Terms of Service

These Terms of Service (the "Agreement") set forth the terms and conditions that apply to use of the informational and technical exchange services (the “Services”) provided by Drimnano S.L.U. or any other entity (the “Company”) receiving Customer’s payment for the Services. Any other terms indicated in the Product or in communication directed from the Company to the Customers constitute an integral part of this Agreement. The Company may offer to enter this Agreement to a corporate entity subject to approval of the Company. In such case for such Customers the following section “Corporate terms” will apply and will take precedence over any other terms hereof.

The Company is not a telecommunications operator, and all telecommunication services in the Product are provided by telecommunication operators in each country where the Product is being used. Using the Product is available only after identification and provision of personal id.

Corporate terms

If the Customer enters this Agreement as a corporate entity, the following information shall be provided to the Company before commencing the Services:
constitutional documents;
bank details;
registered address;
company number;
VAT id (for EU companies);
certificate of registration;
tax residency certificate;
documents confirming the chain of authorization of a signatory;
first and last name of the signatory person;
date of birth of such person;
nationality of such person;
postal address of such person;
serial number and digital image of passport, national ID or driver’s license of such person;
other information requested by the Company.

The Customer shall notify the Company in case of changes of such information and shall immediately disclose information on the actual user of SIM-card or other numbering asset in case of Company’s request.

Applications of corporate Customers to enter this Agreement are subject to the Company’s review and approval. Depending on the type of the Services, provision of additional documents, information may be required, and additional qualifications for the Customers may apply.

The Company may require the Customer to sign and send to a designated agent the hard copies of the documents containing statements of entering into this Agreement by the Customer. The Company is entitled to assign processing and issuing invoices and other required accounting documents to an authorized third party on a certain territory.

The Customer shall sign the accounting documents on a monthly basis upon the Company’s request. Failure to provide the Company with signed documents within 5 business days after request shall result in waiver of the rights to claim any complaints for the quality and accounting of the Services.

Purchase of the Services or SIM-card confirms Customer’s consent to this Agreement.

Drimclub membership terms

The Customer may be offered to participate in Drimclub - a loyalty program which allows to purchase and access to digital and non-digital services available for consuming both in the Product and outside the Product depending on the type of service. Unless otherwise indicated, Drimclub services are subject to the terms of this Agreement. Drimclub services may be removed or modified without prior notice to the Customer.

Drimclub membership is subject to a monthly membership fee which may be charged only to the Customer’s balance on the Account. Inability to debit the membership fee will result in suspension of membership.

In case of any of the Drimclub services is provided by a third party, the Company is not liable for the quality of such service. Any information and/or educational content available to Drimclub members is provided with no warranties of any results of consuming such content.

In case if the Drimclub services provide cashback, the amount of cashback may be only credited to the Account’ balance.

Referral program terms

The Customers may participate in referral program by referring the Products to third parties (“Referral”) by the means provided by the Company. In case if the Referral pays the required amount to its Account for the first time, the Customer which referred the Referral shall be granted with the reward solely to its balance provided that the referral link is not expired. Each engaged Referral shall result in reward only once. Engagement reward shall not be refunded. The Company is entitled to review the Referrals and disapprove an engaged Referral in its sole discretion. The Customers shall fully comply with all applicable laws during the Referrals engagement.

General terms

The Services allow the Customer to connect and utilize a range of services including mobile communication and internet access services, insurance services and other kinds of third party services provided by mobile operators,internet access providers, insurance and other companies (the “Providers”). Company is an independent contractor, and not an employee, agent, joint venturer or partner of the Providers nor is Company authorized to incur any obligations or make any representations on behalf of the Providers, except those provided herein. The Company acts as an intermediary service provider between the Customer and the Providers on a certain territory. The Company does not initiate the data transmission; does not select the receiver of the transmission; and does not select or modify the information contained in the transmission.

By default the communication services include only internet access. The Customer may purchase a phone number on a subscription basis which allows the Customer to make calls and send/receive SMS via the Product. If the subscription is not paid within 30 days after expiration, the phone number shall be forfeited and the Company may use the phone number for other Customers.

