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Privacy and Personal Data Processing PolicyPublication Date: August 8, 2025

1. What this privacy policy governs

This privacy policy (hereinafter — the Policy) applies to all information, including personal data in the understanding of applicable law (hereinafter — “Personal Information”), which LE-KO LLC and/or its affiliates (hereinafter — “LE-KO”), may receive about you during your use of any LE-KO websites, mobile applications, programs, products and/or services (hereinafter collectively — “Services”), information about which you can find on the leko.sport website and other LE-KO owned websites (hereinafter collectively — “Sites”), as well as during the performance by LE-KO / its affiliates of any agreements and contracts concluded with you in connection with your use of the Services. LE-KO may also receive Personal Information from its partners (hereinafter — “Partners”), whose websites, programs, products or services you use (for example, from LE-KO advertisers or fitness studios). In such cases, the transfer of Personal Information is possible only in cases established by applicable law, and is carried out on the basis of special agreements between LE-KO and each of the Partners.

The Policy was developed in accordance with Federal Law of the Russian Federation No. 152-FZ "On Personal Data", Federal Law of the Russian Federation No. 149-FZ "On Information, Information Technologies and Information Protection", as well as other regulatory legal documents that regulate the procedure for processing personal data of Users.

2. Who processes the information

To ensure your use of the Sites and Services, your Personal Information is collected and used by LE-KO, including Limited Liability Company "LE-KO", a legal entity established under the laws of the Russian Federation and registered at: Russian Federation, 443100, Samara, Samarskaya st. 200a (LE-KO LLC).

3. Purpose of this Policy

The protection of your Personal Information and your privacy is extremely important to LE-KO. Therefore, when you use the Sites and Services, LE-KO protects and processes your Personal Information in strict accordance with applicable law.

Following our obligations to protect your Personal Information, in this Policy we would like to transparently inform you about the following:

(a) why and how LE-KO collects and uses (“processes”) your Personal Information when you use the Sites and/or Services;

(b) what is the role and responsibilities of LE-KO as a legal entity that decides why and how to process your Personal Information;

(c) what are your rights in the context of Personal Information processing.

4. What Personal Information LE-KO collects about you

Personal Information collected during the operation of the Sites and/or provision of Services may differ depending on whether you use your account to access the Sites and/or Services.

LE-KO does not verify the Personal Information provided by you, except in cases provided by the user agreement or terms of use of individual services, and cannot judge its authenticity, or whether you have sufficient legal capacity to provide your Personal Information. Nevertheless, LE-KO assumes that you provide accurate and sufficient Personal Information and update it in a timely manner.

LE-KO may collect the following categories of Personal Information about you using recommendation technologies during your use of the Sites and Services:

(i) Personal Information provided by you, such as your name, phone number, address, and age;

(ii) electronic data (HTTP headers, IP address, cookies, web beacons/pixel tags, browser ID data, hardware and software information, application API key, GAID on Android, IDFA or IDFV on iOS, TrueDepth API data on iOS, wi-fi network data);

(iii) date and time of access to the Sites and/or Services;

(iv) information about your activity during your use of the Sites and/or Services (e.g., search history, visited studios data, likes and preferences);

(v) geolocation information;

(vi) other information about you necessary for processing in accordance with the terms governing the use of specific LE-KO Sites or Services;

(vii) information about you that we receive from our Partners in accordance with the terms of agreements concluded between you and the respective Partner, and agreements concluded between LE-KO and the Partner.

LE-KO also uses cookies and web beacons (including pixel tags) to collect Personal Information and link such personal information to your device and web browser (see section 11 of this Policy).

LE-KO does not collect “sensitive” personal information (such as political views, health information, and biometric data), except as provided by user agreements for individual Services. Nevertheless, you may independently provide them to LE-KO, and in such a case, LE-KO will process them as part of providing you with the Services (for example, if you make search queries related to your health). However, you should take into account that LE-KO cannot request your consent for such processing, as it is not aware in advance of the potentially sensitive nature of the Personal Information you may provide to LE-KO.

LE-KO does not collect data for the purpose of creating a user “profile” to the extent that it may significantly affect your rights and freedoms in accordance with applicable law.

5. Legal basis and purposes of processing your Personal Information

LE-KO is not entitled to process your Personal Information without sufficient legal grounds. Therefore, LE-KO processes your Personal Information only if:

(i) processing is necessary to fulfill LE-KO's contractual obligations to you, including ensuring the operation of the Sites and Services;

(ii) processing is necessary to comply with legal obligations;

(iii) processing is necessary to better understand how you interact with our Sites and/or Services; to improve, change, personalize or otherwise enhance the Sites and Services in the interest of all users; to offer you other relevant products that may be of interest to you.

