Updated: November 12, 2025

Privacy Policy

Protecting your personal data is our priority. Learn how we collect, use, and protect your information.

🔒 Your Privacy Matters to Us

We adhere to strict data protection standards and give you control over your personal information.

1. General Provisions

1.1. This Privacy Policy (hereinafter — the Policy) regulates the procedure for collection, storage, processing, use and disclosure of personal data of users of the LirTune platform (hereinafter — the Platform). 1.2. The Platform Administration undertakes to protect the confidentiality of Users' personal data in accordance with the legislation of the Russian Federation and international data protection standards. 1.3. By using the Platform, the User expresses their consent to the terms of this Policy.

2. Information We Collect

2.1. Personal data provided by the User: • Full name or pseudonym • Email address • Phone number • Date of birth • Payment data (when making transactions) • Photos/avatar • Biography and creative description 2.2. Automatically collected data: • IP address and location data • Device and browser information • Visit history and activity on the Platform • Cookies and similar technologies • Content interaction data 2.3. User-created data: • Musical works, texts, audio recordings • Comments, reviews, messages • Playlists, favorites, listening history • Social connections (subscriptions, collaborations)

3. Purposes of Data Processing

3.1. Main purposes: • Providing access to Platform functionality • User identification and authentication • Processing transactions and reward payments • Personalization of user experience • Security assurance and fraud prevention • Technical support and maintenance 3.2. Additional purposes: • Analytics and Platform improvement • Marketing communications (with User consent) • Content and collaboration recommendations • Legal compliance and dispute resolution

4. Legal Bases for Processing

Processing of personal data is carried out on the following bases: • User consent (for marketing communications and optional data) • Contract performance (for providing Platform services) • Legitimate interest (for analysis and service improvement) • Legal obligation fulfillment (for tax reporting, etc.)

5. Data Storage and Protection

5.1. Storage periods: • Account data: until deleted by the User • Transaction data: 5 years (in accordance with tax legislation) • Activity logs: 1 year • Backup copies: 30 days 5.2. Protection measures: • Encryption of transmitted data (SSL/TLS) • Password hashing • Regular security system updates • Limited data access for employees • Regular security audits

6. Data Sharing with Third Parties

6.1. We may transfer data to the following categories of recipients: • Payment systems (for transaction processing) • Hosting providers and cloud services • Analytics services (in anonymized form) • Advertising partners (only with User consent) • Law enforcement agencies (upon lawful request) 6.2. International transfer: Data may be transferred to countries that provide adequate protection in accordance with Russian legislation.

7. User Rights

The User has the right to: 7.1. Access to personal data • Receive information about the processing of their data • Request a copy of stored personal data 7.2. Correction and update • Correct inaccurate or incomplete data • Update information in the personal account 7.3. Deletion and restriction • Delete account and related data • Restrict processing in certain cases 7.4. Objection and consent withdrawal • Withdraw consent to data processing • Object to certain types of processing 7.5. Data portability • Receive data in a structured format To exercise rights, contact: privacy@lirtune.com

8. Cookies and Similar Technologies

8.1. The Platform uses cookies for: • Authentication and security • Content personalization • Analytics and service improvement • Advertising purposes (with consent) 8.2. Cookie management: The User can manage cookie settings through the browser or control panel on the Platform. More details in the separate Cookie Policy.

9. Children's Data

9.1. The Platform is not intended for users under 14 years of age. 9.2. For users from 14 to 18 years old, parental or legal guardian consent is required. 9.3. If data of minors without required consent is detected, such data will be deleted.

10. Automated Decision Making

The Platform may use algorithms for: • Content and collaboration recommendations • Content moderation • Fraud detection • User experience personalization The User has the right to obtain human intervention in the decision-making process.

11. Notifications and Communications

11.1. Types of notifications: • Service notifications (mandatory) • Security notifications • Marketing communications (only with consent) • Policy change notifications 11.2. Notification settings: The User can manage notification settings in the personal account.

12. Policy Changes

12.1. We reserve the right to change this Policy. 12.2. Significant changes will be notified: • Through Platform notifications • By email • Through publication of the updated version 12.3. Continued use of the Platform after changes means acceptance of the new Policy.

13. Contact Information

For all questions related to personal data protection: Email: support@lirtune.com Legal address of the organization 117647, RUSSIA, MOSCOW, PROFSOYUZNAYA ST., 113, BLDG. 2, APT. 10 Request processing time: 30 calendar days

14. Dispute Resolution

14.1. Claim procedure: All disputes are initially resolved through negotiations. 14.2. Supervisory authorities: The User has the right to contact the authorized body for the protection of the rights of personal data subjects. 14.3. Judicial procedure: Disputes are resolved in the courts at the location of the Platform Administration.

Questions about privacy?

Our data protection team is ready to help you with any questions or requests related to your personal data.

Email: support@lirtune.com

Response time: up to 30 calendar days

Working hours: Mon-Fri, 9:00-18:00 (MSK)