Last updated: December 17, 2025

Privacy Policy

Leliuga, MB (“Leliuga”, "we", "us" or "our") provides advanced artificial intelligence (“AI”) platforms - Chiki.StudIO. This Privacy Policy describes how we process personal information that we collect through the Chiki.StudIO platform and the mobile apps and browser extensions related to Chiki.StudIO (collectively, the “Service”).

For content-safety, see User Safety & Content Policy.

For Prohibited AI Practices, see the Usage Policy

We may act as a data processor and process personal information in accordance with the instructions of Organization Owners, Chiki.StudIO API Customers, or Organization Plan Owners. A "Organization" refers to any public-facing website or other forms of online application created through using Chiki.StudIO, and a "Organization Owner" is the creator or operator of a Organization. A "Chiki.StudIO API Customer" is a customer of
our Chiki.StudIO API services. A "Organization Plan Owner" (also referred to as "Owner" in the context of organization roles) is the owner of a Organization Plan subscription who determines how organization data is processed. This includes: (i) personal information of End Users collected through Organizations or API applications, and (ii) personal information of Organization Members generated within Organization Plan. In such cases, the privacy policies of the relevant Organization Owner, Chiki.StudIO API Customer, or Organization Plan Owner (as applicable) will govern the processing of that data.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.

Personal information we collect

Information you provide to us. Depending upon the context in which you interact with us, personal information you may provide to us through the Service includes:

• Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, professional title and company name, and phone number.

• Profile data, such as the username and password that you may set to establish an online account with the Service, any organizations you are a part of and your role within the organization (e.g., organization owner ("Owner”), organization member (“Member”), organization viewer (“Viewer”)), and any other information that you add to your account profile.

• Communications data, based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.

• Transactional data, such as information relating to or needed to complete your subscriptions on or through the Service, including subscription type and transaction history.

• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

• Inputs, prompts and user-generated content, such as messages, photos, images, audio or voice clips, music, videos, comments, questions, files, works of authorship, third party account credentials and other content or information that you upload/use as an input or prompt to, generate, transmit, or otherwise make available on the Service, as well as associated metadata(e.g., how, when, where content was collected or edited; keywords; location info).

• Derived data, if you use certain features of Chiki.StudIO, such as to convert images to videos, videos to new or different videos, or people to avatars, or to upload audio or voice clips, we may derive certain information from images of individual people or from audio or voice clips in order to provide those features. While we do not use such data for purposes of identifying any unique individual, it is possible that some may consider this data biometric data within the meaning of certain U.S. state laws. We will only use and share this derived data for limited purposes, as described in the “How we use your personal information” and “How we share your personal information” sections, below.

• Payment data, needed to complete transactions is collected and processed directly by our payment processors, such as Stripe or RevenueCat, as further described below in the “How we share Your personal information” section.

• Organization end-user account data, such as email address and login credentials where a Organization uses our built-in authentication. We process this data on behalf of the Organization Owner or Chiki.StudIO API Customer to operate their sign-in and account features.

• Other data, not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

We ask that you not provide us with any sensitive personal information (e.g., social security numbers, financial account numbers, government ID numbers, information related to racial or ethnic origin, political opinions, religious or other beliefs, health, biological, biometric or genetic information, criminal background information, or similar data) on or through the Service or otherwise.

Third-party sources. We may combine personal information we receive from you with personal information that we obtain from other sources, such as:

• Public sources, such as public records, social media platforms, and other publicly available sources.

• Third-Party AI Providers. Parts of the Service are integrated with third-party AI platforms (“Third-Party AI Providers”) that help generate outputs (i.e., responses) to your inputs and prompts. These Third-Party AI Providers may infer information about you and share information with us as part of their processing of your inputs and prompts to the Chiki.StudIO platform.

• Service providers that provide services on our behalf or help us operate the Service or our business.

