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Personal Data Processing Policy of LIME HD LLC

LIME HD LLC (hereinafter referred to as the "PD Operator"), Taxpayer Identification Number: 2130132114, Primary State Registration Number: 1142130001221, registered at 33 Presidential Boulevard, Cheboksary, Chuvashia Republic, 428032, attaches great importance to your privacy and the security of your personal data.

We comply with Russian legislation on personal data. When processing your personal data, we adhere to the principles set forth in Article 5 of Federal Law No. 152-FZ "On Personal Data" of July 27, 2006.

We ask you to carefully review this Personal Data Processing Policy (hereinafter referred to as the "Policy") to understand the purposes for which we process your personal data and how you can exercise your rights regarding the personal data we process.

If you have any questions regarding this Policy, suggestions for improving its understanding and navigation, or questions regarding our processing and protection of your personal data, you can contact us directly by email at support@limehd.tv

1. TERMS

Personal data  – any information relating directly or indirectly to an identified or identifiable individual (personal data subject).

Personal data operator – a government agency, municipal authority, legal entity, or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data, and determines the purposes of personal data processing, the scope of personal data to be processed, and the actions (operations) performed with personal data.

Personal data processing – any action (operation) or set of actions (operations) with personal data, performed with or without the use of automated tools. Personal data processing includes, but is not limited to: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction.

Automated personal data processing  is the processing of personal data using computer technology.

Dissemination of personal data  is actions aimed at disclosing personal data to an indefinite number of persons.

Provision of personal data  is actions aimed at disclosing personal data to a specific person or group of persons.

Blocking of personal data  is the temporary cessation of processing of personal data (except in cases where processing is necessary to clarify the personal data).

Destruction of personal data  is actions that make it impossible to restore the contents of personal data in a personal data information system and/or that result in the destruction of tangible media containing personal data.

Anonymization of personal data  is actions that make it impossible to determine the ownership of personal data by a specific data subject without the use of additional information.

A personal data information system  is a collection of personal data contained in databases and the information technologies and technical means that support its processing.

Cross-border transfer of personal data  is the transfer of personal data to a foreign state, a foreign government agency, a foreign individual, or a foreign legal entity.

Internet resources  are all websites, as well as mobile applications, applications for set-top boxes and televisions running various operating systems, the copyright holder of which is the Personal Data Operator.

Cookies  are information data placed by a web server on a user's device when visiting an internet resource for the purpose of automatically identifying the user's device, saving settings, analyzing website traffic, and providing personalized content and advertising.

2. SCOPE

This policy is intended to inform you of our actions regarding the collection, processing, and protection of your personal data in order to achieve our stated purposes for processing personal data on internet resources.

The purposes for processing personal data to which this Policy applies are listed in Section 3.

Please note that our online resources may contain links to resources of other service providers that we do not control and to which this Policy does not apply.

Collection of Personal Data of Minors

Our online resources are not intended for the processing of personal data of minors. If you have reason to believe that a minor has provided us with personal data through our online resources, please notify us by emailing support@limehd.tv .

3. PURPOSES OF PERSONAL DATA COLLECTION

3.1. Purposes of personal data processing, composition of personal data, legal basis for processing, actions (operations) with personal data:

Purpose of processing

Personal data

Legal basis

Actions (operations)

Processing of requests left by you through the relevant request forms located on Internet resources

- name;

- email;

- phone number

Consent of the personal data subject

Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data

Registering and maintaining your account for the following purposes:

- fulfilling the terms of the user agreement;

- ensuring account operation;

- providing personalized services.

Dispatch of advertising and/or informational materials, including information about products/works/services, availability of special offers, promotions related to them, terms and conditions related to the purchase of products/works/services and their delivery, personal and special offers, reminders, and recommendations, including for the purpose of researching opinions on products/works/services.

email, account passwords

Consent of the personal data subject

Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data

Sending advertising and/or informational materials, including information about goods/works/services, availability of special offers, promotions in relation to them, conditions related to the purchase of goods/works/services and their delivery, personal and special offers, reminders and recommendations, including for studying opinions about goods/works/services

email

Consent of the personal data subject

Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data

Ensuring the smooth operation of the Internet resource and improving the user experience by analyzing your traffic, behavior, and the technical characteristics of your device.

- Your requests as a visitor to the Internet resources;

- System information, data from your browser;

- Cookies;

- Your IP address;

- Types of mobile devices you use;

- Number of visits to the Internet resources and page views;

- Duration of stay on the Internet resources;

- The queries you used when accessing the Internet resources;

- The pages from which you accessed the Internet resources;

- Your region of location;

- The date and time of actions on the Internet resources;

- The ID of the device you use.

Consent of the personal data subject

Collection, recording, systematization, accumulation, storage, destruction and depersonalization of personal data

3.2. We process personal data using non-automated and automated processing.

3.3. Personal data is processed until the processing purposes are achieved or until you withdraw your consent. After processing is complete or consent is withdrawn, personal data is subject to destruction in accordance with the procedure established by law.

