This Privacy Policy is an integral annex to the Public Service Agreement
(hereinafter referred to as the "Main Agreement") and governs all legal relationships concerning personal data, including potential disputes.
We ask you to familiarize yourself with this Privacy Policy before entering into the Main Agreement, as it contains and explains all the information you need to know about how we collect, store, provide, and process your data.
The services offered may only be provided to individuals over the age of 18, but not younger. Accordingly, if you provide your personal data under this Privacy Policy, you do so on the condition that you are 18 years old. In case the controller determines a violation of this rule — the provision of personal data by an individual under the age of 18 — they will immediately delete such data.
If personal data of minors under the age of 18 are provided, you guarantee to the controller that you are doing so as the legal representative (you must confirm your authority with official documents upon the controller's request) of the minor data owner, and you also provide the clear consent of the minor data owner for data processing.
Personal data of third parties should not be provided under this Privacy Policy. However, if this is necessary to receive services, the person transmitting third-party data is recognized as the controller of such data and, therefore, automatically assumes responsibility for informing the personal data owner in advance about everything required by the applicable law of the data subject's location and the terms of this Privacy Policy. Additionally, they commit to complying with Article 14 of the GDPR before transferring such third-party data to us.
During cooperation, the controller will use "Cookies" to collect any data from devices you use to access our services. Therefore, we are obliged to obtain your consent to use Cookies during the cooperation. We ask you to provide consent by clicking the "Accept" button before starting to use the site. Cookies are used to improve service quality and retain your user settings.
1. About Us
The data controller and the responsible party under this Privacy Policy is the legal entity providing services under the Main Agreement.
2. Applicable Law
Relevant data protection laws are based on your place of residence, so this Privacy Policy will apply and be valid only for specific locations. The term "personal data" in this Privacy Policy complies with the definition provided by the GDPR.
If you live in California, USA, or Virginia, we apply the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020) and the Virginia Consumer Data Protection Act (Virginia Code Ann. §§ 59.1-575 to 59.1-585) (collectively referred to as "US Data Laws").
If you reside in Ukraine or are a Ukrainian resident, we apply the Law of Ukraine "On Personal Data Protection" to govern relations concerning your personal data.
3. Legal Basis for Data Processing
Under certain data laws, we are required to inform you of the legality (legal basis) for processing your personal data. According to this Privacy Policy, the legal basis is the performance of a service contract to your benefit or the performance of certain steps at your request before entering into the contract.
If the previous basis does not apply, we obtain your consent, which makes this consent a lawful basis. If neither the contract nor consent falls under the criteria of legality, the legal basis is the legitimate interests of the controller.
The basis for processing personal data is your freely given, specific, informed, and unambiguous consent, which you automatically express/provide by entering into the Main Agreement in the manner prescribed by the Main Agreement.
Thus, providing your personal data in this way is voluntary, although if you do not provide your personal data as outlined in the Privacy Policy, you must refrain from using the service, and the controller will be forced to deny you services under the contract and consider any of your requests.
Before starting cooperation, you give us consent to collect, store, accumulate, process, distribute, and use your personal data. However, you retain the right to change your decision and withdraw your consent at any time.
4. Information About Your Rights — General Provisions
Right to access your personal data
You have the right to request a copy of your personal data that we store.
Right to correct/modify your data
We strive to keep your information up-to-date and accurate throughout the cooperation. If you need to make any changes or corrections to your data that you cannot make yourself, contact us.
Right to change your consent and withdraw provided consent
You have the right to change your mind about the amount of data you allow us to store or correct your data by contacting us. If you wish to change your consent, contact us.
Right to delete your data ("right to be forgotten")
You can request the deletion of all your data. To request data deletion, contact us.
5. Your Rights If You Are a Resident of California, USA, or Virginia
This section applies to you if you are a resident of California or Virginia ("Selected US Residents").
According to Virginia law, we are considered a "Controller."
About Personal Information
Personal information of Selected US Residents is any data that can identify you as an individual under US Data Laws, described in Section 6 of this Privacy Policy.
How we collect, use, and share your personal information
Personal information we collect may include: photos and videos where you can be identified if your face is shown or your voice is heard; information about the app, browser, and device you use to access the service; geolocation data; other information you voluntarily provide.
Sensitive personal information (as defined by US Data Laws) we collect may include: precise geolocation; information about your origin; content of messages you send and receive through any internal platform chat or correspondence with our support team.