Depending on the type of Product, the Product may provide the Customers with additional functionality in order to communicate with other Customers or Customer’s contacts, to associate the Customer’s phone number with the Customer’s Account, and to provide data transmission services. The Company does not warrant operability of VPN services on the territories where VPN usage is limited.

Depending on the type of Provider’s services, the Company may not be entitled to terminate such services or accept any claims in respect of such services.

The Company is continuously developing and changing the Product, and therefore its functions may be added, removed or modified at the Company’s discretion without consent or notification from the Customers. The Product does not provide the functionality of calling emergency numbers. The Customers are not entitled to any compensation due to such changes of Product features or their price.

Each Provider has observed registration obligations, as stated in its national law, in a country where the Providers are offering the Services to the Customers, and the Providers hold all licenses, certificates, permits and approvals necessary for the conduct of their business and the performance of its obligations towards the Customers during the term of this Agreement. The Company makes no warranties in that respect.

The Customer’s payment for the Services confirms the Customer’s unconditional acceptance and agreement to the terms and conditions set forth in this Agreement. If the Customer does not agree to be bound by this Agreement, such Customer cannot use the Services. The Company may modify or amend this Agreement from time to time without any further notice which shall be effective immediately upon posting in the Product.
THE CUSTOMER’S CONTINUED USE OF THE CUSTOMER’S ACCOUNT AND/OR THE SERVICES FOLLOWING THE POSTING OF ANY SUCH MODIFICATIONS OR AMENDMENTS WILL BE CONCLUSIVELY DEEMED TO BE ACCEPTED BY THE CUSTOMER.

Returns

Fees paid for SIM-card may be returned in case of absence of connection of SIM-card to the network during 24 hours after Customer’s request to technical support by email or in technical support chat. The given period shall be suspended in case of absence of Customer’s reaction to the message of technical support staff or failure to follow instructions of technical support staff by the Customer. The given period shall be decreased to 12 hours in case of absence of any reaction from technical support staff. In such cases the Customer shall provide a notice to the Company via [email protected]. Within 72 hours of the notice the Company shall send a return confirmation. In case of Customer’s confirmation by email the Company shall return the fees paid for SIM-card and Customer’s balance and shall block the SIM-card.

If the Customer did not open SIM-card package or did not install eSIM to his or her device, the Customer may request refund of the fees paid for such SIM-card. In such case the Customer shall provide a notice to the Company via [email protected]. Within 72 hours of the notice the Company shall send a return confirmation. In case of Customer’s confirmation by email the Company shall return the fees paid for SIM-card and Customer’s balance after receiving SIM-card from the Customer to the address designated by the Company (not applicable for eSIM).

Faults of SIM-card functioning may be claimed within 14 days after its receipt. During 60 days after return of faulty SIM-card its price will be refunded, including delivery fees at the lowest available tariff. Faulty SIM-card shall be returned within 14 days after claiming the fault. Inability to set up required settings in the Customer’s device or defects of Customer’s device or network are not considered as fault. 

Fault-free SIM-card may be returned within 14 days after its receipt. During 60 days after return of SIM-card its price will be refunded less the delivery fees.

Claims on return of the balance from Customer’s account may be filed within 14 days after payment. The Customer is entitled to refund only the payments made within the previous 14 days.

All refunds are transferred to payment methods used for initial payment. Additional request is required to change the payment details for refund.

1. Activation

1.1. A user of the Services (the “Customer”) may request provision and activation of SIM card required for using the Services from the Company or from the Company’s partners and resellers. The provision and activation of SIM card as well as provision of other Services is subject to terms indicated on www.drimsim.com website or the Company’s mobile applications (the “Product”) and subject to a fee.

SIM card may be provided in physical medium or as a virtual asset.

The SIM card is not active and the Services will not be provided to the Customers prior to identification subject to the Spanish Law 25/2007, of October 18, on the conservation of data related to electronic communications and public communications networks.

1.2. The Customer may open an account available through the Product which contains the Customer’s balance (the “Account”) by registering a SIM card and providing necessary registration data.

