PRIVACY POLICY
(Last Updated July 27, 2018)


SPair Ltd, doing business as iTourer (www.wifiinrussia.com, www.itourer.ru), recognizes the importance of your privacy. This privacy policy tells you what personal information we collect and how we use it. iTourer may change this privacy policy from time to time, in its sole discretion, as discussed in section '8. Changes to This Policy' below. By registering or otherwise using or visiting any iTourer website, application, product, software, tool, data feed, and/ or service (collectively the "Service"), you understand and agree to the terms of this policy. Please read this policy carefully.

This Privacy Policy was written in English and may be translated to other languages solely for the convenience of our Site Visitors. In all cases and specifically if a potential conflict between versions arises, the English version of this Privacy Policy controls.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us directly at support@itourer.ru or find more information under section '6. How Does A User Change Or Update Information'.

iTourer is committed to your privacy. This privacy notice explains how we collect, use, disclose, retain, and protect your personal information.

A few key principles regarding GDPR

§ A clear purpose: the controller must specifically inform the customer of the use he will make of his personal data by collecting them

§ Relevant data: the controller must only collect data that is strictly necessary for his treatment; this is the principle of minimizing collection

§ The retention period: the personal data must be kept enough time to the controller to achieve its purpose; beyond that time, the data must be deleted

§ The rights of individuals: individuals can exercise their rights over the personal data held by the controller: access, rectification or deletion

1. What Information Do We Collect?

1.1 Personally-Identifiable Information

We may collect personally identifiable information when you specifically and knowingly provide it to us, for example when you state your name, create an account, request more information on our 'Contact us page', respond to a survey or questionnaire and provide personal information such as your email address, name, phone number or other information. Where applicable, personally identifiable information includes personal data as defined in applicable law.

This Privacy Policy does not apply to the privacy practices of third parties that we do not own or control, including but not limited to any third party websites, services, applications, online resources to which this Site may link or otherwise reference.

iTourer does not consider personally identifiable information to include information that has been anonymized so that it does not allow a third party to identify a specific individual. We collect and use your personally identifiable information to provide the services, operate and improve our service, provide customer service, perform research and analysis aimed at improving our products, service and technology, and display content that is customized to your interests and preferences.

You may always choose not to provide personally identifiable information, but if you choose so, certain parts of the Service may not be available to you. If you have registered an account with us, you will have agreed to provide your personally identifiable information in order to access the services. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this policy, please do not use our Services.

1.2 Sensitive Personal Data

Subject to the following paragraph, we ask that you do not send us, and you do not disclose, any sensitive personal data (such as social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services or otherwise to us.

If you send or disclose any sensitive personal data to us when you submit content to the services, you consent to our processing and use of such sensitive personal data in accordance with this policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such content to us. Please note that even if you have provided such information, we will not store them anywhere on our side.

1.3 Non-Personally-Identifiable Information

We may collect and aggregate non-personally identifiable information which is information which does not permit you to be identified or identifiable either by itself or in combination with other information available to a third party. This information may include information such as a website that referred you to us, your IP address, browser type and language, hardware types, geographic location, and access times and durations. We also may collect navigational information, including information about the service content or pages you view, the links you click, and other actions taken in connection with the service. We use this information to analyze usage patterns as part of making improvements to the Service.

1.4 Cookies, Pixels and Local Storage

We may collect information using cookies, which are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience when using the Services.

We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which are used only by us to recognize your computer or mobile device when it revisits any site or application that is party of the Services; and (2) third party cookies, which are served by service providers on sites or applications and can be used by such service providers to recognize your computer or mobile device when it visits other websites.

2. What Do We Do With The Information That We Collect?

Except as disclosed in this privacy policy, iTourer does not share your personal information with any outside parties.

iTourer will use the personally identifiable information directly provided by you solely for the purpose for which you have provided it, which may include:

§ to operate, maintain, and improve the Services;

§ to manage your account, including to communicate with you regarding your account;

§ to operate and administer any promotions you participate in on any site or application;

§ to respond to your comments and questions and to provide customer service;

§ to send information including technical notices, updates, security alerts, and support and administrative messages;

§ with your consent, to send you marketing emails about upcoming promotions, and other news, including information about products and services offered by us and our affiliates. We retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products or services, such as when you last opened an email from us. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

§ You may opt-out of receiving such information at any time: such marketing emails tell you how to opt-out. Please note, even if you opt out of receiving marketing emails, we may still send you non-marketing emails. Non-marketing emails include emails about your account with us (if you have one) and our business dealings with you;

§ to process payments you make via the Services;and as we believe necessary or appropriate (a) to comply with applicable laws; (b) to comply with lawful requests and legal process, including to respond to requests from public and government authorities; (c) to enforce our Policy; and (d) to protect our rights, privacy, safety or property, and/or that of you or others.

