Privacy Policy

What does this privacy policy govern?

This privacy policy (hereinafter referred to as the “Policy”) governs the handling of all data, including personal data as defined by applicable law (hereinafter referred to as “Personal Data”), which may be obtained from you during the use of the https://lp151.com website (hereinafter referred to as the “Website”), products and / or services presented on the Website (hereinafter referred to as “Services”), as well as during the execution of any agreements and contracts concluded with you in connection with the use of the Website or Services.

We may also receive Personal Data from our partners (hereinafter referred to as “Partners”), websites, programs, products or services which you use. In such cases, the transfer of Personal Data is possible only in accordance with applicable law, and is carried out on the basis of special agreements concluded with each of the Partners. Use of the Website and / or Services may be subject to additional conditions that may change and / or add to this Policy.

Who collects, uses and processes your Personal Data

When you use the Website, your Personal Data is being collected and used by the Controller of the Website, Kamelev Yegor Vladimirovich, reg. # 311784724500633, registered at: 197229, St. Petersburg, ul. Granichnaya, bldg. 21, apt. 62 (hereinafter — “Controller”), or his authorized representatives.

For users located in the European Economic Area (EEA), the Controller has an authorized representative: Anna Romanovna Sroginis, Director of Open Analytics Ltd., established in accordance with the laws of the United Kingdom (UK and Northern Ireland), registered at: 36 Garfield Avenue, Lancaster, UK, LA1 5ET.

Your Personal Data is being processed by Hetzner Online GmbH (hereinafter the Processor):
Industriestr. 25, 91710 Gunzenhausen, Deutschland
Tel.: +49 (0)9831 505-0
E-Mail: info@hetzner.com

What Personal Data We Collect

We may collect the following categories of Personal Data during use of the Website and Services:

1) When registering on the Website (creating an account):
— your name (Nickname);
— your E-mail address

2) When visiting the Website / using the Services:
— Electronic data (HTTP headers, IP address, cookies, web beacons / pixel tags, browser ID data, hardware and software information);
— Data pertaining to the date and time of access to the Site and / or Services;
— Geolocation data;
— Other data about you necessary for processing (in accordance with the terms governing the use of the Site or Services);
— Any information about you that we receive from our Partners in accordance with the terms of the agreements concluded between you and the relevant Partner, and agreements concluded between us and the relevant Partner.

The Site also uses cookies and web beacons (including pixel tags) to collect Personal data and link them to your device and web browser (see the Policies section “How we use cookies ...”).

We do not collect specific categories of Personal Data (such as race, political opinion, health information, or biometric data). Also, we do not collect data in order to compile a “portrait” of the user of the Site and / or Services, if this could significantly affect your rights and freedoms.

Legal basis and purpose of processing your Personal Data

We process your Personal Data only in the following cases that do not conflict with applicable law:

1) processing necessary to fulfill contractual obligations to you, including ensuring the operation of the Website and Services;

2) processing necessary to fulfill the obligations established by applicable law;

3) processing necessary to ensure the legitimate interests of Controller in cases that such processing does not significantly affect your interests, fundamental rights and freedoms. Please note that when processing your Personal Data on the basis indicated, we will always strive to maintain a balance between your legal interests and the protection of the confidentiality of your Personal Data.

We process your Personal Data to ensure your legal interests, for example, in the following cases:

1) to better understand how you interact with the Website and / or Services;

2) to improve, change, personalize or otherwise better the Website and Services for the benefit of all users;

3) in specific instances, we may request your separate consent to the processing of your Personal Data.

We always process your Personal Data for specific purposes and only Personal Data that is relevant to the furtherment of such goals.

In particular, we process your Personal Data for the following purposes:
— granting you access to the Website and / or Services;
— providing access to your account;
— communicating with you to send you notices, requests and information relating to the work of the Website and Services, fulfill agreements with you, and process your requests;

4) to enhance the usability of the Website and Services;

5) to protect your rights and the rights of Controller.

How we protect your Personal Data

In most cases, Personal Data is processed automatically without access to it by any employees / authorized persons of the Controller. If such access is required, it can be provided only to employees / authorized persons responsible for the processing of Personal Data. To protect and ensure the confidentiality of data, all employees of the Controller must comply with the Policy for the Processing and Protection of Personal Data, approved by the Controller. All employees must also follow all technical and organizational security measures in place to protect your Personal Data.

We also use appropriate technical and organizational measures to protect Personal Data from unauthorized, accidental or unlawful destruction, loss, alteration, unfair use, disclosure or access, as well as other illegal forms of processing. We implement these security measures while taking into account the current level of technology, the cost of their implementation, and the risks associated with the processing and nature of Personal Data. Personal Data is also protected by Processor in accordance with terms and conditions provided at: https://www.hetzner.com

Who else has access to your Personal Data. To whom and for what may it be transferred

For internal use

We may transfer your Personal Data to our employees (to the extent specified in the relevant section of the Policy), as well as to authorized persons. In all cases, Personal Data will also be processed only for the purposes set forth in the relevant section of the Policy, unless otherwise established by the terms of use of the Website and / or Services.

