Last updated: 16.07.2021

This Privacy and Cookies Policy (the “Policy”) defines how (i) Lemon (hereinafter referred to as the “Company”, “We”, “Us”) collects, uses and distributes information about You obtained through the online interfaces used by the Company on the website located at (the «Website»), as well as (ii) how the Company uses cookies, what are cookies and what options do you have for configuring the use of these files obtained as part of interaction with the Website.

Before You start using the Website, please read the Policy carefully. Using any functions, services and Website features, including just browsing, You declare that You have read, understood and agreed to abide by Policy conditions, including any mentioned therein special conditions and rules without any exceptions and reservations.

This Privacy and Cookie Policy form part of the Terms of Use. Please read this Policy carefully and by clicking on Register now, You agree with every term of the Policy.

By accessing and registering on the Website, You automatically confirm Your consent to this Policy in the applicable part. Where You do not agree with any part of this Policy, We strongly recommend You stop the registration process and use of the Website.

Any reference to «You», «Your» etc. shall be interpreted as a reference to the individual accessing the Website, the subject of this Policy and the Terms of Use.

This Policy is an integral part of the Terms of Use, all terms and definitions used in this Policy that were not distinctly construed here shall be interpreted in the meaning specified in the Terms of Use. In case the Terms of Use have no definition for a term either, such term is to be understood in accordance with the applicable law or generally accepted meaning.

If You have any questions regarding the provisions of this Policy, please contact Us via the Online-chat system or any other means according to the Website.


1.1. Interpretation

1.1.1. The words of which initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

1.1.2. Any terms, which were used, but not specified under present Policy, shall be interpreted in the way they are interpreted in the Terms, annexures to the Terms and on the Website.

1.2. Definitions

1.3. “Company” (referred to as either “the Company”, “We”, “Us” or “Our”) means the owner of the Website.

1.4. “Services” means all kinds of services provided by the Company through the Website, including but not limited to the data intermediary services, which shall be understood as the transmission of the data between the Users and the Data-Holders with the functionality of the Website.

1.5. “Online-chat system” means the external website owned by the Company, through which User can obtain information on the price for the Services, recharge the balance in order to use the Services and communicate with the Company.

1.6. “Terms of Use” (also referred as the “Terms”) means the Terms of Use that form the entire agreement between You and the Company regarding the use of the Website and the Services.

1.7. “User” means the individual completed the procedure of registration on the Website, who is over the age of 18 and has no legal restrains from entering into binding contracts with the Company.

1.8. “Data-Holder” means any User who provided his/her phone number during the registration and subsequent verification procedures, therefore, committed to cooperate with the Company and Company’s affiliates and deliver all relevant information concerning such phone number as well as the data received on such phone number during the specific periods communicated to him/her by the Company.

1.9. “Parties” or “Party” means the Company, User, Data-Holder and Reseller (if used in plural form) and any of aforementioned subjects with reference to the context (if used in singular form).

1.10. “Personal Data” means any information that relates to an identified or identifiable individual. An identifiable person is a person who can be identified directly or indirectly, in particular by reference to identifiers such as name, identification number, location data, network identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual.

1.11. “Privacy and Cookie policy” or “Policy” means this Lemon Privacy and Cookie Policy, which is periodically updated and published on our Website.

1.12. “Reseller” means the legal entities or other institution, which completed the registration procedure and verification procedure for Resellers on the Website, willing to custom API to provide the access to the Services ordered from the Company to their own users.

1.13. “Website” means a set of information, web forms, hardware and software, and intellectual property objects that can be accessed from various User’s devices connected to the Internet by means of special software for viewing web pages (browser) under the domain name: (equal to http(s)://, with / without the use of the abbreviation "www"), including all subdomains, the exclusive rights and/or the right to use which belong to the Company.

1.14. “You” means the individual accessing the Website.

1.15. “Processing” means any action (operation) or set of actions (operations) performed with or without the use of automation tools with Personal Data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of Personal Data


2.1. By providing services through the Website, the Company, acting reasonably and in good faith, presumes that You:

2.1.1. Have all necessary rights permitting You to register on and use the Website and services offered on the Website;

2.1.2. Provide Us accurate information about Yourself to the extent necessary to use the Website.


3.1. The Company processes information about Users, including their Personal Data, in order to fulfill the Company's obligations to Users regarding the use of the Website.