1.3. For the purpose of activation of the Services, the Customer shall provide proof of identity by uploading its photograph with an international passport to the Company and make a prepayment by entering a valid payment information. The Customer shall also provide its email, phone number and residential address according the information contained in the proof of identity, and notify the Company in case of changes in any of such data. Submission of documents and information shall be subject to Company’s requirements on the format and content of such documents and information. Each type of Services may be subject to provision of additional information and documents indicated in the Product, and additional qualifications for the Customers may apply.

1.4. The Customer acknowledges and agrees that the information provided to the Company and any subsequent changes thereof shall be complete, correct and true, and the Customer shall notify the Company of any change to such information.

1.5. The Services may be suspended according to applicable law in case of invalid identification data.

1.6. The Services shall not be provided to the Customers younger than 18 years old.

1.7. Customs policies vary widely from country to country, so the Customer should contact its local customs office for further information in case of SIM-card delivery. The Customer is considered the importer of SIM-card and must comply with all laws and regulations of the country in which the Customer is receiving the goods.

2. License

2.1. The Company grants the Customer a personal, revocable, non-exclusive, non-sublicensable, and non-transferable license to use the Product subject to the terms of and for the duration of this Agreement.

2.2. The Company is not responsible for holding all licenses, certificates, permits and approvals necessary for provision of the Services by the Providers, and for validity of such of approvals in full force and effect.

3. Use of SIM-card

3.1. If a SIM-card used by the Customer to access the Services is being used to access the Customer’s Account or the Services without his or her permission, the Customer is required to notify the Company immediately. The Customer is responsible for all charges to the Customer’s Account until the Customer notifies the Company of such circumstances.

3.2. The Customer agrees to pay for fees the Services charged to the Account. The Company shall not be held responsible for fraudulent charges that result from theft or fraudulent use of the Customer’s means of payment (credit/debit/charge card, etc.). The Customer agrees and acknowledges that he or she is wholly responsible for the safety and security of the device through which the Customer receives the Services and the Customer agrees that the Company is not liable for unauthorized use of the Services through the Customer’s device. The Company shall not be responsible for any damage caused to or losses incurred by the Customer in case a third party obtains an access to the Customer’s Account information or other personal information.

3.3. The Company may suspend any transaction or current balance of the Customer in the Account if the Customer’s activity is suspected with fraud or unauthorized use.

4. Technical Support

4.1. The Customer may send any questions, concerns or complaints about the Services to [email protected] or via any other contact indicated in the Product.

4.2. Improper performance of the Services or the Product may be reported to the Company, and the Company shall provide reasonable efforts to fix such malfunction as far as such malfunction is a result of errors contained in the Services or the Product. Correction of malfunction may be provided in the form of a temporary fix consisting of instructions for the Customer to implement the correction of malfunction.

4.3. Company’s sole liability and Customer’s sole remedy for any failure of the Company to provide technical support is (a) for the Company to use commercially reasonable efforts to fix or resolve material malfunction, or (b) for the Customer to terminate this Agreement.

4.4. The Company is not liable for and is not required to perform technical support with respect to problems caused by third party products.

4.5. The foregoing technical support terms are exclusive and are in lieu of all other warranties and guarantees whether written, oral, implied or statutory. NO IMPLIED WARRANTY OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE SHALL APPLY. In no event shall the Company be liable for loss of profits or revenues, loss of use of products or services, interruption of business, cost of capital, or for any special, consequential or incidental damages.

5. Payments

5.1. The rates and charges for the Services are indicated in the Product. The rates may be increased by the amount of applicable value-added tax based on the Customer country of residency and/or billing address, including (but not limited to) if the Customer will use the Services in the territory where provision of the Services is subject to value-added tax according to applicable law. The Customer is responsible for checking the applicable rate before using the Services. If the Services are offered free of charge, the amount of Services provided in such manner may be limited.

