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1. SCOPE

1.1. This Notice explains information processing in the LT Journeys application for Android, iOS, Web, Desktop, TV, and other compatible platforms (the “App”).

1.2. It covers the local travel journal and, depending on the features actually supported by a given version, local Wi-Fi synchronization, user-selected backups, AppMetrica crash diagnostics, Yandex advertising, local notifications, content delivery, and external affiliate links.

1.3. Independent cloud providers, advertisers, app stores, operating systems, and sites you visit apply their own documents.

1.4. LT Journeys is in development. This Notice describes the planned model. Before public release, it will be reconciled with the actual features, SDKs, configurations, and app-store disclosures.

2. CONTROLLER AND CONTACT

2.1. Controller and App developer: Igor Vladimirovich Repin, Republic of Bashkortostan, Russian Federation (the “Controller”).

2.2. Privacy and support inquiries: support@luntan.pro.

2.3. Russian Register of Personal Data Operators: No. 2-26-060086, Order No. 143 dated August 19, 2026. Processing commencement date: August 24, 2026.

3. HOW THE APP WORKS

3.1. The App does not require an account or registration with the Controller. Routes, events, meetings, excursions, notes, impressions, photos, documents, and other journey materials are stored locally on your device or in the relevant Web, Desktop, or TV platform storage by default.

3.2. The Controller does not create a cloud profile for you or keep a copy of your journal on its own server. Internet access may be used for public stories and content, consent-based AppMetrica crash diagnostics, advertising, external links, and services you choose.

3.3. Available features and storage methods depend on platform and version. Before introducing a feature that changes data processing, the Controller will update the documentation and legally required controls.

4. LOCAL JOURNAL AND FILES

4.1. You create the journal content and decide what information and files to include. It may contain personal data about you and other people. Do not store unnecessary information without an appropriate lawful reason.

4.2. The App uses local information to organize an itinerary, display cards and timelines, search within the journal, provide reminders, export information, and perform other requested functions. The Controller does not receive journal content on its server.

4.3. Local information remains until you delete the entry, clear App data, uninstall the App, or delete the file. Device loss, browser-storage clearing, or reinstallation may erase information unless you created a backup.

5. LOCAL WI-FI SYNC AND BACKUPS

5.1. Supported versions may synchronize your journal directly between your devices on the same local Wi-Fi network. This synchronization does not use the Controller's cloud server. You must select or confirm the devices being connected.

5.2. You may export or save a backup through a provider available on your device, such as Yandex Disk, Google Drive, iCloud Drive, or another chosen storage service. At your direction, the App hands the file to the selected system provider. The Controller does not receive the cloud password, account, or file copy.

5.3. The selected provider controls the stored copy, encryption, retention, processing locations, sharing, and deletion under its own documents. Deleting the local journal does not delete a previously exported copy.

6. APPMETRICA CRASH DIAGNOSTICS

6.1. If AppMetrica is included in the release build, after your separate affirmative consent it may process a pseudonymous installation identifier, technical device, operating-system, App-version, and session information, as well as errors, crashes, application-not-responding events, and diagnostic data.

6.2. The sole purposes are correction of technical errors, security, and stability. Journal contents, photos, documents, custom user events, screen names, and funnel parameters are not sent to AppMetrica, which is not used for product or marketing analytics.

6.3. AppMetrica transmission is disabled before consent. Declining does not restrict the local journal. You may withdraw consent in Settings to stop future transmission.

6.4. For the Russian service environment, the AppMetrica recipient and service provider is YANDEX LLC, 16 Leo Tolstoy Street, Moscow 119021, Russian Federation. In another jurisdiction, the applicable recipient may be another Yandex group entity identified in the service's current documents. See https://yandex.com/legal/confidential/, https://yandex.com/legal/metrica_agreement/, and https://appmetrica.yandex.com/docs/en/data-security/gdpr.

7. YANDEX ADVERTISING

7.1. On supported platforms, the App may display advertising through the Yandex Advertising Network without Appodeal. Yandex may process an IP address, advertising and other device identifiers, device, operating-system, App and network information, impressions, clicks, performance, fraud-prevention signals, and advertising settings.

7.2. Personalization and available controls depend on country, platform, system permissions, and Yandex documents. Opting out of personalization does not disable all advertising or all technical processing necessary to deliver, measure, and secure it.

7.3. The Controller does not provide Yandex with journal contents, photos, documents, routes, or notes for advertising personalization.

