PRIVACY POLICYThis Privacy Policy explains privacy practices of Lucky Laika Distribution OÜ and applies when
Lucky Laika Distribution OÜ processes Your personal data related to Your use of the VOD Platform.
This Privacy Policy may be subject to change from time to time, without prior written notice, taking
effect upon making the changes available on the VOD Platform. Please read this Privacy Policy
carefully to understand our practices regarding Your personal data and how we will collect and may
use and disclose Your personal data.
If You have any questions about how we process Your personal data specifically or if You wish to
submit an application for exercising Your rights related to processing of Your personal data, pleasecontact us through the contact information provided in the section "Contacts" below.
1.

DEFINITIONS“Content”

means any films, live events and/or other content madeavailable on the VOD Platform;“LLD”

means Lucky Laika Distribution OÜ, a company registered in
Estonia, registry code: 16282680, address: Estonia pst 9,
Tallinn 10143, Estonia, e-mail: info@firebirdmovie.com“VOD Platform”

means the video on demand platform operated by LLD, whichenables to make the Content available to the Users by way ofproviding TVOD services;“TVOD”

means transactional video on demand, referring to the paid
exploitation of content for temporary use by the User by way of
streaming;“Order”

means the declaration of intent of the User to purchase theright to view the selected Content on the VOD Platform inaccordance with these Terms and Conditions;“data controller”

means a natural or legal person, public authority, agency orother body which, alone or jointly with others, determines the
purposes and means of the processing of personal data. In thecontext of this Privacy Policy, data controller means LLD,
unless explicitly stated otherwise;“data processor”

means a natural or legal person, public authority, agency orother body which processes personal data on behalf of the data
controller;“data subject”

mean the natural person end users of the VOD Platform(consumers);“GDPR”

means Regulation (EU) 2016/679 of the European Parliamentand of the Council of 27 April 2016 on the protection of natural
persons with regard to the processing of personal data and on
the free movement of such data, and repealing Directive
95/46/EC (General Data Protection Regulation);“personal data”

means any information relating to an identified or identifiable
natural person (data subject); an identifiable natural person is
one who can be identified, directly or indirectly, in particular on

the basis of such a record as the name, personal identification
code, place of location information or network identifier, or on
the basis of one or more physical, physiological, genetic,
mental, economic, cultural or social identities;“processing”

means any operation or set of operations which is performedon personal data or on sets of personal data, whether or not by
automated means, such as collection, recording, organisation,
structuring, storage, adaptation or alteration, retrieval,consultation, use, disclosure by transmission, dissemination orotherwise making available, alignment or combination,
restriction, erasure or destruction;“Privacy Policy”

defined in the preamble;“Sales Contract”

means the contract concluded between the User and LLD inaccordance with these Terms and Conditions for receiving theright to review the Content on the VOD Platform by way ofTVOD;“special category data”

Personal Data revealing racial or ethnic origin, politicalopinions, religious or philosophical beliefs, or trade union
membership, and the processing of genetic data, biometricdata for the purpose of uniquely identifying a natural person,
data concerning health or data concerning a natural person's
sex life or sexual orientation;“TermsConditions”

means terms for using the LLD services, available athttps://www.firebirdfilm.com/terms-and-conditions
andwww.firebirdfilm.com/vod-terms-and-conditions;and“Website”

means website at https://www.firebirdmovie.com and its
subdomains;“We”, “us”, “our”

has the same meaning as “LLD”;“You” or “User”

has the same meaning as the “data subject”, meaning thenatural person end users of the VOD Platform (consumers).

2.

WHAT PERSONAL DATA WE MAY PROCESS?

2.1

Personal data LLD may process about You if You use our services, VOD Platform or Website
may include the following data:
2.1.1

general personal information: name, age, gender;

2.1.2

contact information: e-mail address; mailing address; phone number;

2.1.3

payment information: payment methods and amounts paid in relation to the use of ourservices;

2.1.4

usage information: information on how our services, VOD Platform or Website areused, including feedback provided;

2.1.5

technical information: technical information collected during Your use of services,
VOD Platform or Website such as your IP address or information collected throughcookies (please also see LLD Cookie Policy for further information about datacollected through the use of cookies);

2.2

More detailed overview of the personal data LLD processes is provided in the Section 5
below.

3.

ON WHAT LEGAL BASIS WE RELY WHEN PROCESSING PERSONAL DATA?

3.1

LLD may process personal data of the User for the purpose of being able to provide theservices in accordance with LLD Terms and Conditions. Legal basis for such data processing
is GDPR Article 6-1-(b), i.e. processing is necessary for the performance of a contract towhich the data subject is party or in order to take steps at the request of the data subject prior
to entering into a contract

3.2

LLD may process personal data when processing is necessary for compliance with a legal
obligation to which LLD is subject. Legal basis for such data processing is GDPR Article
6-1-(c). As an example, LLD may need to process collect and process personal to comply
with accounting regulations and tax obligations. LLD also relies on legal obligation as a valid
legal basis for data processing, when we are obligated to transfer personal data to relevant
authorities on the basis of their valid requests (such as to the court on the basis of valid court
order).

