas Limited Liability Company.
Services — website with a domain name "web.frisbee.live" and instant messaging platform "Frisbee" (including its web-version).
Chatbot — specialized program designed to automate actions and processes via the Messenger user interface.
2. Scope
2.1. This Policy shall govern any interaction between Klaud Atlas and users related to personal data when using the Services.
2.2. This Policy neither governs nor determines the rights and obligations of third parties. It also does not apply to third-party applications or software available to users for integration with the Services.
2.3. Please do not use the Services if you do not agree with the provisions and scope hereof.
3. Who determines the purposes and means of personal data collection
3.1. The purposes and means of how your personal data is collected in these Services are determined by the following legal entity:
Klaud Atlas, Limited Liability Company
8 Naberezhnaya Presnenskaya str
bldg 1, apt 8/484S/5/59A
Moscow, 123112
email (general questions): support@frisbee.live
email (personal data questions): dpo@frisbee.live
4. Personal Data We Collect
4.1. Personal data is any information that could enable direct or indirect identification of a person (e.g., their full name, cellphone number, e-mail, online identifier, etc.).
4.2. In accordance here with, personal data may be collected both directly and indirectly.
Personal data is collected directly when you provide them voluntarily (e.g. when registering in Messenger).
Indirect collection of personal data may occur automatically when accessing the Services, including the collection by third parties (for example, Branch IO SDK, which we use to configure universal hyperlinks, Crashlytics, Firebase, which we use for logging errors).
4.3. We collect the required minimum of your personal data for the purposes hereof:
1) accounting data. We collect your first and last name, email, telephone number when you are registering. You also have the opportunity to provide your photo and specify the nickname in order to improve the efficiency of using some of the functionality of the Messenger (for example, specified links to the User).
2) actions. We collect (and other users see) the information about your network status (status "online", "offline", etc.), as well as some data about incoming and outgoing messages (message sending time, chat participants), when you are using Messenger.
3) User data. All your text messages, audio and video materials will be collected and stored on our server, when you are using Messenger. Accordingly, you or your interlocutor can at any time find it available if necessary. If this information is deleted from chats and channels, it will also be deleted from our server.
4) additional info. We and our contractors may collect additional information about the IP address, the device model with which the Services are used, the device's operating system through which the Services are used, your browser, the browser language and / or the operating system. We may also collect information about your location. You can limit the collection of information about your location by changing the appropriate settings of your device through which the use of the Services is carried out.
5. Data Processing, Storage and Protection
5.1. "Processing" is understood as at least one of the following: storage, modification, retrieval, disclosure, structuring, use, destruction as well as any other action with respect to your personal data.
5.2. We process your personal data for the following purposes only:
1) ensuring the availability of the Messenger. We collect and process accounting data, as well as actions of the User and additional info in order to provide users with the possibility of proper and uninterrupted use of the functionality of the Messenger. After collecting these data, we register your account, make it visible to other users and give you the opportunity to use the functionality of the Messenger in accordance with the Terms of Service (communicate with other users, import audio and video materials, etc.).
2) feedback. We collect and process contact information that you provide when contacting technical support to provide feedback. You can make inquiries to our technical support to clarify questions regarding the technical features of the use of the Messenger, as well as the conditions of the usage of the functionality of the Messenger.
3) offense prevention. We may process your personal data in order to counter crimes, administrative offenses, violations of our Terms of Service, of the rights and legitimate interests of Klaud Atlas and/or third parties, as well as to ensure compliance with applicable law and its binding norms.
5.3. Subject to data anonymisation, your personal data may be used by Klaud Atlas for any other purposes.
5.4. Your personal data will be stored on the servers of our counterparties. We undertake that all our contractors comply with our security requirements for personal data protection and they shall not use your personal data for any purpose other than as indicated in this Policy. Employees of Klaud Atlas shall also take all necessary organisational, legal and technical measures available to us for protection of your personal data. Users of the Messenger shall also be responsible to the maximum possible extent for the provision of accurate account details, keeping passwords and any other information required for authorisation confidential and its protection from unauthorised access by third parties.
