Updated and Effective as of March 2026
Thank you for choosing to be part of our community!

WE HOPE YOU TAKE SOME TIME TO READ THROUGH IT CAREFULLY, AS IT IS IMPORTANT.

This Privacy Policy describes how Individual Entrepreneur Zinovatna Yuliia Volodymyrivna (collectively, “we,” “us,” or “our”) collects, uses, stores, transfers, and discloses personal information from our Users in connection with our Website or/and Web application located at the following Website: https://aspectly.space/ (collectively referred to as “Service”). One way to protect your privacy is to learn how it will be used before you give it out. We attach great importance to your privacy rights and truthfully explain why and how we process your information. We tried to shorten this privacy policy, so it would be easier to understand the rights of a User (referred to as “you,” “yours,” Etc.) and our obligations to the User’s data. «Personal Data» means personal data that relates to you as an identified or identifiable individual.

Where applicable, you must provide us with the relevant Personal Data to be able to use our Services completely. You should not use the Services if you disagree with this Policy, our Terms of Use, and any other agreement that governs your use. BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). You must not use the Service if you disagree or cannot make this promise. In this case, you must (a) contact us and request deletion of your data; and (b) leave the Service and not access or use it.

We may update this Privacy Policy from time to time, so please be sure to check regularly. We will notify you of any material changes by posting the new Privacy Policy on the primary access points to the Services or as otherwise required by applicable law.

If any questions will remain unanswered, please contact us at moc.liamg%40ecaps.yltcepsa

Table of content:

1. Categories of personal data, purposes of the processing, and legal bases

2. Cookies

3. Third parties processing Personal data

4. Term of storage of your personal information.

5. Rights about personal data.

6. Age limitations

7. CCPA rights

8. Miscellaneous

9. Contact information

1. Categories of personal data, purposes of the processing, and legal bases

When the User uses our Services, we can collect, use, receive, process, transfer, and share some of the User’s Personal Data for different legitimate purposes. Below are explanations regarding what Personal Data we may collect or process, why we may collect this data, and the legal bases relied on in each case.

CATEGORY PERSONAL DATA

User-provided information (In some instances, we may require certain Registration Information, in other cases, we may ask you to provide such data voluntarily.)
Contact Data when the User registers for the Service and enters the contract
email; Name/Surname/Nickname; password or passcode; last 4 digits of the card number; comment.
Location Data - we do not collect the User’s precise location
country, state, or coarse location such as Approximate Location Services (general - non-precise location).
Quiz Data - during the onboarding questionnaire, the User may provide different quiz personal data. We do not collect, store, share, or transfer this quiz data or use this data for identification, marketing, or advertising purposes. We are not collecting biometric information.
date and place of birth, birth time, gender, weight, age, photo (arm, face, Etc.), relationship status, future goals, source of stress, answers to the questions, data on physical characteristics (including height, weight, areas for improvement), Etc.
Automatically collected information. When you use the Service, some information about your device and user behavior may be processed automatically. Examples of such information:
Device Info technical data
device type and model, two-character country code, a subdivision of country (e.g., state), city, two-character language code, operating system, and version number (e.g., Windows 10, macOS 14), hardware type, connection type (for example, WiFi, 3G, 4G), network service provider, device motion parameters and carrier.
Identity Data - identify a computer, device, browser, or product
IP Address; session identifiers; browser fingerprint; and other similar unique identifiers.
Usage Data (Events) - indicates user activity on the Service
length of the User's last session in seconds; Length of the User's current session in seconds; Number of sessions recorded; clicks on User's ads; the type of ads and the webpage or website from which such ads were displayed.
Diagnostic information
logs, error reports, events, and the type, number, date, and page relating to this information.
Cookies and Other Tracking Technologies
cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, fingerprinting, device recognition technologies, web-based tracking methods, and other tracking technologies now and hereafter developed ("Tracking Technologies") may be used to collect information about interactions with the Service or information received from third parties.
We collect and use personal data.
We collect personal data to ensure the Service provided, analyze your behavior during the usage of our Service, add new features to our Service, and provide our third-party service providers with information crucial to their services.
Providing Service includes enabling you to use the Service seamlessly and preventing or addressing Service errors or technical issues. As a result of such processing, we will use your email, for example, to send you the purchased product or to render services ordered through our Website. To host personal data and enable our Website to operate and be distributed, we use Amazon Web Services, a hosting and backend service provided by Amazon. We use Paddle.com, payment processing provider, to allow the purchase and process your payments. We use Firebase Performance Monitoring, a monitoring Service provided by Google. Please visit Google’s Privacy Policy and Privacy and Security in Firebase to learn more. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors.

2. Cookies

We use cookies and similar tracking technologies to operate and improve the Service. A cookie is a small text file placed on your device when you visit our website. Cookies allow us to recognize your browser, remember your preferences, and understand how you interact with our Service.