To third parties

We may also transfer your Personal Data to third parties for the purposes specified in the relevant section of the Policy. These third parties may include:

— Authorized national and / or international regulatory structures, law enforcement agencies, central or local executive authorities, other official or state organizations or courts to which the Controller is obliged, upon request, to provide information in accordance with applicable law;

— Any third parties that might be required to provide you with a relevant Service, to fulfill a specific agreement or contract signed by you, or if you have given your permission to transfer your Personal Data;

— Any third parties necessary to ensure legal protection of Controller. This includes but is not limited to third parties related to the violation of User Agreement, this Policy or the conditions governing the use of certain Services, or in a situation where there is a threat of such violation.

Where your Personal Data is stored and processed

Your Personal Data will be stored in the Russian Federation and / or in the EEA.

For Russian users: we record, systematize, accumulate, store, clarify (update, change), retrieve personal data of citizens of the Russian Federation using databases located on the territory of Russian Federation.

For users from the EEA: Russia is a jurisdiction outside the European Economic Area, which was not recognized by the European Commission as providing an adequate level of personal data protection. Therefore, we have taken appropriate measures to ensure that such a transfer is carried out in accordance with the current EU data protection rules.
In particular, we have signed a copy of the Data Processing Agreement between Controller and Processor, which can be found here.

Length of Personal Data storage

Your Personal Data will be stored as long as it’s necessary to achieve the goals for which it was collected, or to comply with applicable law. Terms of storage found at hetzner.com also apply.

After deleting your account, your Personal Data may be used by the Controller for purposes consistent with the applicable law, and only on the condition that they were not withdrawn at the request of the you in the manner prescribed by the applicable law.

Your rights regarding your Personal Data

You have the right to access your Personal Data processed in accordance with this Policy.

If you believe any of your Personal Data to be incorrect or incomplete, you can send a request to the following e-mail address: info@lp151.com.

If consistent with applicable law, you may have the right to:
— request the deletion of your Personal Data collected by the Controller;
— require restrictions on the processing of your Personal Data;
— request a copy of the Data Processing Agreement (DPA) between Controller and Processor;
— object to the processing of your Personal Data.

The Controller will comply with the specified requests in accordance with applicable law.

In cases stipulated by applicable law, you may also have other rights not specified above.

To exercise the above rights, please mail your requests to: info@lp151.com.

If you are not satisfied with the handling of your Personal Data by the Controller, please detail in an email to: info@lp151.com, and the Controller will consider your claim. If you are not satisfied with the Controller’s response, you have the right to file a complaint with the relevant competent authority.

How we use cookies and other similar technologies on the Site / Services

What are cookies and why do we use them

Cookies are small text files placed on the device that you use to access the Site. They contain information that is collected from your device and sent back to the Site at each subsequent visit in order to remember your actions and preferences over time.

The website uses the following types of cookies:

— strictly necessary cookies: these cookies are necessary for the operation of the Site and the provision of the Services to you; among other things, they allow the Site to identify your hardware and software, including the type of browser you are using;

— statistical / analytical cookies: these cookies allow Controller to recognize you, count them, and collect information, such as operations you perform on the Site and in the Services, including information about the web pages you have visited and the content you receive;

— technical cookies: these cookies collect information about how you interact with the Site and / or Services, allowing Controller to identify errors and test new features to improve the performance of the Site and Services;

— functional cookies: these cookies allow Controller to provide certain functions to facilitate your use of the Site, for example, by saving your preferences (such as language and location);

— (third-party) tracking files / advertising cookies: these cookies collect information about you,, traffic sources, pages visited and advertisements displayed for you, as well as (the one that went to the advertised page) (click-throughs?). They allow Controller to display advertisements that may be of interest to you, based on analysis of Personal data collected about you. They are also used for statistical and research purposes.

How long are cookies stored on your device?

The Website uses the information contained in the cookies only for the above purposes, after which the collected data will be stored on your device for a period that may depend on the type of cookies, but not exceeding the period required to achieve their goal, after which they will be automatically removed from your system.

Who else has access to the information contained in the cookies

be transferred and made available to the Controller and / or third parties indicated in the relevant section of the Policy.

When you first visit the Website, your consent to the use of cookies may be requested. If, after you have approved the use of cookies, you change your mind, you can opt to delete the cookies stored in your browser (this process varies from browser to browser — please refer to the browser manual).

If you refuse to use cookies, this may result in the inaccessibility of certain functions of the Website, which may affect your ability to use the Website. You can also change your browser settings to accept or decline all cookies or cookies from certain sites, including the Website, by default.

We can also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:

— Tracking your actions on the Website or in use of Service by accessing and using cookies stored on your device.

— Collection of statistical information related to the operation of the Website or Services.

Privacy Policy update

This Policy may be updated at the discretion of the Controller, in cases where the corresponding changes are related to changes in the applicable law, as well as when the corresponding changes are connected with changes in the operation of the Website.

Questions and suggestions

To send questions and suggestions regarding the validity of this Policy, please use the following e-mail address: info@lp151.com.

You can also use this address to send inquiries about your rights, amendments to your Personal Data, or address the legality of its processing.