文件
Privacy Policy
本文档目前仅提供英文版本。
This policy explains what personal data the Цитата service processes, why and on what legal basis, who can see it, how long it is kept and what rights you have. We collect only what the service needs to work and never use your data for advertising.
Details in square brackets will be filled in before the service launches.
1. Who is responsible for your data
Data controller: [CONTROLLER NAME], [CONTROLLER ADDRESS].
For any questions about personal data, write to [DATA PROTECTION CONTACT EMAIL]. [DATA PROTECTION OFFICER CONTACT DETAILS, IF APPOINTED].
2. What data we process
- Account: email address, password (stored only as an irreversible hash), display name, native language, registration date, roles, notification email settings, date and version of the accepted Terms of Use.
- Your content: words in your personal vocabulary with translations and context sentences, chapter notes (private and public), annotations to passages of text and your “useful” votes for other readers' annotations, saved quotes (the passage, work, chapter and date), clubs you created, club memberships and applications, club notes, club bookmarks, reports you submitted.
- Reading: your reading position in works and reader settings (font size and theme) - in your profile if you are signed in, or in your browser if you allowed functional cookies.
- Moderation: reports about your content together with the text at the time of the report, moderators' decisions, date and reason of a block, hiding of your display name.
- Applications from authors and rights holders (the “For authors” section): name, email address, other contact details, information about the work and the rights to it, interface language at the time of the application, the application status and administrators' notes on it.
- Technical data: IP addresses and request details are used to limit request rates and prevent abuse, and they appear in server logs.
- Traffic statistics: the address of the page you opened without parameters, the day, the site language, your browser's main language, the device type (computer, tablet or phone) and the referral source - the domain of the site you came from or the campaign tag in the link. IP addresses, the browser User-Agent, cookies and identifiers are not stored in the statistics, and the records are linked neither to an account nor to each other, so they cannot show who read what. If you allowed functional cookies, a record also carries a "first visit of the day", "started reading a work" or "first opened a chapter" mark based on data that is kept only in your browser.
3. Why and on what legal basis
- Your account and the service features (reader, vocabulary, notes, clubs) - performance of the Terms of Use (Art. 6(1)(b) GDPR).
- Emails confirming your address, resetting or changing your password and confirming account deletion, as well as club notifications (new applications, club membership updates, new notes) - performance of the Terms of Use (Art. 6(1)(b) GDPR). You can turn club notifications off in your profile or with the link in any such email.
- Security, protection against spam and abuse, content moderation, request rate limits - legitimate interest in running the service safely and fairly (Art. 6(1)(f) GDPR).
- Reviewing applications from authors and rights holders and corresponding about them - steps taken at the applicant's request before entering into a contract (Art. 6(1)(b) GDPR).
- Functional cookies and browser storage - your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time.
- Traffic statistics without identifiers (page views, popular works, languages, referral sources, devices) - legitimate interest in developing the catalogue and the service (Art. 6(1)(f) GDPR). The browser marks used to count visitors and reading depth - only with your consent (Art. 6(1)(a) GDPR).
- Compliance with the law - the controller's legal obligation (Art. 6(1)(c) GDPR) [LIST OF APPLICABLE REQUIREMENTS].
No decisions about you are made automatically: reports are reviewed, and decisions to hide content or block accounts are made, by human moderators. Automatic limits (on the number of notes, clubs and requests) are the same for everyone and do not assess individuals.
4. What other users can see
- Your display name is shown next to your public chapter notes and annotations - to any visitor of the site, including visitors who are not signed in; annotations by users with the native speaker role are marked as such. If you do not want to show your name, keep your notes private or choose a neutral display name in your profile. Who voted for an annotation is not shown to others - only the total count is.
- A club's name, description and creator's name are visible to all visitors.
- Club members can see your name, bookmark colour, the chapter you are reading and your club notes. A club's creator can see the names of applicants.
- Private notes, your vocabulary, saved quotes, reading position and email address are not shown to other users. Only the service administrators can see email addresses.
- Your quotes count towards a work's total number of quotations, which is visible to all visitors - without names and without the text of the quotes.
- If a moderator has hidden your display name, other users see an anonymous label instead.
5. Moderation
Users can report a public note, a club note or a club. A report keeps the text as it was when the report was submitted, so a moderator can see what was reported even if the text was changed later. A moderator can hide content - in response to a report or on their own if they notice a violation - hide a display name and block an account. All of these measures can be reversed, and decisions on content are kept in the moderation history.
