Privacy Notice

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

2. Personal Data We Process when You use the Platform

2.1. Personal Data You provide to Us personally

When You choose to interact with the Platform, We may collect and Process certain Personal Data that You voluntarily provide to Us. This may occur, in particular, when:

• You contact Us via the contact form available on the Platform;
• You reach out to Us using the contacts provided on the Platform;
• or You initiate communication with Us in any other direct way.

At this stage, You may be asked to provide basic identifying and contact information, such as:

• Your full name;
• Your email address;
• Your phone number;
• the content of Your message.

This information is collected solely to allow Us to respond to Your inquiry, provide support, and begin business communication. You knowingly and voluntarily provide this information, and We Process it with care and respect.

In some cases — for example, if You decide to use Our Assistant service in Your business processes — additional categories of Personal Data may be collected. These may include:

• login credentials or passwords to access;
• integration tokens or unique keys for connecting to Your CRM system, telephony provider, or other services;
• information required for personalization of the Assistant's interaction (e.g., profile photo, gender, preferences, age, etc.).

Such Data is collected exclusively based on Your initiative and Consent, and only when You initiate Assistant configuration or cooperation with Us beyond general Platform use. We collect only the Personal Data that You knowingly and voluntarily provide.

Additionally, when using Our Assistant service, Users or Third Parties interacting with the Assistant may voluntarily provide various categories of Personal Data, including — in some cases — special categories of Personal Data (as defined by Article 9 of the GDPR), such as health-related information, religious beliefs, political opinions, or other sensitive content.

Such information is not intentionally requested or required by Us, and We do not actively seek to collect or store special categories of Personal Data. However, We acknowledge the possibility that such Data may be shared voluntarily during interactions with the Assistant.

In these cases, We Process such Data only in accordance with the principles of necessity, data minimization, and based on the Consent of the Data Subject or other applicable legal grounds. Where required, We will provide additional safeguards or request explicit Consent prior to further Processing.

2.2. Personal Data We Process automatically

When You use the Platform, certain technical Data may be collected automatically by third-party analytics and tracking technologies that are integrated into Our Platform — specifically services such as Google Analytics or Meta Pixel.

The automatically collected Data may include:

• IP address;
• MAC address;
• browser type and version;
• operating system;
• screen resolution and device model;
• language and time zone;
• identifiers of the device (UDID, MEID);
• network provider and signal;
• traffic Data and browsing behavior (pages viewed, duration, clicks, navigation paths);
• Cookies, web beacons, and similar tracking technologies.

These tools allow Us to better understand how Users interact with the Platform, improve its performance, and provide relevant functionality. We emphasize that Google Analytics and similar providers implement anonymization and pseudonymization mechanisms to comply with privacy standards, including the GDPR.

In the future, We may integrate other analytics or marketing tools that use cookies and similar technologies. If this occurs, We will update this Privacy Notice accordingly.

For more detailed information about the use of Cookies, please see Section 16 of this Privacy Notice.

2.3. Our role as Controller and Processor

Depending on the context of Personal Data Processing, We may act either as a Controller or Processor under the meaning of the GDPR:

• when We collect and Process Personal Data of Our business clients (Users) (e.g., names, email addresses, login credentials, configuration preferences), We act as a Controller;
• when We Process Personal Data of end-users (e.g., phone call transcripts, voice recordings) on behalf of Our clients (Users) using the Assistant, We act as a Processor and perform such Processing solely under the instructions of the client (Users) and in accordance with a Data Processing Agreement (DPA).

3. Children's privacy

Protecting the privacy and safety of minors is very important to Us. We are committed to complying with data protection laws that regulate the Processing of children's Personal Data — including the GDPR, the Law of Ukraine "On Personal Data Protection", and other applicable regulations.

We do not knowingly Process the Personal Data of individuals under the age from which it is legally permitted to give valid Consent for the Processing of their Personal Data. In the EU, this age is generally 16 years, although in some countries it may be lowered to 13 years. In Ukraine, the minimum age is 14 years (with Consent of a legal representative), and full legal capacity is reached at 18.

