Last Revised: October 21, 2022

Who we are / What we do
The site “kevafeliro” (www.kevafeliro.com) has been developed by Marianna Markelova, who will henceforth be called «We», and in the case of belonging – «us», «our».
Marianna Markelova is the right-holder of all intellectual property of our Products. The Product provides a set intellectual property contained in the information system (including a computer program, database, graphic design of the interface, etc.) access that is provided from various user devices using special software - the site “kevafeliro” (www.kevafeliro.com).

This Privacy Policy applies when you use our Products. By this Privacy policy we care about your PII so give you the opportunity to know what Data we collect and how we process it.

Glossary

The text of our Privacy Policy uses terms and concepts in the following meaning:
Personally Identifiable Information (referred to in this document as «PII») is that alone or in combination with other information or in certain contexts can be used to identify, distinguish or trace you and your Device(s).
Data is all information that we or Third parties have got from you, including technical information about your Device(s) or accounts and non-personal identification information.
Product is all websites, apps, and other services that are associated with “kevafeliro” (www.kevafeliro.com) and published or made available by Marianna Markelova.
Third party (or Third Party Providers) is the third party with whom we entered into an agreement placing an advertisement in the Product and / or collecting, processing and storing your technical, and another data.
Device is a hardware operated by a person and may refer to a smartphone, tablet, PC.
Content is any information that you may get in our Product from us or from Third parties.
Profile and / or Account means the section of the Product that contain details, data, PII and (or) other information about a User. By using an Account, you may access to using the Product.
User is you as the person who had created an Account and use the Product.
Cookie is a small piece of data stored on your Device.
All the above terms can be indicated in the plural. When using the term, it is necessary to start from the context of the text of using the term. All capitalized terms used in this Privacy Policy that are not otherwise defined have the meanings set forth in the Glossary.

1. Introduction

This Privacy Policy governs all websites, apps, and other services that link to, or contain references to, this document and are published or made available by Marianna Markelova, its parent, subsidiaries and affiliates. Please read this Privacy Policy carefully. It summarizes the various ways we acquire and treat your Data when you access, visit and/or use the Product. It also governs your Data that we may acquire offline. Please notice that our Privacy Policy does not cover information collected by web-sites, applications, destinations, or services linked to from the Product that we do not own or control.
You can access this Privacy Policy any time on the Product's description screen, or as otherwise indicated depending on the Product you are using, or any public website's page: https://kevafeliro.com/privacy.

By clicking the button with text «I Agree» or another the same in the Product: you agree to be bound by this Privacy Policy that located web-address at https://kevafeliro.com/privacy. By downloading the Product, registering for any aspect of the Product, or otherwise accessing, visiting or using the Product, you consent to this Privacy Policy too if there is no another notification or agreement.
If you don’t agree with the terms and conditions of this Privacy Policy, you should not access, visit and/or use the Product. We advise that you print or retain a digital copy of this Privacy Policy for future reference.
This Privacy Policy may be modified from time to time, so check back often. So that you are aware changes have been made, we will adjust the «Last Revised» date at the beginning of this document. If we make a significant change in the way we use or share your PII, we will also post on the Product a prominent notice that a change was made. Continued access of the Product by you will constitute your acceptance of any changes or revisions to the Privacy Policy.
This Privacy Police in the part of Personally Identifiable Information must be used only in a case, when you give to us (or to Third Party that provided by us) your PII such as your name, email address, postal address or phone number, not all your Data.