• Third-party login/linked services, such as Google, Microsoft or Linkedin that you use to log into, or otherwise link to, your Service account, including when you utilize or direct the Service to utilize your third-party accounts. This data may include your username and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

• At your direction. Where you consent or direct us to interact with a third party, we may receive only the information needed to carry out the actions you request and consistent with the permissions you grant. This includes data made available to us through Connectors you enable. A “Connector” is a pre-built integration module that allows our AI tool or system to connect to an external data source, application, or service designated by you. Our Connector processes data solely from user-authorized sources and only as instructed by you, and it does not store any of that data. We only access the categories of data you authorize and we follow the applicable provider policies. For example, when you connect Google services, we comply with the Google API Services User Data Policy, including the Limited Use requirements.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

• Device data, such as your computer or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

• Communication interaction data, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.

• Sandbox environment data. When Chiki.StudIO executes tasks on your behalf, it operates within isolated sandbox environments (virtual machines). We may collect: (i) files you upload or that Chiki.StudIO creates during task execution; (ii) shell commands executed and their outputs; (iii) code you provide or that Chiki.StudIO generates; and (iv) task execution logs for debugging and security purposes.

• Chiki.StudIO Browser Operator data. When you enable the Chiki.StudIO Browser Operator extension and the "My Browser" Connector, you grant Chiki.StudIO access to interact with web pages in your local browser environment. This includes: (i) page content that Chiki.StudIO reads, extracts, and processes from web pages you authorize, including content from premium or authenticated services you are logged into; (ii) browser actions such as clicking, scrolling, form filling, and navigation performed on your behalf; and (iii) session context leveraging your existing browser sessions and login states. Data collected through Browser Operator is transmitted to Chiki.StudIO servers for task processing. We do not store your login credentials. You can revoke Browser Operator access at any time by disabling the "My Browser" Connector or uninstalling the browser extension.

Personal Information of End Users and Organization Members. When we process personal information to help Organization Owners operate their Organizations, Chiki.StudIO API Customers operate their applications, or Organization Plan Owners manage their organization, we do so solely at their direction, in our capacity as a data processor. The purposes and means of processing such personal information are determined by the relevant Organization Owner, Chiki.StudIO API Customer, or Organization Plan Owner.

Tracking and other technologies

Cookies and similar technologies. Some of the automatic collection described above is facilitated by cookies and other technologies. We also use Chat and other AI technologies, such as those provided by our ThirdParty AI Providers that employ cookies and software code to operate the chat, input and prompt features that you can use to communicate with us and input your prompts and other data through the Service. These ThirdParty AI Providers may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats or within inputs to facilitate the provision of the app or services.

Cloud Browser. With your prior consent, Cloud Browser may encrypt and store cookies/local storage to persist login state across sessions/devices for certain period; you can view or clear this in settings at any time.

Organizations. Any cookies used for your Organization's purposes are managed by you and may be implemented via your consent management.

For information concerning your choices with respect to the use of tracking technologies, see the Your choices section below and our Cookie Policy.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

• provide the Service;

• transmit your inputs to our Third Party AI Providers for processing and to receive outputs, as necessary to fulfill your requests;

• enable security features of the Service;

• establish and maintain your user profile on the Service;

• facilitate organization collaboration within the Organization Plan, including managing organization member access permissions, synchronizing session data among authorized members, and monitoring organization-wide resource usage;

• operate built-in Organization authentication and Organization-owner analytics on the Organization owner's instructions, and provide related hosting and support.

• communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;

• communicate with you about events or contests in which you participate;

• provide support for the Service, and respond to your requests, questions and feedback;

• execute tasks asynchronously in the cloud, including Scheduled Tasks and background operations that continue running even when you close your browser or device, with task execution logs retained to enable replay and debugging; and

• deploy multiple parallel agents (Wide Research) to process complex, large-scale tasks, where all agents operate under the same data protection controls.

Service personalization, which may include using your personal information to:

• understand your needs and interests;

• personalize your experience with the Service and our Service-related communications; and

• remember your selections and preferences as you navigate webpages.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services. For more information on analytics, see our Cookie Policy.

Marketing and advertising. We, our service providers and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:

• **Direct marketing.**We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt out of communications section below.

