Privacy Policy

PRIVACY, PERSONAL DATA PROTECTION AND COOKIE POLICY

Published at: https://typeonics.com/en/privacy-policy/

This Privacy, Personal Data Protection and Cookie Policy (the “Policy”) explains which personal data is processed when you use the Typeonics website, place orders, receive consultations, training and digital products, communicate with Typeonics, and how cookies and similar technologies are used.

The Policy applies together with the Public Agreement (Offer) published at https://typeonics.com/en/public-offer/ (the “Agreement”). Insofar as data processing relates to the performance of the Agreement, this Policy forms part of the contractual documentation. The terms “Contractor”, “Customer”, “Participant”, “Product”, “Service”, “Consultation”, “Training” and “Digital Content” have the meanings given in the Agreement. In this Policy, “Typeonics”, “we” and “us” mean the Contractor.

The Policy is an informational document on the processing of personal data and does not replace separate consent where such consent is expressly required by law.

For the purposes of this Policy, specialists and other persons engaged by the Contractor may act under two different models provided for in the Agreement. Under the standard model, they perform specific functions on behalf of or on the instructions of the Contractor and do not become an independent party to the agreement with the Customer. Under the platform mode, the main Service may be provided by an independent supplier in their own name; in that case the roles of Typeonics and of such supplier with regard to personal data are determined separately according to the actual purposes and means of processing, the Special Terms and applicable law.

1. GENERAL PROVISIONS

1.1. The Policy applies to the website https://typeonics.com/, its pages, language versions and subdomains (the “Website”), contact forms, communication via email and messengers, and to data processing in connection with Typeonics Products.

1.2. Personal data is processed in accordance with the Law of Ukraine “On Personal Data Protection”, the Law of Ukraine “On Electronic Commerce” and other applicable provisions of Ukrainian law. Regulation (EU) 2016/679 (GDPR) applies to specific processing where its territorial scope so provides, in particular where Typeonics offers goods or services to persons in the EU/EEA or monitors their behaviour there.

1.3. Typeonics adheres to the principles of lawfulness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, confidentiality and protection of personal data.

1.4. Providing personal data is voluntary. However, without the data objectively necessary for a specific Product (for example, name, communication channel and, for certain consultations, questionnaire answers), concluding or performing the Agreement and providing the relevant Product may not be possible.

2. DATA CONTROLLER

2.1. The owner of personal data and, where the GDPR applies, the controller is the Contractor, whose full details are set out in Section 25 of this Policy and in the Agreement. 2.2. Contact for personal data matters: [email protected].

2.3. As at the effective date of this Policy, Typeonics has not appointed a Data Protection Officer (DPO). Should an obligation to appoint a DPO arise under applicable law, the relevant contact details will be published on the Website.

2.4. Under the platform mode provided for in clause 2.10 of the Agreement, Typeonics remains the owner/controller of personal data in respect of those operations whose purposes and essential means it determines itself, in particular platform operation, order processing, organisational communication, payments, support, security and protection of rights. The independent supplier of the main Service may be a separate owner/controller in respect of the data it processes to provide its Service in its own name. Where Typeonics and such supplier jointly determine the purposes and essential means of a particular processing, their roles and responsibilities are determined in accordance with applicable law and, where necessary, by a separate arrangement.

2.5. Should an obligation arise for Typeonics under Article 27 GDPR to appoint a representative in the EU/EEA, the current contact details of such representative will be published in this Policy or on the Website in the manner provided by applicable law.

3. CATEGORIES OF PERSONS WHOSE DATA IS PROCESSED

3.1. The Policy applies to:

• visitors to the Website;
• persons who submit enquiries or complete forms;
• Customers and Participants of Consultations;
• participants in Training, webinars, programmes and Subscriptions;
• persons receiving Digital Content;
• representatives of Business Customers and Participants referred by them;
• persons who have subscribed to information messages;
•  parents and legal representatives of minor Participants, and minors themselves in the cases provided for in the Agreement;
• engaged specialists, contractors and independent suppliers cooperating with Typeonics — in respect of their personal data necessary to organise such cooperation, verify authority, communicate, settle payments and comply with legal obligations.