3.3

LLD may process personal data where processing of personal data is necessary for the
purpose of legitimate interests pursued by LLD or other controller, if appropriate. For example,
we may process statistical and/or aggregated data on how our services, VOD Platform or
Website are used to improve and further develop our services, VOD Platform or Website sothat we can provide a better user experience in future. Legal basis for such data processing is
GDPR Article 6-1-(f). Additionally, LLD may rely on the legitimate interest to establish,
exercise and defend legal claims, to handle complaints or for administrative purposes. Whenrelying on a legitimate interest as a legal basis, LLD ensures that processing is proportionate
and that we have carried out proper legitimate interest impact assessment, if necessary.

3.4

LLD may process personal data based on the consent granted by the User. Legal basis forsuch data processing is GDPR Article 6-1-(a). In those situations, we process personal dataon the terms as provided in the consent that has been granted to us by each User. If you have
granted a consent for data processing, the types and categories of personal data we transfer,the specific recipient(s) of the personal data and other appropriate and relevant information
are provided in the specific consent that may be asked from you.

3.5

More detailed overview of the legal bases LLD relies on when processing personal data isprovided in the Section 5 below.

4.

HOW LONG IS PERSONAL DATA RETAINED?

4.1

LLD does not retain personal data longer than it is necessary for the purposes of processing
personal data or pursuant to applicable law. As a general rule, LLD applies the following
retention periods.

4.2

Personal data related to contracts can be retained during the term of the contract and basedon LLD legitimate interest pursuant to Article 6 (1) (f) of the GDPR until the end of thestatutory limitation periods under applicable law. Accordingly, as a general rule LLD retains
User data collected in relation to the provision of the services as long as it is necessary for theprovision of the service during the term of the Sales Contract and for 3 years after thetermination of such agreement.

4.3

Personal data collected on the basis of the consent will be retained until the withdrawal of theconsent or in accordance with the terms of specific consent.

4.4

Personal data related accounting source documents and accounting journals must be
retained in accordance with the relevant accounting laws. LLD must retain accounting
documents for 7 years.

4.5

More specific details about the retention periods are provided in Section 5 below.

5.

FOR WHAT PURPOSES DO WE PROCESS YOUR PERSONAL DATALLD processes personal data for the following purposes:
Purposeprocessing

of

Types
of
personal data

How have weobtained
personal data
Directly
from
each
data
subject.

Enabling the Userto submit Orderandconclude
Sales Contract toenable access totheContent(performance of
the
Sales
Contract).

E-mail address,
ticket ID createdfor User.

Determining thegeneralgeographic
location of theUser to enable theContent
inaccordance withterritorial
limitations undertheapplicablelaws (including incompliance with
theRegulation(EU) 2017/1128
and other relevant
legal acts)
Sending
newsletter to theUsers who have
opted to receive
marketingtoe-mail.
Accounting
andpayment related
information data(compliance with
the
legal
obligation)

Location data, IP
addressandrelevant technicaldata.

Automatically.

E-mail address.

Directly
eachsubject.

Accounting
source documents
created in thecourse of use of
the services by
the User andperformance
of
the
Sales
Contract
that
include payment

Directly
from
each
data
subject or fromour
payment
serviceproviders.

from
data

Retention
period applied
by LLD
During the termof the Sales
Contract and forthe period of 3
years after theterm of the Sales
Contract basedon our legitimate
interest until the
end
of
the
limitation periods
under applicablelaw.
During the termof the Sales
Contract and forthe period of 3
years after theterm of the Sales
Contract basedon our legitimate
interest until the
end
of
the
limitation periods
under applicablelaw.

Legal basis forprocessing

GDPR
6-1-(b);
ArticleGDPR
6-1-(f).

ArticleGDPR
6-1-(c);ArticleUntil
thewithdrawal of theconsent by the
User.

GDPR
6-1-(a).

Article7 years.

GDPR
6-1-(c).

ArticleGDPR
Article6-1-(b);GDPR
Article 6-1-(f).

Answeringinquires ofdata subject.

the
the

Usage information
concerning
the
use
of
our
services,
VOD
Platform
orWebsite.

Technical
datacollected thoughcookies.

information suchas the amounts
paid by the User,
date of making
the payment andpayment methodused,
To comply with Directly
fromthe requests that eachdata
the User may subject.
send to us fromtime to time.
To be able to Automatically.
understand how
our services areused to enable
betteruser
experience and tohelp us prevent,detectandinvestigate
potentiallyprohibitedorillegal activities on
VOD Platform orourWebsite,including fraud or
intellectual
propertyandcopyright related
violations, and to
enforce our Terms
and Conditions orSales Contract.
Please see Cookie Policy.

