Privacy Policy



"Law" means the Federal Law of the Russian Federation "On Personal Data" with all amendments and additions, as well as other legislative acts of the Russian Federation.

"Controller" means the person who is responsible for the processing and protection of Personal Data of Users located within the EU within the meaning of the General Data Protection Regulation of 27 April 2016 (the "GDRP"). and additions, as well as other legislative acts of the Russian Federation.

"Mobile App" means software (with all existing add-ons and enhancements) designed to run on smartphones, tablets, watches and other mobile devices, and designed for a specific platform (iOS, Android, Windows Phone, etc.). For purposes of this Policy, Mobile Application means the following software: ALGEM.

"Website" - a set of graphic and informational materials, as well as programs for computers and databases, making them available on the Internet at the network address ALGEM.IO

"Personal Data" means any information (IP address, MAC address, cookies, etc.) relating to a directly or indirectly identified or identifiable individual (the subject of the personal data).

"Policy" means this Mobile App Privacy Policy (as supplemented and amended from time to time).

"User" means an entity or individual who has downloaded a Mobile App to a smartphone, tablet, watch or any other mobile device and/or has activated such Mobile App on one of said devices.

"User Agreement" means an agreement between the Operator and the User regarding the procedure, rules and peculiarities of the User's use of the application. The User joins such agreement and has no right to make and/or demand any changes or additions to it.

"Operator" means a state body, municipal authority, legal entity or individual, independently or together with other persons, organizing and (or) performing the processing of personal data, as well as determining the purpose of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

Algem Labs LTD

"Processor" means the person who, according to the GDRP, performs the storage and/or processing of Personal Data received from Users on behalf of the Controller.


General provisions

This Policy applies only to Personal Information received from Users in connection with their use of the Application. The provisions of this Policy are intended to:

(1) determining the types and types of Personal Data obtained, the uses and purposes for which Personal Data are used (processed), and the sources from which such Personal Data are obtained; and

(2) defining the User's rights with respect to the protection of the confidentiality of the Personal Data that he or she transmits; and

(3) determination of the persons responsible for the processing and storage of Personal Data, as well as of the third parties to whom such data are disclosed (in whole or in part).

The rules of this Policy do not apply if third parties process Personal Data that is voluntarily provided by the User.

By installing and/or activating the mobile application on a smartphone, tablet, watch or other mobile device, the User agrees to the terms of this Policy and gives its consent to the Operator to do the following with the User's Personal Data:

(1) collection

(2) entry

(3) storage

(4) systematization

(5) accumulation

(6) clarification (update, change)

(7) extraction

(8) transmission (distribution, provision, access)

(9) depersonalization

(10) blocking

(11) removal

(12) destruction

If the User does not agree with the terms of the Policy and/or some terms of the Policy are not clear to him/her, in this case the User is obliged to stop using the application immediately.

User rights to protect personal data

In connection with the provision of Personal Data, the User automatically receives the following rights:

(1) to obtain data concerning their processing (grounds and purposes of such processing, the methods of processing used, information on the persons who have access to them or to whom they may be disclosed on the basis of a contract or the Act).

(2) obtain data on the location and identity of the persons processing Personal Data.

(3) obtain data on the retention period of Personal Data.

(4) to obtain data on transborder transfers of Personal Data made or suspected to have been made.

(5) to appeal actions or omissions of the Operator to the authorized body for the protection of the rights of subjects of personal data or in court.

(6) receive compensation for losses and/or compensation for moral damages in court as a result of violations of the Operator's rights to protection of his Personal Data by the Operator and/or third parties.

(7) exercise other rights in the field of personal data protection, as provided by law or the provisions of this Policy.


Personal information about users

The Operator does not collect any personal data about Users, which allows to identify it.

Using cookies

This Application uses certain Cookies to store the IP address, User preferences, or the type of device used from the site. The Application may use both Operator's own cookies and third party cookies.