4. WHAT PERSONAL DATA IS PROCESSED

4.1. Data you provide yourself:

• identification data: first name, surname (if provided), nickname or username;
• contact data: email, telephone number (if provided), Telegram, Instagram or other messenger account;
• the content of enquiries, messages and correspondence with Typeonics;
• answers to questionnaires and questions provided before, during or after a Consultation;
•  information you voluntarily disclose during a Consultation or Training.

4.2. Data generated in the course of providing Services:

• order data: selected Product, tariff, date, payment status, history of rescheduling, cancellations, refunds and complaints;
• working and analytical data: notes of the Contractor and/or the engaged specialist, typological hypotheses, identified personality type, conclusions, recommendations, personalised reports;
• audio and/or video recordings of Consultations or classes — under the rules of Section 10;
•  payment data: date, amount, method, payment status, transaction identifier, and data required for the settlement document. Typeonics does not receive or store full bank card details (number, CVV/CVC) — these are processed by the payment provider.

4.3. Data collected automatically when you visit the Website:

• IP address, device type, browser, operating system, language;
• approximate location at country or city level;
• pages viewed, date and time of access, referral source;
• technical logs, error and security data;
• cookie and similar-technology data — in accordance with Section 13.

4.4. If you are an engaged specialist, contractor or independent supplier of Typeonics, we may also process your contact, professional and registration details, information on your qualification or status within Typeonics, payment details, history of interaction with the platform and other data objectively necessary for cooperation, verification of authority, performance of contracts and compliance with legal obligations.

4.5. Typeonics does not collect data that is not necessary for the specified purpose of processing.

5. SENSITIVE AND SPECIAL CATEGORIES OF DATA

5.1. Typeonics Products do not require you to disclose medical diagnoses, health data, racial or ethnic origin, political opinions, religious beliefs, data concerning sex life or sexual orientation, or other special categories of data. We do not deliberately request such information.

5.2. If, during a Consultation or correspondence, you voluntarily disclose information that may fall within special categories of personal data, the mere fact of such disclosure is not automatically regarded as explicit consent to its further systematic processing. Where applicable law requires separate explicit consent or another specific legal basis for recording, storing or otherwise processing such data, that basis is secured before the relevant processing. In the absence of a proper basis, Typeonics, as far as practicable, does not include such data in questionnaires, reports or systematic records and does not use it for other purposes.

5.3. We recommend that you do not send sensitive data unrelated to the purpose of your enquiry or the Product.

6. SOURCES OF DATA

6.1. Personal data is obtained:

• directly from you via Website forms, questionnaires, email, messengers or video calls;
• from the Customer in respect of a Participant where these are different persons (for example, a couples consultation or a Business Customer in respect of an employee) — provided the Customer has a lawful basis to transfer such data and has informed the Participant;
• from the legal representative of a minor;
• automatically when you use the Website — via technical logs, cookies and similar technologies;
• from payment and communication services — to the extent necessary to fulfil the order;
• from an engaged specialist or independent supplier — only to the extent necessary to organise the Product, provide support, process payment, handle an enquiry or dispute, or for another defined lawful purpose.

6.2. Typeonics does not carry out automated or mass collection of personal data from open sources or social networks for typing or marketing purposes. If you yourself provide a link to a public profile or expressly ask us to take publicly available information into account, such information may be used only within the scope of that request and where a proper legal basis exists.

6.3. Where Typeonics obtains personal data not directly from the data subject, in particular from the Customer in respect of another Participant, we fulfil our own obligation to provide appropriate information within the time limits and to the extent provided by applicable law, subject to the exceptions established by law. Where the GDPR applies, such information is provided within a reasonable period after obtaining the data, but no later than one month, or earlier — at the time of the first communication with the data subject or before the first disclosure of the data to another recipient, whichever occurs first. The mere fact that data was transferred by the Customer does not automatically determine the legal basis for all subsequent operations by Typeonics with the Participant’s data; such basis is determined separately for the relevant purpose of processing.

7. PURPOSES AND LEGAL BASES OF PROCESSING

7.1. Responding to enquiries and pre-contractual communication — to contact you, respond and agree the Service. Basis: taking steps at your request prior to entering into the Agreement.