5.5. The personal data we collect will be stored for as long as it is necessary to ensure your ability to use the Services and later for as long as it is necessary for maintaining information records and ensuring information security. Thereafter, we will store your personal data to ensure compliance with our legal obligations and agreements as well as for dispute resolution.
5.6. Any personal data collected and processed hereunder shall be properly protected unless:
1) you consent to their disclosure;
2) such personal data are anonymised;
3) such personal data are subject to disclosure under the applicable law.
5.7. We also guarantee that your personal data shall be used only for the purposes and time set hereunder and our employees and counterparties are aware of the security and privacy recommendations and shall comply with them.
5.8. We will do our best to keep your personal data protected by limiting the number of people who have access to your personal data, running regular scans to identify threats and using anti-virus software and traffic filtering for our servers that store personal data. However, despite any possible measures taken on our part, we cannot guarantee full protection of the Services against information security risks.
6. Transfer and Disclosure
6.1. Users can independently transfer their personal data to other users when using the functionality of the Services (when chatting, when importing audio and video materials, etc.). We urge you to be cautious when transferring your personal data in this way.
6.2. Additionally, your personal data may be provided to our contractors and suppliers. We guarantee that all our contractors and suppliers meet our requirements for personal data protection and that they shall not use your personal data in any way beyond the purposes stated herein.
6.3. To ensure the provision of our services, your personal data may also be transferred to a legal entity created after reorganisation of Klaud Atlas should it be necessary.
6.4. Please note that disclosure of your personal data may be required in accordance with the law and judicial procedures or at the request of public bodies of the country of your stay or other countries. Your personal data will be disclosed if it is necessary for the purposes of national security, law enforcement, protection of the rights and legitimate interests of Klaud Atlas and third parties or for other substantial public interest purposes.
7. Children's Personal Data
7.1. To the extent to which it is not prohibited by the applicable law, we do not authorise the use of our Services by individuals who have not reached the age of legal capacity to enter agreements such as our Terms of Service in accordance with the legislation of the country of their citizenship. We do not collect and process (at least knowingly) their personal data without the consent of their legal representatives.
8. Chatbots
8.1. Within our Messenger, chatbots technology is implemented, through which users can receive necessary and personalized information. Chatbots may also collect some of your personal data. Such personal data collection occurs in the following situations:
1) when you are messaging with a chatbot, download audio and video materials in a dialogue with a chatbot;
2) when you are a member of a channel where a chatbot is used;
3) when you follow the links indicated by a chatbot.
8.2. Despite the technical nature, chatbots can be considered as participants in the process of communication of Messenger users. Therefore, chatbots can collect and process almost the same amount of your personal data as regular Messenger users.
8.3. Chatbots can collect and process accounting data, actions, user information, if users themselves input such data in a dialogue or a channel with a chatbot.
8.4. Chatbots can collect and process your IP address if you follow the links indicated by chatbots.
9. Final Provisions
9.1. This Policy may be amended and (or) modified at any time of the Services operation. In this case, a notice with information about the changes accompanied by the new version of the Policy and date of its adoption will be published in the Services. The User of the Services must read and acknowledge the new version hereof.
9.2. The Policy is an agreement between us and the User about the use of the Services. Any other pre-existing written or oral agreements or arrangements with respect to such use are hereby cancelled.
9.3. If any provision hereof is invalid or unenforceable, other provisions shall remain valid and enforceable to the fullest extent permitted by applicable law.
9.4. Failure to enforce your strict compliance herewith cannot be construed as our waiver of any provision hereof or any right hereunder.
9.5. The applicable law is the law of the Republic of Belarus. The competent court at the location of Klaud Atlas has the exclusive jurisdiction over all disagreements and disputes arising out of or in connection with the Policy. The Policy is drawn up in English and in Russian. In case of any discrepancies, the Russian version of the document shall prevail.
