Privacy Policy

This Privacy Policy has been developed taking into account Our understanding of the importance of Personal Data and Our responsibility to handle it respectfully and securely. Maintaining Your privacy and transparency around how Your Personal Data is used is one of Our top priorities.

The purpose of this Privacy Policy is to explain how We collect, use, store, and otherwise Process Your Personal Data when You interact with the Platform, or use Our Services through the Platform or App.

We want You to feel confident that Your Personal Data is protected and Processed in accordance with applicable legal standards — including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), California Online Privacy Protection Act (CalOPPA), the Law of Ukraine “On Personal Data Protection”, and other relevant data protection regulations. For Users from other jurisdictions, the Processing of Personal Data shall be subject to the data protection laws applicable in their country of residence.

This Privacy Policy applies to all visitors and Users of the Platform and App, regardless of the device or method of access. It explains what information We collect, for what purposes, how long We retain it, and what rights You have regarding Your Personal Data.

Please read this Privacy Policy carefully before using the Platform or submitting any Personal Data.

By using the Platform or App, becoming an Awesome, interacting with the Platform or App, or otherwise providing Us with Your Personal Data, You confirm that:

• (I) You have read, understood, and agree to this Privacy Policy;
• (II) You have reached the age at which You are legally allowed to give Consent to the Processing of Your Personal Data in Your jurisdiction. In any case, You must be at least 16 years old (or 13 in certain regions) or have obtained permission from a parent or legal guardian who agrees to this Privacy Policy on Your behalf.

If You do not agree with this Privacy Policy or any part of it, please do not use the Platform.

1. For convenience, We use the following terms in this Privacy Policy:

“Privacy Policy” — this document, available at https://fontba.se/legal/privacy (hereinafter — “Privacy Policy”, “Policy”).

“Terms of Service” — document, which sets out the rules, rights, and responsibilities for using the Platform and App. You can always find the latest version here: https://fontba.se/legal/terms.

“FontBase” — Senary Domain LLC, file number: 7243120, legal address: 8 THE GREEN, STE A Dover, Kent 19901 (hereinafter — “Company”, “We”, “Us”, “Our”).

“Platform” — the digital environment available at https://fontba.se, managed by the Company, through which the User may access, download, and install the App or fonts on their device.

“Application” — a desktop software product designed for the management, installation, and organization of fonts, which the User may download and install from the Platform onto their device for personal or professional use (hereinafter — “App”).

“Services” — the functionalities, features, and offerings provided by the Company through the Platform. Services include, but are not limited to, access to the Platform, the App, and any functional features, tools, or capabilities made available through the Platform or the App, whether existing now or introduced in the future, as updated, modified, or expanded by the Company from time to time.

“Awesome” — any User who has completed the subscription process through the Platform in order to obtain access to the advanced features and extended functionality of the App.

“Personal Data” — any information relating to a natural person who is identified or can be identified using this information (hereinafter — “Personal Data”, “Data”).

“Processing of Personal Data” — any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (hereinafter — “Process”, “Processing”, “Processing of Personal Data”).

“Subject of Personal Data” — any person who accesses, visits, or otherwise uses the Platform and/or the App, whether free of charge or as Awesome (hereinafter — “Subject of Personal Data”, “User”, “You”, “Your”).

“Consent” — any freely given, specific, informed, and unambiguous indication of the User’s wishes by which they, by a clear affirmative action, signify agreement to the Processing of their Personal Data.

“Third Party” — any legal person, public authority, agency, or body other than the Subject of Personal Data, the Controller, or the Processor, who may access Personal Data in accordance with the law or contractual obligation.

“Controller” — the Company, which determines the purposes and means of Processing of Personal Data.

“Processor” — a natural or legal person, public authority, agency, or other body which Processes Personal Data on behalf of the Controller.

“General Data Protection Regulation” (GDPR) — Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

“CCPA” — California Consumer Privacy Act of 2018, applicable to Users from California, USA.

“CalOPPA” — California Online Privacy Protection Act of 2003.

2. Personal Data We Process when You use the Platform and App

We collect various types of Personal Data about You when You use the Platform and App. For clarity, this Data is divided into two main groups: Automatically Collected Data and Independently Provided Data.

Automatically Collected Data refers to data obtained through technologies that automatically or passively record how You access and interact with the Services.

