NIMSES INC. PRIVACY POLICY

Hello! Nimses Inc. is glad to see you here and asks you to read Nimses Inc. privacy policy (hereinafter referred to as the "Policy") thoroughly. This is a new version of the Policy; the previous one is available here: https://nimses.com/privacy_old/. "Nimses" in the text of this Policy means Nimses Inc., its affiliates or contractors. Nimses Inc. is an American company located in the United States of America, namely in Delaware. Nimses Inc. is the developer and the owner of the different products and services under the brand “Nimses”, including but not limited to Nimses application (hereinafter collectively referred to as the " Services"). Nimses Inc. is the controller of the personal data of the users of the Services. The controller of the personal data is the person or entity who determines the purposes and means of personal data processing.

Nimses has prepared this new Policy, taking into account the latest changes in the legislation regulating the protection of personal data, particularly the requirements of the General Data Protection Regulation (GDPR). Nimses also has structured this Policy for better perception, tried to get rid of legal jargons and complex sentences, and added some examples that hopefully will help you understand this Policy better.

WHY SHOULD I READ THIS POLICY

You are about to use or already are using the Services. When you use the Services, Nimses collects, stores, or otherwise processes your personal data (for example, name, last name, your location data, phone number, etc.). Nimses collects personal information about you in order to provide the services you are asking for and in connection with its business activities. In some cases, Nimses may ask your consent to special types of processing. IF YOU DO NOT WANT NIMSES TO COLLECT AND TO PROCESS YOUR DATA AT ALL, PLEASE DO NOT USE THE SERVICES.

Nimses has prepared this Policy to give you the opportunity to get detailed information about what Nimses does with your personal information, what consequences this might have for you, your rights in respect to your personal data, and how you can control your personal data.

You may also address to this Policy after accepting it if you have any additional questions when using the Services.

WHAT IS THIS POLICY ABOUT

In this Policy, Nimses will tell you about the following:

  • who Nimses is, its name, location, and how Nimses can be contacted;
  • the data Nimses collects and processes about users, as well as the purposes for which Nimses collects and processes data;
  • risks that personal data processing can bring to the users;
  • basic rights of the users regarding their personal data and what control options the user has in relation to his or her personal data.

For your convenience here is placed the content of this Policy:

  • Age restrictions
  • What should I do if I do not understand something in this Policy?
  • What data is collected by Nimses and how is it used?
  • Consequences of processing of personal data processing
  • On what legal grounds does Nimses collect and otherwise process my personal data?
  • For what purposes does Nimses collect and otherwise process my personal data?
  • Why does Nimses collect so much data?
  • How long does Nimses store my personal data?
  • To whom does Nimses provide my personal data?
  • Data transfers outside the EU
  • Automated decision-making, profiling, children
  • Profiling and advertising
  • Profiling, advertising and sensitive data
  • How can I control my data (Your rights in respect to your data)?
  • Contact Nimses
  • Changes to the Policy
  • Miscellaneous
AGE RESTRICTIONS

By registering in and using the Services, you confirm that you are at least 13 years old and you have reached the appropriate age that allows you to enter independently into contracts in your own country.

When Nimses asks you to give the consent to the processing of personal data, you can do it independently on reaching a certain age. By registering in and using the Services, you confirm that you are at least 13 years old and you have reached the appropriate age that allows you to consent to the processing of personal data in your country without prior approval of your parents or holder of parental responsibility over you.

If you are not sure about whether you can independently consent to the processing of personal data, please contact your authorized personal data protection authority in your country.

Nimses may ask you to submit additional documents or to pass through additional procedures to make sure that you are already 13 years old (or more, as required by the laws of your country), if Nimses has reasonable doubts about your age, for example, if the face recognition system indicates that you are not 13 years old (or more, as required by the laws of your country). Nimses may also contact your parents or guardians to obtain consent or approval of the processing of personal data concerning you if you have not reached the appropriate age. For a period of clarification or getting the approval from your parents or guardians, Nimses may restrict the processing of data on you and temporarily block your account.