2. The Types of Data Acquired About You

2.1. Data.
Registration Information. When you register to use the Product(s), sign up for notifications or updates on the Product(s), or participate in our surveys, we may collect your name, email address, gender, age, and any other information that you provide to us.
Profile and Other Information. We may collect additional information from you, such as the information about yourself for your public profile (e.g. age, gender, hobbies, interests, zip code, state, country, tastes, influences, evaluations by/of other users, photographs, visited or planned events).
PLEASE NOTE that any member profile information, media, image, photo, comment, or any other content that you post onto Product(s) will become publicly available and may be collected and used by others. So the information published by you in the Product, as well as most of your actions in the Product will be available to all Internet users.
Social Network Information. If you choose to connect the Product(s) to your social network accounts (or other Third party services or applications), we may collect your profile information (such as your name, gender, age, locale, email address, and profile picture) and other information available on your social network account.
Information Maintained on Your Device. When you use the Product(s), and when you have enabled such collection in your device or Product’s(s’) settings, we may collect certain information maintained on your Device to help us tailor our Product(s) to you, such as the contact information in your Device’s address book, your calendars, or pictures stored on your Device.
Geolocation. We can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections - if you allow it us. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it, so we can't give you some functions of the Product (such as people and events around you).
2.2. Children’s Privacy Data.
Protecting the privacy of young children is especially important. Our Products is not directed to children under the age of 16, and we do not knowingly collect PII from children under the age of 16 without obtaining parental consent. If you are under 16 years of age, then please do not use or access the Product at any time or in any manner. If we learn that PII has been collected on the Product from persons under 16 years of age and without verifiable parental consent, then we will take the appropriate steps to delete this information.
The Product is not intended to be used by children under the age of 16 and is not intended to be used to post content to share publicly or with friends. To the extent that children under the age of 16 have posted such content on the Product, children under the age of 16 have the right to have this content deleted or removed using the deletion or removal options detailed in this Privacy Policy. If you have any question regarding this topic, please contact us as indicated in Section 11. Please be aware that, although we offer this deletion capability, the removal of content may not ensure complete or comprehensive removal of that content or information.
2.3. Anonymous Data.
Some of the Data that we acquire cannot identify, distinguish or trace you or your Device, even if combined with other identifying information, and some Data that could be considered PII when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your Device, but is instead used in an anonymous way, often aggregated with other anonymous Data about other users.
2.4. Credit/Debit Card and Payment Account Data.
We will not ask, and get, and sell or rent your credit/debit card number or payment account Data.
When you subscribe to a paid service or make a purchase directly from us by Product - you provide our payment service provider with information, such as your debit or credit card number or other financial information. We will not get that information about your sensitive Data such as Credit/Debit card or payment account, so you must read Privacy Policy of that payment service provider before take action for pay. After that we will get only information about the fact of payment.

3. How We Acquire Your Data

3.1. Data You Provide.
We and the Third Party mostly receive your Data and PII because you provide it to us and the Third Party by your deliberate choice.
3.2. Data Automatically Collected.
The Product may also automatically collect Data about you, your online behavior and your Device. The Data collected may include, without limitation:
- Unique device identifier generated from the device MAC/IMEI/MEID, which we alter to limit the ability to identify the relevant device in the future;
- An advertising ID, such as the Apple IDFA or the Android Ad ID;
- IP address;
- Device manufacturer and model;
- The operating system and version running on your system or device;
- Browser type;
- Language;
- The make of the CPU, and number of CPUs present;
- The graphics card information, such as type, vendor and driver name, version and graphics API;
- Amount of system and video RAM present;
- Current screen resolution;
- Operating system identifier (e.g., Mac, Windows, etc.);
- A checksum of all the data that gets sent to verify that it did transmit correctly;
- App ID of the game installed;
- Geographic location of you and/or your Device, as well as date/time stamp;
- Pages visited, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data.
3.3. Data Acquired Elsewhere.
We and Third Party may also acquire your PII or Data offline or otherwise outside of the Product. For example, Third Party may purchase or otherwise acquire such Data from third party data suppliers. We and Third Party reserve the right to merge or commingle this other Data with your PII and Data collected on or through the Product.