We use the following types of cookies:

Essential cookies — necessary for the website to function. They enable core features such as session management, user authentication, and security. Without these cookies, the Service cannot be provided. Legal basis: performance of a contract.
Functional cookies — allow us to remember your preferences (such as language or region) and provide enhanced, personalized features. Legal basis: legitimate interest.
Analytics cookies — help us understand how visitors interact with our website, which pages are visited most often, and where errors occur. We use Firebase Performance Monitoring (Google) and similar tools for this purpose. The data collected is aggregated and anonymous. Legal basis: legitimate interest.
Advertising and targeting cookies — used to deliver advertisements relevant to your interests. These cookies track your browsing activity across our website and may be set by our third-party advertising partners. Legal basis: your consent (where required by applicable law).
You can control and manage cookies in various ways. Most browsers allow you to refuse or delete cookies through their settings. Please note that disabling certain cookies may affect the functionality of the Service. For more information on managing cookies, visit your browser’s help documentation. You may also opt out of interest-based advertising by visiting https://optout.aboutads.info or https://adssettings.google.com.

3. Third parties processing Personal data

To provide the Service, we share certain personal data with trusted third-party service providers who process it on our behalf or as independent data controllers. We only share the minimum data necessary for each provider to perform their function.

Amazon Web Services, Inc. (AWS) — cloud hosting and infrastructure. Your data is stored on AWS servers located in the United States. AWS acts as a data processor on our behalf. For more information, see https://aws.amazon.com/privacy/.
Paddle.com Market Ltd (Paddle) — payment processing and Merchant of Record. Paddle handles payment collection, VAT calculation, and billing on our behalf. When you make a purchase, your payment data is processed directly by Paddle. For more information, see https://paddle.com/legal/privacy/.
Google LLC (Firebase) — performance monitoring and diagnostics. We use Firebase Performance Monitoring to detect and resolve technical issues with the Service. Firebase may collect device information and usage data. For more information, see https://firebase.google.com/support/privacy.
Advertising networks — we may work with third-party advertising networks (including Google Ads) to display relevant advertisements. These partners may set cookies or use other tracking technologies to collect information about your activity on our Service and other websites. You can opt out of targeted advertising as described in Section 2 above.
Where we transfer personal data to third parties located outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission, or we rely on an adequacy decision where applicable.

4. Term of storage of Personal data. Security measures.

If you are located outside of the USA and choose to provide information to us, please note that we transfer the data, including Personal Data, to the USA and process it there. Your consent to this Privacy Policy, followed by submitting such information, represents your agreement to that transfer. We retain all Personal Data for as long as you use the Services and 24 months after you stop. If you do not use the Services for 24 continuous months, we erase Personal Data from our database and request the same erasure from any third party to whom your Personal Data may have been transferred. We may erase Personal Data earlier if we no longer need to process such data.

Personal data may be processed by automated and non-automated means and stored at our premises and on our service provider’s servers. We understand that, unfortunately, the Internet’s transmission of information is not entirely secure. We do our best to maintain the privacy and integrity of your information. We have implemented industry-standard security measures, which include encryption to protect your personal information, including all information you input into or share through the Service, and this information is not available to third parties. Our measures include pseudonymization and tokenization; Encryption; Protection of data integrity, Etc. However, transmissions over the Internet are never 100% secure, and you should not provide personal data to avoid risk.

5. Rights about personal data.

We attach great importance to user privacy and would like to explain your data protection rights.