We may use your information to: provide, personalize, and improve our products and services; send you marketing communications; communicate with you for any other reason, including customer support. Your consent to process sensitive personal information is expressly provided under US Data Laws when you create an account, make a payment, accept terms, or upload any sensitive content to your account/profile.
We may share some of your personal information with law enforcement agencies in cases detailed in this Privacy Policy.
(5) Our Privacy Policy outlines all our disclosure and sharing practices, but here are some specific details for residents of Virginia and California.
Virginia Residents:
We do not sell your personal information as defined by Virginia law. However, Virginia law allows exceptions for sharing personal information. If you opt out of data sharing, we may still disclose your information in the following ways:
To a third party acting as our data processor, such as a payment processing provider;
To third parties to provide the product or service you requested;
To our subsidiaries;
If the information is publicly available through media and not restricted to a specific audience;
As part of a merger, acquisition, or similar corporate transaction.
California Residents:
We do not sell your personal information, but we share it as described in the Privacy Policy.
Data Retention
The duration of your data retention is outlined in Section 10 of this Privacy Policy.
Automated Decision-Making/Profiling
We use profiling in our service, as described in the "Profiling" section of this Privacy Policy.
Your Rights as a Resident of California or Virginia, USA
Depending on whether you reside in California or Virginia, you may have the following rights:
Right to access/correct/port data;
Right to deletion: Note that your right to access and delete data is not absolute and may have exceptions depending on your location;
Appointing an authorized representative based on a written document, depending on your residence;
Appeal a decision (Virginia residents only): You may have the right to appeal if we deny any data requests through an established appeals process for your location.
5.1. Your Rights as a Resident of Ukraine
You have all the rights provided by the Law of Ukraine "On Personal Data Protection" and are free to exercise them when receiving services from the Controller. If you need to exercise your rights, contact us.
6. What Data We Collect
We collect your data when you register on our service, create, use, or edit your profile.
We collect your personal data, which may qualify as personal data under applicable data laws. This includes, but is not limited to:
Your real name, phone number, email address, and any other information you voluntarily provide during registration.
If you change your consent regarding providing the minimum required data — contact information, email address, last name, first name — necessary for service delivery, the controller reserves the right to refuse services and delete all your data.
You may also voluntarily provide "sensitive" personal information and data. By providing this information, you give us explicit consent to collect, process, and store it to deliver our services.
Additionally, you can upload videos, photos, and other data to your profile.
We collect your data when you communicate with us.
If you interact with our customer support team, we will retain any information you provide during such communication. We also reserve the right to record and monitor phone calls and written messages for security, service delivery, and service improvement purposes.
We collect your data when you use our services.
We collect all data generated during your use of our application without restrictions. We reserve the right to collect location data (geolocation) from the device you use, whether a computer or mobile device, during your use of our service. If you do not want to share your location data with us, you can disable this feature following your device’s instructions.
7. How We Use Your Data
Main purposes:
To operate, improve, and promote our services;
To provide you with access and usage of the online service;
To manage your registered user profile on our platform;
To enhance and improve service use;
To engage in interactive service features;
To process any actions you take when using our services;
To tailor your experience and remember your preferences;
To provide service-related information upon request;
To respond to your questions, requests, and comments;
To notify you of changes, updates, or modifications to our services or their features;
To ensure compliance with the Privacy Policy and applicable laws and regulations.
Special purposes:
Providing Our Services
The data we collect from you is used for:
Directly delivering our services;
Responding to your service requests and fulfilling them;
Resolving your service-related requests;
Configuring, improving, and delivering our services;
Analyzing and researching your interest and service usage.
Profiling
We offer a profiling feature to help you use our services more efficiently. This feature analyzes your activity within the online service to improve your user experience. You consent to this profiling by checking the consent box during profile registration.
Communications
We use your data for communication purposes, including:
Sending notifications, including about changes, updates, or additions;
Ensuring or enforcing our rights;
Responding to your requests;
Contacting you regarding your profile, providing customer support, managing your profile, and delivering services.
Mobile Device Data Usage
If you access our services via a mobile device, we reserve the right to use data collected from that device for any purposes described in this Privacy Policy.
Non-Personal Data Usage
We use electronic data that contains no identifying information to improve and update our service’s content, design, and functionality. This data helps us personalize user interactions and provide recommendations matching your preferences.
Security
We reserve the right to review and monitor your activity while using our services to ensure compliance with the Master Agreement and this Privacy Policy and to detect any suspicious behavior on your part.