5.2. The Customer may deposit funds on its Account using the payment methods and currencies available with the Product. The Company may engage Drimnano S.L. (Spain) for payments processing. Payment service providers may apply their own terms and fees for processing of deposit. THE CUSTOMER MAY TURN ON AUTOMATIC DEBITING OF FUNDS FROM THE CUSTOMER’S CARD IN CASE IF THE CUSTOMER’S BALANCE IS NOT ENOUGH TO CONTINUE USING THE SERVICES. THE CUSTOMER MAY TURN OFF AUTOMATIC DEBITING IN THE PRODUCT SETTINGS ANY TIME. IT IS THE CUSTOMER’S RESPONSIBILITY TO REVIEW SPENDINGS AND BILLING, AND TO CHECK IF AUTOMATIC DEBITING IS TURNED ON.

5.3. In case if the Customer will have no registered network sessions by using the Service for 360 days, the Customer’s balance will be debited with 0.5 Euro for Account reservation per month starting from 361th day of inactivity. Any activity of the Customer (calls, messages, internet sessions) will stop the debiting. In case if such debiting results in depletion of funds on the Account, this Agreement will be terminated and the SIM card shall become invalid.

5.4. The rates for the Services may be changed from time to time without providing advance notice and may be different depending on the availability of the Services to different categories of Customers. Any and all alterations in pricing policy and special promotions will be indicated in the Product. The Company is entitled to limit the amount of provided free Services any time at its own discretion without prior notice.

5.5. It is the Customer’s responsibility to notify the Company of any changes to the Customer’s payment information, including the expiration date of any credit or debit card used in the Account. If for any reason the Customer’s balance becomes negative, the Customer hereby authorizes the Company to charge the negative balance to any available payment means of the Customer without any additional confirmation.

5.6. The Customer is responsible for reviewing the Customer’s billing information. Failure to notify the Company of any disputed charges within thirty (30) days of the charge being posted to the Customer’s Account will be deemed as full and complete acceptance of the charges. The Customer shall compensate the Company all amounts paid by the Company as penalties and commissions to payment service providers resulted from payment disputes initiated after expiration of 30 days. If the Customer disputes the billing amount the Customer shall provide material evidence of incorrect billing or fraudulent transactions. If the Customer disputes the amounts indicated in the billing data provided in the Account, the billing data available to the Company shall be binding and final for the billing purposes.

5.7. The Customer must provide the Company correct information on the delivery address of the SIM-card and pay for the SIM-card provision and activation. Delivered SIM-cards are subject to activation procedure after delivery. This delivery time may vary for different counties. Delivery is deemed effected on the date that the Company places a SIM-card with a shipping agent for shipment to the delivery address provided by the Customer or provides virtual SIM-card to electronic address of the Customer. The Company will not be held responsible for items that are shipped late, damaged as a result of shipment, shipped to an address that was submitted incorrectly, or not delivered successfully due to Customer’s fault, and in such case the Company is entitled to charge a new delivery and/or and activation fee for the new SIM-card. The Company won’t refund the delivery fee in case if the delivery failed due to Customer’s fault or in case of return of the SIM-card.

6. Termination

6.1. The Customer may discontinue using the Services at any time by notifying the Company by any available means. In such case the Company will deactivate the Customer’s Account with keeping the reactivation ability. In all cases the Customer will remain responsible for payment of all charges for the Services rendered up to the date of termination.

6.2. The Company may suspend provision of the Services to the Customer any time at its sole discretion and terminate this Agreement.

6.3. In case of termination the Company shall refund the amounts paid within the last 14 days on the Customer’s balance to the payment means used for payment within 60 days after termination. In case of unavailability of the initial payment means the Company will make commercially reasonable efforts to request the new payment means for refund. In case if the Company's expenses related to refund will exceed the amount of refund, the Company shall be entitled to reject the refund and offer to use the amount of refund in the Customer's account or to transfer the amount of refund to the account of another Customer.

6.4. The amounts on the Customer’s balance obtained as a result of any promotional offers or otherwise without making the actual payment by the Customer are not subject to refund under any circumstances. In the course of refund the amount of the balance is deducted with the amounts credited as a result of any promotional offers or otherwise without making the actual payment by the Customer.

7. Unlawful Use

7.1. The Customer will not use the Services for any unlawful, abusive or fraudulent purpose, including, but not limited to, for using the Services in a way that (a) interferes with the ability to provide the Services to the Customer or other Customers; (b) abuses any bonus or promotional program; or (c) violates the applicable law. The Customer will not in any way submit any materials to the Company or otherwise take any action that would, in the Company’s sole determination, interfere with the Services or other Customers, infringe the rights of any third party, or otherwise constitute objectionable conduct.