7.2. Conclusion and performance of the Agreement and provision of the platform service — to provide the Product by the Contractor personally or with the involvement of specialists and other persons in accordance with the Agreement; under the platform mode — to enable the selection or booking of an independent supplier, organisational communication, payment, support and other expressly defined functions of Typeonics. Basis: performance of the Agreement with Typeonics, taking steps at your request and/or another proper legal basis depending on the specific operation. Where the Participant is not the Customer and not a party to the Agreement, the legal basis for processing their personal data is determined separately according to the purpose and actual circumstances of such processing.

7.3. Payment and mandatory accounting — to accept payment, issue a settlement document, process refunds, and keep tax and accounting records. Basis: performance of the Agreement and a legal obligation.

7.4. Handling complaints and protecting rights — to consider enquiries, confirm the fact and scope of Service provision, and protect rights in the event of a dispute, payment dispute or chargeback. Basis: the legitimate interest of Typeonics and performance of the Agreement.

7.5. Website operation and security — to ensure proper functioning, prevent fraud and abuse, and keep technical logs. Basis: legitimate interest.

7.6. Website analytics — statistics on visits, pages and referral sources to improve the Website and content. Basis: your consent to analytics cookies and similar technologies.

7.7. Information and marketing messages — news about Products, materials and offers. Basis: exclusively your separate consent. Acceptance of the Agreement does not constitute consent to mailings.

7.8. Reviews, case studies and marketing materials — publication of your review, image, voice or identifiable case study. Basis: exclusively your separate consent for each instance (Sections 24–26 of the Agreement).

7.9. Compliance with requests from competent authorities. Basis: a legal obligation.

7.10. Where processing is based on consent, you have the right to withdraw it at any time. Withdrawal does not affect the lawfulness of processing before withdrawal and does not terminate processing that has another independent basis (for example, the statutory retention of payment documents).

8. SERVICE AND MARKETING MESSAGES

8.1. Service messages (order confirmation, Consultation reminders, delivery of a recording or report, changes to a current Agreement) are sent without separate marketing consent, as they are necessary for the performance of the Agreement.

8.2. Marketing messages are sent only with your separate consent, given via the relevant checkbox in a form or by confirming a subscription.

8.3. You may opt out of marketing messages via the link in the email or by writing to [email protected]. Opting out does not stop service messages relating to a current order.

9. CONSULTATION, QUESTIONNAIRE AND TYPOLOGICAL ANALYSIS DATA

9.1. Questionnaire answers and information provided during a Consultation are used for individual analysis and to form a typological conclusion, recommendations and a report.

9.2. The typological conclusion is formed by the Contractor or an engaged specialist on the basis of live interaction and analysis of the information provided. Tests, questionnaires or software tools, where used, are auxiliary and do not make decisions in place of a human. Typeonics does not use the conclusion as a medical or psychiatric diagnosis and does not make solely automated decisions that have legal or similarly significant effects on you.

9.3. In couples consultations or consultations for parents with a child, information disclosed separately by one Participant (for example, in a preliminary questionnaire or in an individual part of the meeting) is not shared with the other Participant without the consent of the person who disclosed it, unless otherwise agreed at the start of the Consultation.

9.4. Working notes and hypotheses of the Contractor and/or the engaged specialist are internal materials and are not provided to the Participant as a separate document, except where required by law or the Product description. The right of access to personal data contained in such materials is exercised to the extent provided by applicable law.

9.5. Anonymised information from which you cannot be identified may be used to improve the Typeonics methodology and for educational and statistical purposes.

9.6. Under the platform mode, a typological or other professional conclusion may be formed by an independent supplier in their own name. In that case Typeonics accesses questionnaires, recordings, conclusions or other materials of the main Service only when and to the extent objectively necessary for an expressly defined platform function, support, quality control, or the handling of an enquiry or dispute, and where a proper legal basis exists. The independent supplier is responsible for its own separate processing within the role it actually performs.

10. AUDIO AND VIDEO RECORDINGS

10.1. A Consultation or class is recorded only where recording is provided for by the Product or separately agreed by the Parties and a proper legal basis for such recording exists. If recording is not a mandatory component of the specific Product, you may decline it. If the Product cannot be provided in the stated format without recording, or recording is an essential characteristic of the Product, this fact and the consequences of declining recording are communicated to the Customer before Acceptance/payment. Immediately before recording begins, the Participant is informed again that recording is taking place. The mere inclusion of recording in the Product does not replace separate consent or another proper legal basis where required by applicable law.