WHAT SHOULD I DO IF I DO NOT UNDERSTAND SOMETHING IN THIS POLICY?

When Nimses was preparing this Policy, Nimses wanted to be as simple as possible and easy to understand by adults and children, who are users. Nimses tried to put all the important information here using plain and clear language. However, if something in this Policy is not clear for you, perceived ambiguously, thrills you or you have additional questions, Nimses encourages you to contact Nimses at: support@nimses.com.

Nimses will be grateful for your feedback regarding this Policy because each feedback helps Nimses to improve this Policy, make it more transparent and clear to all users.

WHAT DATA IS COLLECTED BY NIMSES AND HOW IS IT USED?

Nimses receives and collects data on users in several ways:

  • directly from you;
  • when you use the Services and as a result of monitoring of your activity in the Services;
  • from third parties.

You will find more details about these three ways below.

1) Nimses collects information that you give or fill in. For example, when a user logs in to use the Services and during the registration or subsequently fills in information about himself or herself in her or his account, Nimses collects data such as:

  • user's name and surname;
  • user’s nickname and user’s displayname;
  • age of the user and date of birth of the user;
  • sex of the user;
  • e-mail address of the user;
  • phone number of the user;
  • user’s avatar;
  • image of the user's face (only if the user has passed through a face-verification procedure)

Also Nimses collects data that you provide about yourself when you contact Nimses support team for solving some problems, which may arise when you use the Services.

When some user carries out business activities (for example, sells goods or services) using Nimses business products, for example, Nimses Goods, Nimses also collects about such user his or her passport data, tax information (including tax number, registration data in tax authorities, etc.), his or her registration data as private entrepreneur (if any), bank information and other information that is necessary for the proper identification of user in accordance with the terms of use of Nimses Goods and fulfillment of obligations, which Nimses may have.

When you make payments (receive payments and/or make payments) using Services, Nimses also collects information about yours payment instruments (electronic wallet, cryptocurrency wallet, payment cards, bank accounts, etc.)

2) Nimses collects information when you use the Services and by monitoring your behavior in the Services. When a user uses the Services, Nimses collects and processes such personal data and personal information as:

  • User’s location information. When a user creates an account and/or uses the Services, Nimses collects information about his or her location using a variety of technologies, including GPS. Nimses also collects the user's IP address and sees where the user spends most of the time.
  • Information about the user’s device. When a user creates an account and/or uses the Services, Nimses collects information about the device from which the user created an account and/or entered the Services, including device model information, operating system version information embedded in the device, device language information, device screen format, unique device identifier. Nimses also collects information about the device memory installed on the device, type of browser, information about connecting other devices to the device, time zone and device charge level, device’s connections to wireless or mobile connections.
  • Information about contacts from the user's phonebook. When a user starts using the Services, Nimses also gets access to the user's phonebook in the user's device.
  • Information about the user’s activity in the Services. When a user uses the Services, Nimses collects information about how much time the user has spent on the Services, the time and date of the last visit to the Services, the data on the users who verified the user, the list of users with whom the user interacted, in particular, send to and received from nims, verified, corresponded. Nimses also collects information about which pages and options the user uses, which ads the user viewed, what music the user was listening to in Nimses Music, what goods the user purchased in Nimses Goods and/or viewed.
  • Information about preferences and interests. By observing your behavior in the Services, Nimses makes certain conclusions and assumptions about your interests and preferences, and Nimses may place you in some category, offer you similar content or users, and if you wish to view advertisements, offer you advertisements based on your interests and preferences.
  • Sensitive information. By observing your behavior in the Services, Nimses may indirectly and unknowingly obtain some sensitive information about you. You can read more about this in the section on profiling, advertising and sensitive data.
  • Information obtained through cookies. When you visit https://nimses.com, Nimses uses cookies on this site. For more information on what Cookies are and for what purposes Nimses uses Cookies, you can read in Cookie Policy.
  • Nimses also collects other information that you place on Services. This is the information you share, send, place, exchange using the Services; for example, text messages you send to and receive from other users of the Services, published and uploaded graphic, text, audiovisual and other content, your posts. Please note, Nimses does not read your messages under any circumstances.
  • Nimses also collects information about your activity when using Services other than the mobile application, if you use them. In particular, Nimses collects information for analytical purposes (including providing you with analytics) regarding your offers for sale of goods/services, the effectiveness of your sales of goods and/or services through Nimses Goods, regarding your advertising campaigns carried out by Nimses Ads and their effectiveness in order to provide you with opportunities and tools to improve your business and to introduce new services. Nimses also collects, stores and analyzes and analyze all data related to your Nimses Exchange transactions on the exchange of nims, the placement and withdrawal of funds considered to be legal payment instrument in at least one country in the world, the placement and withdrawal of e-money or cryptocurrency.

