1. General Provisions
1.1. This personal data processing policy has been drawn up in accordance with the requirements of the current applicable legislation on personal data and determines the procedure for processing personal data and measures to ensure the security of personal data taken by the LEMONAD Partner Network (hereinafter – the “Personal Data Operator” or “Operator”).
1.2. The operator of personal data seeks to maintain the inviolability of personal information and the confidentiality of personal data of users of the Lemonad application and / or visitors to the website http://limonad.com (hereinafter – the “Personal Data Subject”), in accordance with applicable law.
1.3. By downloading our website on your computer, mobile device or using a mobile application, as well as filling out web forms containing your personal data and registering as a user and / or transferring your personal data in another way, you voluntarily provide your unconditional, informed and conscious consent to the collection, processing, storage, use and possible subsequent transfer of your personal data to an indefinite circle of persons (distribution of personal data) provided in connection with registration on the Site and the use of its services under the conditions described in this Policy for the processing and protection of personal data (hereinafter – “Policy”).
1.4. This Policy applies to the processing of personal data of the Personal Data Subject by the Operator using automation tools, including using information and telecommunication networks, and without using such tools.
1.5. The operator of personal data applies the required security measures to ensure the confidentiality of the personal data of the Subject of personal data from loss, theft, unauthorized access, misuse, alteration or destruction.
1.6. The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
1.7. This Policy regarding the processing of personal data applies to all information that the Operator can receive from the Subject of personal data.
ATTENTION! The operator of personal data assumes that the Subject of personal data acts in good faith, prudently, provides reliable and sufficient personal information and makes every effort to keep such information up to date.
2. Basic concepts used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology;
2.2. Blocking of personal data – temporary termination of the processing of personal data (except in cases where processing is necessary to clarify personal data);
2.3. Website – a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address http://limonad.com;
2.4. Information system of personal data – a set of personal data contained in databases, and providing their processing of information technologies and technical means;
2.5. Depersonalization of personal data – actions as a result of which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other subject of personal data;
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
2.7. Personal Data Operator – LEMONAD Affiliate Network.
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable individual (subject of personal data) – the user of the website http://limonad.com;
2.9. Personal data subject – an individual (user of services, subscriber, visitor of the website http://limonad.com, user of the Lemonad application), to whom the processed personal data belongs.
2.10. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons;
2.11. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data permitted by the subject of personal data for dissemination) or to familiarize with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, posting in information and telecommunication networks or providing access to personal data in any other way;
2.12. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign individual or foreign legal entity;
2.13. Destruction of personal data – any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and (or) the material carriers of personal data are destroyed.
3. The operator of personal data has the right to process the following personal data of the Subject of personal data:
- Surname, name, patronymic (if any), date of birth, gender;
- Residence address;
- Contact information (phone, e-mail);
- Data of the main identity document;
- Telegram profile;
- Financial information, including a credit or debit card number (only the last four digits of the card number), or other billing information;
- In situations where this is required by national legislation, the Operator has the right to request additional data from the Personal Data Subject: documents confirming his place of residence; scanned copies of the personal data subject’s identity card; a photograph of the Subject of personal data with a document in hand (with a sample of his handwriting) and other data at the discretion of the Subject of personal data and the discretion of the Operator;
- Also, the site collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics and others);
- The above data hereinafter in the text of the Policy are united by the general concept of “Personal data”;
- Data automatically transmitted to the site in the course of its use using the software installed on the user’s device, including the IP address, information from the cookie, information about the user’s browser (or other program with which the site is accessed), access time, URL of the requested page.
4. Purposes of processing personal data
4.1. The purpose of processing personal data is to inform the Subject of personal data, as a user of services, by sending emails; providing the user with access to services, information and / or materials contained on the website; identification of the user in the framework of the relationship between the Operator and the user; identification of the User within the framework of the Services provided by the Operator; confirmation of the accuracy and completeness of personal data provided by the user; creating a user account; processing and receiving payments from the user; providing the user with effective customer and technical support in case of problems related to the use of the Site, application and / or Services.