The User has the right to disable cookies in the Mobile App at any time by changing certain settings on their smartphone, tablet, watch or other mobile device. Such disabling may result in limiting or changing the User's access to the functionality and/or content of the Mobile App. To disable Cookie Files, follow these steps:

prescribe the procedure for changing/disabling cookies

Using tokens

Tokens (digital product of ALGEM system) cannot be used to identify the User. The Operator is not responsible for the User's disclosure of information about their possession of tokens and the subsequent identification of the User by third parties.


Defining processing goals

Personal Data is collected and processed for the following purposes:

(1) analyzing User behavior, as well as identifying User preferences for certain types of content.

(2) prompt and correct operation of the Mobile Application, improvement of the functioning of the Mobile Application, improvement of the content of the Mobile Application, improvement of the internal architecture and functionality of the Mobile Application.

(3) compliance with the requirements of the Act.

(4) technical support for the Mobile Application, identifying problems in its operation and fixing them.

(5) maintaining communication with the User (communication).

(6) performance of other obligations of the Operator, which have arisen to the User.

(7) any other purposes, subject to the separate consent of the User.

Processing of Personal Data shall be based on the principles of (1) lawfulness of the purposes and methods of processing; and (2) good faith; and (3) compliance of the purposes of Personal Data processing with the purposes predetermined and stated when collecting such Personal Data; and (4) compliance of the amount and nature of Personal Data processed with the stated purposes of their processing.

Terms of personal data processing

Processing of Personal Data shall be carried out when:(1) obtaining consent from the User; or (2) the Operator achieves the purposes stipulated by an international treaty or the Law; or (3) the User provides its Personal Data to an unlimited number of people; or (4) the Operator fulfills other obligations to the User, including, but not limited to, providing certain content to the User.

In the case of depersonalization of Personal Data, which does not directly or indirectly identify the User, the subsequent use and disclosure of such data to third parties is allowed and the rules of this Policy no longer apply to them.

The Operator shall take all possible measures to protect the confidentiality of Personal Data received, except in cases where the User has made such data publicly available.

Processing of Personal Data shall be carried out with or without the use of automated means.


Using analytical platforms

The Operator uses the Google Analytics platform to (1) track the frequency of Users' visits to the Website; and (2) track how the User uses the Mobile App and/or its content; and (3) identify the type and type of content that is popular among Users. The User also consents to the Operator's use of the information obtained about the User from Google Analytics.

For these purposes, the Google Analytics platform may collect data about the User's IP address, geolocation, behavior, as well as their preferences and interest in certain content.

The Google Analytics platform gets access to Personal Data in order to provide the Operator with an understanding of how effective its Mobile App is, what kind of content is popular, how effective the placement of certain advertisements in it is, and also for the purpose of developing and/or improving the Operator's existing marketing strategy.

By installing the Mobile App, the User agrees to the Privacy Policy (Privacy Policy) of Google Analytics, as well as to the automatic installation of appropriate Cookies on the User's device.

Disclosure of personal data to third parties

The Operator shall be entitled to disclose Personal Data (1) to its affiliates, branches and representative offices opened both in the Russian Federation and in other countries; (2) to successors of the Operator, which emerged as a result of its liquidation, reorganization or bankruptcy, and which obtained exclusive rights to the Mobile application; (3) to state bodies, officials and their representatives, if they send a corresponding request in accordance with the requirements of international agreements.

The Operator does not disclose Personal Data to third parties and is not responsible for the disclosure of Personal Data by the User.


Advertising in a mobile app

The Operator may place various advertising materials on mobile "ALGEM" platforms. Advertising materials cannot be used to identify the User. Advertisers do not get access to the User's Personal Data. The Operator is not responsible for the content of advertising materials placed on the "ALGEM" mobile application platform.