4.1.1. The Company automatically collects the following Personal Data when You access the Website: Technical information, including the Internet Protocol (IP) address used to connect Your computer to the Internet, login information, browser type and version, time zone settings, browser plug-in types and versions, operating system and platform; Information about Your visit to websites, including the full URL of unified resource pointers (URLs) on, through, and from websites (including the date and time); services You viewed or searched for; page response time, loading errors, the length of time You visit or use certain pages, page interaction information (such as scrolling, clicking, and hovering), and methods used to navigate from the page.

4.1.2. Aforementioned information is required to improve the operation of the Website, to fulfill our administrative purposes and to protect our business interests.


4.2.1. In order to use the Website You shall complete the registration procedure as foreseen by the Terms of Use and the Website.

4.2.2. During the registration, You will be requested to provide following data: Any combination of letters and(or) digits that will be lately used as Your designation (hereinafter referred to as the “Login”) on the Website and be required every time You entering the Website (mandatory); Any combination of letters and(or) digits (hereinafter referred to as the “Password”) that will be lately required every time You entering the Website (mandatory); Your email address (mandatory); Your mobile number (optional); Your Alipay account number (optional).

4.2.3. The purpose of Processing such data is to identify the User. The entered Login-Password pair is necessary and sufficient information for the User's access to the Website, and the email is necessary for some actions (e.g., changing or restoring the login and (or) password).

4.2.4. The User is not allowed to transfer its Login and Password to third parties and fully responsible for their safety, independently choosing the method of their storage.

4.2.5. The User can allow the storage of Login and Password (using cookies) for further automatic authorization on the Website on the hardware and software used by the User.


4.3.1. Under the process of obtaining the status of Data-Holder/Reseller on the Website You will be requested to provide additional information to those provided during the registration on the Website.

4.3.2. Under the process of obtaining the status of Data-Holder on the Website You may be requested to provide following information: Your phone number; Your contract with the telecommunication company; Other relevant information required to confirm Your conformance to the criteria of Data-Holder.

4.3.3. Under the process of obtaining the status of Reseller on the Website You may be requested to provide following information: Name of Your legal entity; Tax number of Your legal entity; The address of Your website/platform through which You would like to provide the access to the Company’s Services; Other relevant information required to confirm Your conformance to the criteria of Reseller.


4.4.1. We receive and process the information with regards to the transactions between the Users and Data-Holders as a part of Our Services.

4.4.2. This information includes payment details, which may differ for the different payment services available at the Website.

4.4.3. The exact information on the transaction data that may be received and processed can be found on the Website or through the Online-chat system.

4.4.4. We store the data with regard to the payment details and payment services of the Users in an encrypted way in order to fulfill the obligations prescribed by the tax regulations.


4.5.1. We act as a data intermediary and therefore receive the data transmitted by Data-Holders to the Users through the means of the Website.

4.5.2. We do not store such data and delete it from the Website’s system immediately after its display on the User’s Device.


5.1. The Processing of Personal data is based on the following principles:

5.1.1. Lawfulness, fairness and transparency;

5.1.2. Purpose limitation;

5.1.3. Data minimization;

5.1.4. Accuracy;

5.1.5. Storage limitations;

5.1.6. Integrity and confidentiality;

5.1.7. Accountability.


6.1. The Personal Data that the Company processes would not be stored for longer than it is required for the relevant purposes.

6.2. The Company will store Your Personal Data for the whole period of Your contractual relationship with the Company (period of existence of Your account on the Website) and, to the extent permitted, after the termination of this relationship for as long as it takes to fulfill the purposes set out in this Policy.

6.3. Personal Data are stored in a form that allows identification of the subject of Personal Data for no longer than the purposes of Personal data Processing require, unless the period for storing Personal Data is established by applicable law.

6.4. The processed Personal Data are subject to destruction or depersonalization upon achievement of the Processing goals or if it is no longer necessary to achieve these goals, unless otherwise provided by applicable law. In particular, the Company may store special information after fulfilling its obligations under agreements (after the Personal Account has been deleted), if it is required to comply with legal requirements, resolve disputes, prevent fraud or abuse, and to ensure compliance with the provisions of this Privacy and Cookies Policy. Personal Data of Users and visitors are stored for 12 months to analyze the behavioral activity on the Website of Users in an impersonalized form.