7.2. If the Company reasonably believes that the Customer or any third party is using the Customer’s Account in a way abusing the Services or any of the Company’s bonus or promotional programs or otherwise breaching this Agreement or applicable law, the Company may immediately suspend, restrict, or cancel the Customer’s Account and the Customer’s ability to use the Services or the Product without notice with no refund.

7.3. Except to the extent contrary to applicable law, the Customer is prohibited from causing or permitting the reverse engineering, disassembly or de-compilation of the SIM-card, the Services and/or the Product. The Customer is prohibited from reselling, sublicensing or using the SIM-card or the Services to provide service bureau data processing services or to otherwise provide data processing services to third parties. The Customer will not allow the SIM-card or the Services to be used by, or disclose all or any part of the SIM-card or the Services to, any person except the Customer.

7.4. The Customer expressly acknowledges and agrees that any applicable export and import laws govern the Customer’s use of the SIM-card and the Services and he or she will neither export or re-export, directly or indirectly, either the SIM-card or the Services, nor any direct product thereof in violation of such laws, or use either the SIM-card or the Services for any purpose prohibited by such laws.

8. Indemnification and Limitation of Liability

8.1. The Customer agrees, at his or her sole expense, to fully defend, indemnify and hold harmless the Company, its parent, affiliates, shareholders, directors, officers, employees, agents and the Providers from and against any and all claims (including without limitation reasonable attorney’s fees) arising out of or in connection with (i) the Customer’s use of the Services, (ii) the Customer’s Account (including the use of the Customer’s Account by a third party) and (iii) this Agreement.

8.2. EXCEPT FOR DAMAGES CAUSED BY THE COMPANY’S INTENTIONAL MISCONDUCT AND/OR EXCEPT WHERE PROHIBITED BY LAW, THE COMPANY WILL NOT BE LIABLE FOR DAMAGES THAT EXCEED THE AMOUNT OF CHARGES TO THE CUSTOMER FOR THE CUSTOMER’S ACTUAL USE OF THE SERVICES DURING THE PRIOR ONE MONTH PERIOD. UNDER NO CIRCUMSTANCES WILL THE COMPANY BE LIABLE FOR ANY DIRECT, SPECIAL, CONSEQUENTIAL, INCIDENTAL, INDIRECT, EXEMPLARY OR PUNITIVE DAMAGES, INCLUDING, BUT NOT LIMITED TO, LOSS OF PROFIT OR REVENUES, OR INCREASED COSTS OF OPERATION, EVEN IF SUCH DAMAGES WERE FORESEEABLE OR THE COMPANY HAS BEEN SPECIFICALLY ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. IN ADDITION, UNDER NO CIRCUMSTANCES WILL THE COMPANY BE LIABLE FOR DAMAGES ARISING OUT OF OR RELATED IN ANY WAY TO THE CUSTOMER’S INABILITY TO ACCESS, OR THE CUSTOMER’S DIFFICULTY IN ACCESSING, THE SERVICES.

8.3. THE SERVICES ARE PROVIDED "AS IS" AND THE COMPANY DOES NOT MAKE ANY WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION ANY WARRANTIES OF TITLE, NON-INFRINGEMENT OF INTELLECTUAL PROPERTY, MERCHANTABILITY, TECHNICAL COMPATIBILITY OR FITNESS FOR A PARTICULAR PURPOSE WITH REGARD TO ANY SERVICE, PRODUCTS OR MATERIAL PROVIDED PURSUANT TO THIS AGREEMENT. THE COMPANY ALSO MAKES NO WARRANTY THAT THE SERVICES WILL BE UNINTERRUPTED, ERROR FREE OR MEET THE CUSTOMER’S REQUIREMENTS. THE COMPANY DOES NOT AUTHORIZE ANYONE, INCLUDING ITS EMPLOYEES, AGENTS, PROVIDERS OR REPRESENTATIVES, TO MAKE A WARRANTY OF ANY KIND ON BEHALF OF THE COMPANY AND THE CUSTOMER SHOULD NOT RELY ON ANY SUCH WARRANTY. THE CUSTOMER EXPRESSLY ACKNOWLEDGES AND AGREES THAT BECAUSE THE SERVICES ARE PROVIDED OVER MOBILE AND INTERNET NETWORKS OUTSIDE OF THE COMPANY’S CONTROL, THE COMPANY HAS NO RELATED LIABILITY. THE COMPANY IS NOT RESPONSIBLE FOR THE CONTENT OF COMMUNICATIONS TRANSMITTED THROUGH THE SERVICES.