(i) The withdrawal right. It's important to remember that if we process your data based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. Withdrawal is made by the mere notification of us via its Support service, i.e., by emailing moc.liamg%40ecaps.yltcepsa with the topic «Consent withdrawal» or in your account settings on the website.
(ii) The right to be informed. The right to know what Personal Data we hold and how and why we handle your Personal Data. You can ask us for a copy of your Personal Data. If you would like to exercise your right of access, please contact us as described below and let us know what information, in particular, you would like to receive.
(iii) The right to opt-out of direct or target interest advertising by adjusting your browser or account privacy settings. Please note that even if you use your right to opt out, you will still receive advertising but not direct or target interest. You can opt out of interest-based advertising by adjusting your browser's privacy settings, or by visiting the opt-out pages of advertising networks such as Google Ads Settings (https://adssettings.google.com) or the Digital Advertising Alliance opt-out tool (https://optout.aboutads.info).
(iv) The right to request an update or correction (rectify) to any of your Personal Data that is out of date, incomplete or incorrect (according to Article 16 of the GDPR). In certain circumstances, you have the right to ask us to delete the Personal Data we hold about you.
(v) The right to delete your Personal data. (Right to be forgotten). You have the right to request that we delete certain of your Personal data. There are situations where we are unable to delete your data, for example, when: it's still necessary to process the data for the purpose we collected it for; our interest in using the data overrides your interest in having it deleted (for instance, we need the data to protect service from fraud); we have a legal obligation to keep the data or require the data to establish, exercise or defend legal claims.
(vi) The right to object. You have the right to object to our processing of your personal data under certain conditions: we are processing your personal data on the legal basis of legitimate interest or processing your personal data for interest-based advertising. Object to us processing your personal data at any time on grounds relating to your particular situation Object to your personal data being processed for direct marketing purposes.
(vii) The right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence. You can do this if: your personal data is inaccurate; our processing is unlawful; we do not need your information for a specific purpose; you object to processing, and we are assessing your objection request.
(viii) The right to portability of your personal data. In some circumstances, you may have the right to request that the data you provided to us be provided so that you can transfer this to another data controller. You have the right to Request a copy of your personal data in electronic format and transmit that personal data for use in another party's service. If you wish to receive personal data in a machine-readable format, you can send a respective request to .moc.liamg%40ecaps.yltcepsa
(ix) The right to complain to a data protection authority about our collection and use of your personal information. Don't hesitate to contact your local data protection authority for more information. Please see this directory for contact details: https://edpb.europa.eu/about-edpb/board/members_en If you are in Switzerland, please visit this FDPIC site for contact details: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html
(x) The right to request access to the personal information we collect from you, change it or delete it in some circumstances. You have the right to ask for copies of your personal data. To request to review, update, or delete your personal information, please submit a request. We will respond to your request within 30 business days. The User is empowered to request one copy of the personal data undergoing processing free of charge. Any additional documents are provided on a reimbursement basis.
In this case, please send an email to moc.liamg%40ecaps.yltcepsa.

If you are based in the EEA, you have the following rights in addition to the above: The right to complain to the supervisory authority. We would love for you to contact us directly so that we can address your concerns. Nevertheless, you can complain to a competent data protection supervisory authority, particularly in the EU Member State where you reside, work, or where the alleged infringement has occurred.

6. Age limitations

The Service is intended for adults and has a minimum “Age Limit” in each country or region. In general, you must be 16 years of age or older to use the Service, or your age requires parental consent to process your personal data. Following the Federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), we will never knowingly solicit, nor will we accept, personally identifiable information from users of the Service known to be under 13 years of age. Please see our privacy policy for additional information, including how to notify us of any concerns.

If you believe we have information from or about anyone under thirteen (13) years of age, please notify us by email at moc.liamg%40ecaps.yltcepsa. Please include “COPPA Concern” in your message’s subject line and the body for the fastest processing. We will make the most significant efforts to delete the personal data.

7. CCPA rights

Here is the additional information about how we collect, use, disclose and otherwise process the personal data of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”). We adopted this paragraph to comply with CCPA, and any terms defined in the CCPA have the same meaning when used in this notice. California law requires us to disclose the categories of personal information we collect and how we use them, the categories of sources from which we collect personal information, and the third parties with whom we share personal information. We have provided detailed descriptions above in this policy. In particular, our Services have collected the following categories of personal information from its consumers within the last twelve (12) months:

CATEGORY EXAMPLES COLLECTED WE SELL SOURCES OF COLLECTION CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE PERSONAL INFORMATION

A. Identifiers

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number. YES NO User, their Devices Advertisers, Analytics Providers, and Third Parties as Legally required

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal data in this category may overlap with those from other categories. NO NO N/A N/A

C. Protected classification characteristics under California or federal law.

Race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information), driver’s license number, passport number, or other similar identifiers. NO NO N/A N/A

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. YES NO User Payment Service Providers

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data (Hair color, eye color, fingerprints, height, retina scans, facial recognition, voice, and other biometric data). NO NO N/A N/A

F. Internet or other similar network activity.

Browsing history, search history, and information on a consumer’s interaction with a website, application, or advertisement. NO NO User, their Devices Advertisers, Analytics Providers, and Third Parties as Legally required

G. Geolocation data.

Physical location or movements. NO NO N/A N/A

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information. NO NO N/A N/A

I. Professional or employment-related information.

Current or past job history or performance evaluations. NO NO N/A N/A

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. NO NO N/A N/A

K. Inferences drawn from other personal information.

The profile reflects a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. YES NO User, their Devices, Partners Advertisers, Analytics Providers, and Third Parties as Legally required

As a California resident, you have the rights listed below:

You can request information about how we have collected and used your personal information during the past 12 months including the categories: The categories of information we have collected about you; The categories of sources from which the information is collected; The business or commercial purpose for collecting your information; The categories of third parties with whom we have shared your information; and The specific pieces of information we have collected about you;

