Privacy Policy

Last Updated: September 14, 2026

1. Introduction

This Privacy Policy describes how the Project Owner ("we," "us," or "our") collects, uses, and protects information through our service platform (the "Service"). This policy applies to all users of the Service, including visitors to our main website and users accessing the platform via Company application access point.

This policy is governed by and construed in accordance with the laws of Ukraine, including the Law of Ukraine "On Protection of Personal Data."

2. Definitions

  • Project Owner: The entity providing and managing the Service.
  • Company: A business organization that subscribes to the Service and manages its own data through its designated access point.
  • User: Any individual (including employees of a Company or visitors to the main site) who interacts with the Service.
  • Personal Data: Any information relating to an identified or identifiable natural person.
  • Data Controller: An entity that determines the purposes and means of processing personal data.
  • Data Processor: An entity that processes personal data on behalf of the Data Controller.

3. Roles and Responsibilities

To ensure clarity regarding data protection, the following roles are established:

  • Project Owner as Data Controller: We act as the Data Controller for information required to manage the Service, such as billing information, account credentials of Company administrators, and contact details for service communication.
  • Project Owner as Data Processor: When a Company uses the Service to manage its own data (such as client lists or employee records), we act strictly as a Data Processor. We process this information solely on the instructions provided by the Company.
  • Company as Data Controller: Each Company acts as the independent Data Controller for all information it enters or uploads to the Service. The Company is solely responsible for ensuring that the collection and processing of such data comply with applicable laws and that necessary consents have been obtained from their respective users or customers.

4. Information We Collect

We collect information in the following ways:

  • Information Provided Voluntarily: This includes registration details, contact information, and profile settings provided by Users or Company representatives.
  • Information Collected Automatically: To maintain the Service, we automatically collect technical data, including IP addresses, browser types, operating systems, and usage timestamps.
  • Company-Managed Data: The platform stores data provided by Companies for their business operations. This may include information about the Company's customers, staff, and operational records.

5. Purposes of Processing

  • To provide, maintain, and support the functionality of the Service.
  • To optimize service performance and improve user experience.
  • To ensure the security of the platform and prevent unauthorized access or fraudulent activity.
  • To comply with legal obligations under Project Owner's law obligations.

6. Legal Basis for Processing

  • Contractual Necessity: To fulfill our service agreement with the Company.
  • Legitimate Interest: To maintain system security, stability, and operational efficiency.
  • Legal Obligation: To comply with statutory requirements or judicial orders.
  • Consent: Where explicitly required by law for specific processing activities.

7. Data Security and Retention

  • Security Measures: We implement industry-standard technical and organizational measures to protect data from unauthorized access, alteration, or disclosure. We utilize secure isolation protocols to ensure that data belonging to one Company remains private and inaccessible to others.
  • Data Retention: We retain personal data for a period of 3 (three) years from the date of its collection or the termination of the relevant service relationship, unless a longer retention period is required by applicable law or earlier removal is requested by a data owner. After this period, data is securely deleted or anonymized.

8. Data Disclosure and Third Parties

  • Infrastructure Providers: We use third-party hosting and cloud infrastructure providers to deliver the Service. These providers act as sub-processors and are subject to strict confidentiality requirements.
  • Legal Mandates: We may disclose information if required to do so by law, regulation, or legal process.
  • No Sale of Data: We do not sell, rent, or trade personal data to third parties for marketing or any other purposes.

9. User Rights

In accordance with Project Owner's law, Users have the following rights:

  • The right to access the personal data we hold about them.
  • The right to rectify inaccurate or incomplete data.
  • The right to request the erasure of personal data ("right to be forgotten").
  • The right to restrict or object to certain types of processing.
  • The right to data portability.

To exercise these rights, Users should contact their Company representative or use the contact information provided in Section 12.

10. Cookies

The Service uses cookies and similar tracking technologies to be able to provide service, manage user sessions, remember preferences, and analyze platform usage.

11. Limitation of Liability

  • Company Data: The Project Owner assumes no responsibility for the accuracy, legality, or content of the data managed by Companies. The Company is solely responsible for the data it inputs into the Service.
  • Service Availability and Usage: The Project Owner does not take responsibility for the continuous availability of the system, the impossibility of accessing the system, or any consequences arising from the use or inability to use the Service. The Service is provided on an "as is" and "as available" basis.
  • Indirect Damages: To the maximum extent permitted by law, the Project Owner shall not be liable for any indirect, incidental, or consequential damages resulting from the use or inability to use of the Service.
  • Third-Party Links: We are not responsible for the content or privacy practices of any third-party websites linked from the Service.

12. Amendments and Contact Information

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The "Last Updated" date at the top of this page will indicate when changes were made.

For any questions or inquiries regarding this policy, please contact us at:

support@turboatmo.com