10.2. A recording of an individual Consultation may be used by the Contractor and/or the engaged specialist within the relevant Product to provide you with a copy, prepare the conclusion and report, conduct internal quality control and confirm the circumstances of Service provision in the event of a dispute. Access is granted only to persons who objectively need it for the relevant function.

10.3. A recording of an individual Consultation is stored in cloud storage with restricted access for up to 90 calendar days after completion of the Service, after which it is deleted. The period may be extended for the duration of a complaint, payment dispute, court or other legal dispute where the recording is objectively necessary to protect rights, or by separate arrangement between you and the Contractor. At your request, the recording may be deleted earlier once a copy has been provided to you, provided its further retention is not necessary to comply with the law or protect rights.

10.4. Recordings of group classes within Training are retained for the period of access to the relevant programme.

10.5. Purchase of a Product does not imply consent to the use of your image, voice, recording, review or identifiable case study in advertising or public materials. Separate consent is required for this.

10.6. Where a recording is made or received by an engaged person under the standard model, upon completion of the assigned work or earlier on the Contractor’s instruction, that person transfers/returns the recording to the Contractor and deletes all copies remaining under their control, except where retention of a specific copy is expressly required by applicable law. The periods and rules of this Section apply to copies of recordings under the control of Typeonics or persons engaged by it under the standard model; they do not determine the retention period of a copy lawfully provided to the Customer, or of a recording processed by an independent supplier under the platform mode in accordance with clause 10.7.

10.7. Where, under the platform mode, a recording is created or stored by an independent supplier to provide the main Service in their own name, the terms of such processing are additionally determined by their privacy information and/or the Special Terms. Typeonics does not have automatic access to such recording; access is possible only for a defined purpose and on a proper legal basis.

11. PAYMENTS AND FINANCIAL DATA

11.1. Payment is made via independent payment providers (WayForPay or another provider indicated on the payment page) or by bank transfer.

11.2. Bank card details are entered in the payment provider’s interface. Typeonics does not receive or store the full card number, CVV/CVC or other full card details.

11.3. From the payment provider, Typeonics receives the information necessary to confirm payment, identify the order, process refunds, keep financial records and resolve payment disputes.

12. DATA RECIPIENTS AND SERVICE PROVIDERS

12.1. Typeonics does not sell personal data. Transfer of, or access to, data by third parties takes place only to the extent necessary to provide Products, process payments, operate the Website, comply with legal requirements, protect rights or on another proper legal basis.

12.2. Depending on the specific operation and the terms of the relevant service, a provider may act as a processor, a joint controller or an independent controller of personal data. Data may be accessible to the following providers and categories of recipients:

• payment services: WayForPay or another provider indicated on the payment page — acceptance of payments;
• the Website hosting provider and email service — hosting the Website, email correspondence;
•  video communication services: Zoom, Google Meet — conducting Consultations and classes;
• cloud storage: Google Workspace / Google Drive — storing questionnaires, reports and recordings;
•  messengers: Telegram, Instagram and others — communication via your chosen channel;
•  analytics: Google Analytics — Website statistics with your consent;
•  the mailing service actually used by Typeonics — sending emails with your consent;
•  the learning platform actually used by Typeonics — access to Training materials;
•  accounting and legal advisers — accounting and protection of rights, under confidentiality obligations.

12.3. Engaged persons under the standard model. For the direct provision of Products, Typeonics may engage specialists, experts, instructors, consultants, curators, analysts, technical and other contractors. Such persons are provided only with the minimum personal data necessary to perform the assigned function. Throughout the processing period they are obliged to use the data received solely for the defined purpose, maintain confidentiality and comply with data protection requirements, apply protective measures no less stringent than those provided in Section 16, refrain from using the data for their own marketing or other incompatible purposes, and notify the Contractor without undue delay of any security incident concerning the data of Customers or Participants. Upon completion of the assigned work, such persons, on the Contractor’s instruction, return the personal data and/or delete it together with any copies remaining under their control, except where further retention is expressly required by applicable law. Where an engaged person processes personal data on behalf of Typeonics as a processor, such processing is carried out under a written contract defining the purpose, subject matter, scope and conditions of processing and, where the GDPR applies, also in compliance with Article 28 GDPR.

