PRIVACY POLICY

Release 12/01/2019

PRIVACY POLICY STATUS AND ACCEPTANCE  


1. This Privacy Policy (hereafter «Policy») sets common regulations of collection, processing, distribution, use and storage of user personal data of the web-site cinemadrom.com.


2. Here within this Policy the Platform cinemadrom.com uses a term of «Personal data» for information details, which may be related to a certain person (Participant), and it could be used for person identification (including information concerning Participant's occupation, as well as web-site use purpose, directly related to information that allow to determine user identity including data recovered automatically). cinemadrom.com does not take into account Personal data containing anonymous information therefore cinemadrom.com does not identify certain Participant.  


3. This Policy is an integral part of the General Terms and Conditions of LUT (LUTOKEN) and LUMIERE cripto coins Token sale. Conditions that are not regulated by this Policy are being a matter of General Terms and Conditions of LUT Token sale and should be treated accordingly.  


4. Definitions set forth herein this document and mentioned with capital letter are of concern determined within General Terms and Conditions of Token sale cinemadrom.com.  


5. It is determined and intended, that Participant completely read, understood and accepted this Policy after and based on a fact of web-site use, LUT token acquisition or provision of Personal Data on Participant demand. If any Participant does not agree with this Policy as a concept or with any part of it, this Participant must refuse to use the web-site and/ or LUT Token acquisition.  


COLLECTION, PROCESSING AND USE OF PERSONAL DATA  


6. The single and only purpose for collection and processing of Personal Data within cinemadrom.com must be identification of the LUT Token buyer - by the Platform cinemadrom.com.  


7. cinemadrom.com collects Personal Data on the web-site and uses Personal Data provided by a Participant. When a Participant visits web-site or uses our product, cinemadrom.com collects Personal Data, sent from a computer, mobile phone or any other Participant access device.

Personal Data includes:  

• Participant's IP-address;  

• device information, including such information as: identifier, name and type of the operating system, but not limited to it;  

• mobile network information;  

• standard information concerning weblogs history, as well as browser type and pages that has been accessed by Participant on this Web-Site cinemadrom.com. When Participant uses a device with geo-location feature for access and use of the web-site cinemadrom.com, we can gather geo-location data or use any other means of the geo-location, such as Participant's device indicators, which can, for example, transmit data about closest cellular tower or Wi-Fi access points. However, cinemadrom.com does not provide any personal identifying information to third parties without Participant's consent, except cases specified in this document.  


8. If a Participant intends to purchase LUT Token, we collect and store following Personal Data:  

• name;  

• e-mail address;  

• contact phone number.  


9. In some cases (when additional verification is needed from a bank or regulatory department of government compliance, Anti-Money Laundering Policy (AML) or Know-your-customer Policy (KYC), cinemadrom.com may require additional information from Participant, including:  

• residence address;

• date of birth;  

• passport or driver's license;  

• identifying numbers, which you use or registered in your local tax department;  

• utility bills;  

• photos;  

• proof of income origins;  

• other legally certified documents.  

Abovementioned information and details are provided only in case of personal request to a Participant and specified in relevant e-mail message with detailed description of the reason for additional verification request.  


10. cinemadrom.com reserves the right to request basic Personal Data, described in provision 9, before LUT Token purchase and/or any service available on the web-site. cinemadrom.com may refuse web-site access to a Participant in case if cinemadrom.com has rational suspicion caused by actuality, consistency or authenticity of Participant's provided Personal Data.  


11. If a Participant does not provide, specified in provisions 8 and 9 of this agreement, data to the web-site cinemadrom.com, Particiapnt cannot use all the features of the web-site and purchase Tokens at cinemadrom.com and/or use Platform cinemadrom.com Furthermore, cinemadrom.com will not be liable for incomplete service in this case .  


12. When Participant gains access to the Web-Site or uses products or services of it (or Google Analytics or similar service provider on our behalf) it may store small data files, so called cookie-files to computer or any other device of Participant. cinemadrom.com uses this kind of technology to identify you as a Token sale Participant, Web-Site adaption and advertising, or in safety means. Participant may control cookie-files usage in browser settings. If you refuse or delete certain cookie-files you have to understand that joint characteristics and our Web-Site and services, it provides performance may be downgraded.  


13. cinemadrom.com collects from Participants Personal Data only for purposes of cinemadrom.com for proper Web-Site use or for LUT Token purchase. In particular, cinemadrom.com uses Personal Data of Participant for:  

• Web-Site cinemadrom.com administration and service;  

• new services and products development;  

• Web-Site cinemadrom.com personalization for users;  

• technical, support and administrative notifications dispatch;  

• product, services, advertising campaign, events and other information communication that cinemadrom.com consider interesting for you;  

• provision of statistic information to third parties about cinemadrom.com participants (but those third parties will not be able to identify any Participant with this information);  

• detection, investigation and prevention of any kind of suspicious transactions, illegal activities and cinemadrom.com rights and property protection, etc.;  

• Participants Personal Data unification provided by Participants and about Participants.  


14. cinemadrom.com is one and only controller, as well it is the only person that process data, excluding cases, when rational need of control/processing Personal Data of Participant is needed for cinemadrom.com.  


