PRIVACY POLICY OF THE «RYBKAOS» PLATFORM

1. GENERAL PROVISIONS

1.1. This Privacy Policy governs the collection, use, processing, storage, and protection of personal data of the «RybkaOS» Platform Users.

1.2. The Data Controller of personal data is:

• Sole Proprietor Manziuk Lidiia Vasylivna
• Tax ID (RNOKPP/TIN): 2355516623
• Registered Address: 6 Dekabristiv St., Korsun-Shevchenkivskyi, Cherkasy Raion, Cherkasy Oblast, Ukraine
• Email: rybkaos.support@gmail.com

1.3. By using the Platform, the User confirms that they have read, understood, and agree to this Policy.

2. DEFINITIONS

Platform — RybkaOS software, including websites, personal accounts (consoles), Telegram bots, and other services.

Administrator — a person who uses the Platform to create Spaces and manage subscriptions.

Subscriber — a person who obtains access to the Administrator's Space.

Personal Data — any information that directly or indirectly allows the identification of an individual.

3. WHAT DATA WE COLLECT

3.1. Data of Administrators:

• name
• phone number
• email address
• Telegram ID
• Telegram username
• Telegram profile picture
• account data
• subscription plan information
• payment information
• login and activity logs

3.2. Data of Subscribers:

• Telegram ID
• Telegram username
• first and last name
• email address (if available)
• phone number (if available)
• subscription status
• access history
• payment history

3.3. Technical Data:

• IP address
• browser information
• device information
• operating system information
• security logs
• date and time of interaction with the Platform

4. PURPOSES OF PERSONAL DATA PROCESSING

We process data to:

• create user accounts
• provide access to the Platform
• manage subscriptions
• ensure the operation of Telegram bots
• provide technical support
• ensure security
• prevent fraud
• facilitate payments related to the use of the Platform
• comply with statutory legal requirements

5. LEGAL BASIS FOR PROCESSING

Data processing is carried out based on:

• performance of a contract
• legitimate interest of the Platform
• compliance with statutory legal requirements
• the User's consent (in cases provided by law)

6. ROLES REGARDING PERSONAL DATA

6.1. Regarding the data of Administrators, RybkaOS acts as the Data Controller.

6.2. Regarding the data of Subscribers, RybkaOS acts as the Data Processor and processes such data exclusively on behalf of the respective Administrator.

6.3. The Administrator is solely responsible for the lawfulness of collecting and using the data of their Subscribers.

7. DATA TRANSFER TO THIRD PARTIES

We may transfer data to:

• hosting providers
• email service providers
• payment service providers
• Telegram
• analytics services
• state authorities in cases provided by law

We do not sell personal data to third parties.

8. PAYMENTS

8.1. RybkaOS is not a financial institution or a payment intermediary.

8.2. Subscriber payments are made directly to the Administrator's merchant account and are not processed by RybkaOS.

8.3. The Platform does not store full credit card details.

8.4. We may store only masked data and payment tokens.

9. RETENTION PERIODS

Personal data is stored:

• for as long as the account remains active
• for the duration of the performance of the contract
• for the periods established by the legislation of Ukraine

Upon expiry of the retention periods, data is deleted or anonymized.

10. USER RIGHTS

The User has the right to:

• obtain information about their data
• rectify their data
• restrict data processing
• withdraw consent
• request the erasure (deletion) of data
• lodge a complaint with a competent authority

11. SECURITY

The Platform applies appropriate organizational and technical measures to protect data, including:

• TLS encryption
• access control
• event logging
• data backup
• security monitoring

12. TELEGRAM

The Platform uses the Telegram API to identify Users and manage access. The Platform does not have access to Users' private messages and does not analyze their content.

13. CHANGES TO THE POLICY

The Platform reserves the right to amend this Policy. The updated version takes effect from the moment of its publication on the Platform.

14. CONTACTS

Email: rybkaos.support@gmail.com

Website: https://rybkaos.com

Platform: RybkaOS