We presume that by using the Platform, You confirm that:

• You have reached the legal age required to independently give Consent to the Processing of Your Personal Data in accordance with the legislation of Your country of residence;
• or that such Consent has been duly provided by Your legal representative (such as a parent or guardian).

If We discover that Personal Data has been provided by a person who has not reached the minimum legal age and such Consent was not obtained from a legal representative, We will take appropriate steps to delete this information as soon as reasonably possible.

If You believe that We may have collected or are Processing the Personal Data of a child without proper authorization, please contact Us.

We disclaim any liability for situations where individuals under the applicable legal age use the Platform and provide their Personal Data without obtaining the necessary Consent. It is the responsibility of such individuals or their legal representatives to ensure that proper authorization is in place before using the Platform.

To use the Platform, You must be of legal age under this Privacy Notice and Our Terms & Conditions.

4. Purposes of Personal Data Processing

We Process Your Personal Data solely for specific, lawful, and legitimate purposes, in line with the principles set out in the GDPR, the Law of Ukraine "On Personal Data Protection", and other applicable data protection legislation.

Below is a breakdown of the purposes for which We Process Your Personal Data and a brief explanation for each:

We do not Process Your Personal Data for any purposes beyond those described above.

Should We intend to Process Your Data for purposes other than those stated, We will notify You in advance and, where required, request Your explicit Consent, unless otherwise permitted by applicable law.

5. Legal basis for Processing Your Personal Data

We Process Your Personal Data only when We have a valid legal basis to do so, as defined by the GDPR and other applicable data protection laws.

We ensure that all Processing of Your Personal Data is fair, transparent, and limited to what is necessary for the intended purposes. We do not use Your Data for any other purposes without an appropriate legal basis.

If We rely on Consent as the legal basis, We will provide clear options and ensure You can manage or withdraw it easily at any time, without affecting the lawfulness of Processing based on Consent before its withdrawal.

6. Processing of special categories of Personal Data

In the course of using Our Assistant services, it is possible that You or other users may voluntarily disclose special categories of Personal Data — also referred to as sensitive data. This may include:

• Data revealing racial or ethnic origin;
• political opinions or religious or philosophical beliefs;
• trade union membership;
• genetic Data;
• biometric Data for uniquely identifying a natural person;
• health Data;
• Data concerning a person's sex life or sexual orientation.

We do not intentionally collect or Process such Data as part of the core functionality of the Platform. However, since the Assistant is capable of interacting with Users in real-time and receiving open-form inputs (e.g., voice conversations, inquiries, user-generated content), there is a possibility that such Data may be shared voluntarily by You or other users.

We Process special categories of Personal Data only under the conditions allowed by Article 9(2) of the GDPR, in particular:

We do not use sensitive Personal Data for profiling, marketing, or automated decision-making without Your explicit Consent.

All Processing of such Data is carried out with appropriate technical and organizational safeguards, including:

• access restrictions and role-based permissions;
• encryption and secure communication protocols;
• logging and monitoring of access to sensitive Data;
• Data minimization and purpose limitation.

In the course of using the Assistant, voice calls and audio interactions may be recorded and transcribed. These recordings and transcripts may contain Personal Data — such as names, contact details, booking information — and, in certain cases (e.g., in healthcare or customer support contexts), may include special categories of Personal Data as defined under Article 9 of the GDPR, such as health-related information or biometric voice patterns.

We treat all such Data as Personal Data and apply the same legal basis, safeguards, and retention practices outlined in this Notice.

You may withdraw this explicit Consent via the same channel through which it was given or by contacting us at [email protected].

7. Storage of Personal Data

7.1. How long do We keep Your Personal Data?

We retain Your Personal Data only for as long as it is necessary for the purposes for which it was collected, including to:

• operate and maintain Our Platform and Assistant services;
• maintain communication with You during active cooperation;
• comply with Our legal obligations and resolve potential disputes;
• prevent fraud and ensure system security;
• demonstrate compliance with applicable data protection laws.

We apply the principle of storage limitation, as required under the GDPR and national data protection laws. The actual retention period depends on the type of Data, the purpose of Processing, and whether You continue using Our services.

Encrypted backups may be stored for an additional period of up to 6 months after the end of primary storage, for business continuity and disaster recovery purposes, unless earlier deletion is technically possible and legally permitted.