4. How We Use Your Data

4.1. Processing Your Requests for Products.
We and the Third Party use your Data to process your request for Content and/or Product. For example, if you write to our support or to Privacy Policy Coordinator, we may use your email address to send you an answer and to give a right decision and recommendation.
4.2. Administering the Product.
We and Third Party also use your Data for any lawful business purpose in connection with administering the Product, including without limitation for customer service, to help diagnose problems with servers and Product, to improve Products that we offer by tailoring them to your needs, to gather broad demographic information, to analyze trends, to seek compatible advertisers, sponsors, clients and customers, and to track users' movements around the Product and elsewhere on the web or across apps and devices. Your geographic location Data may specifically be used to show you Content (including advertising and sponsored messaging) based on geographic location by and Third Party.
4.3. Access by Third Party Providers.
We may also allow access to your Data by Third Party Providers that provide us with services, such as technical maintenance, market research, community and forums management, auction services, e-commerce, personal/job search and other advertising functionality, but only for the purpose of and to the extent necessary to provide those services.
There are also times when you provide Data to us in areas of the Product that may be managed or participated in by one or more Third Party Providers. In such cases, the Data may be used by us and by such Third Party Provider(s), each pursuant to its own policies. While we may seek to require Third Party Providers to follow appropriate privacy policies and will not authorize them to use your Data except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.
4.4. Marketing Communications.
Third Party Providers may also use your Data to communicate with you about new features, events or other products offered by Third Party Providers, our advertisers, and other companies and individuals with which Third Party Providers have a relationship.
4.5. Legal Requests.
We and Third Party may also provide access to your Data in order to cooperate with official investigations or legal proceedings brought by or otherwise involving governmental and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process. We and Third Party may also provide access to protect our rights and property and those of our agents, customers, and others including to enforce our agreements, policies, and terms of use.
4.6. Employment Opportunities.
If you provide your PII to us in connection with an employment inquiry, without limiting the applicability of the rest of this Privacy Policy, we will use your PII to evaluate your job application, and for related recruiting, reporting and recordkeeping purposes. We may maintain your PII on file, whether we hire you or not, to administer your relationship with us and/or for job applicant related reporting and recordkeeping for as long as required or permitted by law.
4.7. Transfer or Sale of Our Business or the Product.
As our business changes, we may buy or sell various assets owned or controlled by us. In the event all or a portion of the assets are sold, assigned, transferred or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy or otherwise, your Data may be among the transferred assets.
4.8. Combining Your Anonymous Data with PII.
We and Third Party reserve the right to merge or commingle anonymous, non-personally identifiable Data about you, your offline and online behavior, and/or your Device (including its geographic location), with your PII for any lawful business purpose.
4.9. Legal Basis for Processing Personal Data Under General Data Protection Regulation
If you are from the European Economic Area (EEA), we and Third party’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the PII we collect and the specific context in which we collect it.
We may and Third parties process your Data because:
- We and Third parties need to perform a contract with you;
- You have given us permission to do so;
- The processing is in our and Third parties' legitimate interests and it's not overridden by your rights;
- To comply with the law.
4.10 Security and Investigations
We can use your data (including your communications) for security purposes or to prevent or investigate possible fraud or other violations and/or attempts to harm our Members, Visitors or others.
4.11 Delete the Product from Device or Account Closure
We generally delete information about deleted Products or closed account within 30 days of that events, except as noted below.
We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to "unsubscribe" from further messages from us. We will retain de-personalized information after your account has been closed.
Information you have shared with others will remain visible after you close your account or delete the information from your own account or mailbox, and we do not control data that other Members have copied out of our Services. Groups content and ratings or review content associated with closed accounts will show an unknown user as the source. Your account may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.
We do not control data that other Members have copied out of our Products.

5. Sharing Your Data for Marketing; Opt-Out; How to Update Your Data

5.1. Credit/Debit Card and Payment Account Data.
We will not ask, and get, and sell or rent your credit/debit card number or payment account Data or any sensual Data and information.
5.2. Sharing Your Data for Marketing.
Unless otherwise specified on the Product, we may share your Data among our parents, subsidiaries, and affiliates and with other third parties who we think may offer or enable you to become aware of Products that may be of interest to you. Before that transfer, we will ask for your permission or give you a warning.
5.3. How to Opt-Out of Sharing for Marketing.
If you do not wish to have PII such as your name, email address, postal address or phone number shared with third parties for their marketing purposes, contact our Privacy Policy Coordinator as described at the end of this document or make the appropriate selection in the apps on the Product's description screen with legal documents. But note that, in order for us to properly administer the Product, we must continue to share your Data with Third Party Providers as described in Section 4 above (if you object to such sharing, you should not use the Product). Note also that this option to opt-out applies only to PII, and not Anonymous Data.
5.4. How to Opt-Out of Marketing Messages from Us.
If you do not wish to receive future marketing or other commercial messages from Third parties, simply follow the unsubscribe instructions contained within the message you receive in the apps on the Product's description screen with legal documents. But note that you may continue to receive certain communications from Third parties that are necessary for the Product, such as renewal notifications, invoices, technical notices, updates, security alerts, and support and administrative service bulletins.
5.5. Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We and Third parties aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your PII.
If you wish to be informed what PII we hold about you and if you want it to be removed from our systems, please contact us. If you wish to be informed what PII Third parties hold about you and if you want it to be removed from Third parties' systems, please contact them as described at Section 11.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information Third parties or we have on you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your PII.
- The right of restriction. You have the right to request that Third parties or we restrict the processing of your PII.
- The right to data portability. You have the right to be provided with a copy of your PII in a structured, machine-readable and commonly used format by Third parties or us.
Please note that we may ask you to verify your identity before responding to such requests.
5.6. Links To Other Sites
Our Product may contain ads with links to other sites, and apps that are not operated by us. If you click on a Third party’s link, you will be directed to that Third party's site or app. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any Third party’s sites or services, or applications.
5.7 Legal Disclosures
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to
1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies;
2) enforce our agreements with you;
3) investigate and defend ourselves against any third-party claims or allegations;
4) protect the security or integrity of our Services (such as by sharing with companies facing similar threats);
5) exercise or protect the rights and safety of our members, personnel or others.
We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

