PRIVACY POLICY

1. Terms and definitions

Service is a complex software and hardware solution that includes a Site owned by the Company and integrated with the YouTube video service, which serves to promote, optimize and produce video content on YouTube and on the Internet in general.

User – any individual who uses the site with the intention of joining the YouTube partner program using the Company's Service.

User data – provided with the consent of the User at the time of registration on the Site, the data necessary for the Company to make a decision to connect the User to the Company's Service. More details are provided in section 3.

Processing of User Data – any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with User Data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of User Data.

Confidentiality of User Data is a mandatory requirement for the employees of the Company to comply with the rules for processing and storage of User Data, to prevent their dissemination without the consent of the User or other legal basis, as well as to ensure by the Company the necessary mode of storage of User Data.

Use of User Data – actions (operations) with User Data aimed at identifying the User in order to provide access to the Site and obtain confirmation of the accuracy of the information specified by the User.

Destruction of User Data – actions as a result of which it is impossible to restore the content of User Data in the automated registration and accounting system of the Company's Customers or destruction of material media of User Data. Destruction of User Data is carried out in relation to Users with whom, within 30 days from the date of receipt of User Data, no contracts have been concluded and the storage period for their data has expired, or at the request of the User who withdraws his consent to the processing of User Data.

Information – information (messages, data), regardless of the form of their presentation.

Company – a legal entity that owns the Site: LETSON CORPORATION FZE SM Office K1-102-029, Ajman, UAE.

Site – a website located at https://letsoncorp.com/.

Publicly available personal data – personal data, access of an unlimited number of persons to which is provided with the consent of the subject or to which, in accordance with federal laws, the requirement of confidentiality does not apply.

Operator – the Company or a person authorized by it that processes the User Data of the Site users in order to provide authorized access to all the Site services, as well as determining the purposes of the User Data processing, the composition of the User Data, actions (operations) performed with the User Data, the procedure for storage and destruction User data of users.

Consent to the processing of User Data is a voluntary commission of implicated actions by the User when registering on the Company's website https://letsoncorp.com/, and authorizing in Google or YouTube services, namely putting a mark in the appropriate box, which is provided for the User to express consent to the terms of this Privacy Policy and the YouTube Terms of Service and Google privacy policy.

The User Account Control Panel is a web page designed to use the capabilities provided to the User on the Company's Service Site, to keep the User's contact information up-to-date and provide them with other information required by the Company to provide access to the Site. Access to the account page is organized using a secure protocol and only after the User is identified. In the control panel of the User's account, his personal data are indicated, changed and stored.

User account (Account / Personal Account) is a password-protected Internet space. Contains information about the user and accounting for his work on the Site. The account contains personal and contact information provided by the user when registering on the Site and in the course of work on the Site, namely: name, e-mail address, contact phone number.

User – a visitor to the Site. The User is the subject of the User Data upon completion of the registration procedure on the Site in the prescribed manner.

A cookie is a small piece of data that is sent by the Site server and stored on the User's device. Used to save certain data about you, for example, any settings and preferences. The use of cookies is preceded by obtaining the consent of the User.

2. General provisions

2.1. This Privacy Policy for working with User Data of Users is developed in accordance with the provisions of the applicable legislation governing the activities of the Company and the rules of the YouTube Terms of Service and Google privacy policy.

2.2. The purpose of developing the Privacy Policy is to ensure the protection of the rights and freedoms of the User when processing his User Data, including the protection of the rights to privacy, personal and family secrets, as well as to establish the responsibility of officials who have access to User Data for non-compliance with the requirements of the norms, regulating the processing and protection of User Data, as well as determining the procedure for processing and protecting User Data of all Users of the Company's Site, which are subject to processing solely in order to enable the Company to make a decision on connecting the User to the Service by concluding an appropriate agreement.

2.3. This Privacy Policy comes into force from the moment of its approval, and is valid indefinitely, until the entry into force of the Privacy Policy in the new edition.