6.5. The storage period for the required data can be extended for tax compliance purposes according to applicable law. In general, Personal Data will be deleted 12 months after the deletion of the Personal Account is approved.

6.6. We will stop Processing Your Personal Data where You have withdrawn Your consent to Processing that was previously received by the Company.


7.1. The Company protects Your Personal Data and provides it to third parties only in the cases where it is required:

7.1.1. To provide You the Services and functionality of the Website;

7.1.2. In accordance with the legal requirements;

7.1.3. To enforce the terms of the Website's Terms of Use or to protect the rights, property, and security of the Company, Users, or the public.

7.2. To ensure that We provide You with access to the Site, We may share Your Personal Data with the Third-party support service providers and partners that ensure the proper functioning of Our Services.


8.1. The subjects of Personal Data processed by the Company shall have all rights and opportunities to exercise them in accordance with the applicable law, in particular:

8.1.1. The right to be informed: You have the right to be informed about the collection and use of Your Personal Data, in particular, about purposes for Processing of this data, retention periods for that Personal Data, and who it will be shared with. This information must be provided at the time we collect Personal Data from You. If we obtain Personal Data from other sources, we will inform You about this within a reasonable period of obtaining the data and no later than one month, unless You already have the information or if it would involve a disproportionate effort to provide it to You.

8.1.2. Right of access: You have the right to obtain from the Company confirmation as to whether or not Personal Data concerning You are being processed, and, where that is the case, access to the Personal Data and the following information: the purposes of the Processing; the categories of Personal Data concerned; the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations; where possible, the envisaged period for which the Personal data will be stored, or, if not possible, the criteria used to determine that period; the existence of the right to request from the controller rectification or erasure of Personal Data or restriction of Processing of Personal Data concerning the data subject or to object to such Processing; the right to lodge a complaint with a supervisory authority; the existence of automated decision-making, and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such Processing for the data subject.

8.1.3. Right to rectification: You have the right to have inaccurate Personal Data rectified or completed if it is incomplete under request for rectification made verbally or in writing.

8.1.4. Right to erasure (‘right to be forgotten’): You can make a request for erasure by contacting the Company through the Online-chat system or other means provided on the Website to delete all data related to You and the Company has one month to respond to a request. Please take a note, the right could be the subject to certain limitations provided under the applicable law.

8.1.5. Right to restriction of Processing: You have the right to request the restriction or suppression of Your Personal Data. Where Processing has been restricted, such Personal Data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. Please take a note, the right could be the subject to certain limitations provided under the applicable law.

8.1.6. Right to data portability: The right to data portability allows You to obtain and reuse Your Personal Data for Your own purposes across different services. It allows You to move, copy or transfer Personal Data easily from one IT environment to another in a safe and secure way, without affecting its usability. Please take a note, You have the right to have the Personal data transmitted directly from one controller to another, where technically feasible.

8.1.7. Right to object: You have the right to object, on grounds relating to Your particular situation, at any time to Processing of Personal Data concerning You. We will no longer process Your personal data unless we have legitimate grounds for the Processing. You may revoke Your consent to the Processing of Personal Data at any time. Please be advised that the revocation will only take effect in the future. Any Processing that was carried out prior to the revocation shall not be affected thereby.


9.1. We take technical, organizational and legal actions or ensure that they are taken to protect your Personal Data from unauthorized or accidental access, collection, storage, use, transfer, blocking or destruction, as well as from other illegal actions or accidental leaks.