(iv) for specific purposes or in accordance with the requirements of applicable law, we may request your separate consent to the processing of your Personal Information. Your commencement of using LE-KO Sites and/or Services expresses your consent to such processing. We hereby inform you, and you confirm, that you have no obligation to provide us with any Personal Information when you use the Sites or Services and it is based solely on your free will. However, you understand that without providing Personal Information, we will not be able to provide you with the opportunity to use the Services, and your use of the Sites will be limited.

This Policy applies only to LE-KO Sites and Services. LE-KO does not control and is not responsible for third-party Internet resources that the User may access via links available on the Sites or Services.

LE-KO always processes your Personal Information for specific purposes and only that Personal Information that is relevant to achieving such purposes.

We process your Personal Information for the following purposes:

(i) providing you with access to the Sites and/or Services;

(ii) communicating with you to send you technical messages, support service messages, notifications, requests and information related to the operation of the Sites and Services, fulfilling agreements with you and processing your requests and applications, administering the Services;

(iii) personalizing advertising and offers taking into account your preferences, history of attending Classes and other Personal Information about you available to LE-KO;

(iv) improving the usability of the Sites and Services, including displaying the most relevant search results and providing more personalized Sites and Services, optimizing the user interface, as well as improving, protecting, enhancing the Site, Services and other LE-KO products, applications and Services;

(v) creating new LE-KO products, utilities and offers;

(vi) protecting your rights;

(vii) collecting, processing and presenting statistical data, big data and other research.

6. How LE-KO protects your Personal Information

In most cases, Personal Information is processed automatically without access by any LE-KO employees. If such access is needed, it can only be granted to those LE-KO employees who require it to perform their tasks. To protect and ensure data confidentiality, all employees must comply with internal rules and procedures regarding Personal Information processing. They must also follow all technical and organizational security measures in place to protect your Personal Information.

LE-KO has also implemented sufficient technical and organizational measures to protect Personal Information from unauthorized, accidental or unlawful destruction, loss, alteration, misuse, disclosure or access, as well as other unlawful forms of processing. These security measures have been implemented taking into account the current state of technology, the cost of their implementation, the risks associated with processing and the nature of Personal Information.

7. Who else has access to your Personal Information and to whom it may be transferred

7.1 Within LE-KO, its employees and affiliates.

LE-KO may transfer your Personal Information to its employees (within the limits specified in section 6 of this Policy). LE-KO may also transfer your Personal Information to its affiliates; by using LE-KO Services, you consent to such transfer. In all cases, Personal Information will also be processed only for the purposes set out in section 5 of this Policy.

7.2 Outside LE-KO and its affiliates.

LE-KO may also transfer Personal Information to third parties to achieve the purposes set out in section 5 of this Policy, and by using LE-KO Services, you consent to such transfer.

Such third parties may include:

(i) Partners, such as studio owners providing sports, fitness, health, and wellness services; website and application owners, advertising networks, and other partners providing LE-KO with services related to placing and displaying advertisements on websites, programs, products, or services owned or controlled by such partners;

(ii) advertisers or other persons who display advertisements to you on LE-KO Sites and/or Services, as well as information service providers or consultants.

LE-KO may also transfer Personal Information to third parties not part of LE-KO and its affiliates:

(i) any regulatory body, law enforcement agencies, central or local executive authorities, other official or government bodies or courts, to which LE-KO is obliged to provide information in accordance with applicable law upon a corresponding request;

(ii) third parties, if you have expressed consent to the transfer of your Personal Information or the transfer of Personal Information is required to provide you with the relevant Service or to fulfill a specific agreement or contract concluded with you;

(iii) any third party for the purpose of ensuring the legal protection of LE-KO or third parties in case of your violation of this Policy.

8. Where your Personal Information is stored and processed

Your Personal Information will be stored in the Russian Federation.

LE-KO records, systematizes, accumulates, stores, clarifies (updates, changes), and extracts personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation.

9. How long we store your Personal Information

LE-KO will store your Personal Information for as long as necessary to achieve the purpose for which it was collected, or to comply with legislative and regulatory requirements.

If you wish any of your Personal Information to be deleted from LE-KO's databases, you can independently delete the necessary Personal Information using your account through the Service (where applicable).