A blocked user can see the reason for the block and sign in in restricted mode to download their data and delete their account. A block restricts behaviour on the service, not the rights to your own data.
6. External API partners
If you apply for access to the catalogue API (the “For developers” section), we additionally process:
- App details: name, description, website, organisation, requested and assigned rate limit tier, application date and the version of the API terms of use you accepted.
- Access data: the client identifier (client_id). The app secret and access tokens are stored only as an irreversible hash (SHA-256); the secret itself is shown once when created and is not kept by us.
- Administrator decisions: the app state, access term, reason for rejection, suspension or revocation, the date of the decision and who made it, internal administrator notes.
- App request statistics: the number of requests by day, endpoint and response code, and the time of the last request. IP addresses and request contents are not included in these statistics.
Purposes: reviewing the application, granting and checking access, enforcing rate limits and the API terms of use, emails to the app owner (administrator decisions, reminders 30 and 7 days before access ends). Legal basis: [LEGAL BASIS - FOR EXAMPLE, PERFORMANCE OF A CONTRACT: THE API TERMS OF USE].
App data is visible only to its owner and to administrators. Apps are included in the data export from your profile and are deleted together with the account. Request statistics are kept for 13 months; expired tokens are deleted automatically. Rejected and revoked applications are kept for [RETENTION PERIOD FOR PARTNER APPLICATIONS] unless the account is deleted earlier.
8. Who receives your data
We do not sell data or share it for advertising. Data is processed only by contractors the service cannot work without, under data processing agreements:
- Hosting: [PROVIDER NAME, COUNTRY OF HOSTING].
- Email delivery: [EMAIL SERVICE NAME, COUNTRY].
- Traffic protection and delivery: [SERVICE NAME, COUNTRY - ONCE CONNECTED].
Transfers outside the European Economic Area: [STATE WHETHER THERE ARE ANY AND THEIR SAFEGUARDS - FOR EXAMPLE, STANDARD CONTRACTUAL CLAUSES].
Data may be disclosed to public authorities only in the cases and in the manner required by law.
9. How long we keep data
- Your account and content are kept as long as the account exists. When you delete your account, they are deleted immediately.
- Emails wait in the sending queue until they are sent; an email that could not be sent after 8 attempts is deleted after 14 days. When you delete your account, unsent emails are deleted immediately, except the email confirming the deletion.
- Applications from authors and rights holders are kept for [AUTHOR APPLICATION RETENTION PERIOD]; at the applicant's request an application is deleted earlier. An application submitted from an account stays, without a link to it, when the account is deleted.
- When you delete your account, moderation records are kept in anonymised form: reports you submitted and moderators' decisions no longer link to you (the target, reason, comment and decision are kept), and in reports about your content the text is erased as well. These records are kept for [MODERATION RECORD RETENTION PERIOD].
- Server logs are kept for [LOG RETENTION PERIOD].
- Traffic statistics records are kept for 25 months and then deleted automatically.
- Database backups are kept for [BACKUP RETENTION PERIOD], after which deleted data disappears from them as well.
10. Your rights
- Access and portability: you can download all your data as a single JSON file in your profile.
- Rectification: you can change your name and native language in your profile; to change your email address, write to [DATA PROTECTION CONTACT EMAIL].
- Erasure: you can delete your account with all its data in your profile. This is also available while your account is blocked.
- Withdrawing consent: use the "Cookie settings" link at the bottom of every page.
- Restriction of processing and objection to processing based on legitimate interest: write to [DATA PROTECTION CONTACT EMAIL].
- Complaint to a supervisory authority: [SUPERVISORY AUTHORITY OF THE CONTROLLER'S LOCATION] or the data protection authority of your country.
We respond to requests within one month. To protect your data, we may ask you to confirm that the request comes from the account owner.
11. Age
The service is intended for users aged 16 and over. Some EU countries set a lower age from which people can use online services on their own (13 to 15), but the service applies a single threshold of 16 for everyone. If we learn that an account was created by someone under 16, the account will be deleted.
12. Data security
Passwords are stored only as hashes, access to data is limited by roles, requests are protected against forgery, and the rate of sign-in attempts and other sensitive actions is limited. The connection to the site is encrypted [HTTPS - AFTER LAUNCH].
13. Changes to this policy
The version date is shown at the top of this document. We will notify you in advance about significant changes [NOTIFICATION METHOD - FOR EXAMPLE, BY EMAIL OR ON THE SITE].
14. Contact
[CONTROLLER NAME], [CONTROLLER ADDRESS], [DATA PROTECTION CONTACT EMAIL].