Independently Provided Data refers to data that You actively provide to Us on Your own initiative while using the Services.

Below is an overview of the types of Data We may collect when You use the Services:

2.1. The App

a) Automatically Collected Data

When You use the App, We automatically collect the following Data:

• Your IP address;
• Your computer’s unique ID, operating system, the version of application, downloaded on Your computer;
• time when You open and close the App;
• the errors, which may occur during Your use of the App and the fonts downloaded to the App.

We may use this Data to, among other things, help diagnose problems with Our servers, analyze trends, resolve bugs and gather information for aggregate use. We collect it every time, when You use the App or Services. We can see how much time You spend using Services and when just to adjust Our App and make it as user friendly as possible.

As with most websites and technology services delivered over the Internet, our servers automatically collect information when You access or use the App and record it in log files on Your computer. This log data includes App version, when the App was launched, when it was closed, Your actions in the App, crash reports and operation system, technical messages. This is needed to support the normal functioning of the App on Your computer with minimum service errors.

b) Independently Provided Data

Before You become Awesome, the Company does not request or require any Personal Data from You.

Once You choose to become Awesome, We are required to collect Personal Data for the purposes of billing, payment processing, and account administration. This is the only stage at which the provision of Personal Data is requested from You.

We request only the minimum Data necessary to process Your payment and to register You as Awesome. This may include:

• email address;
• full name;
• billing address;
• payment card details.

We do not collect any Data beyond what is necessary to complete the transaction and provide You with access to Awesome. All payment-related data, including credit card numbers, is processed through secure servers and transmitted using industry-standard encryption technologies to prevent unauthorized access during data transmission.

For security reasons, please ensure that all purchases are made exclusively through our Platform. We do not authorize any third-party platforms or alternative sources to sell or distribute access to App or Awesome.

2.2. The Platform

a) Automatically Collected Data

We do not collect any Personal Data when You browse Our Platform. At this stage, the only data processed relates to analytics, for the purposes of pursuing our legitimate interests, including evaluating and improving the performance and reach of Our Services. The information received is aggregated and anonymized, and it does not enable us to identify any individual user.

b) Independently Provided Data

If You choose to receive newsletters, updates, new Awesome features, promotional materials, or other communications from Us, You may subscribe through the dedicated form available on Our Platform. In doing so, You may be required to provide certain Personal Data, such as Your name and email address.

We collect and Process Personal Data for the purpose of delivering such communications, based on Your Consent.

You may withdraw Your Consent at any time by using the unsubscribe link included in each communication or by contacting Us directly. Withdrawal of Consent does not affect the lawfulness of processing carried out prior to such withdrawal.

2.3. Children's Privacy

Ensuring the privacy and safety of children online is a top priority for Us. We are committed to complying with the privacy laws, particularly concerning the protection of children's Personal Data.

We knowingly do not Process the Personal Data of children under the age of 13 (applies to Users who are residents of countries with a reduced minimum age for Personal Data Processing) and children under 16, and We also do not offer them to use the Platform or App.

If We become aware that a person who has not reached the age from which it is permitted to Process their Personal Data has provided Us with their Personal Data without the Consent of a legal representative, guardian, or other person authorized to provide such Consent, We will take all necessary measures to delete such Data. If You believe We might have any information from or about a child under 16 (or 13 if applicable), please contact Us at email.

We disclaim any responsibility or liability in the event that a person under the legal age for Personal Data Processing begins using the Platform or App and provides their Personal Data without obtaining the necessary Consent from their legal representatives. It is the responsibility of such persons or their guardians to ensure that the appropriate Consent is obtained prior to using the Platform or App. You must be of legal age to be in line with Our Privacy Policy, as well as with Our Terms of Service.

3. Data We do not Process

We do not access, monitor, or retrieve any Personal Data stored on Your device, including files, folders, or applications. We do not read or modify Cookie files created by other websites, nor do we place any tracking cookies on Your device for Our own purposes.

The Company does not use cookies to collect Personal Data or track Your activity outside of the Platform or the App. Any analytics or operational data collected by the Company is limited to aggregated, anonymized usage data strictly necessary for maintaining and improving the Services.