12.4. Independent suppliers under the platform mode. Where the main Service is provided by another person in their own name, Typeonics informs the Customer before Acceptance of that person’s identification and contact details to the extent required by law, of the role of Typeonics and of the allocation of functions in respect of personal data. To organise such a Service, Typeonics may transfer to the independent supplier the data objectively necessary for booking, communication, provision of the Service, payment, support or handling of an enquiry. Where such supplier independently determines the purposes and essential means of further processing for its Service, it acts as a separate controller and is responsible for such processing in accordance with the law and its own privacy information. If, before Acceptance, the Customer was not expressly informed of the platform mode and the independent supplier, the standard model under clauses 2.7–2.9 of the Agreement and clause 12.3 of this Policy applies.

12.5. Where Typeonics and another person jointly determine the purposes and essential means of a specific personal data operation, they may act as joint controllers. In that case the allocation of responsibility, the contact point and other information required by applicable law are determined and communicated to the data subject in an appropriate manner. Where the GDPR applies to such joint processing, the allocation of obligations is set out in a transparent arrangement in accordance with Article 26 GDPR, and its essence is made available to the data subject to the extent required by law. The mere fact of cooperation with Typeonics does not automatically imply joint control — the role is determined by the actual circumstances of the specific processing.

12.6. Data may also be disclosed:

• to banks, payment systems and parties to a payment dispute — to the extent necessary to handle the payment or chargeback;
• to public authorities, courts and law enforcement bodies — only on the basis and in the manner established by law.

12.7. The list of providers and categories of recipients may change as Typeonics develops; up-to-date information is provided on request to the extent provided by law. When selecting providers, Typeonics takes into account their reliability and the available contractual and technical data protection safeguards.

13. COOKIES AND SIMILAR TECHNOLOGIES

13.1. Cookies are small pieces of data stored on your device when you use the Website. The Website may also use local storage, pixels and tags.

13.2. The Website may use the following categories of technologies depending on its current configuration:

•  Necessary — security, operation of core functions, language selection and other technical functions required for the proper operation of the Website or to provide a function requested by the user. Basis: necessity for the operation of the Website. Separate consent is not required for technologies that fall within an exemption from the consent requirement under applicable law. Current information about their purposes and retention periods, or the criteria used to determine them, is provided on the “Cookies” page.
•  Analytics — Google Analytics or another analytics service, if activated: statistics on visits, pages and referral sources to improve the Website and content. Basis: consent. Such technologies can be rejected through the consent-management mechanism.
•  Marketing — Meta Pixel, Google Ads or other advertising technologies, if used: measurement of advertising effectiveness, attribution and remarketing. Basis: consent. Such technologies can be rejected through the consent-management mechanism.
•  Embedded content — YouTube videos, social media widgets and other third-party content that may set its own cookies or similar technologies. Basis: consent. Activated only after consent has been obtained; if consent is declined, the relevant content or function may not be displayed.

13.3. Non-essential cookies and similar technologies are not activated until your consent has been obtained.

13.4. If the Website uses non-essential cookies or similar technologies for which consent is required under applicable law, a consent-management mechanism is provided before those technologies are activated, allowing the user to accept them, reject them or customise individual categories. If the Website uses only necessary cookies and similar technologies for which consent is not required, such a mechanism may not be displayed.

13.5. Continuing to browse the Website does not in itself constitute consent to non-essential cookies.

13.6. Current information about the cookies and similar technologies used on the Website, their purposes and retention periods, or the criteria used to determine them, is provided on the “Cookies” page and, where the Website uses a consent-management mechanism, may also be displayed in the cookie settings centre.

13.7. You may also manage cookies through your browser settings; blocking necessary cookies may affect the operation of certain Website functions.

13.8. Rejecting non-essential cookies and similar technologies does not restrict access to the main content of the Website. However, certain additional functions or embedded third-party content that depend on such technologies may be unavailable. Where such a function is essential for a specific Product, the relevant technical conditions and available alternatives, if any, are communicated to the Customer before Acceptance.

