Last updated: 2024-05-09

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Owner and Data Controller

MB “Žinučių linija”, V. Nagevičiaus g. 3, Vilnius 08237, Lithuania

Owner contact email: info@sip.tg

Owner contact Telegram: @siptg_support

Since the use of third-party Trackers through SIP.TG cannot be fully controlled by the Owner, any specific references to third-party Trackers are to be considered indicative. In order to obtain complete information, Users are kindly requested to consult the privacy policies of the respective third-party services listed in this document.

Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner should they wish to receive any further information on the use of such technologies by SIP.TG.

  • Personal Data (or Data)

    Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

  • Usage Data

    Information collected automatically through SIP.TG (or third-party services employed in SIP.TG), which can include: the IP addresses or domain names of the computers utilized by the Users who use SIP.TG, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

  • User

    The individual using SIP.TG who, unless otherwise specified, coincides with the Data Subject.

  • Data Subject

    The natural person to whom the Personal Data refers.

  • Data Processor (or Processor)

    The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

  • Data Controller (or Owner)

    The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of SIP.TG. The Data Controller, unless otherwise specified, is the Owner of SIP.TG.

  • SIP.TG (or this Application)

    The means by which the Personal Data of the User is collected and processed.

  • Service

    The service provided by SIP.TG as described in the relative terms (if available) and on this site/application.

  • European Union (or EU)

    Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

  • Cookie

    Cookies are Trackers consisting of small sets of data stored in the User’s browser.

  • Tracker

    Tracker indicates any technology — e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting — that enables the tracking of Users, for example by accessing or storing information on the User’s device.

This privacy policy relates solely to SIP.TG, if not stated otherwise within this document.

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Types of Data collected

Among the types of Personal Data that SIP.TG collects, by itself or through third parties, there are: Trackers; Usage Data; number of Users; session statistics; payment info.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using SIP.TG.

Unless specified otherwise, all Data requested by SIP.TG is mandatory and failure to provide this Data may make it impossible for SIP.TG to provide its services. In cases where SIP.TG specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies — or of other tracking tools — by SIP.TG or by the owners of third-party services used by SIP.TG serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through SIP.TG.

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Mode and place of processing the Data

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Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of SIP.TG (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

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Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

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Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

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Cookies Policy

This document informs Users about the technologies that help SIP.TG to achieve the purposes described below. Such technologies allow the Owner to access and store information (for example by using a Cookie) or use resources (for example by running a script) on a User’s device as they interact with SIP.TG.

For simplicity, all such technologies are defined as “Trackers” within this document – unless there is a reason to differentiate.

For example, while Cookies can be used on both web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile apps as they are a browser-based Tracker. For this reason, within this document, the term Cookies is only used where it is specifically meant to indicate that particular type of Tracker.

Some of the purposes for which Trackers are used may also require the User’s consent. Whenever consent is given, it can be freely withdrawn at any time following the instructions provided in this document.

SIP.TG uses Trackers managed directly by the Owner (so-called “first-party” Trackers) and Trackers that enable services provided by a third-party (so-called “third-party” Trackers). Unless otherwise specified within this document, third-party providers may access the Trackers managed by them.

The validity and expiration periods of Cookies and other similar Trackers may vary depending on the lifetime set by the Owner or the relevant provider. Some of them expire upon termination of the User’s browsing session.

In addition to what’s specified in the descriptions within each of the categories below, Users may find more precise and updated information regarding lifetime specification as well as any other relevant information — such as the presence of other Trackers — in the linked privacy policies of the respective third-party providers or by contacting the Owner.

There are various ways to manage Tracker related preferences and to provide and withdraw consent, where relevant:

Users can manage preferences related to Trackers from directly within their own device settings, for example, by preventing the use or storage of Trackers.

Additionally, whenever the use of Trackers is based on consent, Users can provide or withdraw such consent by setting their preferences within the cookie notice or by updating such preferences accordingly via the relevant consent-preferences privacy widget, if available.

It is also possible, via relevant browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent preferences.

Other Trackers in the browser’s local memory may be cleared by deleting the browsing history.

With regard to any third-party Trackers, Users can manage their preferences via the related opt-out link (where provided), by using the means indicated in the third party’s privacy policy, or by contacting the third party.

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Locating Tracker Settings

Users can, for example, find information about how to manage Cookies in the most commonly used browsers at the following addresses:

Users may also manage certain categories of Trackers used on mobile apps by opting out through relevant device settings such as the device advertising settings for mobile devices, or tracking settings in general (Users may open the device settings and look for the relevant setting).