6. Cookies and Related Technologies; Do Not Track (DNT)

6.1. Cookies/Local Device Storage.
Third Party Providers by our Product will at times place and/or store code or other types of information and/or software on your Device or within your browser, such as cookies (including flash cookies), locally shared objects, and HTML5 (collectively, «Local Device Storage»). We and Third Party Providers may use Local Device Storage in connection with the Product for any lawful business purpose, including without limitation to determine whether you have seen a particular advertisement before on the same or different Device and to otherwise control the display of ads, to track the movements of individual users through the Product and elsewhere on the web or across apps, devices, and geographic locations, to help diagnose problems with servers, to gather broad demographic information, to conduct research, to deliver editorial Content, to record registration and personalization information, and to otherwise administer the Product. For example, if you register on any part of the and Third Party Providers' products and are given the option to save your user name and password, Third Party Providers may provide this convenience to you via Local Device Storage. Local Device Storage may also collect and store your PII, which may be shared with our parent, subsidiaries, and affiliates and other third parties.
6.2. You May Disable Local Device Storage.
If you do not want Local Device Storage, your Device or browser may include an option that allows you to not accept it. However, if you disable Local Device Storage, some portions of the Product may not function properly.
6.3. Tracking Technologies.
In addition to Local Device Storage, Third Party may use web beacons, web bugs, internet or pixel tags, clear gifs, digital fingerprinting (aka «Machine Identification») and similar technologies (collectively, together with Local Device Storage, the «Tracking Technologies») on the Product and in our communications with you, such as within email and text messages and push notifications. Third Party use Tracking Technologies to determine which of our messages have been opened by recipients, and for all or some of the same lawful business purposes we describe above for use of Local Device Storage.
6.4. Do Not Track (DNT).
Your browser setting may allow you to automatically transmit a «Do Not Track» (DNT) signal to websites and online services that you visit. There is no consensus among industry participants as to what DNT means in this context, and some browsers automatically apply DNT signals by default and therefore do not necessarily reflect our visitors' choice as to whether they wish to receive advertisements tailored to their interests. As a result, like many websites and online services, we do not alter our practices when the Product receives a DNT signal from a visitor's browser. As discussed below, you may opt out of the use of your Data for online behavioral advertising by third parties at any time. To find out more about DNT, please visit http://allaboutdnt.com.

7. Online Behavioral Advertising (OBA) and How to Opt-Out of OBA

7.1. How OBA Works.
Third Party Providers will at times also use Tracking Technologies for purposes of «online behavioral advertising» (OBA). OBA allows the serving of advertisements tailored to interests you have shown by browsing on the Product and on other sites, applications, destinations, and services, using the same or a different Device. To enable OBA, these Third Party Providers use Tracking Technologies to collect Data including for example the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of your Device, as well as date/time stamp, IP address, pages visited, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The use of Tracking Technologies by Third Party Providers is subject to their own privacy policies, not this Privacy Policy, and we have no responsibility or liability in connection therewith. You may visit Third Party Providers' sites and discover their own privacy policies.
7.2. Opt-Out of OBA.
If you do not want OBA at all, you may be able to opt-out by visiting http://www.aboutads.info, http://www.networkadvertising.org, http://www.youronlinechoices.com/uk аnd/or by clicking the «Ad Choices» icon that appears in advertising served through OBA. Please note that the option to opt-out applies only to tracking by Third Party Providers across this Product and other sites, applications, destinations, and services, and not tracking among pages within the Product itself.

8. Transfer of Your Data Among Jurisdictions

We are Spain-based but our Product is geared to a worldwide audience. Your Data may be processed, transferred to, and maintained on, servers and databases located within the European Union, and U.S., and elsewhere where the privacy laws may not be as protective as your jurisdiction. We reserve the right to transfer your Data to and from any state, province, country or other governmental jurisdiction. Your consent to this Privacy Policy followed by your submission or our collection of such Data represents your agreement to any such transfer.

