1.1. This Policy is an official document of LUNDA Padel Limited Liability Company (OGRN: 1105004001167, INN: 5079011867, address: 143700, Moscow Region, work settlement Shakhtovskaya, Volochanovskoe sh., d.12 "b") (hereinafter referred to as the "Application Administration" or "Company"), and defines the procedure for processing and protecting information (hereinafter referred to as "Information") about individuals (hereinafter referred to as "Users") using the Lunda Padel software product, including the mobile application and website (hereinafter referred to as the "Application").
1.2. The purpose of this Policy is to ensure proper protection of information about Users, including their personal data, from unauthorized access and disclosure.
1.3. Relations related to the collection, storage, dissemination and protection of information about the Users of the Application are governed by this Policy and the License Agreement (hereinafter collectively referred to as the "Rules"), as well as the applicable legislation.
1.4. The condition for using the Application is the User's consent to the Rules. Each time the Application is accessed and/or actually used, the User agrees to the terms of this Policy, as well as to the terms of the License Agreement available at https://app.lundapadel.ru/regulations.html (hereinafter referred to as the "Agreement") in the versions that were in effect at the time of the actual use of the Application. A number of terms used in the Policy have the meaning defined in the License Agreement.
1.5. The current version of the Policy is available to any Internet user by following the link https://app.lundapadel.ru/policy.html. This Policy may be amended by the Application Administration. Any changes to the Policy are made by the Application Administration independently and come into force on the day following the day of publication of such changes. The Application Administration notifies Users of changes to this Policy, including by publishing a new version of this Policy. The User undertakes to independently familiarize themselves with the changes made to the Policy. The User's actual use of the Application after changes are made to the terms of this Policy signifies the User's agreement with the new terms.
1.6. If the User disagrees with the terms of this Policy, the use of the Application must be terminated immediately.
2.1. The Application Administration, granting Users the right to use the Application within the limits described in the Agreement, acting reasonably and in good faith, believes that the User:
has all necessary rights allowing them to register and use the Application;
provides accurate information about themselves to the extent necessary to gain access to and use the Application;
is aware and agrees that information about themselves posted by the User in the Application will be reflected in their Profile, and that such information may be available to other users of the Application.
2.2. The Application Administration does not verify the accuracy of the received (collected) information about Users.
The Application Administration processes information about Users for the purpose of fulfilling the agreement with the User (the License Agreement available at https://app.lundapadel.ru/regulations.html ).
4.1. The Information processed by the Application Administration includes:
4.1.1. Account Data, which means:
(a) data about the User provided by the User to create an account during registration in the Application;
(b) additional information filled in by the User when editing their account during the use of the Application;
(c) data additionally provided by the User at the request of the Application Administration for the purpose of the Company fulfilling its obligations to the User arising from the agreement on providing the Application's functionality.
4.1.2. Other data necessary for the functioning of the Application, namely:
(a) data on technical means (devices), technological interaction with the Application (including the host IP address, the User's operating system type, browser type, device type and model, device location data, Internet service provider);
(b) information automatically obtained when accessing the Application using bookmarks (cookies);
(c) information obtained as a result of the User's actions in the Application, in particular, information about adding any content;
(d) information obtained as a result of the actions of other Users in the Application;
(e) generalized analytical information about the use of Internet services.
The Accounting and Other data received by the Application Administration in the volume necessary and sufficient for their classification in accordance with applicable legislation as personal data are processed by the Application Administration as personal data under the terms of this Policy.
4.2. The table below provides a more detailed list of Account Data and Other Data that are processed by the Application Administration for the purpose of fulfilling the agreement with Users:
Information Collected
Purpose of Processing
Common for all platforms (web version, Android and iOS applications) when using the Application
Account Data, namely:
1) Data about the User provided by the User to create an account during registration in the Application, including name, surname, date of birth, gender, mobile phone number and other information necessary for the performance of the agreement with the User. During registration, the User is assigned an internal ID number that identifies the User in the Application;
2) Additional information filled in by the User when editing their account during the use of the Application, including email address, Telegram username, photo and video images and other information necessary for the performance of the agreement with the User;
3) Data additionally provided by the User at the request of the Application Administration (information specified by the User in the account, such as name and surname, email address, phone number, photo and video images);
Fulfillment of the Agreement with the User, in particular to provide access to the Application, to manage the Application, to confirm the ownership of the account in the Application by the applicant.
