This Policy describes how personal data of users of the Merilo mobile application (the “App”) is processed.
The terms used in this Policy have the meanings ascribed to them in Federal Law No. 152-FZ of July 27, 2006, “On Personal Data.”
1. Data Controller
The data controller is Limited Liability Company “VIGO” (LLC “VIGO”), address: 125438, Moscow, vn.ter.g. Municipal district Koptevo, st. Mikhailovskaya, 63B, building 2, premises. 21/4 (the “Operator”).
Contact email: info@vigo.tech.
2. General Provisions
2.1. The Operator processes personal data to provide the App’s features, ensure its operation, store and synchronize measurement results, and for other purposes specified in this Policy.
2.2. The Operator does not use users’ original email addresses for advertising or informational email campaigns.
2.3. During authentication, the original email address is used to calculate a hash value required to identify the user account. The Operator does not store the original email address in the primary Merilo database.
3. Volume of personal data being processed
Depending on the features used, the App may process the following data.
3.1. Account and Measurement Data
- A hash value derived from the email address and used to identify the user account;
- An internal account identifier and information about the account status;
- results of internet connection quality measurements associated with the User’s account;
- Information about measurement timestamps and technical events necessary for the App to function;
- Network type (Wi-Fi or mobile network);
- Network identifiers, such as SSID, BSSID, and cell tower identifiers;
- Connection parameters, including data transfer speed, latency, and connection stability.
- Device model;
- Operating system version.
The actual categories of data processed depend on the features used in the App and its data collection settings.
3.2. Location Data
The App may request permission to access the device’s location data (precise or approximate) for the following purposes:
- Identifying the location where measurements are performed;
- Analyzing connection quality and data transfer speeds across different geographical areas;
- Improving the accuracy of measurement results.
Access to location data depends on the permissions granted by the User and the device settings. The User may change these permissions in the device settings.
4. Purposes of Processing
Data is processed for the following purposes:
- Creating and identifying user accounts;
- Authenticating Users and providing access to the App’s features;
- Storing and synchronizing measurement results;
- Displaying measurement history and providing analytical features;
- Conducting research and statistical analysis of communication network quality;
- Generating aggregated statistics;
- Ensuring the operation and security of the App and identifying technical errors;
- Responding to user inquiries and providing technical support.
5. Legal Grounds for Processing
5.1. The Operator processes personal data on the legal grounds provided for by the laws of the Russian Federation.
5.2. In cases where processing is based on the User’s consent, such consent is requested separately and may be provided in electronic form, including through the User’s performance of conclusive actions.
5.3. The User may withdraw consent to personal data processing by contacting info@vigo.tech. Withdrawal of consent does not preclude further processing where other legal grounds provided for by the laws of the Russian Federation apply.
6. Hashing and Storage
6.1. During authentication, the App receives the email address from the selected authentication provider, if the provider makes the address available. The address is used to calculate a hash value required to identify the user account.
6.2. The Operator does not store the original email address in the primary Merilo database and does not use it to send emails to the User.
6.3. The hash value, account identifier, and associated data are stored for as long as necessary to achieve the purposes of processing, unless a different retention period is required by the laws of the Russian Federation.
7. Authentication Providers and Third Parties
7.1. In the Russian Federation, the application uses Yandex-based authorization. The availability of authorization methods may vary depending on the region and technical conditions.
7.2. When using the relevant authentication method, the User interacts with the selected provider in accordance with its terms of service and privacy policy. The provider may independently process the User’s data to provide its services.
7.3. The Operator does not store the original email address in the primary Merilo database and does not transfer it to email service providers for mailing campaigns.
7.4. To operate the App, the Operator may use technical services and contractors involved in hosting and maintaining its infrastructure.
7.5. Data may be disclosed to government authorities in cases provided for by the laws of the Russian Federation.
8. Data Storage
8.1. The Merilo database is located in the Russian Federation.
9. Data Retention and Account Deletion
9.1. Data is retained for as long as necessary to achieve the purposes of processing, unless a different period is required by the laws of the Russian Federation.
9.2. The User may delete their account and associated data using the account deletion feature in the App.
9.3. Deleting an account may result in the loss of access to saved measurement history and synchronization features.
9.4. The processing of personal data may be terminated upon the achievement of the purposes for which the data is processed, the expiration of the consent, the withdrawal of consent by the data subject, or the discovery of unlawful personal data processing.
9.5. In the event that the inaccuracy of personal data or the unlawfulness of its processing is confirmed, the personal data must be updated by the data controller, and the processing must be discontinued, as the case may be.
10. Rights and obligations
10.1. The User may contact the Operator regarding personal data processing, request information about such processing, request the correction, blocking, or deletion of data where provided for by law, and withdraw consent where processing is based on consent.
Requests should be sent to info@vigo.tech.
10.2. The User may manage the permissions granted to the App in the device settings, including refusing to grant access to location data.
Refusing certain permissions may limit the functionality of the corresponding App features.
10.3. The Operator has the right to collect, record, systematize, accumulate, store, clarify (update, change), extract, use, transfer in cases provided for by law and necessary for the operation of the Application, depersonalize, block, delete and destroy personal data, with or without the use of automation tools.
10.4. The operator is obligated to process personal data solely on lawful grounds; to refrain from disclosing personal data to third parties without a legal basis; to rectify any identified violations that occurred during the processing of personal data; to provide the User with information as required by law; and to implement necessary and sufficient measures to protect personal data.
10.5. The Operator shall respond to requests or inquiries from personal data subjects (or their representatives) and authorized bodies concerning the inaccuracy of personal data, the unlawfulness of its processing, the withdrawal of consent, or a data subject’s access to their own personal data in accordance with the procedures and timeframes stipulated by the legislation of the Russian Federation.
11. Children
The App is not specifically intended for children. Any age restrictions applicable to the use of the App are determined by the relevant terms of use and applicable law.
12. Security
12.1. The operator and other persons who have gained access to personal data are required not to disclose such personal data to third parties or disseminate it without the consent of the data subject, unless otherwise provided for by federal law.
12.2. The operator shall take or ensure the implementation of the legal, organizational, and technical measures required by the legislation of the Russian Federation to protect personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, disclosure, or dissemination, as well as against any other unlawful actions involving personal data.
13. Changes to This Policy
The Operator may update this Policy. The current version is available at: https://www.merilo.one/en/privacy.
14. Contact Information
Vigo LLC (OOO “VIGO”)
Email: info@vigo.tech Website: https://vigo.tech/