• Where permitted by law and with your permission where required, we process certain online identifiers to (i) show you more relevant ads, (ii) measure ad performance, and (iii) build or refine audiences. We may share this information—sometimes in hashed or de-identified form—with our advertising partners for conversion measurement, audience creation, and optimization. We only engage in personalized ads and re-marketing after we have received your valid consent.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;

• protect our, your or others' rights, privacy, safety or property (including by making and defending legal claims);

• audit our internal processes for compliance with legal and contractual requirements or our internal policies;

• enforce the terms and conditions that govern the Service; and

• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events – for more information, see How we share your personal information, below.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and that of other individuals whose personal information we collect. We may make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Processor services for Organizations and API. When you create and operate a Organization or use the Chiki.StudIO API to process personal information about your End Users, you (or your organization), as a Organization Owner or a Chiki.StudIO API Customer, act as the data controller for that processing activities and we act as your data processor, handling such personal information only on your documented instructions and our Data Processing Addendum (”DPA”), to host your Organization, or execute your API requests.

Further uses, in some cases, we may use your personal information for further uses, in which case we will ask for your consent to use of your personal information for those further purposes if they are not compatible with the initial purpose for which information was collected.

Retention

We generally retain personal information to fulfill the purposes for which we collected it, and for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. We purge or remove customer data containing confidential information (which may include certain personal information) from the application environment, in accordance with best practices, when customers leave the Service.

Note the following concerning how we retain and handle personal information for particular Services:

For Organization-related data (e.g., session logs, minute usage records), retention periods are also determined by the organization Owner or Member in accordance with organizational needs and applicable laws.

Browser Sandbox. If you use the Chiki.StudIO Browser's sandbox (virtual machine) mode (the “Sandbox”), it operates as an ephemeral, isolated environment that may be reset. Sandbox data is stored separately from your regular sessions and is retained for up to 7 days from your last activity for free plans and up to 14 days for paid plans, after which it is automatically deleted (or sooner if the Sandbox is reset).

Retention of End Users' Personal Information. We store and retain End Users' personal information collected by a Organization Owner or a Chiki.StudIO API Customer solely in accordance with their instructions. In such cases, the applicable retention period is determined by the relevant Organization Owner or Chiki.StudIO API Customer. We act only as a data processor and retain such personal information on their behalf. For Members in a Organization Plan seeking to delete personal information related to organization activities, please contact your organization Owner or Member.

Organization Member Rights. If you are a Organization Member and wish to exercise data subject rights (access, correction, deletion) regarding data processed within your Organization Plan, you should first contact your Organization Owner or Member. If you do not receive a response within 30 days, or if your request relates to data that Chiki.StudIO controls independently (such as billing information or service usage data), you may contact us directly at [email protected] and we will assist you to the extent permitted.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

• Our corporate parent, subsidiaries, and affiliates.

• Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).

• Third party AI providers. We use third party AI providers to power certain aspects of the Chiki.StudIO platform, such as operating the chat and/or processing user inputs/prompt features, data analytics and recommendations.

• Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe and RevenueCat. Our payment processors may use payment data in accordance with their privacy policy located at, https://stripe.com/privacy and https://www.revenuecat.com/privacy/, respectively.

• Advertising Partners. We work with advertising and analytics providers such as Google (Google Ads/Analytics), LinkedIn (Insight Tag/Conversions API), and X (formerly Twitter). These partners may set or read cookies and receive limited information from us to provide ad measurement, audience services, and optimization, subject to your choices. See our Cookie Policy for the specific cookies used, providers, purposes, and retention periods.

• Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

• Organization Owners and Chiki.StudIO API Customer. If you interact with a Organization or an application built on the Chiki.StudIO API, information you submit may be shared with, or directly collected by, the Organization Owner or the customer of Chiki.StudIO API (”Chiki.StudIO API Customer”) operating that experience, in accordance with their privacy policies.