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Consequences of denying the use of Trackers

Users are free to decide whether or not to allow the use of Trackers. However, please note that Trackers help SIP.TG to provide a better experience and advanced functionalities to Users (in line with the purposes outlined in this document). Therefore, if the User chooses to block the use of Trackers, the Owner may be unable to provide related features.

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The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Access to third-party accounts, Analytics, Tag Management and Handling payments.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

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Telegram data retrieved by SIP.TG

SIP.TG may ask for some Telegram permissions allowing it to perform actions with the User’s Telegram account and to retrieve information, including Personal Data, from it. This service allows SIP.TG to connect with the User’s account on the Telegram Messenger, provided by Telegram Messenger Inc.

For more information about the permissions, refer to the Telegram privacy policy.

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Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

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Access to third-party accounts

This type of service allows SIP.TG to access the Data from your account and perform actions with it.

These services are not activated automatically, but require explicit authorization by the User.

  • Telegram account access

    This service allows SIP.TG to connect with the User’s account on the Telegram Messenger, provided by Telegram Messenger Inc.

    Place of processing: European Union.

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Analytics

SIP.TG uses Trackers to measure traffic and analyze User behavior to improve the Service.

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  • Google Analytics 4 (Google Ireland Limited)

    Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of SIP.TG, to prepare reports on its activities and share them with other Google services.

    Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

    In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.

    In order to understand Google’s use of Data, consult Google’s partner policy.

    Personal Data processed: number of Users, session statistics, Trackers and Usage Data.

    Place of processing: Ireland — Privacy Policy — Opt Out.

    Storage of Cookies duration:

    • _ga: 2 years
    • _ga_*: 2 years

  • Yandex Metrica (YANDEX, LLC)

    Yandex Metrica is an analytics and heat mapping service provided by YANDEX, LLC.

    Yandex Metrica is used to display the areas of SIP.TG that Users interact with most frequently. This shows where the points of interest are.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Russian Federation — Privacy Policy.

    Storage of Cookies duration:

    • _ym_d: 1 year
    • _ym_isad: 2 days
    • _ym_uid: 1 year
    • _ym_visorc_*: 30 minutes
    • i: 1 year
    • yabs-sid: duration of the session
    • yandexuid: 1 year
    • ymex: 1 year

  • Tilda (Tilda Publishing Ltd.)

    Analytical cookies on Tilda are used to collect information about how visitors interact with the website.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: See the Tilda privacy policy — Privacy Policy.

    Storage of Cookies duration:

    • previousUrl: 30 minutes
    • tildasid: 30 minutes
    • tildauid: 90 days
    • __ddg1_: 1 year

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Tag Management

SIP.TG uses so-called “technical” Cookies and other similar Trackers to carry out activities that are strictly necessary for the operation or delivery of the Service.

This type of service helps the Owner to manage the tags or scripts needed on SIP.TG in a centralized fashion.

This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

  • Google Tag Manager (Google Ireland Limited)

    Google Tag Manager is a tag management service provided by Google Ireland Limited.

    In order to understand Google’s use of Data, consult Google’s partner policy.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland — Privacy Policy.

  • Referral program

    Referral program is managed by the Owner. We track the source from which the User come from.

    Personal Data processed: Trackers.

    Place of processing: European Union.

    Storage of Cookies duration:

    • partner: 30 days

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Handling payments

Unless otherwise specified, SIP.TG processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. SIP.TG isn’t involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

  • Stripe (Stripe Payments Europe, Limited)

    Stripe is a payment service provided by Stripe Payments Europe, Limited.

    Personal Data processed: payment info.

    Place of processing: European Union — Privacy Policy.

  • PayPal (PayPal Inc.)

    PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

    Personal Data processed: payment info.

    Place of processing: See the PayPal privacy policy — Privacy Policy.

  • Smart Glocal (Smart Glocal Services Limited)

    Smart Glocal is a payment service provided by Smart Glocal Services Limited, which allows Users to make online payments.

    Personal Data processed: payment info.

    Place of processing: Hong Kong — Privacy Policy.

  • NOWPayments (NOWPayments Ltd.)

    NOWPayments is a payment service provided by NOWPayments Ltd., which allows Users to make online payments.

    Personal Data processed: payment info.

    Place of processing: See the NOWPayments privacy policy — Privacy Policy.

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Further Information for Users

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes.
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

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Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

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The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

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Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

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How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

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Additional information about Data collection and processing

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of SIP.TG or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

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Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, SIP.TG may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

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System logs and maintenance

For operation and maintenance purposes, SIP.TG and any third-party services may collect files that record interaction with SIP.TG (System logs) or use other Personal Data (such as the IP Address) for this purpose.

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Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

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Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within SIP.TG. It is strongly recommended to check this page often, referring to the date of the last modification listed at the top.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.