15. Participant has right to gain access, browse and edit Personal Data via message to cinemadrom.com in written form.  


16. Participant has right to demand from cinemadrom.com delete Personal Data, provided by Participant or terminate agreement of collection, processing and storage of his (her) Personal Data any time. To do so, Participant must send related message, and cinemadrom.com is obliged to terminate Personal Data from any resource for 24 hours starting from the moment when cinemadrom.com received corresponding query. However, cinemadrom.com leaves right to suspend service for Participant referring to project cinemadrom.com and /or terminate Participant's account on Web-Site without any notice, as well as compensation payouts.  


17. cinemadrom.com will not publish any of Personal Data related to LUT Token purchase without written consent of any Participant.  


PERSONAL DATA SECURITY AND SHARING  


18. cinemadrom.com applies every effort and mean in accordance with applicable laws, to keep Personal Data secure.  


19. cinemadrom.com stores and processes all the Personal Data at cinemadrom.com servers in various jurisdictions where indoor spaces and/or service providers of cinemadrom.com located. Providing your Personal Data, you agree that it will be transfered, stored and processed. cinemadrom.com undertakes every mean possible to provide safe treatment of Personal Data in accordance with this Policy. cinemadrom.com protects Personal Data in accordance with international standards by using physical, technical and administrative means of safety, aimed to prevent and reduce the risks of misuse, unauthorized access, disclosure and alteration of Personal Data. Some of cinemadrom.com protection means and guarantees are network protection systems and data encryption, physical access control means, in our data processing centers and means of authorization access control to the information. cinemadrom.com also allow access to Personal Data only to employees and parties to perform their duty concerning the work and maintenance. All our physical, digital and processing protection means developed in accordance with applicable laws and regulations. Third parties may be in different countries, where laws concerning general data protection might be less strict than in your country. From times to times, your Personal Data may be stored in different places, and in this case cinemadrom.com guarantees that Personal Data will be carefully stored and processed with correct level of security.  


20. cinemadrom.com sometimes needs to compare provided Personal Data which are for the third parties databases to ensure data accuracy and confirm identity. This procedure allows cinemadrom.com conduct and comply with regulations of Anti-Money Laundering (AML) and «Know Your Customer» (KYC) procedures.  


21. cinemadrom.com will not provide Participant's Personal Data to third parties except corresponding partners of cinemadrom.com for identity match. cinemadrom.com leaves the right to provide Personal Data to:  

• banking or brokerage partners;  

• companies which cinemadrom.com is planning to merge with or which plan to purchase cinemadrom.com (in case of such merging, cinemadrom.com will inform all Participants and will require, that new merged company must comply with provided regulations towards Personal Data);  

• identification service providers to prevent fraudulent activities;  

• law enforcement, government officials or any other third parties, whereas cinemadrom.com is forced to do so in accordance with decision of the court of law or similar legal procedure;  

• hired or cooperating with platform counter-parties or agents for Personal Data processing procedures whose services driven by the practical point of view;  

• other third parties only with Participant's consent or direct order from Participant.  


22. cinemadrom.com will not provide Personal Data to other users or third parties except cases stated in provision 21 of this particular Policy, without consent or direct order of Participant.  


23. cinemadrom.com will not sell or provide Personal Data to third parties.  


24. cinemadrom.com may unite Personal Data with information, which is provided to cinemadrom.com by other companies and use it to upgrade and personalize Web-Site and our products, as well as our content and advertising.  


25. cinemadrom.com may use name and e-mail address of the user to provide product or services information, which may be interesting for the user.  


26. Services of cinemadrom.com may contain links to web-sites or from web-sites of our partners, advertisers and affiliates (including, among the others, web-sites where Web-Site is being advertised). While redirected to one of those web-sites, please note, that those web-sites and any services available on them, has their own Privacy Policies and cinemadrom.com is not responsible or liable for those policies or any Personal Data, which can be requested with use of the web-site data or services, such as contact data and geo location data. Before providing Personal Data to these web-sites or use their services please read abovementioned rules and privacy policy.  


INFORMATION STORAGE  


27. In accordance with applicable law and need to provide services to Participants, cinemadrom.com may store Personal Data of Participants. This requirement is determined by a need to comply with legal obligations and possible dispute resolution. cinemadrom.com may store your Personal data during the time of your possession of LUT Tokens and crept coins LUMIERE and/or while you use Web-Site. Besides, Personal Data may be stored even after period stated before till cinemadrom.com is needed to keep relevant information for answers or reactions to any questions that may occur afterwards.  


SAFETY  


28. cinemadrom.com uses relevant digital and processing guarantees for confidential information protection, which is provided by a Participant, for loss-protection, misuse, disclosure, alteration and termination. Please note, that data and information transfer (including e-mail messages) via Internet or any other public networks is not safe. Please note, that LUMIERE is not responsible for safety for any data transferred via Internet or side content.  


PERSONAL DATA ALTERATION/UPDATE/TERMINATION  


29. Participant leaves right to demand from cinemadrom.com access to Personal Data and demand alterations, update and termination of incorrect and/or inaccurate data by addressing to the cinemadrom.com. Nevertheless, this query must comply General Terms and Conditions of LUT Token Sale cinemadrom.com and comply with legal liabilities.  


AMENDMENTS


30. cinemadrom.com leaves right to modify and alter this Policy on its own convenience. Changes can be found in «Last update date» specified above. Further Web-Site usage confirms accept of Participant of these Provisions.