8.4. Except for the Customer’s obligation to pay for the Services, neither the Company nor the Customer is liable to the other for any delay, failure in performance, loss or damage due to causes beyond reasonable control, including but not limited to acts of God, fire, strikes, explosions, power failure, earthquake, flood, water, labor disputes, terrorism, acts or omissions of carriers or suppliers, systems failure and acts of regulatory or governmental agencies.

8.5. Neither the Company nor the Provider guarantees any level of performance of the Services in a any specific coverage area.

9. Communication

9.1. Any information including any materials, messages, ideas, suggestions, or other communications (collectively - "Information") the Customer transmits to the Company in any manner shall be and remain the exclusive property of the Company. The Customer’s submission of any Information shall constitute an assignment to the Company of all worldwide rights, titles and interests in all copyrights and other intellectual property rights in the Information. The Company will be entitled to use, reproduce, disclose, publish and distribute any Information the Customer submits for any purpose whatsoever, without restriction and without compensating him or her in any way. For this reason, the Company prohibits the Customers to send the Company any Information that the Customer does not wish to assign to the Company, including any confidential information or any Information subject to third party rights.

10. Assignment

10.1. The Company may assign all or part of its rights and obligations under this Agreement to any party at any time without notice to the Customer. In case of assignment the Company will have no further obligation to the Customer in connection with such assigned obligations.

11. General

11.1. If any provision of this Agreement is held to be invalid, illegal or unenforceable, the remaining provisions of this Agreement will continue in full force and effect.

11.2. This Agreement, together with any written amendments or written modifications, will constitute the entire agreement between the Customer and the Company with respect to the Services provided hereunder and will supersede and replace all prior or contemporaneous understandings or agreements, written, electronic or oral, between the Customer and the Company. No written or oral statement, advertisement or service description not expressly contained in the Agreement will be allowed to contradict, explain, modify or supplement it.

11.3. This Agreement shall be interpreted, governed by and construed in accordance with the laws of the Principality of Andorra. The Customer agrees, in the event any claim or suit is brought in connection with this Agreement, to the exclusive jurisdiction and venue of the courts of the Principality of Andorra. In any action to enforce this Agreement, including, without limitation, any action by the Company for the recovery of fees due hereunder, the Customer shall pay the Company reasonable attorney’s fees and costs in connection with such action. The Customer acknowledges and agrees that this governing law provision applies no matter where the Customer resides, or where he or she uses or pays for the Services. This Agreement is originally written in the English language and the English language version shall control over any translations.


Drimnano SLU
CIF L-715014-M
Passatge d'Europa, 1, 4th floor, AD500 Andorra la Vella, Andorra
+376 333 433
[email protected]


Publication date: March 30, 2022
Effective: April 07, 2022
Previous version of the document: February 25, 2022

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Drimnano SLU
Registration No. CIF L-715014-M
Legal address: Passatge d'Europa, 1, 4th floor, AD500 Andorra la Vella, Andorra
Telephone number: +376 333 433
Email: [email protected]

Contacts of Data Protection Officer:
Legal address: Passatge d'Europe, 1, 4th floor, AD500 Androrra la Vella, Andorra
Telephone number: +376 333 433
Email: [email protected]

Amendments to this Policy will be posted to https://drimsim.com/ru/privacy-policy and will be effective when posted. If we’ll make any material changes to this Policy we will notify the data subjects by email (sent to the e-mail address specified in the account) or by means of a notice on the website prior to the change becoming effective. Any data subject can choose to discontinue use of our products and services if the data subject does not accept the terms of this Policy, or any modified version of this Policy.