4. Purposes of Personal Data Processing

We use Your Data to ensure the smooth operation of Our Platform and App, improve the user experience, and provide Services. We Process the Personal Data collected concerning You only for the specific and limited purposes specified below:

• Service delivery. To provide, operate, maintain, and protect our Services, including ensuring their proper delivery and performance; supporting functionality; preventing, detecting, and addressing service errors, security incidents, fraud, or technical issues; as well as monitoring, analyzing, and improving the functionality, stability, and overall user experience of the Services.
• Analytics. In order to understand what to build or how to improve the Services, We need to understand trends and demand for Our features.
• Communication with You. We process certain information to send emails and other communications. This includes responding to Your requests, comments, and inquiries. If You contact Us, We may use Your information to provide a response and resolve the matter. We may send You service-related, technical, and administrative communications, including updates about the Services, important notices, security alerts, and fraud-prevention messages. These communications are necessary for the proper provision of the Services and, therefore, are considered an essential part of Your use of the Services. You may not opt out of receiving such essential communications.
• Marketing communications. Based on Your subscription and Consent, we Process Your Personal Data to send You marketing and commercial communications, including newsletters, updates, new Awesome features, promotional materials, and other information You have opted to receive.
• Transaction Processing and account verification. To process transactions and track purchase history and verify Your identity for Awesome subscription. The Company may need to contact You for invoicing, account management, and similar purposes. We use account data to keep track of billing and payments according to Your Awesome subscription.
• Developing and Service fixing. The Company tries to make the Services as useful as possible, so we are using the information to develop the Service and fix the bugs and errors as well as to come up with new Awesome features.
• Detection and prevention of fraudulent or unlawful activities. We may Process Your Personal Data to detect, investigate, and prevent activities that may violate Our policies, constitute fraud, or be otherwise unlawful. This includes monitoring for unauthorized access, suspicious transactions, security breaches, or any activity that could compromise the integrity, security, or proper functioning of the Services.
• Enforce Our Terms of Service. We use the Data We collect to enforce Our Terms of Service, Policy and the law. This includes enforcing, investigating, and reporting conduct that violates Our Terms of Service, Policy, or the law, responding to requests from law enforcement, and complying with legal requirements. In some cases, We may also use or share Your Personal Data to cooperate with law enforcement requests, escalate safety issues to law enforcement, industry partners, or others, or comply with Our legal obligations.

We do not use Your Personal Data for any purposes other than those specified in the Policy. Any further Processing of Your Personal Data will be carried out only with Your express Consent or in accordance with the requirements of the law.

We will not sell Your Personal Data, including e-mail address, nor do we provide it to advertisers or mass marketers. In other words, You will never receive junk mail based on Data You submit directly to Company.

5. Legal basis for Processing Your Personal Data

We Process Your Personal Data in accordance with applicable data protection laws, including the GDPR, on the following legal bases:

• Consent: We Process Your Personal Data when You give Your explicit Consent, for example by agreeing to Our Terms of Service and this Privacy Policy, or by giving permission for certain Data Processing activities.
• Contractual necessity: We Process Your Personal Data when it is necessary to fulfill Our contractual obligations to You, for example, such as to provide the Services You have requested or to complete transactions on the Platform.
• Legitimate interests: in some cases, We Process Your Data based on Our legitimate business interests, such as ensuring the security of the Platform and App, improving Our Services, or preventing fraud, provided that these interests are not overridden by Your rights and freedoms.
• Compliance with legal obligations: We may Process Your Personal Data when necessary to comply with legal obligations, such as regulatory or tax requirements, or in response to a legal request or claim.

We are committed to ensuring that Your Personal Data is Processed in a transparent and lawful manner in accordance with Your rights and applicable privacy law.

6. Storage of Personal Data

6.1. How long do We keep Your Personal Data?

We will store Your Personal Data for the period necessary to fulfill the purposes set forth in the Policy. We also endeavor to retain Your Personal Data for as long as Your Awesome is active or as needed to provide You with certain Services for purchasing Awesome. When determining the duration of such periods, We first decide whether We need to collect Personal Data at all, and, if such a need really exists, We keep it only for the period necessary to realize the purposes of collection, or until the moment You make a corresponding request to delete Your Personal Data.

When We have no ongoing legitimate business need to Process Your Personal Data, We will either delete or anonymize such Data, or, if this is not possible (for example, because Your Personal Data has been stored in backup archives), then We will securely store Your Personal Data and isolate it from any further Processing until deletion is possible.