3) Nimses can receive information about you from third parties. This can happen, for example, as a result of receiving information from other users, for example, if another user's phone book contains your phone number. Similarly, certain user’s information may be obtained from third-party organizations with which Nimses integrates its products or which provide Nimses with certain analytical services or from advertisers with which Nimses cooperates.

PLEASE NOTE THAT NOT ALL DATA SPECIFIED IN THIS POLICY SHALL BE NECESSARILY COLLECTED AND PROCESSED ABOUT YOU AS OF NOW. IF YOU WANT TO FIND OUT AN EXHAUSTIVE LIST OF DATA THAT NIMSES HAS ABOUT YOU, YOU MAY USE YOUR RIGHT TO ACCESS INFORMATION ABOUT YOURSELF.

CONSEQUENCES OF PROCESSING OF PERSONAL DATA

When using the Internet, you should always keep safety in mind, and the use of the Services is not the exemption. It is important to keep in mind what content you share with others, and that, for example, other users may identify where you are from the analysis of your posts. You should also keep in mind that any user can copy the content you share and post it on other resources.

Please note that if you delete your account, some personal data will remain in Nimses’ system in an anonymized form, it will be stored in such a way that it will be impossible to identify the user. This is necessary to give Nimses an opportunity to check whether a user was previously registered or not. Nimses will use such data only in order to prevent fraud, when a user who violates the terms and conditions and whose account was deleted will attempt to re-register within the Nimses system again. By saving such data, Nimses will rely on its legitimate interest.

ON WHAT LEGAL GROUNDS DOES NIMSES COLLECT AND OTHERWISE PROCESS MY PERSONAL DATA?

Nimses collects and processes your data based on the following legal grounds:

  • One of the reasons why Nimses collects and processes the user’s data is the existence of a contract between the user and Nimses. By registering in and using Services, you and Nimses conclude a contract for the provision of services. In order to provide you with services as a whole, as well as with a separate component, such as Nimses Music, Nimses Goods, etc., Nimses must collect and process certain data about you. For example, because the Nimses application is a geolocation application and promises you to show you users who are near you in real time, Nimses should collect information about your location, because without it Nimses simply will not be able to provide to you the services you ask for.
  • Legitimate interest. Another reason for the collection and processing of your data is legitimate interest pursued by Nimses or by third party. Nimses uses a legitimate interest in processing your data, for example, when Nimses processes your data to fix bugs in the Services and to ensure its smooth operation, to improve and to enhance the work of the Services, to develop and to introduce new functions and services, to ensure security of the users of the Services, and to ensure secure work of the Services, to transfer data within the organizational structure of Nimses, for example, to affiliated companies, to transfer certain information at the request of the intellectual property rights holders who claim that a particular user has placed illegal content. It is important to emphasize that Nimses will not use legitimate interest as a basis for processing of user data if the rights, freedoms and interests of the users of the Services override the interest of Nimses or third party.
  • Legislative requirements. Nimses may process a user’s data if it is required by the law that applies to Nimses. For example, Nimses may provide data on users at the request of courts or other authorized bodies or when collection and identification are required by the legislation on financial monitoring and prevention of money laundering or by other applicable laws.
  • Consent. Nimses relies solely upon the user's consent when using personal user data for the purpose of displaying targeted advertising, marketing and promotional mailing, or for other purposes for which a specific user’s consent must be granted.
FOR WHAT PURPOSES DOES NIMSES COLLECT AND OTHERWISE PROCESS MY PERSONAL DATA?

