1. Introduction

This Privacy Policy describes how Individual entrepreneur Tsarenko Inna Volodymyrivna ("Service Provider", "we", "us", or "our") collects, uses, and protects your personal information when you use the Subtie service available at https://www.subtie.com/.

By accepting our Terms of Service, you give permission to collect and process your personal data as described in this Privacy Policy.

2. What Data We Collect

We may collect the following categories of data:

2.1 Personal Information

• Registration Data: Name, email address, phone number (as specified during account creation)
• Account Information: Username, password (encrypted), account preferences

2.2 Technical Data

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, session duration, feature usage patterns
• Service Data: Files uploaded, flashcards created, learning progress

Important: We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health information, or biometric data.

3. How We Collect Your Data

We collect data through the following methods:

• Direct Collection: When you register for an account, fill out forms, or provide feedback
• Automatic Collection: Through your use of our website and application (basic analytics)
• Service Usage: When you upload files, create flashcards, or use learning features
• Communication: When you contact us for support or inquiries

4. Why We Use Your Data

We process your personal data for the following purposes:

4.1 Service Provision

• Provide access to our language learning services
• Maintain and manage your user account
• Process and store your learning content (flashcards, books, progress)

4.2 Communication and Support

• Send informational messages and service updates via email
• Respond to your queries and provide customer support
• Notify you of important changes to our services

4.3 Service Improvement

• Analyze usage patterns to improve our application
• Develop new features and enhance existing functionality
• Ensure service security and prevent unauthorized access

5. Data Sharing and Disclosure

We may share your data in the following limited circumstances:

5.1 Third-Party Services

• Payment Processing: With payment processors (e.g., PayPal, Stripe) for subscription and payment handling
• Service Providers: With technical service providers who assist in service delivery (under strict confidentiality agreements)

5.2 Legal Requirements

• When required by law, court order, or legal process
• To protect our rights, property, or safety, or that of our users
• In connection with legal proceedings or regulatory investigations

Important: We do not sell, rent, or trade your personal data to third parties for marketing purposes.

6. Data Retention

We retain your data for the following periods:

• Account Data: As long as your account remains active or as needed to provide services
• Technical Data: Up to 12 months after your last activity
• Communication Records: Up to 3 years for support and legal purposes
• Deleted Accounts: Data is permanently deleted within 30 days of account deletion

7. Your Rights Under GDPR

If you are located in the European Economic Area, you have the following rights:

• Right of Access: Request copies of your personal data
• Right of Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your data ("right to be forgotten")
• Right of Portability: Request transfer of your data to another service
• Right to Object: Object to processing of your data for direct marketing
• Right to Restrict Processing: Request limitation of data processing

To exercise any of these rights, please contact us at andriitsarenko@subtie.com. We will respond to your request within 30 days.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure.

9. Cookies and Tracking

We currently do not use cookies or tracking technologies in this application. If this changes in the future, we will update this policy and notify users accordingly.

10. International Data Transfers

Your data may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place to protect your data in accordance with applicable privacy laws.

11. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Changes will be published on this page with an updated date. We encourage you to review this policy periodically.

12. Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Email: andriitsarenko@subtie.com

Service Provider Details: Tsarenko Inna Volodymyrivna
Location: Kyiv, 16v Mitropolita Vasylya Lypkivskoho St., 03035, Ukraine

This Privacy Policy should be read in conjunction with our Terms of Service and Refund Policy.

13. Language

These terms are also available in Ukrainian (Українська).