If We have collected Your Data but no longer have an active cooperation with You and there is no legal obligation to retain it, We will delete Your Personal Data within 3 months of the end of communication, as per Our internal retention policy.

If You continue to use Our services, We will retain the Data for the duration of Your account's existence.

Please consult the privacy policy of the relevant provider for details on how Your billing Data is retained on their side.

We minimize the amount and duration of Personal Data storage. Once the relevant retention period ends, or You exercise Your right to erasure (where applicable), Your Data will be either:

• securely erased from Our systems, or
• anonymized in such a way that it can no longer be linked to You.

We ensure that all deletion processes are carried out securely and in accordance with the best industry practices.

7.2. Where do We store Your Personal Data?

We are committed to ensuring that Your Personal Data is stored securely and in accordance with applicable data protection laws, including the GDPR.

Your Personal Data is hosted on servers located in Germany, within the European Economic Area (EEA), which ensures that the storage and Processing of Data complies with the strict privacy standards of the European Union.

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. 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. Any transmission is at Your own risk.

7.3. Security of Your Personal Data

We have put in place appropriate security measures to prevent Your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

We apply the following security measures appropriate to the possible risks:

In the event of a Personal Data breach, We are committed to responding swiftly and in accordance with applicable Data protection laws, including the GDPR and relevant local regulations, by promptly assessing the breach, notifying the relevant supervisory authority, within 72 (seventy-two) hours of becoming aware of the breach, providing all necessary details. Unless the Personal Data breach is unlikely to result in a risk to the rights and freedoms of natural persons where the notification is not made within 72 (seventy-two) hours, it could be accompanied by reasons for the delay.

By adhering to these measures, We reaffirm Our commitment to maintaining the confidentiality, integrity, and availability of Your Personal Data at all times.

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

We do not sell, rent, or otherwise share Your Personal Data with Third Parties for marketing or advertising purposes.

We transfer Personal Data only to Our internal team members — such as technical specialists, integrators, or support staff — who are involved in ensuring proper functioning of the Assistant. All such individuals are subject to strict confidentiality obligations, including NDAs.

This limited access is granted exclusively to ensure the provision and improvement of the Platform and Assistant functionality. Personal Data is shared internally only on a need-to-know basis and always in accordance with applicable data protection laws, including the GDPR.

Authorities. We reserve the right to disclose and / or report any Personal Data of the User, if this is required by any law of Ukraine or the European Union or another normative legal act, or a confirmed legal requirement of state authority and / or local authorities, for the purpose of compliance with the requirements of the laws of Ukraine and the legislation of the European Union, protection of the integrity of the Platform, to fulfill the requests of Users, state authorities and / or local authorities, or for the purpose of facilitating any investigation by law enforcement agencies or an investigation aimed at guaranteeing public (national) security. In some cases, We may also provide the User's Personal Data to the authorities of the European Union and the authorities of other countries, if such provision of Personal Data is required by law, or in the event of an official request from such an authority as part of a criminal investigation.

9. International transfers of Personal Data

As of now, We store and Process all Personal Data on secure servers located in Germany, within the European Economic Area (EEA), in full compliance with the GDPR.

However, certain third-party services integrated into Our Platform — such as analytics (e.g., Google Analytics) or marketing tools (e.g., Meta Pixel) — may technically involve limited cross-border Data Processing outside the EEA. In such cases, We ensure that the Processing is minimized and that adequate safeguards are implemented, including:

• the use of Standard Contractual Clauses (SCCs) approved by the European Commission;
• anonymization or pseudonymization of transmitted Data;
• and vendor assessments to ensure compliance with data protection standards.

Should any additional international Data transfers become necessary in the future, We will ensure that such transfers are carried out in full accordance with applicable data protection laws and based on appropriate safeguards, including adequacy decisions or binding contractual mechanisms.

10. Your rights regarding Personal Data

Under the GDPR, You have a set of rights that allow You to control how Your Personal Data is collected and used. You can exercise these rights at any time by contacting Us at [email protected].

To protect Your privacy, We may ask You to verify Your identity before responding to a request. This helps ensure that Personal Data is not shared with anyone who is not authorized to receive it.