Nimses collects and processes personal user data for the following purposes:

  • direct work of the Services and the provision of the relevant services to the users;
  • fixing bugs in the Services and ensuring the proper operation of the Services;
  • improving and enhancing of the Services and developing and introducing of new services and functions;
  • ensuring the safety and security of the users of the Services and the safety and security of the provision of the Services;
  • profiling of the users and making automated decisions (including solely automated decisions) on this basis;
  • profiling of the users and use of the users’ profiles in order to display targeted advertising to such users;
  • for advertising and marketing activities;
  • to comply with the requirements of the legislation and the requirements of third parties (including but not limited to the requirements, notice, claims of copyright and trademark holders);
  • to monitor the compliance of users with the terms and conditions of the Services;
  • in order to contact the user.
FOR WHICH PURPOSES DOES NIMSES COLLECT AND OTHERWISE PROCESS MY PERSONAL DATA?

Here are some examples that might help you understand these purposes.

Example 1

This example illustrates one of the cases when Nimses uses user’s data directly for the Services provision. Nimses collects user location data because Nimses application is a geolocation application, and one of the ideas embodied in its work is to show to user other users who are near the user in real time, as well as the other activity that is near the user in real time. The overwhelming majority of existing services and functions that will soon appear in the Services are based on the user's location, for example, the Temples. As the use of the Nimses application without access to the user's geolocation is impossible, Nimses simply will not be able to provide you with the services you asked without using your geolocation data.

PLEASE NOTE: IF FOR ANY REASONS, IT IS UNACCEPTABLE FOR YOU THAT NIMSES COLLECTS DATA ABOUT YOUR LOCATION, PLEASE DO NOT USE NIMSES APPLICATION, AND IF YOU ARE ALREADY USING NIMSES APPLICATION, YOU CAN ALWAYS DELETE YOUR ACCOUNT.

Nimses collects the data that identifies you, including your last name, name, nickname, phone number, avatar, etc., because such data allows other people to find you and communicate with you, which is one of the task for the Nimses application and Nimses should process such data in order to execute a contract concluded between Nimses and the user.

Example 2

This example illustrates one of the cases when Nimses uses user’s data for fixing bugs in the Services. Nimses collects device model information, operating system version embedded in the device, screen format in the device from which the user enters the Services, so that if the user has any technical problems with the work of the Services, the support team could solve this technical issue.

Example 3

This example illustrates one of the cases when Nimses uses user’s data for the purpose of improving and enhancing of the Services and developing and introducing of new services and functions. Nimses collects device language data to display all information, including informational messages in language that is convenient for the user. Nimses tracks the user behavior in the Services, for example, how often a user has used some function or pushed the button, to improve the product design of the Services and make them user-friendly. Please note that Nimses does not interfere with your private life and does not violate the secrecy of your correspondence under any circumstances, Nimses only collects aggregated and anonymous analytical information about which buttons the users frequently clicked or which functions the users frequently used.

Example 4

This example illustrates one of the cases when Nimses uses user’s data for the purpose of the safety and security of the users of the Services and the safety and security of the provision of the Services. Nimses collects data about a unique user device identifier for security purposes, in particular, to prevent so-called bots from using the Services, for example, when a large number of users are logged in from one phone but from different numbers – this creates an excessive load on Nimses’ infrastructure and is a signal for Nimses about a suspicious user.

Example 5

This example illustrates one of the cases when Nimses uses user’s data for the purposes of profiling of the users and making automated decisions (including solely automated decisions) on this basis. If you need more information on profiling, you can find it in the section on profiling. By watching your behavior in the Services, Nimses can make certain assumptions about your interests and preferences, for example, by analyzing the history of purchases on Nimses Goods, Nimses may offer you certain products that are similar to those that you have previously purchased or viewed.

Example 6

This example illustrates one of the cases when Nimses uses the user’s data for the purpose of profiling to display targeted advertisements.

