CONFIDENTIALITY RULES FOR USERS OF

BARRACUDA MESSENGER

 

  1. General.

1.1. These Rues (hereinafter the ‘Rules’) regulate relations between a titleholder, owner of mobile applications, legal entity specified in c.10.8. License Agreement,  (hereinafter the ‘Licensor’ or the ‘Company’)  and a User (Individual) – licensee (hereinafter the ‘Licenseeor ‘User’) to keep confidential, ensure protection of history of correspondence (messages,  CHATs) and other information (history of photos, images, etc.) provided by the Licensee within use of mobile application – messenger, against unauthorized access and disclosure, for devices based on Android and iOS platforms having commercial name  ‘Barracuda Messenger’ (hereinafter the  ‘Messenger’).

1.2. Subject to these Rules, the Company does NOT collect, store and/or process personal data of Users. The User agrees and instructs the Company to collect, record, accumulate, store, update, modify, extract, use, block, remove and destroy accounting and other non-personal data of the User.

1.3. Upon registration, (authorization or similar within the context) or logging in the Messenger via number of his cellular (mobile) phone earlier registered as accounting data, the User thereby gives his unconditional consent with the terms and conditions of these Rules.

1.4. Upon each access and/or actual use of the Messenger, the User agrees with the terms and conditions of these Rules and also with the terms and conditions of the License Agreement in versions which were valid at the moment (beginning) of an actual use of Messenger.

1.5. These Rules are available to all Users of the Internet at:

https://vipbarracuda.com. The Company has a right to modify the current Rules without notice.

1.6. If the User does not agree with the terms and conditions of these Rules, use of the Messenger must be immediately terminated.

 

  1. Information for Users.

2.1. Whenever the Messenger and its services are used, the Company believes that the User:

-     has necessary rights for registration and use of the Messenger;

-     understands that some types of information transferred by him to other Users cannot be removed by the User himself;

-     is acquainted with these Rules, gives his consent to them and undertakes rights and obligations set out herein.

2.2. The Company does not verify authenticity of a phone number of the User.

 

  1. Information about Users.

3.1. With a view to discharge obligations of the Company to the Users and with respect to the use of their services, the Company does no collect, process, store personal data of the User.

3.2. Accounting data of Users include number of cellular (mobile) phone only, without indication of its owner and they are not information based on which such person (subject of personal data) can be unambiguously identified and its use cannot mean collection, processing of personal data of its owner.

3.3. Registration in the Messenger is possible only via number of cellular (mobile) phone to which code of access to the application, i.e. Messenger, is sent. Registration in the Messenger is impossible via other services of the Company or services of third companies and also via Accounts in social networks.

 

  1. Extra information about Users.

4.1. The Company can process information not referred to personal data of the User such as:

 

  1. Processing of information about Users by the Company.

5.1. Accounting data (numbers of cellular phones) of Users are stored on electronic media (bases, servers) only and processed with the use of computer-aided systems except for cases when manual processing is necessary in connection with compliance with statutory requirements.

5.2. For the utmost performance of the License Agreement between the User (Licensee) and the Company (Licensor) and for providing the User with an access to the use of functional capabilities, the Company promotes the provided services and products, develops and introduces new services and products, optimizes quality of services and products, rationalizes available functional of the Messenger and its services.

 

  1. Encryption of correspondence, audio and video messages

6.1. The Messenger employs end-to-end encryption – method of data communication, when only those users participating in the communication have an access to messages. Use of end-to-end encryption does not allow third persons to gain an access to cryptographic keys. Symmetrical and asymmetrical algorithms can be applied for exchange of keys. End-to-end encryption suggests that encryption keys are known only to the parties which communicate between themselves.

6.2. Information which must be encrypted is divided into two types: data-at-rest (for instance information in a mobile device) and data-in-motion (electronic correspondence). Encryption of data-at-rest provides protection in case of loss or theft of a device. The Messenger uses both protection of data-at-rest and protection of data-in-transit. For protection of data-at-rest, it uses encryption of the whole database, while for protection of data-in-transit, in order to enhance safety, it uses a HTTP, i.e. HTTPS (Hyper Text Transfer Protocol Secure). Data in HTTPS are communicated over cryptographic protocols SSL or TLS. HTTPS is not a separate protocol.

6.3. Databases of the Messenger (server) use access control both physical (guard by man, locks, safes, etc.) and technical (electronic). Electronic access control employs computers to handle challenges connected with restrictions imposed by key-operated locks and keys.

6.4. To prevent intrusions and to monitor health status of databases, personal inter-network screen (firewall or brandmauer) is used. Firewall is software that monitors on a real-time basis activity of network (computer, server, databases, etc.) on which it is installed and also filters traffic. Personal firewall is installed directly on a protected computer, server, database, etc.

 

  1. Cookies

7.1. Cookies  are small text data files which can be placed at your device via websites which you visit. Cookies are used to provide Users with stricter safety, configurable content, etc. Messenger as a mobile application does NOT use cookies.

 

  1. Continuity. Emergency recovery.

8.1. Business continuity management (BCM) includes such notions as an ‘incident’ and ‘business continuity management and emergency recovery’ which imply any unscheduled, unexpected event leading to cessation of key, critical processes and functions, total loss of control over equipment. We undertake all necessary measures to ensure integrity, availability, continuity, authenticity of information and failure tolerance.

8.2. Time out in case of emergency situation:

Recovery Time Objective or downtime interval due to reasons attributed to the Licensor (Company) – 200 minutes.

Level of Business Continuity or acceptable productivity level (loading share) in emergency situations – above 10% of routine operations.

 

  1. Coding standards and deployment procedure.

9.1. Deployment procedure involves automation of testing of incremental modifications in software and prompt deployment of updated versions on the work platform. With operation in such mode, modifications introduced by software specialists can reach clients within mere several days.

9.2. The Company has a predetermined set of rules and agreements (Coding Standard) which describe basic principles of execution of a programme code jointly used by a group of developers. iOS version uses Swift language. Advantages of this language for IPhones: support of Cocoa and Cocoa Touch framework, compatibility with main coding base Apple written in Objective-C, simultaneous use of classic Objective-C and modified from Apple В as compared to C, Swift requires much less code. As Apple claims, it works faster than its counterparts. Android uses Java. Programs in Java are translated into Java bite code implemented by virtual Java machine (JVM), a program that processes bite code and transfers instructions to equipment how to interpret. Advantage of this method of program run is a total independence of a bite code from operating system and equipment which allows to run Java applications on any device for which there is a relevant virtual machine. Another important specific feature of Java technology is a flexible safety system within which program run is completely controlled by a virtual machine. Any operations that go beyond set powers of the program (for instance an attempted unauthorized access to data or connection with another computer) cause immediate interruption.

 

  1. Registered office and communication with Users

10.1. With respect to questions connected with compliance with these Rules please contact the legal entity at the following addresses: