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**Privacy Policy**\\ 
This Privacy Policy is effective as of May 25, 2018.

**What This Policy Covers**\\
We respect the confidentiality of your personal data and take measures to safeguard it. This Policy describes the information we collect, how we use that information, our legal basis for doing so, and your rights regarding the information we collect.\\ 
We have implemented and maintain appropriate technical and organisational measures in order to protect personal data against loss, misuse and alteration, and to prevent personal data from being accessed by unauthorised persons. All your personal data is stored on secure servers.

**Who We Are**\\
When we refer to “we”, “our” or “us” in this Policy, we mean the company Telecommunication Technologies LLC, which acts as a controller of the information that is being collected from you. We list our contact details, as well as the contact details of our EU representative, at the end of this Policy. 

** What We Collect ** \\ 
In the process of your use of this set-top box (device), we may collect the following data.\\ 
  * **Device technical information.** This data comprises device type, serial number, MAC address, User Agent of a browser of the device, firmware version of the device, language of the device, portal URL used on the device, date of first use of a codec (computer program for encoding or decoding a digital data stream or signal) on the device, statistics on use of the applications installed on the device.\\ 
  * **Device location information.** This data comprises country and city of the device, IP-address used by the device. 

**Lawful Basis and Use of Collected Information**\\
We process personal data based on our legitimate interests for the following purposes:\\
  * **Use of data analytics to improve and develop our products and services.** For these purposes, we collect device type, serial number, MAC address, User Agent of a browser of the device, firmware version of the device, language of the device, portal URL used on the device, statistics on use of the applications installed on the device, country and city of the device, IP-address used by the device.\\
  * **Troubleshooting, data analysis, testing, system maintenance, user support, and counterfeiting prevention.** For these purposes, we collect device type, serial number, MAC address, User Agent of a browser of the device, firmware version of the device, language of the device, portal URL used on the device, statistics on use of the applications installed on the device, country and city of the device, IP-address used by the device.\\ 
  * **Statistics on use of codecs.** For these purposes, we collect device type, serial number, MAC address, firmware version of the device, country and city of the device, IP-address used by the device, date of first use of a codec. 

**How We Share Information We Collect**\\
We do not normally share with third parties personal information we collect. We limit access to your personal data to employees, agents, and contractors who need to access it to perform the abovementioned purposes. We may share the information with our affiliated companies in the course of normal business activities. Personal information may also get into possession of another controller as a result of a merger, acquisition or another business transaction. 

**How Long We Keep Information**\\
We keep the information we collect for as long as it is necessary to fulfill the purposes for which it was collected based on the following criteria:\\ 
  * the information we collect is device-specific;\\
  * the information we collect is of non-sensitive nature. 

**Your Rights**\\ 
Data subjects residing in certain countries, including the EU, are afforded certain rights regarding their personal information, subject to exceptions and exemptions set out in the applicable legislation. To exercise your rights, you can contact us at our email dataprivacy@infomir.com. These rights include:\\
  * **Access to your personal data.** You can clarify whether your personal data is being processed and ask us for a copy of your personal data in machine-readable form.\\ 
  * **Change or correct your personal data.** You can ask us to change, update or fix your personal data in certain cases, particularly if it is inaccurate.\\    
  * **Restrict processing or delete your personal data.** In some cases, you can ask us to restrict processing of your personal data or delete all or some of your personal data.\\ 
  * **Object to processing.** If you believe that the collection or processing of your personal data is unlawful on grounds related to your situation, you can object to such collection or processing.\\  
  * **Data portability.** In certain cases, you can transmit your personal data collected by us to another controller or ask us to transmit your personal data to another controller.\\ 
  * **File a complaint with a supervisory authority.** You may have the right to file a complaint with a relevant supervisory authority if you believe that your data protection rights are being infringed.\\ 
  * **Right to object to automated decision-making.** You have the right not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.

**How We Protect Personal Data**\\ 
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. We will respond to requests about this within a reasonable timeframe.

**Our Policy Towards Minors**\\
We collect only information that relates to the device and do not knowingly collect personal information from natural persons under 18. 

**Changes to Our Privacy Policy**\\
We may change our Privacy Policy from time to time. We will let you know of any changes and their effective date.  

**Contact Information**\\ 
If you have any questions or complaints regarding this Policy or you want to exercise your data protection related rights, you can communicate with us at the email address dataprivacy@infomir.com or by post at the addresses below: 

**Controller:**\\ 
Telecommunication Technologies LLC\\                                              
1 Mytna Square\\
Odesa 65026\\
Ukraine

**EU representative:**\\ 
Infomir OÜ\\
Rävala pst. 8, kabinet A312\\
Tallinn 10143\\
Estonia
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