Provided the user wants to view the advertisement, in order to show to the user the advertisement that fits with the preferences and interests of such user, Nimses will use personal data of the user. For example, if Nimses sees that the user spends his or her time at the stadium, such user may be offered advertisement of sporting goods or sporting events. You can find more information on the process of profiling in the section on profiling. Nimses respects your privacy, you can always withdraw your consent to process your data for the above-mentioned purpose.

Example 7

This example illustrates one of the cases when Nimses uses user’s data for advertising and marketing activities. Nimses collects the user’s location data and, based on this, may send the user relevant advertisements and marketing messages that may relate to the events taking place near the user's location. Nimses respects your privacy, you can always withdraw your consent to process your data for the above-mentioned purpose.

Example 8

This example illustrates one of the cases when Nimses uses user’s data to comply with the requirements of the legislation and the requirements of third parties (including but not limited to the requirements, notice, claims of copyright and trademark holders). Nimses collects information about the user’s name, surname, e-mail, telephone number in order when some disputes or claims from third parties arise, particularly, when holder of some intellectual property rights reports a notice about infringement of intellectual property rights by a certain user, Nimses can provide to such holder of some intellectual property rights with user’s contact information.

Example 9

This example illustrates one of the cases when Nimses uses the user’s data to monitor the compliance of users with the requirements of the Services terms and conditions. Nimses collects information about a unique device identifier to prevent the registration of so-called bots from one device, but from many telephone numbers. Nimses may monitor posts and content, which is published by the user in order to prevent publishing of the content that violates the Services terms and conditions.

Example 10

This example illustrates one of the cases when Nimses uses the user’s data to communicate with the user. For example, if Nimses wants to notify you of important information about changes in this Policy or in connection with the recovery of access to your account. Nimses can contact you using the personal data that you provided.

WHY DOES NIMSES COLLECT SO MUCH DATA?

Nimses respects the principle of "data minimisation" and collects and processes data based on this principle. Nimses collects so much data only for the purposes specified in this Policy.

HOW LONG DOES NIMSES STORE MY PERSONAL DATA?

Nimses stores your personal data only when it is necessary for you or Nimses for the purposes indicated in this Policy. The last one also applies to any other third person who performs certain actions on behalf of Nimses. If Nimses does not need certain information about you and does not need to store information about you in accordance with the requirements of the law, Nimses will delete it or will store it in an anonymized way.

TO WHOM DOES NIMSES PROVIDE MY PERSONAL DATA?

Nimses transfers and can transfer your data:

  • to third parties – processors, namely, companies that help Nimses to collect, to store, to analyze, to structure, and to process information or perform other actions according to Nimses’ instructions;
  • to third parties – companies that Nimses integrates or otherwise connects certain products and services with;
  • to third parties – advertisers; in this case Nimses provides general and aggregated information and it is impossible to identify a particular person;
  • to its subsidiaries and affiliated companies;
  • to other users who receive certain information about you using the information displayed on your account (for example, they can see your last visit in Services, your approximate location, etc.);
  • to third parties, when some legal reasons arise (for example, the disclosure of certain contact information about the user who posted illegal content at the request of the copyright holder of such content);
  • to third parties in the case of carrying out mergers and acquisitions operations with Nimses;
  • to state and court authorities, when there are relevant legal obligations and relevant requirements.
DATA TRANSFERS OUTSIDE THE EU

The data of the users from the EU can be transferred to third countries outside the EU and the European Economic Area. If such data is transferred outside the countries of the EU and the European Economic Area to the third countries, Nimses will use appropriate measures to ensure that such a transfer is legal. The measures might include the standard contract clauses approved by the European Commission or the use of the Privacy Shield program to which Nimses intends to become the party. You can contact Nimses, and Nimses will send you the standard contract clauses Nimses used in case Nimses has resorted to such a measure.

As Nimses and the users of the Services conclude a contract, certain data of the users from the EU may be transferred to third countries outside the EU and the European Economic Area for providing the Services and executing such a contract. By accepting this Policy, the user confirms that his or her personal data may be processed by Nimses in the United States to execute the contract concluded between the parties.