6.2. Where do We store Your Personal Data?

We adhere to generally accepted industry standards to protect Your Personal Data both during transmission and after receipt. The Personal Data listed in sections 2.1(a) and 2.2(b) of this Policy will be stored in the cloud-based database service Supabase, operated by Supabase, Inc. The Data shall be stored on servers located in the United States, which may be part of a network of data centers distributed globally. Supabase implements appropriate administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of the Personal Data.

The Personal Data related to payments, as specified in section 2.1 (b) of the Policy, will be stored on servers managed by Stripe, Inc. (or its affiliated entities or subprocessors), a payment processing service headquartered in the United States. Stripe stores payment Data on its secure servers located in compliance with applicable data protection laws and standards, including in the United States.

The Personal Data collected automatically, as outlined in section 2.2 (a) of the Policy, will be collected and stored on servers of the relevant analytical services that the Company utilizes for the purpose. The list of provided services is specified in section 7 of the Policy.

Processing of Personal Data is carried out using computers and/or automated means in accordance with procedures and methods that correspond to the purposes of collecting Personal Data.

We take the protection of Your Personal Data very seriously. We take all commercially reasonable measures to prevent unauthorized access to Your Personal Data and those data obtained in the process of using the Platform or App. Not only that, but We strive to protect Your Personal Data by various means in order to preserve its confidentiality and integrity, prevent unauthorized use or disclosure of Your Personal Data, and protect Your Personal Data from loss, misuse, disclosure, alteration, and/or destruction.

Please note that no method of Data transferring over the Internet can provide a 100% guarantee of preventing information leakage. As a result, while We strive to protect your Data, we cannot ensure or warrant the security of any Data You transmit to Us, and You use the Services and provide Us with Your Data at Your own risk. If by any chance You have reason to believe that your Personal Data is no longer secure (for example, Your Awesome login and password may have been compromised), please immediately contact Us.

7. Do We transfer Your Personal Data to Third Parties?

We may engage service providers and specialists to help Us provide, support, and develop the Platform or App, as well as to better understand how it is used. These third-party providers offer services such as cloud hosting, customer and technical support, marketing, analytics, and online payments.

We do not transfer Your Personal Data to Third Parties except when it is necessary to fulfill a legal obligation, upon Your explicit request, or in other circumstances outlined in this Policy. We understand the importance of protecting Your Personal Data, which You voluntarily and knowingly provide to Us, and We take all possible measures to ensure its security.

In some instances, to ensure the proper functioning of the Platform, certain categories of Our employees (such as administrative staff) or Third Party service providers (e.g., independent technical service providers, hosting providers, IT services, and communication services) may have access to Your Personal Data.

We ensure that access to Your Personal Data is provided only to those Third-Party companies and individuals that can guarantee the highest level of data protection, confidentiality, and security, and who will use Your Personal Data solely for purposes consistent with this Policy and in compliance with applicable data protection laws. We limit the Data provided to such service providers to that reasonably necessary for them to perform their functions (a need-to-know basis).

Financial institutions, such as banks or payment service providers (e.g., Stripe Inc.), that can be involved to provide financial, banking services, payment services / tools, for the possibility of payment for subscription on the Platform.

Currently, online payments on the Platform are carried out using the services of the payment systems Stripe (Stripe, Inc. and its affiliates). You are encouraged to review the Privacy Policy of Stripe for more information on their Processing of Your Personal Data.

Authentication and account management providers (e.g., Supabase Inc.) that may be engaged to enable secure login, user authentication, and storage of account-related data (such as email address and profile information) necessary for the functioning of the Platform or App.

Currently, user authentication and account data storage are carried out using the services of Supabase (Supabase, Inc. and its affiliates). You are encouraged to review the Privacy Policy of Supabase for more information on their Processing of Your Personal Data.

Application monitoring and error-tracking service providers (e.g., Sentry Inc.) that may be involved to track, diagnose, and resolve technical issues occurring during the use of the Platform and App.

Currently, We use Sentry (Sentry Inc. and its affiliates) for anonymized error monitoring and diagnostic logging. We configure Sentry to minimize the collection of Personal Data and to process technical diagnostic information in an anonymized or pseudonymized form. You are encouraged to review the Privacy Policy of Sentry for more information on their Processing of Your Personal Data.