How We Use Your Photos and Other Content
As stated in the Master Agreement, you grant us a license to freely use photos/videos you upload to our service for commercial and advertising purposes. You retain the right to revoke this license under the terms specified in the Master Agreement.
In certain cases provided by applicable law, we may be required to disclose some or all data about you that we hold to third parties, strictly in cases provided by law.
Third-party providers engaged by us to provide services to you
We share your data with third parties that help us deliver our services, solely for the purpose of providing these services and only to the extent necessary. We do not transfer your data to third parties for marketing, advertising, or any other purposes that do not align with the intended use of your personal data.
Disclosure to the controller company’s employees
Within the controller company, access to your personal data is granted only to employees responsible for providing services under our cooperation, contacting you, and offering customer support (including refunds). These employees or team members are given access to your data only to the extent necessary to perform their tasks.
Change of ownership, mergers, and acquisitions
If we sell or acquire shares in our company, your data will be included among the assets transferred during such a transaction. Likewise, if our company’s assets are acquired by a third party, your data will be transferred as part of this asset transfer.
Business partners
When you register your profile and use services in our app, we may receive your personal data from our business partners, provided they have obtained your prior consent to share such information with us in accordance with the laws of your location. However, we will never disclose or transfer this data to any business partners not involved in providing services to you.
9. Where your data is stored
Your data is stored in Germany, where the data center operator’s servers are located. We reserve the right to transfer and store data collected from you in locations outside the European Economic Area (EEA). Additionally, your data may be processed by law enforcement and/or employees or independent contractors of our third-party suppliers located outside the EEA. By submitting your data, you agree to such storage, transfer, and processing. We will take all reasonable measures to protect your data in accordance with this Privacy Policy. Moreover, under data protection laws, we enter into mandatory data processing agreements with third parties involved in processing your data.
10. How long we store your data
Generally, we retain your data as long as we provide you with our services until your profile is deleted.
From a data retention perspective, our users are divided into several groups:
Active users – you regularly log in and use our services. If you are classified as an active user, we will retain your data until you delete your profile.
Inactive users – your profile is archived. In this case, we store your data indefinitely. You may contact us separately to request the deletion of your data.
Deleted users – your profile is deleted, and all information about you is automatically, permanently, and irreversibly erased within 24 hours.
If any law requires the controller to retain your personal data for a longer period, or if the controller believes it should do so (e.g., to handle potential claims from you or resolve financial issues), the controller will retain your personal data for the aforementioned additional period. After these periods end, your data will be deleted.
11. Security
The controller guarantees that your personal data is processed with the highest level of confidentiality and that all possible and necessary measures (including those provided by the "Sintegrum" platform's Data Security Strategy), both technical and organizational, are taken to ensure the security of your data and prevent its alteration, misuse, loss, theft, and unauthorized handling or access. Data processing is conducted in accordance with data protection regulations.
However, despite these efforts, the controller cannot guarantee 100% secure data transmission over the Internet. While we take all reasonable efforts to protect your personal data, we cannot guarantee the complete security of data transmitted to our service. Any data transmission is at your own risk. We take all possible, available, and necessary measures to protect your data from unauthorized disclosure or access. We also cannot guarantee that your data will not be disclosed, transferred, or used in ways that violate this Privacy Policy or the law. We are not responsible for any data disclosure resulting from unauthorized access, transmission errors, or other issues beyond our reasonable control.
12. Changes to this Policy
We regularly review this Privacy Policy and reserve the right to make any changes, amendments, or adjustments by publishing a new version on the application’s website.
13. Contact
If you have any questions about this Privacy Policy or wish to exercise any of the rights listed above, please contact us at:
.gro.ytisrevorpmi%40ofni
Data protection officer: .gro.ytisrevorpmi%40ofni
The controller reserves the right to request identity documents from you before processing any of your requests in accordance with this Privacy Policy and the laws of your location.
14. Complaints
We will make every effort to review and resolve any requests, claims, or complaints you may submit regarding your personal data or this Privacy Policy. However, if you are not satisfied with the handling of your requests, claims, or complaints, you have the right to file a complaint with the relevant data protection authority under the laws of your location.
15. Applicable law
This Privacy Policy is governed by the law of the Master Agreement. All EEA residents using the controller's services have all the rights concerning their personal data provided by the GDPR.
16. Miscellaneous
In case of any conflict between the provisions of this version and the Ukrainian version, the Ukrainian version of this Privacy Policy shall prevail over versions in other languages.
This Privacy Policy is effective from 01.03.2025.