AUTOMATED DECISION-MAKING, PROFILING, CHILDREN

Services are capable of making certain completely automatic decisions, for example, to block certain operations that are carried out on Nimses Exchange or to block an account after user's face recognition. In case such automatic decisions have legal consequences and significant impact on you (for example, the user's face detection system indicates that you have not reached a certain age and Nimses refuses to provide you with the Services or if any transaction on Nimses Exchange is blocked), you have a number of rights.

You may address Nimses to explain why a certain decision has been made by the system, or to appeal such decisions, to request human intervention, so that any decision can be made taking into account human intervention and not automatically. The above rights are not absolute and in some cases may not be applied.

One of the automatic decisions that the system implements is profiling. Since this process is rather technologically uneasy and invisible to you, here Nimses will try to explain to you its essence and why you need to know about its existence.

Nimses wants to provide you with transparent and accessible information about the process of profiling and its consequences for you. Profiling is a process of collecting user’s data. Based on this collected data, a profile of a user is formed, and it contains assumptions about the interests of such a user, his preferences, habits, lifestyle in general. Nimses can use profiling, for example, to offer you products that are similar to those you have watched or bought in Nimses Goods or offer musical compositions that are similar to those you have already listened to in Nimses Music.

In case you use Services and you are under the age of 18 or you have a child who uses Services and is under the age of 18, please read the following. Children are a very sensitive category of users who may not fully understand the risks and consequences of personal data processing.

All users, including users under 18, may be subject to solely automatic decisions made by Nimses’ algorithms.

However, Nimses is continuously monitoring and periodically reviewing its policies and rules for forming a user profile, display promotional and marketing proposals in order to prevent cases where profiling and solely automated decision making, including profiling, will have legal implications and significant impact on users under the age of 18. In case you have witnessed such incidents, please contact Nimses to take appropriate measures.

PROFILING AND ADVERTISING

For Nimses to offer advertisers better advertisements placing recommendations, Nimses will use the profiling process for each user.

Based on the collected user data and user profile data, results on ads that might be interesting to the user are generated by Nimses software algorithms.

Below are some examples that will help you understand the essence of profiling and its consequences for you:

  • For example, if Nimses sees that a user is often in the city center based on user-geolocation data, this user can see coffee shops, restaurants, other events, etc. in the city center.
  • Or if Nimses sees that the user often sends nims for photos of coffee, then such a user can see advertisements related to coffee or coffee shops, and so on.
  • Similarly, the user can see sports clothing advertising, if according to geolocation data Nimses sees that the user is in a gym or at a sport event.
  • Similarly, the user can see an advertisement about a concert or music festival, which involves performers, such a user most often listens to in Nimses Music.
  • If, according to geolocation data, Nimses sees that the user moves with a speed that indicates that the user is more likely to use a car or bicycle, the user may see advertisements for car manufacturers, bicycles, fuel advertisements, or advertisements for maintenance or refueling stations.

It is important to remember that Nimses never transmits and sells data that was collected about a specific user to the advertisers. Nimses respects your rights, and in case you wish to refuse to have your data processed for marketing or advertising purposes, you can always change it in the application settings.

You also have the right to know about all the personal data that Nimses may process, including your profile data that Nimses has formed. For example, based on user data processing, Nimses can rank users according to different categories, such as "Drivers", "Android users", and others.

HAVING RIGHTS ACCESS TO PERSONAL INFORMATION, YOU MAY ALWAYS FIND OUT WHAT KIND OF DATA HAS BEEN COLLECTED ABOUT YOU AND WHAT KIND OF PROFILE HAS BEEN FORMED BY NIMSES FOR THE CURRENT DATE.

If you think that the advertisement that you see has a significant impact on you and your rights, you may ask Nimses to explain why you see such advertisement, or you may contest such advertisement, request human intervention, so that the offers can be displayed taking into account human intervention and not automatically. The above rights are not absolute and in some cases may not be applied.