We do not knowingly collect any personal information from children under the age of 18. Our products and services are not offered to individuals under the age of 18.

Refusal to provide the data may result in unavailability of provision of our products and services or poor user experience.

Each data subject has the right to lodge a complaint to supervisory authority in case of personal data breach, misuse or any violation of applicable law related to personal data processing.

Categories of Personal Data and Purposes of Processing

Contact details of our customers for the following purposes:
- to enter a contract with a customer;
- to perform a contract with customers;
- to comply with legal obligations on providing the data to government bodies;
- to provide technical support as part of our contract performance;
- to conduct marketing communications on our offerings as our legitimate interest;
- to contact our customers for service evaluation purposes by phone calls or other available means as our legitimate interest.

Any marketing communication is subject to the right to objection. The rights to objection may also apply to other kinds of processing activities.

Technical specifications of customer’s device for the following purposes:
- to enter a contract with a customer;
- to perform a contract with customers;
- to comply with legal obligations on providing the data to government bodies;
- to provide technical support as part our contract performance;
- to conduct marketing communications on our offerings as our legitimate interest;
- to support availability of our products and services;
- to improve customer experience.

Device identification and location data for the following purposes:
- to perform a contract with customers;
- to comply with legal obligations on providing the data to government bodies;
- to provide technical support as part of our contract performance;
- to support availability of our products and services as part of our contract performance.

Information on credit cards and other payment details for the following purposes:
- to perform a contract with customers;
- to provide technical support and fraud detection as part of our contract performance.
- to conduct anti-fraud activities as our legitimate interest.

Cookie data for the following purposes:
- to conduct marketing communications on our offerings as our legitimate interest;
- to deliver targeting ads by our advertisers on the basis of data subject’s consent;
- to collect statistical information based on data subject’s consent;
- to support availability of our products and services as part of our contract performance;
- to improve customer experience as part of our legitimate interest.

Cookie title Category Storage period Data processor Description
Facebook Pixel Marketing Lifetime Facebook Allows to measure effectiveness and optimize ads.
Facebook SDK Marketing Lifetime Facebook Allows to integrate website with Facebook.
Google analytics Statistical Lifetime Google Allows to analyze behaviour of website users.
Google Tag Manager Essential Lifetime Google Allows swift connection of Google Analytics and Yandex.Metrika with the website.
Yandex.Метрика Statistical 24 months Yandex Allows to obtain visual reports, recordings of user’s activities, track traffic sources and evaluate ads effectiveness.
Adspire Statistical 24 months Adspire Allows integration with CPA networks.
Branch.io Statistical 24 months Branch.io Provides traffic attribution and analytics.
FreshChat Essential 24 months Freshworks Inc Provides website messaging functionality.
Stripe Essential 24 months Stripe Provides payment functionality.
SourceBuster Statistical 24 months it-agency.ru Provides traffic source data.
JivoSite Essential 24 months jivo.ru Provides website messaging functionality.
Mango Essential 24 months Mango Telecom LLC Provides communication functionality.
Vkontakte Marketing 24 months Vkontakte LLC Provides individual content
Youtube Essential Up to 10 years Google Inc. These cookies are set by YouTube to track usage of its services.
Twitter Marketing Up to 14 years Twitter Inc. These cookies are set by Twitter to track usage of its services.
Linkedin Marketing Up to 6 months Linkedin These cookies are set by Linkedin to track usage of its services.
Vkontakte Marketing Up to 24 months Vkontakte These cookies are set by Vkontakte to track usage of its services and provide individual content.
Mail.ru Marketing Up to 6 months Mail.ru These cookies are set by Mail.ru to track usage of its services and provide individual content.
CHANGE COOKIE OPTIONS

Data on the customers’ communications with our products and services for the following purposes:
- to perform a contract with customers;
- to comply with legal obligations on providing the data to government bodies

Passport data and personal photo for the following purposes:
- to identify the customer in order to enter a contract with a customer;
- to comply with legal obligations on providing the data to government bodies;
- to conduct marketing communications on our offerings as our legitimate interest.