Web Analytics Service Providers (e.g. Plausible Insights OÜ and Google LLC) to evaluate and improve the performance of Our Platform, App and Services. These tools help Us understand general usage patterns, measure traffic, and analyze how You interact with the Platform and App.

Plausible (Plausible Insights OÜ) operates without collecting any Personal Data and does not use cookies. It provides Us only with aggregated, non-identifiable statistical information. You are encouraged to review the Privacy Policy of Plausible for more information on their Processing of Your Personal Data.

8. Data transfers

We may transfer Your Personal Data outside Your country of residence or the European Economic Area (EEA) to ensure the functioning of Our Services. This may include transferring Data to servers or service providers located in other jurisdictions.

When transferring Data outside the EEA or other countries where Our Company operates, We ensure that appropriate measures are in place to protect Your Data in accordance with the requirements of Data protection laws, including:

• For users in the EU, We comply with the requirements of the GDPR.
• For users in California, USA, We comply with the requirements of the CCPA (California Consumer Privacy Act).
• For users in other countries where Data protection laws exist, We comply with the relevant local requirements.

We use Standard Contractual Clauses or other legal mechanisms to ensure an adequate level of protection for Personal Data when it is transferred outside the specified jurisdictions.

9. How can You exercise Your right to privacy?

You, as a Subject of Personal Data, have the right to interact with Your Data directly or through a request to Us. This section describes these rights and how You can exercise them:

• Right to access: You can request an explanation of the Processing of Your Personal Data, as well as details regarding the Processing activities such as the manner in which the Personal Data are Processed, the purpose for which the Processing is done, the recipients or the categories of Personal Data recipients, etc.;
• Right to rectification: You have the right to obtain the correction, without justified delay, by the Company of inaccurate / unjustified Personal Data, as well as the completion of incomplete Personal Data;
• Right to erasure (“right to be forgotten”): You can send Us a request to delete Your Personal Data from Our systems and/or databases. We will remove them unless otherwise provided by law;
• Right to restrict the Processing: You may partially or completely prohibit Us from Processing Your Personal Data;
• Right to Data portability: You can request to receive all the Personal Data You provided to Us in a structured way, commonly used and in an easy-to-read format, as well as the right for this Data to be transmitted by the Company to another controller, to the extent that the conditions provided for by law are met;
• Right to object: You may object to the Processing of Your Personal Data;
• Right not to be subject to an automated individual decision: the right not to be the subject of a decision taken solely on the basis of automated Processing activities, including the creation of profiles, which produce legal effects concerning the Subject of Personal Data or similarly affect him / her in a significant measure;
• Right to withdraw Consent: You can withdraw Your Consent at any time;
• Right to file a complaint: If Your request was not satisfied, You could file a complaint to the regulatory body of the National Supervisory Authority for the Processing of Personal Data or competent courts, to the extent You deem necessary.

To exercise Your rights, please contact Us using this email. Please note that before providing the information according to Your request, We may ask You to provide additional Data to confirm Your identity.

In the event that We receive Your request, We will endeavor to respond as soon as possible, but no later than 30 (thirty) days from the date of receipt of the request.

10. External links

We may post active links to sites that are not maintained by the Company. If You visit such sites, You should review their privacy policies and operating principles. We are not responsible for the Personal Data Processing policies and practices of other companies, and any information You provide to such companies is subject to their сompany policies.

11. Dispute resolution

Before filing a claim in court in disputes arising from the relationship between the User and Us, it is mandatory to submit a claim (a written proposal for voluntary settlement of the dispute). The recipient of the claim shall, within 30 (thirty) calendar days from the date of receipt of the claim, notify the applicant of the claim in writing about the results of the consideration of the claim.

In case of failure to reach a compromise, any dispute, controversy or claim arising out of or relating to this contract, including the conclusion, interpretation, execution, breach, termination or invalidity thereof, shall be settled by the International Commercial Arbitration Court at the Ukrainian Chamber of Commerce and Industry in accordance with its Rules. The Policy is governed by and constructed in accordance with the law of Ukraine.

12. Changes to the Policy

As the laws and standards evolve, as well as Our business, We may, at our sole discretion, revise this Privacy Policy and periodically update this document with the changes. We encourage You to review Our Privacy Policy to stay informed. If We make changes that materially alter Your privacy rights, We will provide additional notice via email or through the Platform. If You disagree with the changes to this Privacy Policy, You should stop using the Services and deactivate Your Awesome account and let Us know so we will remove all Your Personal Data.