We respond to all valid requests within 30 (thirty) calendar days of receipt. If more time is needed due to the complexity or number of requests, We will inform You accordingly.

We are committed to supporting Your rights and maintaining transparency about how Your Data is used within Our system. If You have questions or concerns, do not hesitate to reach out.

11. Cookies

11.1. What are Cookies?

Cookies are small pieces of data (text files) or parts of program code that contain a unique User ID and information about how You use the Platform. Cookies are transmitted through a server and stored on Your device when You visit and / or use the Platform. They are stored on Your device when You use the Platform. Cookies are transmitted through a server and stored locally on Your device to help enhance Your experience and track usage patterns. These technologies are passive, meaning they do not contain harmful programs, viruses, or spyware and cannot access other information on Your device.

A Cookie consists of 2 parts: the name and the content or value of the Cookie. Moreover, the duration of existence of a Cookie is determined. Data stored using these technologies can only be accessed by the Platform or services that store it, which ensures Data consistency and privacy across visits. Cookies themselves do not require Personal Data to be used and, in most cases, do not personally identify Users.

On the Platform, Data may be stored temporarily ("session data") or for a longer period ("persistent data"). Session data is erased when You close Your browser. "Persistent Cookies" remain on the User's device for a certain period of time specified in the Cookies. They are activated every time the User visits the Platform.

Cookies may also be used to collect anonymous statistics about the experience of visiting the Platform. The data collected is not personally identifiable and is limited to the minimum information necessary to optimize the performance of the Platform.

In order to obtain additional general information about Cookies, You can check out information about HTTP Cookies, which is available at the following link.

11.2. Consent to the use of Cookies

Cookies are not strictly necessary for visiting and / or using the Platform (except for the "strictly necessary" type of Cookies) and will be used by Us only after obtaining Your Consent to their use. Once You agree to Our use of Cookies in a separate notice about the use of Cookies, We will consider Your Consent to be obtained.

When You have given Us Your Consent to use Cookies when visiting and / or using the Platform, the Processing of the Data collected by Cookies is carried out in accordance with Art. 6(1)(a) GDPR, in accordance with which the Processing shall be lawful only if and to the extent that at least one of the following applies: the Subject of Personal Data has given Consent to the Processing of his or her Personal Data for one or more specific purposes. You can familiarize Yourself with the text of the GPDR by following the link: https://eur-lex.europa.eu/eli/reg/2016/679/oj.

You may certainly change Your Cookie settings on Your device at any time. For more information, please read section 10.6. "How You can manage Your Cookies settings".

11.3. The types of Cookies We collect:

11.4. The purposes of collecting Cookies.

The Platform uses Cookies for the following purposes:

• ensuring the proper functioning of the Platform,
• ensuring the security of Users while they are on the Platform,
• adjusting and enhancing Your interaction experience with the Platform,
• obtaining standard analytics information,
• detecting errors and identifying their causes to improve Platform performance,
• evaluate performance and improve UX,
• assess effectiveness of Our communications and posts.

We assure You that all Data collected through Cookies is used solely for the purposes stated in this Notice, and Cookies in no way are harmful to You or Your device, as they do not make any changes to its configuration.

11.5. Services used to collect Cookies

Cookies utilized on the Platform may be retained on the servers of their respective providers for varying durations. The storage duration of each Cookie is contingent upon its specific function and purpose. For instance:

- Google Analytics
Google Analytics helps Us analyze how Users interact with the Platform, providing insights into usage patterns and traffic. Cookies collected by Google Analytics may be stored for up to 2 (two) years, depending on the purpose. Google LLC automatically manages storage regions based on User location. Additional information about Google Analytics' cookie policies can be found here.

- Meta Pixel (Facebook Pixel)
Meta Pixel is a tool provided by Meta Platforms, Inc. that allows Us to measure the effectiveness of Our advertising by understanding the actions Users take on the Platform. Cookies set by Meta may store information such as browser type, time spent on the Platform, and pages visited. These cookies can help Us track conversions from Facebook ads, optimize ads based on collected data, and build targeted audiences for future ads.
Cookies set by Meta Pixel are typically stored for up to 90 days. Meta automatically manages storage and processing infrastructure depending on the User's location. You can read more about Meta's use of cookies and tracking technologies in their policy here.