2.4. The company has the right to make changes to the Privacy Policy at any time. When the Privacy Policy changes, the Company notifies the Users about this in the order of posting the new edition on the Site at the permanent address. Previous versions of the Privacy Policy are stored in the archive of the Company's documentation.

2.5. The continued use of the Site by the User after the posting of the Privacy Policy in the new edition is recognized by the Parties as the unconditional acceptance by the User of the terms of the Privacy Policy in full.

3. Data composition

3.1. The User Data of the Users processed by the Companies includes:

3.1.1. Data provided by the User in connection with registration on the Site:

e-mail addresses associated with the Google account, YouTube channels, as well as specified by the User for feedback and setting up referral links;
information about the preferred language of communication;
YouTube channels and Information related to them, including the channel URL, its name, the number of views and subscribers of the channel, the date the channel was created, the presence or absence of comments, their number, information about the objects of copyright and related rights posted on the channel, including their names, the number date of posting and information about views).

The Company, prior to making a decision to join the User to the Service, may additionally request other information necessary to conclude an agreement (for example, Surname, Name, Patronymic). In the event that the User signs an agreement, the User Data specified in such an agreement shall be deemed provided to the Company on the basis of such an agreement.

3.1.2. Personal data provided in connection with the User's request to the Company with relevant requests (about the processing of User Data, about the termination of the processing of User Data, etc.):

surname, name, patronymic of the applicant;
information about the reasons and purpose of the appeal;
information about the presence of a personal account on the Site and the possibility of it identification;
the signature of the User or his representative.

3.1.3. Additional personal data of the User provided by the User on his own initiative without demanding such by the Company.

3.2. The Company collects and stores the data specified in clause 3.1. of this Privacy Policy in electronic form, containing information about the User obtained as a result of filling out and sending by the User the Feedback Form established by the Company. The form provides for a message by the User to the Company:

e-mail;
information entered by the user in the text message field.

3.3. The data specified in clause 3.1. of this Privacy Policy are processed by the Company.

3.4. User Account Control Panel:

3.4.1. The Company stores for 30 days, only information in electronic form:

received from YouTube channels, and Google accounts, access to which is provided to the Company by the User;
data from the Personal Account on the Site, indicated by the User himself;
containing data about the User.

The Company does not process special and biometric personal data of Users.

4. Purpose of processing User Data

4.1. The purpose of processing the User's Data is the implementation of a set of actions aimed at the implementation of the following tasks:

the Company makes a decision to connect the YouTube channel to the Company's media network, incl. on the conclusion of a license agreement with the User.
creating and maintaining a User account (User account) on the Company's Website;
identifying the User on the User's account page and providing access to the services of the Site https://letsoncorp.com/;
providing the User with information about the Company, our services, and events;
communication with the User when the User contacts the Company (feedback form, etc.);
fulfillment of the powers and duties assigned to the Company by the legislation of the location of the Company;
sending the Company news materials to the User, provided that the User subscribes accordingly.

4.2. The condition for the termination of the processing of User Data is the liquidation of the Company, as well as the corresponding request (request) of the User to delete his User Data or termination.

4.3. The processing of User Data is carried out on the basis of the principles:

the legality of the purposes and methods of processing User Data;
good faith;
compliance of the purposes of processing User Data with the purposes predetermined and declared during the collection of User Data, as well as the powers of the Company;
correspondence of the volume and nature of the processed User Data, methods of processing User Data to the purposes of processing User Data.

5. Collection and protection of User Data

5.1. The procedure for obtaining (collecting) User Data:

5.1.1. The User provides all User Data, voluntarily in electronic form, by accepting requests and confirming the consent requested from the User before using and during the use of the Site. Also, User Data can be obtained by filling out feedback forms by the User, e-mail sent from the User to the address of the company, or written agreements between the User and the Company.