You can request a copy of the personal information that we have collected about you during the past 12 months. Also, according to the California “Shine the Light” law users who are California residents have the right to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. To make such a request from us, if entitled, please use the contact information listed below;

You can ask us to delete personal information we have collected from you. We may need certain types of information so that we can provide our Services to you. If you ask us to delete some or all of your information, you may no longer be able to access or use the Services;

You have the right to be Free from Discrimination. We may not discriminate against you because you have exercised your rights, including, for example, by denying you access to our online services or charging you different rates or prices for the same online services, unless that difference is reasonably related to the value provided by your data;

You have the right to opt out of the sale of Personal Information, which is defined in a way that may include the transfer of data to third parties to personalize ads for you. Please note that the CCPA defines the term “sale” very broadly to include any exchange of data for consideration of any kind, not simply selling your data for monetary compensation. Depending upon the circumstances, the term “sale” could include a company providing a resident’s data to another entity to assist the company with targeted advertising. We do not sell to third parties, and within the last 12 months have not sold, any of your personal information. If you opt out of the ‘sale’ of your information, we will not sell your information, including to our advertising partners, but you may continue to receive ads from our Services, which may not be as tailored to your interests;

You have the right to complete your transaction;

You have the right to provide you a good or service;

You have the right to perform a contract between us and you;

You have the right to protect your security and prosecute those responsible for breaching it;

You have the right to fix our system in the case of a bug;

You have the right to protect the free speech rights of you or other users;

You have the right to comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);

You have the right to engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;

You have the right to comply with a legal obligation;

You have the right to make other internal and lawful uses of the information that are compatible with the context in which you provided it;

Other Rights. You can request certain information about our disclosure of your information to third parties for their own direct marketing purposes during the preceding calendar year (to the extent we have shared information for such purposes within the given period). This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.

You may exercise your California privacy rights described above by emailing us to .moc.liamg%40ecaps.yltcepsa We will need to confirm your identity (e.g. first name, last name, account name, email address, state of residence, etc.) and California residency to process your requests to exercise your information, access or deletion rights. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.

The California Consumer Privacy Act (“CCPA”) provides California residents with the additional rights listed here. To exercise these rights, see the “Exercising Your California Privacy Rights” subsection below.

Social sharing features

User has the right to know and see what information we have collected about you over the past 12 months, including:

The categories of information we have collected about you;
The categories of sources from which the information is collected;
The business or commercial purpose for collecting your information;
The categories of third parties with whom we have shared your information;
The specific pieces of information we have collected about you;
Right to Delete

The User has the right to request that we delete the information we have collected from you (and direct our service providers to do the same). There are several exceptions, however, that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:

Complete your transaction;
Provide you a good or service;
Perform a contract between us and you;
Protect your security and prosecute those responsible for breaching it;
Fix our system in the case of a bug;
Protect the free speech rights of you or other users;
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.);
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws;
Comply with a legal obligation;
Make other internal and lawful uses of the information that are compatible with the context in which you provided it.
Right to Opt-out

You have the right to “opt-out,” or direct us to stop “selling” or otherwise sharing your information with third parties in exchange for monetary or other valuable consideration. To submit an opt-out request, please follow the instruction under the ‘Opt-out of targeted advertising’ paragraph found above, to adjust your account privacy settings on our website.

Other Rights

You can request certain information about our disclosure of your information to third parties for their own direct marketing purposes during the preceding calendar year (to the extent we have shared information for such purposes within the given period). This request is free and may be made once a year. You also have the right not to be discriminated against for exercising any of the rights listed above.

Exercising Your California Privacy Rights

To request access to or deletion of your personal information, to opt-out, or to exercise any other rights under California law, please write us an email to .moc.liamg%40ecaps.yltcepsa

8. Miscellaneous

Conditions of the present PRIVACY POLICY may be unilaterally changed by us if required under the applicable laws or in other relevant cases with obligatory notification of the Users. The new version of the PRIVACY POLICY enters into force and is subject to observance by the User after the User has expressly agreed to its applicability. If the User does not agree to the relevance of the new version of the PRIVACY POLICY, the User will discontinue the usage of the Service of Individual Entrepreneur Zinovatna Yuliia Volodymyrivna and will not be allowed to use its account without the provision of unambiguous consent to the applicability of the new version of the PRIVACY POLICY.

8b. Data Breach Notification

In the event of a personal data breach, we will notify the relevant supervisory authority within 72 hours of becoming aware of it, where feasible. If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you without undue delay.

9. Contact information

DATA CONTROLLER:

Individual Entrepreneur Zinovatna Yuliia Volodymyrivna is a sole proprietor registered in Ukraine with the registration number EDRPOU 3706504061 and a registered address at 18 Peremohy Square, Derhachi, 62303, Ukraine

Email: moc.liamg%40ecaps.yltcepsa