7.4. Yandex Privacy Policy: https://yandex.com/legal/confidential/. International advertising is also governed by https://yandex.com/legal/international_ads_privacy_policy/en/.

8. LOCAL NOTIFICATIONS AND SYSTEM FEATURES

8.1. With permission, the App may schedule local reminders on your device. The Controller's server does not send addressed LT Journeys push messages and does not receive a push token for that purpose.

8.2. You may grant access to system features needed for a selected action, such as files, photos, camera, calendar, or location. Platform controls request the permission, and access must be used only for the displayed function.

8.3. If you export an event, file, or material to another app, calendar, or cloud service, the selected recipient controls subsequent processing.

9. STORIES, CONTENT, AND AFFILIATE LINKS

9.1. If the App loads public stories, images, recommendations, or service materials from luntan.pro or infrastructure identified in the content, the server may technically receive the IP address and ordinary network-request information. Before release of this feature, the actual logged fields and retention periods will be verified and reflected in an updated Notice if necessary.

9.2. Stories, recommendations, or other sections may contain affiliate links to independent travel services. The Controller may receive compensation for a referral or qualifying action.

9.3. Before you follow a link, the Controller does not send journal content to an unspecified future partner. After you leave the App, the site receives ordinary network information and independently processes information you provide. Specific providers and links to their documents will be added before an integration automatically sends them additional data.

10. EMAIL INQUIRIES

10.1. If you email support@luntan.pro, the Controller processes the sender address, name or alias, message, voluntarily attached files, date, time, and technical headers to respond, provide support, handle a complaint, and protect legal rights.

10.2. Separate consent is not required to prepare the response you requested. Ordinary correspondence is retained for up to 12 months after it ends. Complaints, disputes, and necessary evidence may be retained until the applicable legal-protection period expires, ordinarily no more than three years. Do not send passwords, payment data, identity documents, or a complete journal copy unless necessary.

11. LEGAL BASES

11.1. The legal basis is determined separately for each operation: performance of an agreement or steps you request; consent for AppMetrica crash diagnostics and operations where consent is required; compliance with law; and legitimate interests in security and legal protection where those interests are not overridden by your rights. Under Russian law, the applicable basis is determined under Article 6(1) of Federal Law No. 152-FZ. Where the GDPR or UK GDPR applies, it is determined under Article 6(1).

11.2. Local processing performed by you, where the Controller does not receive the information, does not create a Controller database of that information. Advertising, cloud, and external-site providers may independently determine their own purposes and legal bases.

12. RECIPIENTS AND INTERNATIONAL PROCESSING

12.1. Depending on the feature, recipients may include luntan.pro hosting in the Russian Federation; the applicable Yandex group entity as the AppMetrica and advertising provider; your operating system, local device, calendar, file or cloud provider; a partner site; and an authority where legally required.

12.2. The Controller does not use server-delivered LT Journeys push notifications, store the journal in its own server database, or send that content to a foreign push provider. However, Yandex, platform services, a cloud provider you select, or an external site may conduct international processing depending on the enabled feature, configuration, and their own documents.

12.3. If you select a foreign cloud provider or visit an external site, that service processes information in the locations it identifies. Your selection does not give the Controller access to your cloud backup.

13. SECURITY AND RETENTION

13.1. The Controller uses data minimization, access restrictions, secure connections, software updates, and deletion procedures for operations actually supported. For local Wi-Fi synchronization, use a trusted network and confirm the devices you connect.

13.2. Journal content remains locally until you act; copies remain under the selected provider's settings; AppMetrica and advertising data remain under the actual configuration, consent, and Yandex rules; and correspondence remains as stated in Section 10. Network-request retention periods will be stated after the actual server configuration is verified before release.

13.3. No storage or transmission method is absolutely secure. You are responsible for device locking, your cloud-account password, and backups.

14. YOUR RIGHTS AND DELETION

14.1. Subject to applicable law, you may request information, correction, restriction, deletion, or termination of processing; withdraw consent; and complain to a data-protection authority or court.

14.2. Delete local content using the App, platform, or file system. Delete exported files and cloud copies separately. Withdraw AppMetrica consent in Settings. For Controller data inquiries, email support@luntan.pro.

15. AGE AND CHANGES

15.1. The App is intended for users aged 18 and older and is not child-directed. Any separate child-focused edition will be a distinct product with different purposes, interfaces, and documents.

15.2. The current Notice is published at https://luntan.pro/legal/journeys-privacy/ with its update date. Material changes will also be communicated in the App when required.