9. Data Security and Notification

9.1. Security Measures.
We take commercially reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, PII that you share with us.
9.2. No Liability for Breach.
Because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the Data that you send to us or the security of servers, networks or databases, and by using the Product you agree to assume all risk in connection with your Data. We are not responsible for any loss of such Data or the consequences thereof.
9.3. Breach Notification.
In the event that we believe the security of your PII in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you by email, push notification, or otherwise.

10. Notice to California Customers - Your Privacy Rights

10.1. Shine the Light.
California's «Shine the Light» law, Civil Code Section 1798.83, gives California customers the right to prevent our disclosure of their personal information to third parties for those third parties' direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business' practices related to disclosing personal information to third parties for the third parties' direct marketing purposes. Alternatively, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties' direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. If you wish to opt-out of our sharing of your Data with third parties for the third parties' direct marketing purposes or to find out more about your opt-out rights, please contact our Privacy Policy Coordinator as described below.
10.2. Online Erasure.
California's «Online Erasure» law, Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services to allow registered users who are under the age of 18 and residents of California to request removal of Content they post. If you fit that description and posted Content on a section of our Product that is directed to minors, you may request removal of the Content by contacting our Privacy Policy Coordinator as described below. In response to your request, we may elect to make the Content invisible to other users and the public (rather than deleting it entirely), in which case the Content may remain on servers we control and/or may be publicly available elsewhere if a third party copied and reposted the Content.

11. Privacy Policy Coordinator

11.1. Our Privacy Policy Coordinator
If you have any concerns or questions about any aspect of this policy, please feel free to contact our Privacy Policy Coordinator as follows:
Privacy Policy Coordinator - Marianna Markelova
e-mail: welcome@kevafeliro.com
If you wish to exercise this right, please contact our Privacy Policy Coordinator and state which of these items you wish to opt-out of sharing with third parties.
Also, as discussed above, if you have registered on any part of the Product and you wish to update or make changes to your PII on file with us, you may contact our Privacy Policy Coordinator.
11.2. Privacy Policy of Third Party
The Product contains elements of code (include Cookies) that allows you to show ads, analyze Data, research marketing indicators, and the Product is distributed using the following Third parties:
a) Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043)
You can read Google’s privacy policy by the link:
https://policies.google.com/privacy

You may opt-out of having your data on Google Inc. by contacting them;
b) Yandex, LLC (16 Lva Tolstogo str., Moscow, 119021, Russia)
You can read Yandex’s privacy policy by the link:
https://yandex.com/legal/confidential
You may opt-out of having your data on Yandex, LLC by contacting them;
c) Individual Entrepreneur Nikita Obukhov (Primary State Registration Number: 309732819400022)
You can read Tilda’s privacy policy by the link:
https://tilda.cc/privacy/

You may opt-out of having your data by contacting legal@tilda.cc;
d) Apple Inc. (One Apple Park Way, Cupertino, California, USA, 95014)
You can read Apple’s privacy policy by the link:
https://www.apple.com/legal/privacy/en-ww/

You may opt-out of having your data on Apple Inc. by contacting them;
e) Functional Software, Inc. (45 Fremont Street, 8th Floor, San Francisco, CA 94105)
You can read Sentry’s privacy policy by the link:
https://sentry.io/privacy/

You may opt-out of having your data on Functional Software, Inc. by contacting them.
f) Facebook Inc. (1601 Willow Road, Menlo Park, CA, 94025, USA)
You can read Facebook’s privacy policy by the link:
https://www.facebook.com/about/privacy/
You may opt-out of having your data on Facebook Inc. by contacting them.
g) Cloudinary Ltd. (3400 Central Expressway, Suite 110 Santa Clara, CA 95051, USA)
You can read Cloudinary’s privacy policy by the link:
https://cloudinary.com/privacy



Note: Only inquiries about this policy or your PII should be sent to the Privacy Policy Coordinator. No other communications will be accepted or responded to.
For communications on other matters, please contact us through the means described on the Product, if available (e.g. in the «Contact Us» section).

* * * * * * * * * * * * * *

If you don't agree to the terms contained in this Privacy Policy, you must immediately exit the Product and delete all Product's information from Device.