Other Data, namely:
4) information about the User's activity during the use of the Application;
5) information obtained as a result of the actions of other Users in the Application;
6) generalized analytical information about the use of Internet services;
We use this information to manage the Application. We may also use it to process complaints on your behalf and provide you with better services.
7) information obtained as a result of your use of payment functions in the application;
We use this information to manage the Application. We may also use it to process complaints on your behalf and provide you with better services.
8) information created by you in the Application;
We use this information to manage the Application, including to provide you with services.
Lunda Padel Application for Android and iOS
9) Data that becomes available to the Application Administration during the User's use of the Application, including device type, OS version, device model, time zone, preferred language, OS name, application version, year of manufacture of the User's mobile device, and other information necessary for the performance of the agreement with the User.
Fulfillment of the agreement with the User, in particular for managing the Application, improving the operation and personalization of the Application.
4.3. The functionality and rules of use of the Application may provide the User with the opportunity to place any other information in the Application (if applicable), in addition to that specified in clauses 4.1 and 4.2 of this Policy, if it does not contradict the requirements of the current legislation. The Company does not intend to process such information, as well as biometric and special categories of personal data. By posting information about themselves, the User understands that it may be available to an indefinite number of Internet users.
4.4. The Application Administration does not intend to process and does not process biometric data (in particular, does not use photo and video images for the purpose of identifying users) and special categories of data.
4.5. For the purpose of fulfilling obligations to provide the Application's functionality, the User expresses to the Application Administration consent to use the phone number or other User identifier to send messages to the User from the Application using the Application Administration's notification tools (push notifications), including with the involvement of services and applications of the Application Administration's partners or using other services and applications owned by the Application Administration. The Application Administration's own SDK is used for this, and User data is not transferred to the Application Administration's partners.
4.6. Cookies Processing
Cookies are small pieces of data that websites request from the browser used on the User's computer or mobile device. Cookies are stored locally on the computer or mobile device of Internet users.
The Application Administration collects and processes cookies in relation to Users visiting the Application's website.
The following types of cookies are used in the Application:
strictly necessary cookies / technical cookies: these cookies are necessary for the operation of the application and providing the User with the Application's services; among other things, they allow the Company to identify the User's hardware and software, including the browser type;
functional cookies: these cookies allow providing certain functions to facilitate the use of the Application, for example, by saving preferences (such as language and location).
Cookies are processed by the Application Administration solely for the purpose specified in section 3 of this Policy, under the terms and in the manner defined by this Policy.
5.1. The processing of User information is carried out in accordance with the following principles:
(a) legality of the purposes and methods of processing Account and Other Data;
(b) good faith;
(c) compliance of the purposes of processing such data with the purposes previously defined and declared during their collection, as well as with the powers of the Application Administration;
(d) compliance of the volume and nature of the processed Account and Other Data, and the methods of their processing, with the purposes of processing Account and Other Data;
(e) inadmissibility of combining databases created for incompatible purposes that contain Account and Other Data.
5.1.1. Terms and Purposes of Processing Account and Other Data
The Application Administration processes the User's Account and Other Data for the purpose of fulfilling the Agreement between the Application Administration and such User on granting the right to use the Application (section 3 of the Agreement https://app.lundapadel.ru/regulations.html).
5.1.2. Collection of Account and Other Data
The collection of the User's Account and Other Data is carried out during registration and/or authorization in the Application by the User filling out the registration form or by other available means, as well as subsequently when the User, on their own initiative, adds additional information about themselves using the Application's tools. The collection of Other Data is carried out during the User's use of the Application's functionality.
5.1.3. Storage and Use of Account and Other Data
Account and Other Data of users are processed and stored on the territory of the Russian Federation, while storage is carried out exclusively on electronic media, and processing is carried out using automated systems, except for cases where non-automated processing of Account and Other Data is necessary in connection with the fulfillment of legal requirements.
Account and Other Data are stored by the Application Administration until the purposes of their processing are achieved, namely for the duration of the Agreement with the User.
5.1.4. Transfer of Account and Other Data
Account and Other Data of Users are not transferred to any third parties, except for cases expressly provided for by these Rules.