11.6. How You can manage Cookies settings?

You can manage and control the privacy Cookies settings through Your desktop browser's privacy or security settings.

To manage tracking and Data collection on different desktop browsers:

• For Chrome: go to Settings > Privacy and Security > Cookies and other site data to set Your preferences for cookies and tracking data,
• For Firefox: navigate to Settings > Privacy & Security and adjust options under Cookies and Platform Data to control Data collection,
• For Safari: go to Preferences > Privacy and configure cookie management settings according to Your preferences.

For additional information about managing Platform tracking and Cookie settings, You can visit Your browser's support page.

PLEASE NOTE THAT CHANGES TO THE TRACKING AND DATA COLLECTION SETTINGS MAY RESULT IN LIMITED FUNCTIONALITY OF THE PLATFORM, WHICH COULD IMPACT YOUR USER EXPERIENCE.

12. Sending marketing communications

By providing their Personal Data and checking the relevant box during registration or when submitting a contact form on the Platform, Users give their explicit Consent to receive marketing communications from the Company. This Consent confirms the User's wish to receive materials such as product updates, special offers, news about the Platform's development, and other relevant content that may be of interest to them.

We use the email address voluntarily provided by the User to deliver these communications. We aim to ensure that marketing messages are sent no more than 2–3 times per month, are relevant, and provide value to the User based on their preferences and previous interactions with the Platform.

Our communications are sent exclusively by Us. We do not share Your Personal Data with Third Parties for their own direct marketing purposes.

All marketing activities are carried out in full compliance with applicable data protection laws, including the GDPR, the Law of Ukraine "On Personal Data Protection", and other anti-spam and e-privacy regulations.

If You decide to withdraw Your Consent, You may unsubscribe at any time by clicking the "Unsubscribe" link in any of Our emails. You may also contact Us directly via the contact form on the Platform or at [email protected] to stop receiving such communications. We will promptly stop Processing Your Data for marketing purposes.

If You have not provided Your Consent to receive marketing communications, We will only contact You regarding matters directly related to Your specific request or interaction with the Platform.

We may use cookies and similar tracking tools in Our communications to measure engagement, evaluate the effectiveness of campaigns, and optimize future Content. You may manage such preferences through Your browser settings or Cookie Policy tools, as outlined in this Privacy Notice.

If You have any questions about how We handle marketing communications or wish to change Your communication preferences, please contact Us using the details provided in this Privacy Notice.

13. External links

The Platform may contain links to external websites, platforms, or services that are not operated or controlled by the Company. These links may be included, for example, in informational materials, blog content, or in communications sent through the Platform.

Please note that We are not responsible for the content, privacy practices, or security of any third-party websites or services. The presence of a link on Our Platform does not imply endorsement or affiliation with the linked resource, unless expressly stated.

We recommend that You carefully review the privacy policies and terms of service of any third-party resources before sharing Your Personal Data with them, as such websites may Process Your Data independently of Our Platform and under their own policies.

If You encounter any link that appears inappropriate, unsafe, or that violates applicable laws or this Notice, please contact Our team at [email protected] so We can take appropriate action.

14. Changes to this Notice

We reserve the right to update or amend this Privacy Notice at any time and for any reason by publishing a new version on the Platform. We encourage You to review this Notice periodically to stay informed about any changes.

If You do not agree with the revised version of the Notice, You must stop using the Platform and may request the deletion of Your Personal Data.

If the changes are substantial, We will notify You at least 15 (fifteen) calendar days before such changes take effect and, where legally required, obtain Your Consent again.

15. Dispute resolution

Before initiating legal proceedings in court, the User must first submit a written claim (a proposal for voluntary settlement of the dispute) to Us. Within 30 (thirty) calendar days of receiving the claim, We will respond in writing regarding the outcome of the claim review.

If no agreement is reached, the dispute shall be resolved by the competent courts of Ukraine, in accordance with the applicable legislation of Ukraine. This Notice is governed and interpreted in accordance with the laws of Ukraine.