5.1.2. The User's consent to the processing of his User Data is stored electronically.

5.1.3. The User's consent to the processing of User Data for the purposes of this Privacy Policy is valid until the goals of their processing are achieved or in case of loss of the need to achieve these goals before the User's consent is withdrawn, in any case, the period should not exceed 30 days from the date of receipt of the User Data.

5.1.4. The processing of User Data without the consent of the User is carried out in the following cases:

User data is publicly available;
at the request of judicial or law enforcement agencies in cases stipulated by law;
the processing of User Data is carried out for statistical purposes, subject to the mandatory depersonalization of User Data.

5.1.5. The Company does not request or process special categories of User Data: data about his race, nationality, political views, religious or philosophical beliefs, health status, intimate life.

5.2. The procedure for processing User Data:

5.2.1. The User provides the Company with reliable information.

5.2.2. Only employees of the Company who are allowed to work with User Data and who have signed a Non-Disclosure Agreement for User Data may have access to the processing of User Data.

5.2.3. Employees admitted to work with User Data perform their duties in accordance with internal local regulations, in particular in accordance with this Privacy Policy. With the above data, employees were instructed on how to work with User Data.

5.2.4. The processing of User Data can be carried out exclusively for the purposes established by the Privacy Policy and in compliance with applicable law.

5.2.5. When determining the volume and content of the processed User Data, the Company is guided by this Privacy Policy, the goals and objectives of the processing and applicable law.

5.3. User data protection

5.3.1. The protection of User Data is understood as a set of measures (organizational, administrative, technical) aimed at preventing unauthorized or accidental access to them, destruction, modification, blocking, copying, distribution of User Data, as well as against other illegal actions.

5.3.2. The protection of User Data is carried out by the Company.

5.3.3. When protecting User Data, the Company takes all necessary organizational, administrative, and technical measures, including:

anti-virus protection;
audit (monitoring) security / vulnerability;
management of access to the network, management of the local network, control over the premises of the Company, where User Data is stored;
registration and accounting;
ensuring the storage of information containing User Data, excluding access to them by third parties;
general control over compliance by employees with measures to protect User Data;
protection of User Data stored in the electronic databases of the Company from unauthorized access, distortion, transfer, and destruction of information, as well as from other illegal actions;
data transmission over secure communication channels. The interfaces of information systems are protected using the HTTPS protocol using end data encryption certificates when transferring between the storage server and the workstation; to transfer information to the equipment, an impersonal form is used that contains only IP addresses and other technical attributes of the services provided;
the persons directly involved in the processing of User Data are familiar with the provisions of the documents that determine the policy regarding the processing of User Data, local acts on the processing of User Data;
a person responsible for organizing the processing of User Data has been appointed;
models of security threats to personal data in information systems have been developed;
accounting of machine media of User Data is provided;
it is possible to restore User Data, modified or destroyed due to unauthorized access to them;
rules for access to User Data processed in the information system have been developed, and registration and accounting of all actions performed with User Data in the information system is provided;
the possibility of uncontrolled penetration or stay of unauthorized persons into the premises where work with User Data is carried out is excluded;
the safety of the User Data carriers and information security means is ensured.

5.4. Storing User Data

5.4.1. The personal data of Users in electronic form are stored on the servers of the Company.

5.4.2. Protection of access to personal data of Users is ensured by:

using licensed antivirus programs that prevent unauthorized entry and access to personal data of Users;
differentiation of access rights of employees using an account;
firewall.

5.4.3. Answers to written requests from other organizations and institutions about User Data of Users are given only with the written consent of the User himself unless otherwise provided by applicable law. User data can be transferred at the official request (prescription) of authorized and competent state bodies without obtaining the consent of the Users.

6. Transfer and storage of User Data

6.1. Transfer of User Data

6.1.1. The transfer of User Data is understood as the transfer of information through communication channels and / or on tangible media.