For example, we provide:

(1) restriction and indication of the Company's employees who have access to Personal Data;

(2) familiarization of the Company's employees with the requirements of the applicable legislation and regulations on the Processing and protection of Personal Data;

(3) accounting and storage of material data carriers and their use, which excludes theft, substitution, unauthorized copying and destruction of information;

(4) identification of security threats to the confidentiality of Personal Data during their Processing and formation of threat variants;

(5) development of Personal Data protection systems based on threat modes;

(6) testing and checking the availability and effectiveness of information security tools;

(7) implementation of a permissive system for access to information resources, hardware and software for Processing and protecting information;

(8) registration and recording of actions of Users of Personal Data information systems;

(9) password protection of Users’ access to the Personal Data information system;

(10) implementation of anti-virus control, prevention of penetration into the corporate network;

(11) detection of intrusions into the Company's corporate network that violate or create prerequisites for violating the established requirements for Personal Data security;

(12) centralized management of the Personal Data protection system;

(13) training employees who use information security tools used in Personal Data information systems on the rules for working with them;

(14) monitoring User actions, conducting proceedings on violations of Personal Data security requirements.

9.2. We store and process Your Personal Data on servers located in various jurisdictions where our representative offices or service providers are located. By accepting the terms of this Policy, You agree for such transfer, Processing and storage of Data. We take all necessary steps to ensure that Your Personal Data is processed securely in accordance with this Policy. Third parties to whom Personal Data may be transferred for the operation of the Website may be located in other countries where the laws on Personal data Processing may be less stringent than in Your country.

9.3. We do not disclose this information to third parties unless it is required to ensure Your access to the Website and to the Services or if We believe that such disclosure is necessary (for a legitimate purpose: for example, if You or other persons are threatened) under applicable law.

9.4. The Website may contain links to websites maintained by third parties whose information and privacy practices differ from ours. We are not responsible nor liable for the information or privacy practices used by such third parties. We strongly recommend You to read the privacy policies of all third-party websites before using such websites or providing any Personal Data or any other information on or through such websites.

9.5. Obligations of Data-Holders

9.5.1. In case You receive the status of Data-Holder on the Website, You agree that any information received on Your Device during the Time Slots shall be deemed as Personal Data and be protected under present Policy.

9.5.2. As the Data-Holder You commit not to share any such information with third parties and delete the SMS-message immediately upon the transmission of its content to the Users through the Website.

9.5.3. You agree not to provide the access to the Device used to receive the SMS-messages addressed to the Users to any third party and inform the Company if such access was provided at any time You being the Data-Holder.

9.5.4. In case the Device which was used to receive the SMS-messages addressed to the Users is stolen, lost or is irretrievably out of Your use for any other reason You commit immediately inform the Company through the Online-chat system.

9.6. Obligations of Resellers

9.6.1. In case You receive the status of Reseller on the Website You agree to implement and ensure the abidance on Your website policy that at least provides the level of confidentiality and security of personal data foreseen by this Policy.


10.1. Cookies are small files that are stored on the hard drive of Users of the Website. A cookie file is stored in Your web browser and allows the Website or third parties to recognize You as a User and make it easier for You to use the Website during subsequent visits. These cookies allow the Company to track the use of the Website and its functions. Using them allows You to better and more effectively serve Users and personalize the Website for a specific User.

10.2. The Company may use cookies to recognize repeated User visits, the type of content viewed and other websites to which the User was redirected from the Website, the time when each page and section of the Website was opened, and the functions used. All Personal Data that may be contained in cookies are processed based on the consent of the relevant subject in accordance with the Privacy and Cookies Policy.

10.3. The Website uses following cookies:

No. Name Domain Purpose of use
1 PHPSESSID We use it to improve the functionality of the Website.

10.4. To find out how to delete cookies and how to configure deletion or refuse them, use the help function in Your web browser.

10.5. Please note that if You delete cookies or refuse to use them, You may lose access to some of the Website's features: You will not be able to log in to Your account, save settings, and some pages will not display correctly.


11.1. This Policy may be revised, changed, updated and / or supplemented at any time, without the need for prior notification to the User, at the Company's discretion. Any such modification shall be effective immediately.

11.2. The Company notified the Users on the modification of the Policy by publishing the revised version on the Website with updated date of publication.

11.3. You hereby agree and We strongly recommend that You will check the publication of revised Policy on the Website at least twice per month.

11.4. By registering on the Website, the User automatically confirms their consent to this Policy in the applicable part. If the User does not agree with this Policy, we strongly recommend You stop using the Website.

11.5. After posting the updated version of the Policy on the Website, further use of the Website is considered as acceptance of the terms of the updated Policy.