The Company may transfer Users' Account and Other Data to third parties, in compliance with the purpose and if there are legal grounds specified in this Policy. Such third parties may include:
persons who participate in the provision of services related to the placement and display of information to users (including offers relevant to users' interests) in programs, products or services that are owned or controlled by such persons (e.g., Clubs, advertising networks, Organizers of sporting events and other persons, etc.);
persons who have legal grounds to process Account and Other Data, for example, if the transfer of Account and Other Data to such persons is carried out with the User's consent, including if Account and Other Data are necessary to provide the User with the appropriate service or to perform a specific agreement or contract concluded with the User, in particular, mobile operators and/or technological partners acting between the Company and mobile operators, in fulfillment of clause 6.4.10 of the License Agreement, clause 7.3 of this Policy. These persons also include partners and affiliates of the Company, whose data processing is provided for by the terms of this Policy;
any government or local self-government body to which the Company is obliged to provide information in accordance with applicable law upon the relevant request.
In order to provide a high-quality, multifunctional, user-friendly service focused on the personal needs and interests of Users, the Application Administration develops, improves, optimizes the current and implements new functionality of the Application (informational, communicative, advertising, educational, entertainment and other nature), including with the participation of partners and/or affiliates.
Taking into account the above, and also considering the Application Administration's compliance with the processing purposes specified in section 3 of this Policy, the User agrees and instructs the Application Administration to carry out the following actions:
processing, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), comparison, extraction, use, blocking, deletion/destruction of the User's Account and Other Data;
transfer of Account and Other Data to partners and affiliates, and their processing by partners and affiliates, on the basis of an instruction from the Application Administration (by the methods specified in this clause), as well as joint processing by partners and affiliates of Account and Other Data with data available to partners and affiliates;
collection (receipt) from partners and/or affiliates of the results of processing Account and Other Data together with data available to partners and affiliates, including in the form of integer and/or text values and identifiers.
The Application Administration may carry out cross-border transfer of Information to the minimum extent necessary for the purposes specified in this Policy, to third parties specified in this clause of the Policy.
5.1.5. Termination of Processing of Account and Other Data
Upon achieving the goals of processing the Accounting and Other Data, the Application Administration shall stop processing the Accounting and Other Data in one of the ways provided for by applicable law.
6.1. Users have the right to:
6.1.1. freely and free of charge access information about themselves by downloading their Profile in the Application, provided they log in to the Application using their phone number;
6.1.2. independently make changes and corrections to information about themselves in the User Profile in the Application, provided that such changes and corrections contain current and accurate information;
6.1.3. delete information about themselves from their Profile page in the Application;
6.1.4. require the Application Administration to clarify, block or destroy their Account Data if such data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and if it is impossible to independently perform the actions provided for in clauses 6.1.2. and 6.1.3. of this Policy;
6.1.5. receive from the Application Administration, upon request, information related to the processing of their Account Data.
6.2. The Application Administration is not responsible for the disclosure of the User's Account Data by other Users of the Application.
6.3. When Account Data (other user information) is deleted from the User Profile or the User account is deleted from the Application, information about the User copied by other Users is preserved.
7.1. The Application Administration takes technical and organizational-legal measures to ensure the protection of the User's Account and Other Data from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions.
7.2. To authorize access to the Application, the User's mobile phone number and access code are used. The User is responsible for the safekeeping of this information. The User must not transfer the access code to third parties and is obliged to take measures to ensure its confidentiality.
7.3. To ensure more reliable protection of User information, the Application Administration uses a system for linking the page to a mobile phone. To implement this system, the User must provide the Application Administration with their mobile phone number.
For the purpose of registering the User in the Application, their authorization, confirming the relevance of the phone number linked to the account, and restoring access to the account, the Application Administration is also entitled to send an access code via SMS message and/or via Telegram or by other technical means. After receiving the access code, the User must enter it in the corresponding window of the Application.
8.1. The Application Administration is not responsible for the actions of third parties who, as a result of using the Internet or the Application, gain access to information about the User. The Application Administration recommends that Users take a responsible approach to deciding on the amount of information about themselves posted in the Application.
9.1. Information about the Account and Other Data processed by the Application Administration, including the User's personal data, in connection with their use of the Application, is provided to the User or their representative upon request.
9.2. Requests are sent in writing to the address of the Application Administration or in another form stipulated by applicable law.
9.3. The User has the right to withdraw consent to the processing of their personal data by sending a written application to the Application Administration at the location of the Application Administration in accordance with the requirements of the current legislation.
Version as of 08/27/2025