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
• Account Information: Username, password (encrypted), account preferences
• Payment Information: Payment transaction data (processed by third-party payment processors – we do not store full credit card numbers)

Note: Phone number collection is optional and only used if you choose to provide it for account recovery or support purposes.

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 (Legal Basis Under GDPR)

We process your personal data for the following purposes and legal bases under GDPR Article 6:

4.1 Service Provision (Legal Basis: Contract Performance)

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

Processing is necessary for the performance of our contract with you (Terms of Service).

4.2 Essential Communication (Legal Basis: Contract Performance & Legal Obligation)

• Send essential service updates and notifications (e.g., account changes, security alerts)
• Respond to your queries and provide customer support
• Notify you of critical changes to our services or terms

4.3 Marketing Communications (Legal Basis: Consent)

• Send promotional emails, newsletters, and marketing materials about our services
• Inform you about new features, offers, or updates

You may opt out of marketing communications at any time by clicking the "unsubscribe" link in any marketing email or by contacting us at contact@subtie.com. Opting out of marketing emails will not affect essential service communications.

4.4 Service Improvement (Legal Basis: Legitimate Interest)

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

We have a legitimate interest in improving our service and ensuring security, which does not override your fundamental rights and freedoms.

4.5 Legal Compliance (Legal Basis: Legal Obligation)

• Comply with Ukrainian tax, accounting, and business regulations
• Respond to legal requests and court orders
• Maintain records as required by law

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., WayForPay) 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 contact@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. Analytics and Tracking

Analytics: We use PostHog, a privacy-focused analytics platform, to understand how users interact with our service. This helps us improve the application and identify technical issues.

What we track:

• Pages visited and features used
• Session duration and navigation patterns
• Technical errors and performance metrics
• General usage statistics (aggregated and anonymized)

Privacy-First Approach: We minimize data collection and anonymize data where possible. Analytics data is used solely for service improvement and is not sold or shared with third parties for marketing purposes.

Cookies: We use essential cookies necessary for the Service to function (e.g., authentication, session management). We do not use third-party advertising or tracking cookies.

10. Data Storage and International Transfers

Primary Data Storage: Your personal data is primarily stored on servers located in Europe using MongoDB Atlas (Europe region), ensuring compliance with European data protection standards.

Third-Party Services: We use the following third-party services that may process your data:

• MongoDB Atlas (Europe): Database hosting for user accounts, content, and learning data
• PostHog: Analytics platform for understanding service usage and improving user experience (anonymized where possible)
• WayForPay: Payment processing for subscriptions (Ukraine-based)

Some of these services may transfer data outside the European Economic Area (EEA). When data is transferred internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions where the recipient country is deemed to provide adequate data protection
• Contractual obligations requiring third-party processors to protect your data in accordance with GDPR standards

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: contact@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).