13. Contact information

If You have any comments, doubts, or questions regarding this Policy, please contact Us via email. We will try to answer You as soon as possible, but no longer than within 30 (thirty) calendar days.

14. Additional information for residents of the United States of America

This section applies only if You are a resident of certain U.S. states that have implemented state-level privacy laws. You, as a Subject of Personal Data, have some special privacy rights. To use them, please contact Us via email.

Please note! Depending on the state and legislative requirements, We have from 30 (thirty) to 60 (sixty) days to exercise Your request, with the right to postpone it for 30 (thirty) days more. If Your complaint is not satisfied, You can file a complaint with the Federal Trade Commission.

Your rights vary depending on the laws that apply to You, but may include:

• Right to access. You can request an explanation of the Processing of Your Personal Data. Areas: California; Colorado; Connecticut; Indiana; Iowa; Oregon; New Jersey; Maryland; Minnesota; Montana; Tennessee; Texas; Utah; Virginia; Delaware; Nebraska; New Hampshire.
• Right to correct. You can change the Data if it is inaccurate or incomplete. Areas: California; Colorado; Connecticut; Indiana; Oregon; New Jersey; Maryland; Minnesota; Montana; Tennessee; Texas; Virginia; Delaware; Nebraska; New Hampshire.
• Right to delete. You can send Us a request to delete Your Personal Data from Our systems. Areas: California; Colorado; Connecticut; Indiana; Iowa; Oregon; New Jersey; Maryland; Minnesota; Montana; Tennessee; Texas; Utah; Virginia; Delaware; Nebraska; New Hampshire.
• Right to portability. You can request all the Personal Data You provided to Us and request to transfer Data to another Controller. Areas: California; Colorado; Connecticut; Indiana; Iowa; Oregon; New Jersey; Maryland; Minnesota; Montana; Tennessee; Texas; Utah; Virginia; Delaware; Nebraska; New Hampshire.
• Right to opt out of sales. The right to opt out of the sale of Personal Data to Third Parties. Areas: California; Colorado; Connecticut; Indiana; Iowa; Nevada; New Jersey; Maryland; Nebraska; Montana; Tennessee; Texas; Utah; Delaware; Virginia; Minnesota; New Hampshire.
• Right to opt out of certain purposes. The right to opt-out of Processing for profiling / targeted advertising purposes. Areas: Colorado; Connecticut; Indiana; Montana; New Jersey; Maryland; Minnesota; Nebraska; Tennessee; Texas; Utah; Delaware; Virginia; New Hampshire.
• Right to opt out of Processing of sensitive Data. The right to opt-out of Processing of sensitive Data. Areas: California; Utah.
• Right to opt in for sensitive Data Processing. The right to opt in before Processing of sensitive Data. Areas: Colorado; Connecticut; Indiana; Montana; Tennessee; Texas; Virginia.
• Right against automated decision-making. A prohibition against a business making decisions about a consumer based solely on an automated Process without human input. Areas: California; Colorado; Connecticut; Indiana; Iowa; New Jersey; Minnesota; Montana; Tennessee; Texas; Virginia.
• Private right of action. The right to seek civil damages from a Controller for violations of a statute. Areas: California.

Please note! Some states do not have privacy laws. The rights of residents of such states are governed by U.S. federal law. If Your state is not on the list, please contact Us, via email.

Access to specific Data and the right to transfer Data

With certain exceptions, if You are a resident of the state of California, USA, You have the right to request a copy of the Personal Data (defined as Personal information for the purposes of this section) We have collected about You in the 12 (twelve) months prior to Your request. After receiving Your request and establishing Your identity, We will inform You of:

• categories of Personal information that We have collected about You,
• Our business or commercial purpose for collecting such Personal information,
• categories of Third Parties with whom We share this Personal information.

Also, if You are an Oregon resident, Delaware, Minnesota (effective from 31/07/2025), Maryland (effective from 01/10/2025) You also have the right to receive a list of the specific Third Parties to which We have disclosed Personal Data in Our capacity as a Controller, provided that We are not required to disclose its trade secrets.

