CONFIDENTIALITY RULES FOR USERS OF
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 ‘Licensee’ or ‘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
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
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
1.5. These Rules are available to all Users of 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
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
- 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.
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.
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.
Extra information about Users.
4.1. The Company can process information not referred
to personal data of the User such as:
data about hardware, devices, technological interaction ( including
type of an operating system of the User;
geographic location and Internet provider;
data received as a result of access to camera, microphone and other
information automatically received upon access to the Messenger;
information received as a result of actions of the User in the
information received as a result of actions of other Users in the
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
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.
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
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
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.
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.
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
Level of Business Continuity or acceptable productivity
level (loading share) in emergency situations – above 10% of
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.
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
Bulgaria Office: Nesebr, Sveti Vlas, Vit Str., N 1,
Villa Florence complex, office 1, zip code 8256. E-mail:
Almaty City, Almaly District, Turkebayev Str., N 38, np. 32