3 years.

GDPR
6-1-(b).

ArticleUp to 3 years.

GDPR
6-1-(f).

Article6.

WHEN DO WE SHARE YOUR PERSONAL DATA?

6.1

LLD may share User personal data with certain third parties service providers e.g. IT
suppliers, other service providers or co-operation partners.

6.2

LLD may also share User personal data with third parties if LLD is legally required to do so,for example if personal data is requested from us by any authority competent to ask such datain accordance with applicable law.

6.3

LLD may also share your personal data with third parties if you have granted your consent forthat for specific transfer or based on other appropriate legal basis (for example, performanceof a contract or legitimate interest).

6.4

LLD may transfer User personal data to third countries, i.e. countries outside the EU/EEA
area, for the purposes explained in this Privacy Policy. When transferring User personal data
to third countries, LLD will ensure that the transfer is subject to appropriate safeguards under
the GDPR and that User rights are protected, such as the Commission’s model contracts forthe transfer of personal data to third countries (i.e., the standard contractual clauses). User

may request a copy of the safeguards we have put in place with respect to the transfer of
personal data by contacting LLD via contact details below.
6.5

In relation to the use of the Services and the Platform, User personal data may be disclosed
to following recipients:

Type
recipientofProviders
IT-services
serversofandProviderspayment
solutions.

PurposedisclosureofLocation of therecipientAppliedsafeguard

Role of therecipient

Provisionof
IT-solutions andotherrelatedservices(including
servers)
necessary
for
LLD
daily
businessfunctions and toenablethefunctionalityof
VOD Platform.

EEA
worldwide.

andData processing
agreements

Processor to
LLDofProvisionofpayment
solutionsandotherrelatedservicestoenabletofunctionality
tomake payments
under the Sales
Contract.

EEA
worldwide.

andData processing
agreements

Processor to
LLD

Other
serviceproviders to LLD

Provision of otherservices that arenecessaryfor
LLD to enable thePlatformandServices.

EEA
worldwide.

andData processing
agreements

Processor to
LLD

Public authorities
on the basis ofvalid
requests(such as thecourt on thebasis of valid
court order).

Legal obligation
to comply withsuch requests.

EEA
worldwide.

and

N/A

Independent
controller

6.6

LLD may also share personal data in connection with business transfers, such as any
reorganization, restructuring, merger or sale, or other transfer of assets, provided that thereceiving party agrees to protect Your personal data in accordance with this Privacy Policy.

6.7

LLD may also share anonymized User data and/or statistical data with third parties, forexample for research purposes. Please be noted that in cases where we share anonymized
User data and/or statistical data we make sure that no personal data is shared (which means

that no User can be identifiable) and therefore personal data processing regulation and the
GDPR shall not apply to such transfers (as no personal data is shared).
7.

HOW DOES LLD PROTECT YOUR PERSONAL DATA?

7.1

To protect User personal data from unauthorized access, unlawful processing or disclosure,accidental loss, modification or destruction, LLD uses appropriate technical and organisational
measures that comply with applicable laws. These measures include but are not limited to theimplementation of appropriate computer security systems, protection of paper and electronic
format files by technical and logical means, controlling and limiting access to documents andbuildings.

8.

COOKIE POLICY

A. WHAT ARE COOKIES?
8.1

Cookies are small text files that are placed on Your computer or other device (such as
smartphone, tablet, etc) by websites that You visit. They are widely used in order to makewebsites work, or work more efficiently, as well as to provide information to the owners of thesite. The table below explains the cookies we use and why.

8.2

Cookies may be session cookies or persistent cookies.

8.3

8.2.1

Session cookies are temporary cookie files, which are erased when You close Yourbrowser

8.2.2

Persistent cookies remain in the browser's subfolders until You delete them manuallyor Your browser deletes them based on the duration period contained within thepersistent cookie's file.

Cookies may be first party cookies or third-party cookies.
8.3.1

First party are cookies set by the website You’re visiting. Only that website can read
them.

8.3.2

Third-party cookies are cookies set by external services.

B.
8.4

WHICH COOKIES DO WE USE?