To exercise Your rights, You may submit the request by sending an email. We will ensure that Your request is processed in accordance with the relevant legal requirements. We may require specific information from You to help Us confirm Your identity and process Your request. You have the right not to be discriminated against for exercising any of Your rights.

Non-discrimination

We will not discriminate against You for exercising Your rights related to the Processing of Your Personal information, as well as Your right to refuse to receive Our Features in the future, or for refusing to receive further marketing, informational / advertising materials from Us.

Do not sell and share my Personal information

Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have the right to opt out of the “sale” or “sharing” of their Personal information. “Sale” refers to the disclosure of Personal information to a Third Party for monetary or other valuable consideration. “Sharing” refers to the disclosure of personal information for cross-context behavioral advertising.

We do not sell or share Your Personal information as those terms are defined under the CCPA and CPRA. We do not use any Third-Party advertising or analytics services, and We do not disclose Your Data to Third Parties for marketing purposes. The only Third Party with access to Personal Data is Our payment Processor (Stripe), which acts solely as a service provider on Our behalf and does not use Your Data for any purpose other than Processing transactions.

If You are a resident of California or any U.S. state that grants similar rights, and You would like to ensure Your preference is recorded, You may contact us via email. We will log Your request and confirm that Your information is not being sold or shared.

We do not collect sensitive Personal information as defined under the CCPA.

COPPA (Children Online Privacy Protection Act)

When it comes to the collection of Personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

Fair Information Practices

The Fair Information Practices Principles form the backbone of privacy law in the United States, and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect Personal Data.

In order to be in line with Fair Information Practices We will take the following responsive action, should a data breach occur: We will notify the Users via Platform notification within 7 (seven) business days.

We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data Collectors and Processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and / or prosecute non-compliance by Data Processors.

15. Additional information for residents of Canada

This section applies only to residents of Canada. The Company Processes Personal Data in accordance with the Personal Information Protection and Electronic Documents Act, Personal Information Protection Act of British Columbia, Personal Information Protection Act of Alberta, and Act respecting the protection of Personal information in the private sector of Quebec have the right to interact with its data directly or through a request to Us regarding privacy issues.

This section describes the privacy rights of Canadian residents and how they can exercise them:

• Right to access. You can request an explanation of the Processing of Your Personal Data.
• Right to rectification. You can change the Data if it is inaccurate or incomplete via request or profile settings on the Platform.
• Right to delete. You can send Us a request to delete Your Personal Data from Our systems. We will remove all Data unless some of them We have to store in compliance with the law requirements.
• Right to Data portability. You can request all the Personal Data You provided to Us and request to transfer Data to another Controller.
• Right to object opt-out. You may object to the Processing of Your Personal Data.
• Right to withdraw Consent. You can withdraw Your Consent at any time.
• Right not to be subject to automated decision-making. You can object to being subject to automated-based Processing to know if there are consequences due to such Processing.
• Right to lodge a complaint. If Your request is not satisfied, You can file a complaint to the regulatory body.

To exercise Your rights, contact Us at via email. We have 30 (thirty) calendar days to exercise Your request from the moment it is received on Our contact email.

We have the right to extend the 30-day period for providing an answer to the request for another 30 (thirty) calendar days in the event that:

• failure to respond within the initial 30 (thirty) calendar days may be considered unreasonable interference with Our business,
• We need additional time for consultation,
• We need additional time to convert the Personal Data into a format that is easy to read.

You have the right to file a complaint with the ffice of the Privacy Commissioner of Canada (OPC) if We do not respond to Your request within the first 30 (thirty) days.

In the event of a leak of Your Personal Data, We will promptly notify You of such a case and the degree of threat to Your Personal Data. In accordance with PIPEDA, We will immediately notify the Office of the Privacy Commissioner of Canada (OPC) and keep a record of the leak that has occurred.

We may disclose Personal Data to Third-Party service providers and related corporations located outside of Canada for the purposes described in the Policy. The Policy requires that the Company share Your Personal Data abroad in a manner that requires the highest standards of confidentiality and security when transferring Personal Data abroad. Please note that when Personal Data is transferred abroad, it may be accessed by courts, law enforcement agencies, and national security agencies. Before disclosing Personal Data, We will assess possible risks that may adversely affect the protection of Personal Data. We ensure the appropriate level of integrity and protection of Personal Data when transferred to Third Parties, which is required by the provisions of PIPEDA, by entering into agreements with such companies, which provide for the limitation of the use of Personal Data by the Third Party solely for the purposes provided for in the agreement.