The user may opt out of such advertising at any time in the following way:



Request to stop processing of personal data

Each User has the right to object to the processing and/or storage of his Personal Data by the Operator. Such an objection may be expressed as follows:


Request for information on personal data

If the User has any questions related to the manner of application or use of this Policy, the manner and/or method of processing of Personal Data, the User may ask such question as follows:


Change (update, addition, correction) or deletion of personal data

The User has the right to change or delete his Personal Data at an time independently, except when such change or deletion may lead (1) to a violation of the rules of this Policy; or (2) to a violation of the Law; (3) the nature of such Personal Data is evidence in any litigation arising between the Operator and the User.

The User has the right to change or delete their Personal Data in the following manner:



Storage is performed independently by the Operator.

The storage is for as long as is necessary to achieve the stated purposes of processing Personal Data.

The operator undertakes to destroy or anonymize the Personal Data immediately after achieving the purpose of processing the Personal Data.


Users in the Russian Federation

Use of the Mobile App is intended for individuals over the age of 18.

If the User is a minor, the User must immediately stop using this Mobile App.

Users in the European Union

Use of the Mobile App is intended for individuals 16 years of age or older.

If the Operator becomes aware that the User's age does not correspond to the permissible age for using the Mobile application, in such case the Operator undertakes to immediately block such User's access to the Mobile application.


Protecting the confidentiality of Personal Data is paramount and important to the Operator. The Operator adheres to all required international standards, rules and recommendations for the protection of Personal Data.

The operator has implemented a number of technical and organizational methods to protect Personal Data from disclosure or unauthorized access to it by third parties.


General provisions

Since the Mobile App is accessible to users from the European Union, the Operator undertakes to additionally adhere to the GDRP provisions.

The controller within the meaning of this Policy is the Operator.

The Operator shall store Personal Data for a reasonable period necessary to achieve the purposes of processing, but not less than the period prescribed by the local legislation of the Member State of the European Union in whose territory the Mobile application is available, for the storage of any type of Personal Data. Upon expiry of the retention period, the Operator undertakes to immediately destroy or anonymize such data.

Official representative

Since the Controller is located outside the territory of the European Union, the following person is designated as its official representative for the protection of Personal Data of Users in the European Union: Russia, address: Rostov-on-Don, contact details: https://discord.gg/xXpYCnUJ

User rights to personal data protection

Under Chapter 3 of the GDRP, users within the European Union have the following rights with respect to the protection of Personal Data:(1) the right to be informed of their Personal Data; and (2) the right of access to their Personal Data; and (3) the right to rectification of Personal Data; (4) the right to erasure of Personal Data; and (5) the right to restrict processing of Personal Data; and (6) the right to transfer Personal Data to third parties; and (7) the right to object. https://discord.gg/xXpYCnUJ


Availability of the text of the policy for review

Users can read the terms of this Policy at the following link: https://algem.io/privacy-policy/

This Policy may be translated into a foreign language for those Users who access the Application outside the Russian Federation. In the event of a discrepancy between the text of the original (Russian language) and its translation, the original language shall prevail.

This revision of the Policy is effective from 13.05.2022.

Policy changes and additions

This Policy may be changed from time to time. The Operator shall not be liable to the User for changing the terms of this Policy without the User's permission and/or consent.

The User undertakes to check the provisions of this Policy on a regular basis for possible changes or additions.

Applicable law

This Policy was developed in accordance with the current legislation on personal data protection of the Russian Federation, in particular, with the provisions of the Federal Law of July 27, 2006 № 152-ФЗ "On Personal Data" (with all additions and amendments), the Federal Law of July 21, 2014 № 242-ФЗ "On amendments to certain legislative acts of the Russian Federation in terms of clarifying the processing of personal data in information and telecommunications networks" (with all additions and amendments), as well as provisions of the General Regulations

Risk of disclosure

Regardless of the measures taken by the Operator to protect the confidentiality of Personal Data received, the User is hereby deemed to be duly informed that any transmission of Personal Data on the Internet cannot be guaranteed to be secure, and therefore the User makes such transmission at its own risk.