PROFILING, ADVERTISING AND SENSITIVE DATA

Nimses strives to be honest with you and provide you with transparent information about how your personal data, is processed and the consequences it may have for you. Handling user personal data, Nimses may receive certain information about a user that may be treated as sensitive data that became known to Nimses as a result of observing the user's activity in the Services, though the user did not directly provide this data. Such sensitive data includes: data on racial or ethnic origin of a user, data about user's political views, data about the religious or philosophical beliefs of a user, data on user participation in trade unions, health data, data about the sexual orientation of a user, data regarding the sexual life of a user.

Below are some examples that will help you understand how this might happen:

  • for example, if according to user-generated geolocation data, Nimses sees that the user often goes to church, so Nimses can assume that the user is a religious person and belongs to a particular religion;
  • or, if a user frequently attends a dental clinic, Nimses can make some conclusions about the health of the user.

Nimses may also use such data in the process of profiling and, as well as for marketing and advertising purposes. For example, if a user frequently attends a dental clinic, Nimses can make some conclusions about the health of the user and the user can see some promotional offers of dental clinics.

In case something about profiling and its consequences is unclear for you, you can always write on support@nimses.com. Here you will receive help and necessary explanations.

Nimses respects your rights, and in case you wish to refuse to have your data processed for marketing or advertising purposes, you can always change it in the application settings.

HOW CAN I CONTROL MY DATA (YOUR RIGHTS IN RESPECT TO YOUR DATA)?

RIGHT TO WITHDRAW YOUR CONSENT

If Nimses asks you to give the consent, you can always withdraw your consent to processing personal data by changing the appropriate settings. By withdrawing your consent to processing data, you still be able to use the Services, but some functions or components may not be available to you.

In case you do not want Nimses to process your data for any purpose, you can always easily delete your account, but please pay attention to the fact that your accumulated nims will be annulated in this case. Therefore, if you decide to delete the account, Nimses recommends you firstly to use your nims in the available Services (for example, Nimses Goods, Nimses Music, etc.).

Please note that if you delete your account, some personal data will remain in Nimses’ system in an anonymized form, it will be stored in such a way that it will be impossible to identify the user. This is necessary to give Nimses an opportunity to check whether a user was previously registered or not. Nimses will use such data only in order to prevent fraud, when a user who violates the terms and conditions and whose account was deleted will attempt to re-register within the Nimses system again. By saving such data, Nimses will rely on its legitimate interest.

THE RIGHT TO FILE A COMPLAINT

If you think that Nimses violates your rights with respect to your personal data, you can file a complaint with an authorized body in your country. If you are in the territory of the European Union, you can file a complaint with a control body located in the EU Member State at the place of your residence or place of work or at the place where your rights are likely to be violated.

RIGHT TO ACCESS TO PERSONAL DATA

You have a right to access the data that Nimses collects about you. To exercise this right, please send a request to the following email address: support@nimses.com. Nimses may ask you to carry out additional verification procedures to ensure that the information is provided to the right user. Nimses responds to such requests for free, but a user abuse can lead to the fact that Nimses will refuse to process the request or will ask such a user to pay a fee.

THE RIGHT TO OBTAIN A COPY OF YOUR PERSONAL DATA

You have a right to download a copy of all data that Nimses collects about you based on your consent and on the contract that exists between you and Nimses. To exercise this right, please send a request to the following email address: support@nimses.com. Nimses may ask you to carry out additional verification procedures to make sure that the data is provided to the right user. Nimses responds to such requests for free, but a user abuse can lead to the fact that Nimses will refuse to process the request or will ask such a user to pay a fee.

THE RIGHT TO DATA PORTABILITY

You have the right to send data, which Nimses collects about you based on your consent and on the contract that exists between you and Nimses, to another organization. Nimses can independently transmit such data to another organization according to your instructions, but only if Nimses has a technical ability to do so. To exercise this right, please send a request to the following email address: support@nimses.com. Nimses may ask you to carry out additional verification procedures to make sure that the data is provided to the right user. Nimses responds to such requests for free, but a user abuse can lead to the fact that Nimses will refuse to process the request or will ask such a user to pay a fee.