• Linked third party services. If you log into the Service with, or otherwise link your Service account to, a social media or other third party service, we may share your personal information with that third party service. The third party's use of the shared information will be governed by its privacy policy and the settings associated with your account with the third party service.

• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

• Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments and financing of Leliuga, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Leliuga as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

• Other users and the public. At your election, user-generated content data may be visible to other users of the Chiki.StudIO platform and the public. For example, other users of platform or the public may have access to your information if you chose to make information available to them, such as when you share content. In addition, we offer users the ability to join a organization, and certain of their information may be visible to other organization members based on role permissions:

• Sharing under Organization Plan: if you, as a Member, join a organization set up by its Owner, the Owner of such organization may access all session data of organization members (including task steps and content), monitor individual and organization minute usage, export session data, and view content created during Members' sessions; the Member of such organization may access a subset of session data, manage minute allocation across the organization, but cannot view personal account details or detailed individual session information.

This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.

Your choices

In this section, we describe the rights and choices available to all users. Users who are located in Europe can find additional information about their rights below.

• Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.

• Opt out of communications. You may opt out of marketing related emails by following the opt out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt out of marketing related emails, you may continue to receive service related and other non-marketing emails.

• For information about cookies and other technologies employed by the Service and how to control them, see our Cookie Policy.

• Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.

• Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

• Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

• Linked third-party platforms. If you choose to connect to the Service through your Google, Microsoft or Linkedin account or other third-party platform, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party.

• Delete your content or close your account. If you are an individual user, you can choose to delete certain content through your account. If you wish to request to close your account, please contact us.

• Organization-related privacy controls. As a member of a organization, you have the ability to manage your privacy settings through the organization management features, such as restricting the sharing of non-collaborative content with other members. However, certain information (e.g., aggregate minute usage, task progress visible to the organization) may still be accessible to Owners or Members as required for organization operation.

• Connector and Browser Operator controls. You can view, manage, and revoke access to any Connector at any time through your Chiki.StudIO settings. For Browser Operator, you can disable the "My Browser" Connector or uninstall the browser extension to immediately stop local browser access. When you remove a Connector, all associated login information and saved credentials are cleared.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards designed to protect the personal information we collect. Security procedures are in place to protect the confidentiality of your data. Despite commercially reasonable safeguards, online and email transmissions are not fully secure. Please submit information at your own discretion; we accept no liability for any unauthorized circumvention of the Services' or third-party privacy or security measures.

International data transfers

We are headquartered in Lithuania and may use service providers that operate in other countries. Your personal information may be transferred to the Lithuania or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should read the important information provided below about transfer of personal information outside of Europe.

Children

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child's parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Depending on the change that we make to this policy, we might notify you of the change or ask for your consent to it. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).

Privacy Policy Changes Related to End Users. Organization Owners and/or Chiki.StudIO API Customers may update their own privacy policies from time to time with respect to their processing of End Users' personal information. As a data processor, we may adjust our processing activities related to such personal information in accordance with the updated privacy policies and instructions of the relevant Organization Owner and/or Chiki.StudIO API Customer.

How to contact us and our Data Protection Officer

We have appointed a Data Protection Officer responsible for overseeing privacy compliance.

Contact: [email protected].

Addendum

Notice to European users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.

Controller. Leliuga is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR' (as and where applicable, the “GDPR”)). See the ‘How to contact us' section above for our contact details.

Processor. For personal data that we process on behalf of Organization Owners or Chiki.StudIO API Customer, the Organization Owner or Chiki.StudIO API Customer is the controller and we are their processor under the GDPR. For processor-context questions or to exercise your rights, please contact the relevant Organization Owner or Chiki.StudIO API Customer.

Organization Plan Processing. For personal data that we process on behalf of Organization Plan Owners, the Organization Plan Owner (typically the employer organization) is the controller and we are their processor under the GDPR. Organization Members should direct data subject requests to their Organization Plan Owner in the first instance.

