Privacy and Terms
Date 22.10.2018
This privacy policy (hereinafter - the Policy) applies to all personal information, including personal data within the meaning of applicable law (hereinafter referred to as "Personal data", "Personal information"), which HotLabs LLC may receive about you when you use it. any websites, programs and / or services of HotLabs LLC (hereinafter collectively referred to as "Services"), and also during the execution of HotLabs LLC / its partners of any agreements and contracts concluded with you in connection with your use of the Services. HotLabs LLC may also receive Personal Data from its partners (hereinafter referred to as "Partners"), whose services you receive. In such cases, the transfer of Personal Data is carried out on the basis of special agreements concluded between HotLabs LLC and each of the Partners.

What is the purpose of this policy?
The protection of your Personal Information and your privacy is extremely important for HotLabs LLC. Therefore, when you use the Services, HotLabs LLC protects and processes your Personal Information in strict accordance with applicable law.

This Policy informs you:

(a) why and how HotLabs LLC uses ("processes") your Personal Information when you use the Services;
(b) what tools you can use to reduce the amount of Personal Information collected about you;
(c) what are your rights in relation to the processing of Personal Information.
  1. Personal Information We Collect
We collect Personal Information about you from various sources listed below:

Personal data provided by you

The personal information you provided when registering (creating an account) in Wi-Fi wireless networks is "Hotbot Wi-Fi" such as your first name, last name, phone number, e-mail address, and User Name in the instant messengers.

Personal data provided by our Partners

Information about you that we receive from our Partners when you use the Services in accordance with the terms of agreements concluded between you and the relevant Partner, and agreements concluded between HotLabs LLC and the Partner.

Personal data automatically transmitted to us when you use the Services

Electronic data (HTTP headers, IP address, browser identifier data, hardware and software information), information about your activity while using the Services (Chat history; email address; phone number), date and time of access to Services.
2. Ways to use your Personal Data
We may use the Personal Data obtained by us for the following purposes:

  • Provide our services, communicate with you and respond to your requests.
  • Prevent cases of fraud, unauthorized transactions, to prevent claims.
  • Ensure your interaction with us through the Services.
  • Process and fulfill your requests when using the Services.
  • Perform, evaluate and improve the quality of our work, provide you with services and information.
  • Perform data analysis (including personal data depersonalization).
  • Perform validation, search and analysis of data to ensure the operation, protection and improvement of our Services
We process your Personal Data for specified purposes in the following cases:

  • If you consent to the use of your Personal Data;
  • We need your Personal Data to ensure that you use the Services and to ensure your interaction with us through the Services;
  • We need your Personal Data to improve the work, protect the Services.
3. Providing your Personal Data to third parties
We do not pass and do not sell or otherwise disclose Personal Information we receive about you, except as specified in this Policy or the confidentiality of which we inform you at the time of data collection.

We may disclose information about you in the following cases: (i) if we are obligated to do so in accordance with the requirements of the law or a court order; (ii) to respond to a request from a court, law enforcement or government official; or (iii) if we believe that the provision of data is necessary to prevent harm to life and health or material damage, or as part of the investigation of fraud or other violations (reliably known or suspected).

In addition, we may transfer your Personal Data if we sell or transfer our company or property (in whole or in part). In the event of a sale or transfer of a company or property, we will try to oblige the person to whom we transfer the business (property) to use the Personal Data you provide in a manner consistent with this Privacy Policy.
4. Your rights and choices
You have certain rights and choices regarding what Personal Information we may receive from you, how we may use this information and how we will communicate with you.

In particular, you may do the following:

  • Withdraw your consent to the processing of your Personal Data (at any time and for free) and require the deletion of your Personal Information. The preferences you set apply to subsequent operations and do not affect the legality of data processing until the consent is withdrawn.
  • To object to the processing of your Personal Information, if it is provided for by applicable law.

In some cases, these rights may be restricted by law.

If we do not fully meet your expectations regarding the processing of your Personal Data or you want to file a complaint about how we protect the confidentiality of data, let us know, as this will allow us to fix a possible problem. For the most effective resolution of the issue, please provide a full description of the relevant circumstances. We try to consider and respond to all complaints within a reasonable time in the manner prescribed by applicable law.

You can contact us at
5. Ways to protect your Personal Data
We apply the necessary administrative, technical and physical measures to protect your Personal Data from accidental or unlawful destruction, loss, unauthorized alteration, disclosure or access, unlawful use and other illegal forms of processing of Personal Data we have.

We also try to delete your data or translate it into a form that does not allow you to establish your identity after the data are no longer required for the purposes for which we receive and process it or after receiving your request for deletion. Our corporate data retention policies have specific retention periods, and we regularly check our databases to remove unnecessary data.

In particular, when you provide us with personal data over the Internet, we use the SSL cryptographic protocol, which is the industry standard for encrypting data on the Internet, to ensure the security of the data you provide. This cryptographic protocol encrypts data transmitted from your device to our server.
6. How long is personal information stored
HotLabs LLC will store your Personal Information for as long as it is necessary to achieve the purpose for which it was collected, or to comply with legal and regulatory requirements.
7. Where personal information is stored
Your Personal Information will be stored in the Russian Federation.

HotLabs LLC records, systematizes, accumulates, stores, refines (updates, changes), retrieves personal data using databases located in the territory of the Russian Federation.
8. Changes to the Privacy Policy
To reflect changes in our privacy practices, we may make changes to this Privacy Policy.

We undertake not to make significant changes, not to impose additional burdens or restrictions on your rights established by this Policy without your notice. You will be notified of such changes. Appropriate notifications can be displayed in the Services (for example, through a pop-up window or banner) before such changes take effect, or can be sent to you via other channels of communication (for example, via e-mail, if you provided us with your contact details) .
Our contact details
You can email us at if you have any questions, comments, or complaints about this Privacy Policy or our privacy practices or you want to exercise your rights and options.