THE RIGHT TO DATA CORRECTION

You have the right to change your personal data if data, which Nimses has at its disposal, are outdated or inaccurate. You can change your profile information in your profile settings. In case you have difficulties in changing your information, please contact Nimses at support@nimses.com.

THE RIGHT TO BE FORGOTTEN

In certain cases, you have the right to ask Nimses to remove the data that Nimses has about you. For example, you can do so if you withdraw your prior consent or if you object to processing of your personal data based on legitimate interest and Nimses does not have any interest that prevails over your rights, freedoms and interests. To exercise this right, please contact Nimses at the following email address: support@nimses.com. Nimses may ask you to perform additional verification procedures to make sure that the appropriate user has contacted it. There are certain cases in which the above described right cannot be exercised. Nimses will inform you if they occur.

Please note if you delete your account, some personal data will remain in Nimses’ system in anonymized form, it will be stored in such a way that it will be impossible to identify the user. This is necessary to give Nimses an opportunity to check whether a user was previously registered or not. Nimses will use such data only in order to prevent fraud, when a user who violates the terms and conditions and whose account was deleted will attempt to re-register within the Nimses system again. By saving such data, Nimses will rely on its legitimate interest.

THE RIGHT TO RESTRICTION OF PROCESSING

In certain cases, you have the right to ask Nimses to restrict the processing of personal data about you. For example, if you object the processing of personal data about you based on a legitimate interest pending the determining whether there is a legitimate interest that prevails. For example, when you object to processing, Nimses may freeze your account and not collect any information about you for a certain time until Nimses finds out whether your interests, rights and freedoms prevail over Nimses’ interests or interests of third parties.

To exercise this right, please contact Nimses at the following email address: support@nimses.com. Nimses may ask you to perform additional verification procedures to make sure that you are the appropriate user.

THE RIGHT TO OBJECT

If processing of personal data is based on legitimate interest, you have a right to object such processing. If Nimses does not have an interest that outweighs your rights, interests and freedoms, Nimses will stop processing your data. To exercise this right, please contact Nimses at the following email address: support@nimses.com. Nimses may ask you to perform additional verification procedures to make sure that you are the appropriate user.

I HAVE SUBMITTED THE REQUEST TO NIMSES. WHEN WILL THE RESPONSE COME?

As a rule, Nimses will process your request and will respond to it within 30 calendar days from the receipt of the corresponding request from you. In some cases, this period may be extended by two months. This might occur, for example, for technical reasons or because of big inflow of requests. You will be notified of such extension and the reasons for it within 30 calendar days from the receipt of your request.

DO I HAVE TO PAY FOR SUBMITTING MY REQUEST?

No, you don’t. Nimses accepts and processes the requests for personal data free of charge. However, if there are reasons for Nimses to believe that requests are sent unfairly, Nimses reserves the right to refuse processing such requests or to establish a reasonable fee for such processing. In any case Nimses will respond to your request within 30 calendar days.

CONTACT NIMSES

The Services, the Nimses application, and website https://nimses.com belong to Nimses Inc., located in the USA, Delaware, and its affiliates.

Nimses Inc. is a controller in relation to the personal data of users of the Services. Nimses determines what data to collect about users and for what purposes to use this data.

Should you have any questions do not hesitate to contact Nimses using following contacts:

Address: 1209, N ORANGE street, WILMINGTON, 19801, USA Phone number: (650) 288 1989 e-mail: support@nimses.com

CHANGES TO THE POLICY

In case of changes to this Policy, Nimses will notify you of this. If the changes in this Policy are significant, Nimses will do its best to inform you about the changes and to make such changes clearly introduced to you. If changes to this Policy are not significant, Nimses will notify you of such changes by posting the updated Policy on website and in the relevant section of the application.

MISCELLANEOUS

This Policy comes into force on May 25, 2018. Provided the translation of this Policy into different languages exist, the text of this Policy set out in English shall control and prevail.