Privacy Policy

Last updated 15 June 2026

This Privacy Policy ("Policy") explains how [OPERATOR NAME] (registration code [●], address: [ADDRESS]) ("Operator", "we") collects and processes the personal data of users of the "Svicha Online" web application ("Service").

We process personal data in accordance with the Law of Ukraine "On Personal Data Protection" No. 2297-VI of 01.06.2010 and, for users located in the European Union, with regard to the General Data Protection Regulation (GDPR).

Privacy is sacred to us. Spiritual-guidance conversations are never recorded or stored (zero retention).

1. Data controller (operator)

2. What data we process

Depending on how you use the Service, we may process:

3. What we do not store

4. Purposes and legal bases

We process data on the following bases (Art. 11 of Law No. 2297-VI):

5. Sharing with third parties (processors)

To operate the Service we engage the following data processors:

6. Cross-border transfer

Some processors may store data outside Ukraine. Such cross-border transfers are made in accordance with Art. 29 of Law No. 2297-VI to states providing adequate protection and/or on the basis of your consent and appropriate contractual safeguards.

7. Retention periods

8. Your rights

Under Art. 8 of Law No. 2297-VI (and GDPR where applicable) you have the right to:

9. Cookies and local storage

We use cookies and local storage necessary for the Service to work (session, chosen theme and language) and — with your consent — for push notifications and anonymized analytics. Analytics does not autocapture typed text and does not record sessions.

10. Data security

We apply organizational and technical measures: row-level security (RLS), encryption in transit, two-factor authentication for clergy and administrators, and data minimization.

11. Children

The Service is intended for persons aged 18 or older (or 16 with parental/guardian consent). We do not knowingly collect data from younger children.

12. Changes to this Policy

We may update this Policy. The current version is always available in the Service with its update date.

13. Contact

For questions about personal data processing and to exercise your rights, contact: [EMAIL].