Accountability

The Company is accountable for all Personal Data in Our possession or control. We have established policies and procedures aimed at protecting the Personal Data of Users, Our clients and personnel. We have appointed a Privacy Officer to oversee privacy issues for the Company. We have also educated Our personnel about the Privacy Policy and their role in protecting the Personal Data of Users, Our clients, and personnel.

If You have questions about Our privacy practices, You are free to contact the Privacy Officer via email.

16. Additional information for residents of Australia

This section applies only to residents of Australia. The Company Processes Personal Data in accordance with the Australian Privacy Act 1988 (“APA”) and the Data Breach Notification Guidelines (2018).

Prior to Processing Your Personal Data, the Company will inform You of the Personal Data Controller, the basis and purpose of the Processing, and whether Your Personal Data will be transferred outside of Australia. The Company will not Process “sensitive data” without Your prior Consent.

The Company will not send You marketing emails without Your Consent.

We may disclose Personal Data to Third-Party service providers and related corporations located outside of Australia for the purposes set out in this Policy. It is the Company's policy that the Company shares Your Personal Data overseas in a manner that requires the strictest privacy and security standards while transporting Personal Data overseas.

In the event of a breach of Your Personal Data, We will promptly notify You of such a breach and the extent of the threat to Your Personal Data. In accordance with the APA, We will immediately notify the Office of the Australian Information Commissioner (OAIC) of such a breach.

To request information about what Personal Data We are Processing about You, please contact Us via email.

17. Additional information for residents of Ukraine

The conditions of this section apply only to residents of Ukraine, which is contained in the Privacy Policy and relates to specific requirements, in accordance with the provisions of the legislation of Ukraine, in particular, the Law of Ukraine “On Personal Data Protection” №2297-VI dd. 01.06.2010.

Each User’s personal non-proprietary rights regarding Personal Data are inalienable and inviolable.

The User, resident of Ukraine, has the following rights in relation to the provided Personal Data:

• to know about the sources of collection, location of the provided Personal Data, purposes of their Processing, and location of the Company;
• to receive information about the conditions for providing access to Personal Data, in particular, information about third parties to whom Your Personal Data is transferred;
• to access his / her Personal Data;
• to receive, no later than 30 (thirty) calendar days from the date of receipt of the request, except in cases provided for by law, a response on whether his or her Personal Data is Processed, as well as to receive the content of such Personal Data;
• to submit a reasoned request to the Controller with an objection to the Processing of his / her Personal Data;
• to submit a reasoned request to change or destroy his / her Personal Data by the Company if this Data is Processed illegally or is unreliable;
• to protect his / her Personal Data from unlawful Processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or discrediting the honor, dignity and business reputation of the User;
• to file complaints about the Processing of Personal Data to the Ukrainian Parliament Commissioner for Human Rights or to the court;
• to apply legal remedies in case of violation of the legislation on the protection of Personal Data;
• to make warnings regarding the restriction of the right to Process his / her Personal Data when giving Consent;
• if We Process Your Personal Data on the basis of the User’s prior Consent to this Processing — to withdraw the Consent to the Processing of Personal Data, after which such Processing will cease;
• if the Personal Data is exclusively Processed automatically, including profiling, which may have legal consequences for the User;
• to receive protection from an automated decision.

In order to exercise any of the above rights, the User shall contact the Company in writing via email.

The Subject of Personal Data is obliged to submit a request for access to Personal Data to the Controller, in accordance with the requirements provided for in part 3 of article 16 of the Law of Ukraine “On Personal Data Protection” №2297-VI dd. 01.06.2010. The period for examining the request for its satisfaction will not exceed 10 (ten) business days from the date of its receipt. During this period, the Controller will inform the User submitting the request that the request will be granted, or the relevant Personal Data will not be provided, indicating the grounds specified in the relevant regulatory legal act. The request shall be satisfied within 30 (thirty) calendar days from the date of its receipt, unless otherwise provided by law.

The Controller will notify the Ukrainian Parliament Commissioner for Human Rights of the Processing of Personal Data that poses a particular risk to the rights and freedoms of Personal Data Subjects within 30 (thirty) business days from the date of commencement of such processing.