4. WHAT ARE YOUR RIGHTS?

4.1. General Information about Your Rights

In accordance with Federal Law No. 152-FZ, you have the following rights regarding the processing of personal data:

  • the right to access personal data;
  • the right to rectify personal data;
  • the right to block and delete personal data;
  • the right to appeal our actions or inactions;
  • the right to appeal decisions made solely on the basis of automated processing of personal data;
  • the right to withdraw consent.

4.2. Requesting Additional Information to Identify the Subject of Personal Data

When exercising your rights, we may request additional information that will allow us to reliably identify you. Such information will be required in rare cases.

We strive to request the minimum amount of additional information necessary to identify you.

We will not be able to exercise your rights if you do not provide additional information to identify you in response to our request.

4.3. Terms of Providing Information on Your Rights

Information related to the exercise of your rights is provided free of charge. If your request is manifestly unfounded or excessive, in particular due to its repetitive nature, we may refuse to respond or charge a fee for providing the requested information.

4.4. Right to Access Your Personal Data

You have the right to receive from us accurate information about the processing of your personal data and, if possible, access to your personal data and the following information:

  • confirmation of the processing of personal data by the personal data operator;
  • legal basis and purposes for processing personal data;
  • purposes and methods used by the personal data operator for processing personal data;
  • name and location of the personal data operator, information about persons (except for the personal data operator's employees) who have access to personal data or to whom personal data may be disclosed under an agreement with the personal data operator or under federal law;
  • personal data processed relating to you and the source of such data;
  • The procedure for exercising your rights under Federal Law No. 152;
  • Information on completed or proposed cross-border data transfers;
  • The name or last name, first name, patronymic, and address of the person processing your personal data on behalf of the Personal Data Operator, if the processing has been or will be entrusted to such person.

4.5. Right to Correction of Your Personal Data

We make every effort to identify inaccurate, incomplete, or outdated data.

If your data is inaccurate, incomplete, or outdated, you have the right to request that we correct the data concerning you without undue delay.

We will notify you of the correction once your personal data has been corrected.

4.6. Right to Block and Delete Your Personal Data

You have the right to block and delete the personal data we process about you.

If we are unable to delete your personal data, we reserve the right to block it for up to six months and, during this period, find a solution to delete it. We also reserve the right, instead of deleting it, to anonymize your personal data so that it cannot be identified.

We will notify you of the blocking, deletion, or anonymization of your personal data.

4.7. Right to appeal our actions or inactions

You have the right to object to the processing of your personal data in response to our actions or inactions.

To do so, you may contact the local office of Roskomnadzor in your region.

4.8. Right to appeal decisions made solely on the basis of automated processing of personal data

You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects concerning you or similarly significantly affects you.

You have the right to contact us to appeal our actions when we make decisions based solely on automated processing of personal data, if any.

4.9. Right to withdraw consent

If your data is processed on the basis of consent, you have the right to withdraw it.

4.10. How can you exercise your rights?

We offer several ways to exercise your rights:

Send a request to the following address: 428032, Chuvashia Republic - Chuvashia, Cheboksary, Presidential Blvd. 33, including information about your or your representative's identity document (type of document, series and number, by whom and when issued), your full name or the full name of your representative, information about your relationship with us that will confirm the processing of your personal data, and your signature or the signature of your representative;

You can also contact us directly by email at support@limehd.tv

4.11. How and when we can exercise your rights

We may limit the scope of our obligations and your rights (to access, rectify, block, or delete data) in the following cases:

  • The processing of personal data, including personal data obtained as a result of investigative, counterintelligence, and intelligence activities, is carried out for the purposes of national defense, state security, and law enforcement;
  • Personal data is processed by authorities that have detained the data subject on suspicion of committing a crime, charged the data subject with a criminal offense, or applied a preventive measure to the data subject prior to the filing of charges, with the exception of those provided for by the criminal procedure legislation of the Russian Federation;
  • Personal data is processed in accordance with legislation on combating the legalization (laundering) of proceeds from crime and the financing of terrorism;
  • A data subject's access to their personal data violates the rights and legitimate interests of third parties;
  • Personal data is processed in cases stipulated by the legislation of the Russian Federation on transport security, in order to ensure the stable and secure operation of the transport system and protect the interests of individuals, society, and the state from acts of unlawful interference for the purposes of the transport system;
  • When we have legal grounds for continuing to process your personal data.

Some rights are subject to special conditions, without which they cannot be exercised. If we cannot implement your right at your request, we will write a reasoned refusal.

5. DATA SECURITY

The personal data we collect and store is considered confidential. It is protected from loss, alteration, or unauthorized access in accordance with Russian data protection legislation. To this end, we use technical and organizational measures. We are constantly improving our data protection systems.

6. POLICY CHANGES

We reserve the right to amend our Policy at any time. We ask that you regularly review all updates to our Policy.

7. CONTACTS

Please note that the contact information provided in this section is used only for communication regarding personal data processing and protection. Inquiries you send to the contact information provided in this Policy that are not related to personal data protection will not be considered.

For questions regarding the processing and protection of personal data, you can contact us directly by emailing us at support@limehd.tv