This Privacy Policy specifies the method of collecting, processing and storing personal data necessary to provide services provided through the Pisennyk.com.ua website (hereinafter "Website") and the mobile application "Pisennyk" (hereinafter "Application").

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will inform you of any changes by updating the "Last updated" date of this Privacy Policy. We encourage you to periodically review this Privacy Policy to stay up to date with updates. Your continued use of the website and application after the date of the revised Privacy Policy will be deemed informed, will be governed by and will be deemed your acceptance of the changes to any revised Privacy Policy.

Personal data Administrator

The administrator, i.e. the entity deciding how your personal data will be used, is Lune Systems BV with its seat in Hullenbergweg 280, 1101BV Amsterdam, the Netherlands (hereinafter "We" or the "Publisher") - the publisher of the Pisennyk.com.ua website, and the mobile application "Songbook" (Pisennyk).

For questions and requests regarding personal data, please contact us via the contact form.

Data collected automatically

• The Publisher does not collect personal data without the User's consent, but only data that does not have such an attribute, in particular demographic data and data on the use of the Website or Application. The collection of data described in the preceding sentence takes place automatically (hereinafter referred to as "automatically collected data").
• Data collected automatically does not allow for the unequivocal identification of the User.
• Data collected automatically may be used by the Publisher to improve the quality of the services provided, in particular in the event of an error. In the situation described above, the data collected automatically will relate to the Application error, including the state of the User's mobile device at the time of the error, identification of the User's mobile device at the time of the error.
• It is not possible to change or delete data collected automatically.

Collection of personal data

You can use our website without providing any personal information. To create an account and allow access to personalised functionalities (like adding content to favourites) you must provide:

• Your name or nickname
• correct e-mail address

If for some reason you do not provide this personal data, you will not be able to use the personalised options of the Website and Application.

Data from social networks

To facilitate the registration process, the Application and the Website may, with your consent, access basic information about your social network account, such as Apple, Facebook, Google, including your name, email address, gender, birthday, current city and the URL of your profile picture.

Processing of personal data

We process the users' personal data collected by the Publisher in a manner consistent with the scope of the consent granted by the user or on the basis of other statutory premises legalising the processing of data (primarily for the purpose of providing services and for a legally justified purpose - direct marketing of our products or services), in accordance with the requirement laws.

We also process your personal data for the purposes indicated below, based on the legitimate interest of the Publisher, which is:

• monitoring your activity and all other users' activity, including, for example, searching for keywords, publishing content and managing your activity on the website;
• matching advertisements in accordance with the content previously viewed by you;
• contacting you, including for purposes related to permitted marketing activities, through available communication channels;
• providing payment services;
• ensuring the security of the services that we provide you electronically, including enforcement of the internal rules of Tipping and counteracting fraud and abuse, and ensuring traffic safety;
• conducting research and analysis, including in terms of functionality, improvement of services or estimation of the main interests and needs of visitors;
• handling your requests, in particular sent to the user service department and via the contact form;
• organization of loyalty programs, competitions and promotional campaigns in which you can take part;
• conducting statistical analyzes;
• data storage for archiving purposes (showing compliance with our obligations under the law).

If you agree, we process your personal data for the purpose of:

• saving data in cookies, collecting data from websites and mobile applications;
• organization of competitions and promotional campaigns in which you can take part;

You can withdraw your consent to the processing of personal data at any time in the same way as you expressed it. We will process your personal data until you withdraw your consent.

User rights and obligations

We guarantee the fulfilment of all your rights under the general data protection regulation, i.e. the right to access, rectify and delete your data, limit their processing, the right to transfer them, not to be subject to automated decision making, including profiling, and the right to object to processing Your personal data.

You can exercise these rights when:

• regarding the request for data rectification: you will notice that your data is incorrect or incomplete;
• in relation to the request to delete data: your data will no longer be necessary for the purposes for which it was collected by the Publisher; you will withdraw your consent to the processing of data; you object to the processing of your data; Your data will be processed unlawfully; the data should be deleted in order to fulfill the obligation resulting from the law or the data has been collected in connection with the provision of electronic services offered to the child;
• in relation to the request to limit the processing of data: you will notice that your data is incorrect - you can request that the processing of your data be restricted for a period that allows us to check the correctness of this data; Your data will be processed unlawfully, but you will not want it to be deleted; Your data will no longer be needed for us, but you may need it to defend or pursue claims; or you object to data processing - until it is determined whether the legitimate grounds on our side override the grounds for objection;
• in relation to a request for data transfer: the processing of your data takes place on the basis of your consent or a contract concluded with you and when this processing is carried out automatically.

You have the right to lodge a complaint regarding the processing of your personal data by us to the supervisory body, which is the Inspector General for Personal Data Protection.

Objection to the processing of your data

You have the right to object to the processing of your personal data when:

• the processing of your personal data takes place on the basis of a legitimate interest or for statistical purposes, and the objection is justified by the specific situation in which you have found yourself,
• Your personal data is processed for direct marketing purposes, including profiling for this purpose.

Provision of personal data

We share your personal data with entities that support us in the provision of electronic services, i.e. those that provide payment services, support user service, support the promotion of offers, and cooperate in marketing campaigns. We can transfer your personal data to public authorities fighting against fraud and abuse.

Due to the need to prevent the performance of certain functions of internet robots, we use the Google reCAPTCHA mechanism to sporadically test whether the behavior of users of our trading platform is not characterized by the behavior of robots. In this case, we may disclose your IP address to Google LLC.

We may also work with selected third party vendors such as Google Analytics to enable the use of tracking technologies and remarketing services on the Application and the Site by using first party cookies and third party cookies to analyze and track the use of the Application and the Site by users. Determine the popularity of specific content and better understand online activity. By accessing the Application, you consent to the collection and use of your information by these third party providers. We do not share personal data with these third party suppliers.

Storage of personal data

We store your personal data for as long as your account is active, and also after its deactivation, for the purposes of:

• performance of obligations under the law, prevention of abuse and fraud,
• statistical and archiving,
• for a maximum of 10 years from the date of deactivation of the account.

We store your personal data for marketing purposes for the duration of the account activity or until you object to such processing, depending on which of these events occurs first.

In the case of organizing loyalty programs, competitions and promotional campaigns in which you can participate - we will process your data for the duration and the period of settlement of the award ceremony. In order to be accountable, i.e. to prove compliance with the provisions on the processing of personal data, we will store data for the period in which Publisher is obliged to keep data or documents containing them to document the fulfillment of legal requirements and enable control of their fulfillment by public authorities.

Your personal data will be processed in an automated manner (including in the form of profiling), however, it will not have any legal effects on you or similarly significantly affect your situation.

Privacy policy for minors

We do not knowingly obtain information from children under the age of 13. If you become aware of any information we have collected from children under the age of 13, please contact us using the contact details provided below.

Contact details

Lune Systems BV, Hullenbergweg 280, 1101BV Amsterdam

Last Updated: March 20, 2021