6.1.2. When transferring User Data, employees of the Company must comply with the following requirements:

not to disclose the User's personal data to third parties for commercial purposes;
not to disclose the User's personal data to a third party without the written consent of the User, except in cases established by law;
notify the persons receiving the User's personal data that these data can be used only for the purposes for which they are communicated, and require these persons to confirm that this rule has been observed;
allow access to personal data of Users only to specially authorized persons, while these persons should have the right to receive only those personal data of Users that are necessary to perform specific functions;
transfer User Data of Users within the Company in accordance with this Privacy Policy, local regulatory documents, and job descriptions;

6.1.3. The Company does not carry out a cross-border transfer of User Data.

6.2. Storing User Data

6.2.1. The storage of User Data of Users is understood to mean the existence of records in electronic systems (local network) and on the material media of the Company. User data is stored primarily on electronic media and processed with the use of automated systems, except for cases when the manual processing of User Data is necessary for connection with the fulfillment of legal requirements.

6.2.2. The storage of User Data can be carried out no longer than required by the purpose of processing, but in any case no more than 30 days, unless otherwise provided by law or an agreement with the User. Continued use of the Service by the User for more than 30 days is the User's consent to continue storing User Data beyond the time limit set in this clause.

6.2.3. During the storage period, personal data cannot be anonymized or destroyed.

6.2.4. After the expiration of the storage period, personal data may be anonymized and destroyed.

7. Blocking, depersonalization, destruction of User Data of Users

7.1. The procedure for blocking and unblocking User Data:

7.1.1. Blocking of User Data of Users is carried out with a written application of the User.

7.1.2. Blocking User Data implies a temporary suspension of the processing of User Data (unless the processing is necessary to clarify User Data).

7.1.3. Blocking of User Data can be temporarily removed if required to comply with the legislation of the Russian Federation.

7.1.4. Unblocking of User Data is carried out with his written consent (if there is a need to obtain consent) or the User's statement.

7.1.5. The User's repeated consent to the processing of his User Data (if necessary to obtain it) entails the unblocking of his User Data.

7.2. Procedure for the destruction of User Data

7.2.1. Destruction of User Data - actions as a result of which it becomes impossible to restore the content of User Data in the information system of User Data and (or) as a result of which tangible media of User Data are destroyed, as well as the termination of any access to personal data.

7.2.2. When the User Data is destroyed, the employees of the Company cannot gain access to personal data.

7.2.3. Destroyed User Data in the Company's system and on the Website cannot be restored.

7.2.4. The operation of destroying User Data is irreversible.

8. Rights of the Company when working with User Data

8.1. The company has the right to:

provide personal data of Users to third parties, if provided for by applicable law (tax, law enforcement, judicial authorities);
refuse to provide User Data in cases stipulated by law;
use the User's personal data without his consent in cases provided for by law.

9. User rights

9.1. The user has the right to:

demand clarification of your User Data, their blocking or destruction if the data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
require a list of processed User Data available in the Company and the source of their receipt;

9.2. Users have the right to send their requests to the Company, including requests regarding the use of their User Data in the form of an electronic document through the feedback form on the Site.

The request sent by the User must comply with the requirements established by the Company, namely, contain the following information:

e-mail address or other data allowing contact with the submitter of the request;
surname, name, patronymic of the applicant;
information about the reasons and purpose of the appeal;
information about the presence / absence of a personal account on the Site and the possibility of its identification;
signature of the user or his representative.

If necessary, in order to promptly and fully consider the User's request by the Company, the Company has the right to request additional information from the User.

The Company undertakes to consider and send a response to the User's request no later than 30 days from the date of receipt of the request.

10. Responsibility for violation of the rules governing the processing and protection of User Data

10.1. Company employees guilty of violating the rules governing the receipt, processing, and protection of User Data bear disciplinary, administrative, civil, or criminal liability in accordance with the current legislation of the Russian Federation and internal local acts of the Company.

10.2. The company bears civil and administrative responsibility for violation of legislation in the field of processing and protection of User Data.