Our GDPR Representatives. We have appointed the following representatives in Europe as required by the GDPR – you can also contact them directly should you wish:

• **Our Representative in the EU.**Our EU representative appointed under the EU GDPR is EDPO. You can contact them:

• via: https://edpo.com/gdpr-data-request/

• by post: Avenue Huart Hamoir 71, 1030 Brussels, Belgium

  • **Our Representative in the UK.**Our UK representative appointed under the UK GDPR is EDPO. You can contact them:

• via: https://edpo.com/gdpr-data-request/

• by post: 8 Northumberland Avenue, London, WC2N 5BY, UK

Our Data Protection Officer. We have appointed a Data Protection Officer (DPO). The DPO independently performs their duties—informing and advising us and monitoring our compliance with the EU GDPR and the UK GDPR (as applicable). The DPO's contact details are provided in the “How to contact us and our Data Protection Officer” section.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

• **Contractual Necessity.**Where we need to perform a contract, we are about to enter into or have entered into with you.

• **Legitimate Interests.**Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests.

• **Compliance with Law.**Where we need to comply with a legal or regulatory obligation.

• Where we have your specific consent to carry out the processing for the Purpose in question.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information'

Other info

We may use limited profiling to personalise advertisements and measure performance.

Your rights

European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

• Access– Provide you with information about our processing of your personal information and give you access to your personal information.

• Correct– Update or correct inaccuracies in your personal information.

• Delete– Delete your personal information where there is no good reason for us continuing to process it.

• Transfer– Transfer a machine-readable copy of your personal information to you or a third party of your choice.

• Restrict– Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.

• Object– Object to our processing of your personal information where we are relying on Legitimate Interests; also object to direct marketing at any time.

• Withdraw Consent– When we use your personal information based on your consent, you may withdraw that consent at any time.

Exercising these rights. You may submit requests by email to [email protected] or our postal address above. We may request specific information from you to help confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on several factors (e.g., why and how we are processing your personal information). If we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en

For users in the UK – the contact information for the UK data protection regulator is below:

The Information Commissioner's Office

Water Lane, Wycliffe House

Wilmslow - Cheshire SK9 5AF

Tel. +44 303 123 1113

Website: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe

We may share your personal information with third parties who are based outside Europe.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by implementing one of the following mechanisms:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time).

Transfers to territories without an adequacy decision.

We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g. the United States, Lithuania).

However, in these cases:

we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or in limited circumstances, we may rely on an exception, or ‘derogation', which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision' or ‘appropriate safeguards' – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at [email protected].

Notice to users in the State of California

This section applies to individuals in the State of California and, where applicable, to our provision of Services that is subject to the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (”CPRA”). We may disclose personal information to third-party service providers or contractors for the purpose of providing our Services, subject to written contracts restricting their use of the information.

Notice to South Korea users

This section applies to individuals in the Republic of Korea and, where applicable, to our provision of services that is subject to Korea's Personal Information Protection Act (PIPA).

We have appointed a Personal Information Protection Officer under the PIPA—see How to contact us for contact details. Other PIPA disclosures are set out in this Privacy Policy.

We transfer personal information to service providers outside of South Korea for hosting, storage, customer support and security. Because these transfers are necessary to provide the Service, we rely on the bases permitted under the PIPA for cross-border outsourcing/storage and we supervise such providers.

Notice to Japan users

This section applies to individuals in Japan under the Act on the Protection of Personal Information (APPI), including APPI's extraterritorial provisions where applicable. Leliuga is the “personal information handling business operator” for the processing covered by this Privacy Policy.

Notice to Singapore users

This section applies to individuals in Singapore and is subject to the Personal Data Protection Act 2012 (PDPA) and its regulations and guidelines.

Notice to Lithuania users

Leliuga is a company incorporated in Lithuania, act as data controller and is responsible for the collection, use, and disclosure of your personal data as described in this Privacy Policy.

If a notifiable data breach occurs, we will notify the Personal Data Protection Commission (PDPC) and affected individuals where required, within the timelines prescribed by law.

When transferring personal data outside Lithuania, we ensure that the recipient provides a standard of protection that is comparable to the PDPA.