LLD uses the following cookies:

CookieType

Description_gaThird party
cookie foranalytics

This cookie is installed by Google
Analytics. The cookie is used to calculate
visitor, session, campaign data and keep
track of site usage for the site's analytics
report. The cookies store information
anonymously and assign a randomly
generated number to identify uniquevisitors.
Google Analytics is a web analytics
service offered by Google that tracks andreports website traffic. Google uses thedata collected to track and monitor theuse of our Service. This data is sharedwith other Google services. Google may
use the collected data to contextualize

Retention
period2 years

_gid_gat_UA-210783191-1

Third party
cookie foranalytics

Third party
advertisementcookietest_cookie

Third party
advertisementcookieIDE

Third party
advertisementcookieand personalize the ads of its own
advertising network. For more informationon the privacy practices of Google,
please visit the Google Privacy & Terms
pageavailableathttps://policies.google.com/privacy?hl=en.
Installed by Google Analytics, _gid cookie
stores information on how visitors use a
website, while also creating an analytics
report of the website's performance.
Some of the data that are collected
include the number of visitors, theirsource, and the pages they visit
anonymously.
Google Analytics is a web analytics
service offered by Google that tracks andreports website traffic. Google uses thedata collected to track and monitor theuse of our Service. This data is sharedwith other Google services. Google may
use the collected data to contextualize
and personalize the ads of its own
advertising network. For more informationon the privacy practices of Google,
please visit the Google Privacy & Terms
page available athttps://policies.google.com/privacy?hl=en.
A variation of the _gat cookie set by
Google Analytics and Google Tag
Manager to allow website owners to track
visitor behaviour and measure site
performance. The pattern element in thename contains the unique identity numberof the account or website it relates to.
Google Analytics is a web analytics
service offered by Google that tracks andreports website traffic. Google uses thedata collected to track and monitor theuse of our Service. This data is sharedwith other Google services. Google may
use the collected data to contextualize
and personalize the ads of its own
advertising network. For more informationon the privacy practices of Google,
please visit the Google Privacy & Terms
page available athttps://policies.google.com/privacy?hl=en.
This cookie is set by DoubleClick (which
is owned by Google) to determine if thewebsite visitor's browser supports
cookies.
This cookie is set by Doubleclick andcarries out information about how the end
user uses the website and any

1 day

1 minute

15
minutes

2 years_gcl_au

Third party
advertisementcookiecookie_consent

Preference
cookieC.

advertising that the end user may haveseen before visiting the said website.
Used by Google AdSense forexperimenting with advertisement
efficiency across websites using theirservices
To track whether the user has accepted
the cookies or not.

3 months

1 year

HOW TO MANAGE COOKIES

8.5

You can manage and delete cookies as You wish. Please note that all functions of theWebsite or VOD Platform may not work properly if You delete or block cookies.

8.6

More information on cookies and details for deleting the cookies may be accessed on
http://aboutcookies.org.

8.7

Please note that You can delete all cookies that are already on Your device by clearing thebrowsing history of Your browser. This will remove all cookies from all websites You havevisited.

8.8

Please also note that Your browser settings options (for example Google Chrome, Microsoft
Edge, Mozilla Firefox, Microsoft Internet Explorer, Opera or Apple Safari) may allow You toprevent any cookies being placed on Your device, but You may then have to manually adjust
some preferences every time You visit a site/page. For more information, please visit thebrowser developer's website.

9.

DATA SUBJECT RIGHTS

9.1

LLD is dedicated ensuring that all data subject rights arising under applicable law are always
guaranteed to the User. In particular, any User who is a data subject has:

10.

9.1.1

the right to access the personal data processed about him/her;

9.1.2

the right to request that rectification of any inaccurate personal data about him/her;

9.1.3

the right to request erasure of personal data and/or restrict of processing of personal
data if personal data is processed without a valid legal basis for processing;

9.1.4

the right to receive processed personal data in a structured, commonly used andmachine-readable format and have the right to transmit personal data to anothercontroller;

9.1.5

the right to object to the processing of personal data;

9.1.6

If the User believes that his/her rights have been infringed, the User may contact andlodge a complaint to the supervisory authority applicable for the User jurisdiction(Data Protection Inspectorate in Estonia address Tatari 39, Tallinn 10134, info@aki.ee
or other competent authority in the User jurisdiction. List of national Data Protection
AuthoritiesinEU
isavailableathttps://edpb.europa.eu/about-edpb/board/members_en).

GOVERNING LAW AND JURISDICTION

This Privacy Policy will be governed by the substantive law of Estonia, unless the mandatory
provisions applicable to consumers provide for a different governing law. If the respective dispute
resulting from this Privacy Policy cannot be settled by negotiations, then the dispute will be finallysolved in Harju County Court in Tallinn, Estonia, unless the mandatory provisions applicable toconsumers provide for a different jurisdiction. Data subjects may also lodge complaint to relevant Data
Protection Authority (see Section on Data Subject Rights above).
11.

CONTACTS

If you have any questions about this Privacy Policy or if you have any concerns about how we use
your personal or if you want to exercise your rights as described above, please contact LLD via e-mailor in writing using the following contact information:business name: Lucky Laika Distribution OÜ
address: Estonia pst 9, Tallinn 10143, Estonia
e-mail: info@firebirdmovie.com