Profiling

We maintain profiles of our customers as it’s required to provide our customers with history of use of our products and services. The profile includes current balance and billing history. No automated decision making is conducted on the basis of profile except for the cases when our products and services may be provided in different manner on the basis of the customer’s balance. Insufficient balance may result in suspension of availability of our products and services.

Recipients of Personal Data

We may share personal information with the following recipients:
- our employees;
- hosting providers;
- technical support providers;
- partners which act as our contractors for provision of our products and services;
- government bodies.

We may transfer the data outside of EU and EEA provided that the transfer is subject to model contract clauses on international transfers of personal data.Providing information to our data processors is subject to signing a data processing agreement that sets out the subject-matter and duration of the processing, the nature and purpose of the processing, the type of personal data and categories of data subjects and the obligations and rights of the controller.

Period of Storage

The data will be stored during the period when our products and services are provided to the customer and as long as we have a legal obligation to store the data in order to supply it to government bodies.

Sensitive Information

We do not process the following information in any manner:
- racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data and health data or data concerning a person’s sex life or sexual orientation.

Rights of the Data Subjects

Each data subject has the following rights which may be exercised by contacting us. All the rights below have specific exceptions in certain cases. The requests will be processed within 30 days.

Right to access allows any data subject to request the following information from us:
- if its data is processed;
- which data is processed;
- which are the recipients or categories of recipients of personal data;
- data storage period;
- existence and nature of the rights to rectification/erasure/restriction/objection,
- existence of the right to lodge a complaint to supervisory authorities;
- sources of data;
- existence of profiling and automated decision making including their logic and consequences;
- existence of safeguards of international data transfers.

Right to rectification is the right to correct incorrect data and the right to complete the incomplete data.

Right to erasure (“to be forgotten”) means that the data subject may request erasure of his or her data in the following cases:
- the data is no longer needed for the purposes of processing;
- consent for processing is withdrawn and no other grounds of processing apply where such processing is based on consent;
- data subject objects to processing;
- processing is unlawful;
- the data is related to a child and was processed in the context of offering a service directly to a child.

Right to restriction means that processing shall be restricted if:
- the data subject claims that the data is inaccurate and controller needs to verify if it’s really inaccurate;
- processing is unlawful but the data subject wants processing to be restricted rather than the data to be erased;
- processing is no longer required for its purposes but the data subject requires it for specific purposes;
- processing is under objection but the controller needs to verify if objection is not overridden by legitimate interest of the controller.

Right to notification means that the data controller shall communicate the request of the data subject in exercise of his or her rights to each recipient unless it proves that it will take disproportionate effort.

Right to data portability means that data subject may request the data controller to provide collected data in structured and readable form.

Right to object means that the data subject based on its personal circumstances may override legitimate interests of the controller which constitute the basis for processing.

The data subject has the right not to be subject to profiling which significantly affects his or her interests.

Protection of Information

We take the following measures on protection of personal data to prevent the data breaches, misuse and the violation of rights of data subjects:
- Providing this Policy for review to any person or entity which is about to process the personal data.
- Keeping our officers and contractors responsible for proper data processing conducted by such officers and contractors.
- Providing advice to any officer, data subject or partner on the subject of compliance with this Policy.
- Making sure no access to personal data is provided to unauthorized parties.
- Using only reliable and tested software for processing or personal data.
- Assuming technical and organizational risks of data processing before such processing takes place.
- Ensuring that all actions in respect of the data are exercised by protected accounts to access the data and all data storages are available only to a limited number or persons on a password basis.
- Ensuring that we are able to suspend data processing or withdraw any piece of data from processing if we believe that such processing may violate applicable law.
- In case of change in any business process we will determine whether such change is data-related and check if such change falls in line with this Policy.
- Providing that each location and device where personal data may be stored is a safe environment.
-Utilizing firewall to minimize the risk of unauthorized access to the hosting infrastructure.
- Where necessary using third-party vendors to perform security assessments to identify issues with its data security that could result in security vulnerabilities.
- Providing encryption of most sensitive personal data.
- Ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services.
- Providing the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident.
- Processing regular testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the data processing.

Effective: February 22, 2022