4.2. The operator has the right to send the user notifications about new products and services, special offers and various events. The user can always refuse to receive informational messages by sending an email to the Operator at email@example.com with the note “Refusal of notifications about new products and services and special offers”.
4.3. Anonymized user data collected using Internet statistics services are used to collect information about user actions on the site, improve the quality of the site and its content.
5. Legal basis for the processing of personal data
5.1. The operator processes the personal data of the service user only if they are filled in and / or sent by the user independently through special forms located on the website http://limonad.com. By filling out the appropriate forms and / or sending his personal data to the Operator, the user agrees with this Policy.
5.2. In case of disagreement with the provisions of this document (in part or in whole), the person who has expressed such a will is not entitled to use its services.
5.4. Please note that in accordance with the national legislation of each of the countries in which the services are provided, the Operator is obliged to store the subscriber data regulated by law for the period specified in the law.
6. The procedure for collecting, storing, transferring, distributing and other types of processing of personal data
6.1. The security of personal data processed by the Operator of personal data is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection of each of the countries in which the Operator’s services are provided.
6.2. The operator ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons.
6.3. The personal data of the Personal Data Subject will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of the current legislation.
6.4. If inaccuracies in personal data are revealed, the Personal Data Subject can update them independently by sending a notification to the Operator to his email address firstname.lastname@example.org with the note “Updating personal data”.
6.5. The period for processing personal data is unlimited. The subject of personal data can at any time revoke his consent to the processing of personal data, including those allowed for distribution, by sending a notification to the Operator by e-mail to his email address email@example.com with the note “Revocation of consent to the processing of personal data”.
6.6. The operator has the right to entrust the processing of personal data to a third party with the consent of the Subject of personal data, unless otherwise provided by applicable law, on the basis of an agreement concluded with a third party, the condition of which is confidentiality on non-disclosure of personal data.
6.7. Representatives of state authorities (including those controlling, supervisory, law enforcement and others) gain access to personal data processed by the Operator in the amount and manner determined by applicable law.
ATTENTION! The operator of personal data reserves the right to verify the identity of the Subject of personal data before exercising his rights by requesting identity documents
It is not allowed to provide personal data belonging to another subject without his consent. You are responsible for the consequences that may result from failure to comply with the above requirement.
Your data may be transferred to the territory of a foreign state in the cases and in the manner provided for by applicable law (cross-border transfer).
7. Cross-border transfer of personal data
7.1. Before starting the cross-border transfer of personal data, the operator is obliged to make sure that the foreign state, to whose territory it is supposed to transfer personal data, provides reliable protection of the rights of subjects of personal data.
7.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is a written consent of the Personal Data Subject to the cross-border transfer of his personal data and / or the execution of an agreement to which the Personal Data Subject is a party.
8. Obligations of the Personal Data Subject
8.1. The subject of personal data is obliged to transfer reliable personal data necessary to achieve the purposes of processing, as well as to confirm the accuracy of personal data by presenting original documents. In the event of a change in personal data necessary to achieve the goals of processing, provide the updated personal data and confirm the changes with original documents, as well as comply with the requirements of applicable law.
9. Terms of processing personal data
9.1. The terms for processing personal data are determined based on the purposes of processing, but no longer than is determined by applicable law. Personal data, the processing (storage) period of which has expired, must be destroyed or anonymized, unless otherwise provided by applicable law. The storage of personal data is carried out in a form that makes it possible to determine the Subject of personal data, no longer than required by the purpose of processing personal data. The processed personal data are subject to destruction or depersonalization upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by law.
10. Age restrictions
10.1 The operator does not provide services to users under the age of 18.
11. Final provisions
11.1. The user can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail firstname.lastname@example.org.
11.2. This document will reflect any changes in the personal data processing policy by the Operator. The policy is valid indefinitely until it is replaced with a new version.
11.3. The current version of the Policy is freely available on the Internet at http://limonad.com.
11.4. When changes are made to this Policy, the date of the last update is indicated. If you continue to interact with the Operator in any way, in particular (not limited to) through the Site and / or Application, and / or you have not withdrawn your consent to the processing of your data, you agree with the current version of the Policy, including consent to the processing of your data.
Date of publication of this Policy and its entry into force: 23.03.2022