16. Contact information

If You have any questions, comments, or concerns regarding this Privacy Notice, please contact Us using any of the following methods:

• by email: [email protected],
• by phone: +38 (099) 482 9573,
• by Telegram: @viacheslavsaloid,
• or by using the contact form available on the Platform.

We will make every effort to respond as soon as possible, and no later than 30 (thirty) calendar days from the date of receiving Your inquiry.

17. 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 at [email protected].

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.

Also, You may submit a complaint as follows:

• For Colorado residents, to the Colorado AG at: https://coag.gov/file-complaint/
• For Connecticut residents, to the Connecticut AG at: https://www.dir.ct.gov/ag/complaint/
• For Montana residents: https://dojmt.gov/consumer/
• For Oregon residents: https://justice.oregon.gov/consumercomplaints/
• For Texas residents: https://oag.my.salesforce-sites.com/CPDOnlineForm
• For Utah residents: https://attorneygeneral.utah.gov/contact/complaint-form/
• For Virginia residents, to the Virginia Attorney General at: https://www.oag.state.va.us/consumercomplaintform
• For residents of Florida at: https://www.myfloridalegal.com/consumer-protection/consumer-complaint-form

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

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, [email protected].

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 to: [email protected]. 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

California residents have the right under the California Consumer Privacy Act as well as California Privacy Rights Act to opt out of the "sale" and "share" of their Personal information by a company governed by CCPA. In this context, the word "sale" means any "selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a Third Party, for monetary or other valuable consideration". If You are a resident of other US states that give You rights to opt out of "sale", "share" and / or use of Personal information for "targeted advertising", You may also find this information helpful.

In exceptional cases, We may share Your Personal information as it is described in section 8. We do not and will not "sell" Your Personal information, but We recognize that the CCPA defines "Personal information" in such a way that providing access to identifiers associated with You may be considered a "sale". In the event that these Platform visitor identifiers and inferences may be identified as a sale under the CCPA, please use the "Do not sell and share my Personal information" setting on the Platform's home page. After receiving Your request through the "Do not sell and share my Personal information" setting, the Company makes a corresponding entry in its database of Personal information / Platform Users, which indicates that the Company is aware of the impossibility of further selling Your Personal information. Also, if You would like to record Your preference that We will not "sell" and "share" Your Personal information in the future, please contact Us via [email protected].

Finally, if Your browser supports it, You can use the Universal Opt-Out Mechanism mentioned below.

Universal Opt-Out Mechanism

For residents of California, Colorado, Connecticut, New Hampshire, Texas, Montana, New Jersey, Minnesota (effective from 31/07/2025), Delaware (effective from 01/01/2026), Oregon (effective from 01/01/2026), Maryland (effective from 01/04/2026) We recognize the Global Privacy Control ("GPC") signal. If You are using a browser setting or plug-in that sends an opt-out preference signal to each website You visit, We will treat that as a valid request to opt out. To download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If You choose to use the GPC signal, You will need to turn it on for each supported browser or browser extension You use.

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, Platform a data breach occur:

• - We will notify the Users via Website 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.

18. Additional information for residents of Ukraine

This section applies only to residents of Ukraine and is based on the Law of Ukraine "On Personal Data Protection" No. 2297-VI dated 01.06.2010.

Each User's personal non-property rights in relation to Personal Data are inalienable and inviolable.

As a resident of Ukraine, You have the right to:

• be informed about the sources, location, and purpose of the Processing of Your Personal Data;
• access Your Personal Data and receive a copy within 30 (thirty) calendar days after request;
• request correction or deletion of inaccurate or unlawfully processed Data;
• object to the Processing of Your Data in justified cases;
• withdraw Your Consent to Processing at any time;
• restrict or condition Your Consent when granting it;
• be protected from automated decisions that significantly affect You;
• file complaints to the Ukrainian Parliament Commissioner for Human Rights (ombudsman) or the court in case of violation of Data protection legislation.

To exercise any of these rights, please contact Us at: [email protected].

We will review Your request within 10 (ten) business days and respond within 30 (thirty) calendar days, unless otherwise required by law.

If the Processing of Personal Data poses a particular risk to Your rights and freedoms, the Controller will notify the Ukrainian Parliament Commissioner for Human Rights within 30 (thirty) business days of initiating such Processing.