We may share this information with service providers who perform services on our behalf, such as those services listed above, or other services like processing information requests, displaying stored data you access, to assist us in marketing, to conduct audits, etc. Those companies will be permitted to obtain only the personal information they need to provide the service they provide, will be required to maintain the confidentiality of the information, and will be prohibited from using it for any other purpose.

We will only retain your personally identifiable information as long as reasonably required to provide you with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes). iTourer will provide you with information about iTourer's data and how it will be used upon request. Should your data stored by iTourer be incorrect, iTourer will correct it. In this regard, you can write to iTourer at the address listed in section '6. How Does A User Change Or Update Information' or contact them in any other way. In addition, customers can view the data in their account that iTourer has stored about them and correct it if necessary.

You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) our collection of sensitive personal data; (iii) any new processing of your personal data that we may carry out beyond the original purpose. Please note that your use of some of the Services may be ineffective upon opt-out. You may also: (A) access the data we hold about you at any time via your account or by contacting us directly; (B) update or correct any inaccuracies in your personal data by contacting us; (C) in certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we delete your data. You may contact us at support@itourer.ru anytime for any other questions you may have about your personally identifiable information and our use of it.

3. Disclosure

As a general rule, iTourer will not disclose any of your personally identifiable information except under one of the following circumstances:

§ we have your request or permission, including the permission granted by your acceptance of this Privacy Policy;

§ we determine in good faith that it is legally required to be revealed by any relevant statute, regulation, ordinance, rule, administrative or court order, decree, or subpoena;

§ it is information that we determine must be disclosed to correct what we believe to be false or misleading information or to address activities that we believe to be manipulative, deceptive or otherwise a violation of law; where you are otherwise notified at the time we collect the data; where we need to share your information to provide the product or service you have requested;

§ when such disclosure is made subject to confidentiality restrictions in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by iTourer. iTourer may share the non-personally identifiable information that iTourer gathers, in aggregate form only, with advertisers and other partners.

4. Children's Policy

The Terms of service clearly provide that Users must be (i) 18 or older, or (ii) 13 and older if either (a) an emancipated minor, or (b) he/she possess legal parental or guardian consent. iTourer does not knowingly collect personally identifiable information from users under 13. In the event that we learn that we have collected any personal information from a user under the age of 13, we will attempt to identify and delete that information from our database.

5. International Usage

The Service is owned by iTourer and may be accessed in Russia and abroad. For data protection purposes, iTourer is the controller and, unless otherwise noted, is also the processor of data. Information collected may be retained, and may be stored, processed, accessed, and used in jurisdictions whose privacy laws may be different and less protective than those of your home jurisdiction.

iTourer has also contracted with third party service providers to manage the logistics and customer support for an optimal 24/7 service. Some data needs to be disclosed and transferred to these third parties to ensure the fulfillment of the service. All third party involved have been engaged under a binding confidentiality agreement and have a limited access to iTourer database for the purposes of providing support.

6. How Does A User Change Or Update Information?

If you have any questions or concerns about this privacy policy or would like the personally identifiable information that you have provided to be removed from our files, please contact iTourer via email at support@itourer.ru.



7. Security and Encryption

We follow generally accepted industry standards to help protect your personal information. No method of transmission over the internet, mobile technology, or method of electronic storage, is completely secure. Therefore, while we endeavor to maintain physical, electronic, and procedural safeguards to protect the confidentiality of the information that we collect online, we cannot guarantee its absolute security. Our service has security measures in place designed to protect against the loss, misuse and alteration of the information under our control. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All service information is maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords. You are responsible to keep your password secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at support@itourer.ru.

8. Changes to This Policy

We reserve the right to change the terms of this privacy policy at any time. When we make changes, we will revise the last updated date at the top of the policy. If there are material changes to this statement or in how we will use your personal information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you an email. We encourage you to review this policy whenever you visit one of our websites or applications.