10. Your Rights

10.1 What rights you have.

If provided by applicable law, you have the right to access your Personal Information processed by LE-KO in accordance with this Policy.

If you believe that any information LE-KO holds about you is incorrect or incomplete, you can contact us at support@leko.sport.

If provided by applicable law, you also have the right to: demand the deletion of your Personal Information or part thereof, as well as withdraw consent to the processing of your personal information; demand restrictions on the processing of your Personal Information. LE-KO will comply with these requests in accordance with applicable law. In cases provided by applicable law, you may also have other rights not listed above. When you use the Services, the transfer of Personal Information is carried out with your consent, expressing free will and your interest (in particular, based on a contract with you) and is not a legal obligation.

10.2 How you can exercise your rights.

To exercise the above rights, please contact LE-KO (see section 13 of this Policy). If you are not satisfied with how LE-KO processes your Personal Information, please let us know and we will consider your claim.

11. How we use cookies on the Sites or when you use the Services

11.1 What cookies LE-KO uses and why.

Cookies are a small piece of data that is received and processed by the device you use to access the Sites. Cookies store and send back to the Sites information that helps your work with the Sites and allows us to remember your preferences over time, such as browser settings or recognizing your account.

The Sites and Services use the following types of cookies:

necessary cookies: these cookies are necessary for the operation of the Sites and the provision of Services to you; among other things, they allow LE-KO to identify your hardware and software, including your browser type;

statistical/analytical cookies: these cookies allow us to recognize users, count their number, and collect information such as your actions on the Sites and Services, including information about the web pages you have visited and the content you receive;

technical cookies: these cookies collect information about how users interact with the Sites and/or Services, which allows us to identify errors and test new functions to improve the performance of the Sites and Services;

functional cookies: these cookies allow us to provide certain functions to facilitate your use of the Sites, for example, by saving your preferences (such as location);

(third-party) advertising cookies: these cookies collect information about users, traffic sources, visited pages. They allow us to display advertisements that may be of interest to you, based on an analysis of the Personal Information collected about you. They are also used for statistical and research purposes.

11.2 How long cookies are stored on your device.

LE-KO uses the information contained in cookies only for the purposes indicated above, after which the collected data will be stored on your device for a period that may depend on the corresponding type of cookies, but not exceeding the period necessary to achieve their purpose, after which they will be automatically deleted from your system.

11.3 Who else has access to the information contained in cookies.

Personal Information collected through cookies placed on your device may be transferred to and accessed by LE-KO and/or third parties specified in section 7 of this Policy. The use of Personal Information outside the Sites or Services for advertising purposes, if any, may be subject to separate user agreements available on third-party websites.

When you first visit the Sites, your consent to the use of cookies may be requested.

If, after you have approved the use of cookies, you wish to change your decision, you can do so by deleting the cookies stored in your browser (this can usually be done in your browser settings — please refer to your browser's user manual or its developer's website). After that, a pop-up window requesting your consent may be displayed again, and you will be able to make a different choice. If you refuse the use of cookies, this may result in some functions of the Sites being unavailable to you and will affect your ability to use the Sites. You can also change your browser settings to accept or reject all cookies by default, or cookies from specific sites, including LE-KO Sites. If you have approved the use of cookies on one of LE-KO Sites, we will assume that the use of cookies on all Sites has been approved by you.

LE-KO may also use web beacons (pixel tags) to access cookies previously placed on your device for the following purposes:

(i) determining your actions on the Sites and during the use of the Services by accessing and using cookies stored on your device;

(ii) collecting statistical information related to the operation of the Sites, Services, or LE-KO products and offers.

12. Updating this Policy

This Policy may be amended. LE-KO has the right to make changes at its discretion, including, but not limited to, cases where the relevant changes are related to changes in applicable law, as well as when the relevant changes are related to changes in the operation of the Sites and Services.

LE-KO undertakes not to make significant changes, impose additional burdens or restrictions on your rights established by this Policy without your notification. You will be notified of such changes. Corresponding notifications may be displayed on the Site or in the Services (for example, through a pop-up window or banner) before such changes come into effect, or may be sent to you through other communication channels (for example, by email, if you have provided us with your contact details).

Details for sending legally significant messages to LE-KO LLC:

Limited Liability Company "LE-KO"
TIN: 6317166912
KPP: 631701001
OGRN: 1246300012188
Settlement account: 40702 810 8 5440 0076665
Email address: Legal@leko.sport
Location address: Russian Federation, 443099, Samara Region, Samarsky District, Samara, Vodnikov str., building 60, office 809