Cross-Border Data Transfer Policy

This Cross-Border Data Transfer Policy describes the principles and procedures applied by LineOnMe when personal data may be transferred from the Russian Federation to recipients located in foreign countries in connection with the use of LineOnMe services, third-party integrations, messaging platforms, social networks, CRM systems, marketplaces, technical infrastructure, and other external services.

The personal data operator is Individual Entrepreneur Trapeznikova, INN 720604305670, OGRNIP 323774600657411, email: info@lineon.me, telephone: +7 (495) 021-80-50 (the “Operator” or “LineOnMe”).

1. General Provisions

For the purposes of this Policy, a cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to a foreign public authority, foreign individual, or foreign legal entity.

LineOnMe carries out cross-border transfers only where such transfers are necessary for the operation of the Service, the performance of agreements, the provision of functionality requested by the User, or on another lawful basis.

Cross-border transfers are performed in accordance with applicable legislation, including the legislation of the Russian Federation on personal data.

2. Initial Collection and Storage of Data

Where the requirements of Russian legislation on localization of personal data apply, the collection, recording, systematization, accumulation, storage, clarification, and retrieval of personal data of citizens of the Russian Federation are carried out using databases located within the Russian Federation, except where otherwise permitted by applicable law.

A subsequent transfer of personal data to a foreign recipient may be performed only in accordance with the applicable requirements for cross-border personal data transfers.

3. Situations in Which Cross-Border Transfers May Occur

Cross-border transfers may occur when a User connects or uses a third-party service whose infrastructure, servers, legal entity, processors, or other recipients are located outside the Russian Federation.

Such services may include, depending on the functionality selected by the User:

• messaging services;
• social networks;
• marketplaces;
• CRM systems;
• cloud and infrastructure providers;
• analytics and technical services;
• communication and notification services;
• other services connected by the User.

Third-party platforms may include, among others, TikTok, Telegram, WhatsApp, MAX, Facebook, Instagram, VK, Avito, Kommo, Bitrix24, and other platforms supported by LineOnMe.

4. Categories of Data That May Be Transferred

Depending on the connected integration and the functionality authorized by the User, the following categories of information may be transferred:

• name and contact information;
• account and platform identifiers;
• usernames and display names;
• CRM contact, lead, and deal identifiers;
• messages and communication history;
• comments and replies;
• files and attachments;
• publication or video identifiers;
• communication timestamps and statuses;
• technical and authorization information;
• other information necessary to provide the User-requested integration.

The exact scope of information depends on the permissions granted by the User and the functionality provided by the corresponding third-party platform.

5. Purposes of Cross-Border Transfers

Personal data may be transferred to foreign recipients for purposes including:

• connecting and operating third-party integrations;
• receiving and sending messages;
• receiving and processing comments and replies;
• synchronizing CRM and communication-platform data;
• sending User-authorized responses and actions to connected platforms;
• processing attachments and media;
• authentication and authorization through third-party platforms;
• technical support and maintenance;
• ensuring security and preventing abuse;
• providing other functionality requested by the User.

6. Assessment Before a Cross-Border Transfer

Before carrying out a cross-border transfer where such assessment is required by applicable law, LineOnMe obtains and evaluates information about the intended foreign recipient and the conditions under which personal data will be processed.

Such assessment may include:

• information about the foreign recipient;
• information about measures used by the recipient to protect personal data;
• conditions for termination of personal data processing;
• applicable personal data legislation of the foreign state where required;
• other information required by applicable law.

7. Notification of the Competent Authority

Where required by applicable legislation of the Russian Federation, LineOnMe submits a separate notification to the competent personal data authority regarding its intention to perform a cross-border transfer before beginning the relevant transfer activity.

The notification may specify, among other information, the purposes and legal basis of the transfer, categories of personal data, categories of data subjects, foreign countries involved, and information concerning the assessment of foreign recipients.

8. Countries Providing Adequate Protection

Where personal data is transferred to a foreign country included in the applicable official list of countries providing adequate protection of the rights of personal data subjects, the transfer may be performed after completion of the procedures required by applicable law, unless the competent authority has prohibited or restricted the transfer.

9. Other Foreign Countries

Where a foreign country is not included in the applicable list of countries providing adequate protection of the rights of personal data subjects, LineOnMe observes the additional procedures, limitations, and waiting periods required by applicable law before commencing the relevant transfer.

10. Third-Party Platforms

When a User voluntarily connects a third-party platform, the User instructs LineOnMe to perform the technical exchange of information necessary to provide the selected functionality.

Foreign third-party platforms process information in accordance with their own terms, privacy policies, technical requirements, and applicable legislation.

LineOnMe does not determine the independent processing practices of such third-party platforms beyond the data transmitted or received through the authorized integration.

11. Data Minimization

LineOnMe seeks to limit cross-border transfers to the categories and volume of information reasonably necessary to provide the corresponding functionality.

The availability of information through an integration is also limited by the permissions granted by the User and the access scopes provided by the third-party platform.

12. Security Measures

LineOnMe implements necessary and reasonable organizational and technical measures designed to protect personal data during processing and transfer, including measures intended to prevent unauthorized access, alteration, disclosure, loss, or unlawful processing.

Authorization tokens, API credentials, and other technical integration data are subject to access restrictions and appropriate security measures.

13. Suspension or Termination of Transfers

LineOnMe may suspend, restrict, or terminate a cross-border transfer where:

• the transfer is no longer necessary;
• the User disconnects the relevant integration;
• the third-party platform terminates or changes the relevant API access;
• LineOnMe identifies a material security risk;
• the competent authority prohibits or restricts the transfer;
• continuation of the transfer would violate applicable law.

Where required by applicable law or a binding decision of the competent authority, LineOnMe takes reasonable measures to ensure termination of processing or deletion of previously transferred data by the relevant recipient.

14. User Responsibility

Where a User transfers to LineOnMe personal data of its customers, employees, contractors, or other third parties, the User is responsible for ensuring that it has an appropriate legal basis for such processing and for the use of the selected integration.

15. Changes to this Policy

LineOnMe may update this Policy in connection with changes in applicable law, Service functionality, supported integrations, data-processing practices, or technical infrastructure.

The current version is published on the official LineOnMe website.

16. Language

This Policy is provided in English and Russian. In the event of inconsistencies, the Russian-language version shall prevail to the extent permitted by applicable law.

17. Contact Information

Individual Entrepreneur Anzhelika Sergeevna Trapeznikova
INN: 720604305670
OGRNIP: 323774600657411
Email: info@lineon.me
Telephone: +7 (495) 021-80-50
Website: lineon.me