Privacy Policy

Last updated: October 12, 2025 •
Effective date: October 12, 2025

1. Definitions

• “Mobile Application” — software (including all updates and enhancements) designed to operate on smartphones, tablets, and other mobile devices on specific platforms (iOS, Android).
• “User” — a natural or legal person that has installed the Mobile Application on a device and/or activated it.
• “Rightsholder / Controller (GDPR) / Operator (152-FZ)” — the person/entity that holds the exclusive rights to the Mobile Application and determines the purposes and means of processing personal data. For the purposes of this Policy, such person is the owner of east173.com. Contact: privacy@east173.com.
• “Personal Data” — any information relating to an identified or identifiable natural person, including data provided by the User to the Rightsholder and/or automatically collected by the Mobile Application.
• “User Agreement” — the agreement between the Rightsholder and the User on the terms of use of the Mobile Application (an adhesion contract without the User’s right to make amendments).

2. General Provisions (Scope and Acceptance)
2.1. This Policy applies only to the Mobile Application. It does not extend to third-party websites, applications, or services that may be accessed via links within the Application.
2.2. By installing, accessing, or using the Mobile Application, the User unconditionally accepts this Policy and consents to the processing of their personal data as described below. If the User disagrees, they must refrain from using the Application and delete it.
2.3. As a rule, the Application does not verify the accuracy of data provided by Users and assumes such data is current, sufficient, and accurate.

3. Purposes of Processing
3.1. We collect and process only the personal data necessary to provide and improve the services, except where other retention periods and obligations are mandated by law.
3.2. Personal data is processed for:
3.2.1. Identification and authentication of the User, providing access to features and data in the Application.
3.2.2. Provision of personalized resources and in-app content.
3.2.3. Communication and support: usage notifications, responses to inquiries, handling requests and incidents.
3.2.4. Verification of data accuracy for security and compliance purposes.
3.2.5. Technical maintenance and improvement: diagnostics, performance monitoring, troubleshooting.

Legal bases (where applicable): performance of a contract (provision of the Application/services), legitimate interests (e.g., Application security and improvement), consent (e.g., optional permissions/analytics/marketing), and compliance with legal obligations.


4. What Data We Process

• Data provided by the User: account or profile data, contact details (name, email, phone), contents of support requests, preferences.
• Automatically collected data: device identifiers (e.g., IDFV/Android ID; where used — Advertising ID), IP address (which may indicate approximate location), OS and device model, language, time zone, app version, in-app events, crash logs, diagnostic and operational metrics.
• Location data (if enabled): approximate or precise location required to provide specific features; access can be disabled in device settings.
• Media and files (when using the relevant features): access to camera, photos, microphone, files — strictly to perform selected actions; permissions can be revoked in device settings.
• Notifications: device token for push notifications (can be disabled in settings).
• Payments (if applicable): receipts and transaction metadata from Apple App Store / Google Play for entitlement management; we do not receive full payment card data.
• Data from third parties: when connecting external accounts/services — to the extent you authorize.

5. Conditions of Processing and Disclosure to Third Parties
5.1. Personal data is treated as confidential, except where the User deliberately makes it public (e.g., by posting content in open sections).
5.2. Processing is carried out by lawful means, with or without automation, for no longer than necessary for the stated purposes.
5.3. We may disclose data to:

• Service providers (hosting, analytics, crash reporting, support, push notifications, email delivery) under agreements that ensure data protection.
• Professional advisers and competent authorities where required by law or to protect rights and safety.
• In corporate changes — in connection with a merger, acquisition, or asset sale.

6. Cross-Border Transfer
Data may be processed and stored outside your country. Where necessary, lawful transfer mechanisms are used (e.g., EU Standard Contractual Clauses) and a transfer impact assessment is performed.

7. Data Retention
We retain personal data only as long as necessary for the purposes described above or to comply with legal obligations and resolve disputes. Examples: support inquiries — up to 24 months; analytics/crash logs — per provider settings or until you opt out; account data — while the account is active and for a reasonable period thereafter.

8. Security
We apply organizational and technical measures proportionate to the risks (access control, encryption in transit, environment segregation, backups, least-privilege). No method of transmission or storage is absolutely secure.

9. User Obligations
9.1. The User shall:
9.1.1. Provide the data necessary to use the Application.
9.1.2. Keep the data current and accurate.


10. Rightsholder/Operator Obligations
10.1. The Rightsholder/Operator shall:
10.1.1. Use the data strictly for the purposes stated in this Policy.
10.1.2. Ensure confidentiality and not disclose data without the User’s prior consent, except as provided by this Policy or by law.
10.1.3. Take necessary measures to protect data from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, and other unlawful actions.

11. Data Subject Rights and How to Exercise Them
Depending on your jurisdiction, you may have rights to access, rectification, erasure, restriction, objection, data portability, and the right to withdraw consent at any time.

• EEA/UK (GDPR): you also have the right to lodge a complaint with a supervisory authority.
• USA (state laws, incl. California/CPRA): rights to access/correct/delete and to opt out of targeted advertising, the “sale”/“sharing” of personal information, and certain profiling.
• Russia (where applicable): processing may be carried out in accordance with Federal Law No. 152-FZ “On Personal Data”; rights provided therein apply.

How to submit a request: write to privacy@east173.com. We may request identity verification and will respond within the timeframes required by applicable law.

12. Children
The Application is not intended for children under 13 (or under 16 in the EEA/UK). We do not knowingly collect children’s data. If you believe a child has provided data, please contact us to have it deleted.

13. Security Incident Notification
If a personal data incident occurs that may entail risks to rights and freedoms, we will notify you and/or regulators as required by applicable law.


14. Liability
14.1. The Rightsholder/Operator that has failed to fulfill its obligations may be liable for losses incurred by the User due to unlawful use of personal data, in accordance with applicable law.
14.2. The Rightsholder/Operator is not liable where the confidential information:
14.2.1. Became public before its loss or disclosure;
14.2.2. Was obtained from a third party before receipt by the Rightsholder/Operator;
14.2.3. Was disclosed with the User’s consent.


15. Dispute Resolution and Governing Law
15.1. Pre-trial procedure: before filing a lawsuit, a written claim for voluntary settlement must be submitted.
15.2. The addressee shall respond within 10 (ten) calendar days from the date of receipt of the claim.
15.3. If no agreement is reached, the dispute shall be considered by a competent court in accordance with the law of the Russian Federation.
15.4. Mandatory consumer protection rules of your country of residence may apply in any case.

16. Changes to this Policy
We may update the Policy from time to time. The updated version is posted in the Application (and on east173.com) with an adjusted “Last updated” date. If changes are material, additional notice may be provided.


17. Contacts
Email: privacy@east173.com


Disclosure for store listings (Apple/Google)
The Application may request the following permissions: Camera, Photos/Media, Microphone, Location (approximate/precise), Bluetooth, Notifications, Device identifier, Diagnostics/crash logs. All permissions are used solely to enable app features; you can revoke them in your device settings.

California Notice at Collection
We collect the categories of personal information described in Sections 4–5 for the purposes in Section 3 and retain them as stated in Section 7. Disclosure of personal information to third parties is carried out under Section 5. We do not knowingly sell/share the personal information of consumers under 16. To opt out of “sale”/“sharing” or targeted advertising (if applicable), use the options described in Section 11.