14. INTERNATIONAL DATA TRANSFERS

14.1. Certain providers, including Google, Zoom, Meta, Telegram and others, may process or store personal data in various countries, including outside Ukraine and the EU/EEA, including the United States.

14.2. Where Chapter V GDPR applies to a specific processing and international transfer, the transfer of personal data to a recipient in a third country or international organisation is carried out on the basis of a mechanism provided by the GDPR: a European Commission adequacy decision; the EU-U.S. Data Privacy Framework — only in respect of a specific US organisation that, at the time of transfer, holds valid participation in the relevant programme covering such transfer; EU Standard Contractual Clauses (SCCs); or another permissible mechanism depending on the recipient and the specific transfer. Irrespective of the application of the GDPR, cross-border transfers are also carried out in compliance with the applicable requirements of Ukrainian law on the transfer of personal data to foreign entities and with proper legal bases and safeguards.

14.3. Where, under the platform mode, data is transferred to an independent supplier located in or processing data in another country, Typeonics carries out such transfer within its role only where a proper legal basis exists and, where required by applicable law, an appropriate international transfer mechanism is in place. Any onward international transfer carried out by the independent supplier as a separate controller for its own Service is its responsibility.

14.4. If you wish to avoid the use of a particular third-party service, you may contact Typeonics. We will consider the possibility of an alternative means of providing the Service where technically, organisationally and contractually feasible; the availability of an alternative is not guaranteed.

14.5. The use of a third-party service or independent supplier may additionally be governed by their own privacy policy and terms.

15. DATA RETENTION PERIODS

15.1. Personal data is retained for no longer than necessary for the purposes of processing, unless a longer period is required by law, contract or the need to protect rights.

15.2. Retention periods:

•  enquiries from persons who did not become Customers — up to 12 months after the end of communication;
•  order data, contractual correspondence, questionnaires, working materials, conclusions and reports — for the duration of the Agreement and 3 years after the last Service was provided (limitation period), and in the event of a dispute — until its resolution;
•  audio and video recordings of individual Consultations — in accordance with Section 10;
•  accounting, tax and payment documents — for the periods established by tax, accounting and other applicable legislation; for categories of documents for which clause 44.3 of the Tax Code of Ukraine sets a minimum period of 1,095 days — no less than that period, unless a longer period is required by law;
•  marketing contact data — until consent is withdrawn or you unsubscribe; minimal opt-out records may be retained for as long as objectively necessary to avoid resuming marketing messages contrary to your choice;
• copies of data held by engaged persons (standard model) — no longer than the period of performance of the assigned work; upon its completion the data is returned to the Contractor or deleted in accordance with clause 12.3;
• technical logs and security data — up to 12 months;
• backups — until their scheduled overwriting or deletion in accordance with the documented technical backup cycle of the specific system or provider; during this period, data in backups is not used for new purposes and is restored only where necessary to ensure integrity, security or continuity of the service;
•  cookies — in accordance with Section 13.

15.3. Upon expiry of the period, data is deleted or irreversibly anonymised. Anonymised data may be retained for statistics and to improve the methodology.

15.4. Under the platform mode, Typeonics retains only the data, and for only the periods, necessary for its own platform, contractual, payment, security and rights-protection functions. Retention periods for data processed by an independent supplier for its main Service are determined by that supplier in accordance with its legal role, applicable law and privacy information.

16. SECURITY OF PERSONAL DATA

16.1. Typeonics applies technical and organisational measures proportionate to the nature of processing and the risks, including HTTPS on the Website, need-to-know access restrictions to storage, robust authentication mechanisms and, where supported by the service, two-factor authentication, software updates, backups, deletion of data upon expiry of retention periods, and confidentiality obligations for engaged persons.

16.2. No method of transmitting or storing information guarantees absolute security. In the event of a personal data breach, Typeonics carries out a risk assessment and notifies the competent supervisory authority and/or the affected data subjects in the cases and within the time limits expressly provided by applicable law.

16.3. You are also responsible for security on your side: do not share access links to recordings and materials with third parties, and notify us of changes to your contact details.

17. RIGHTS OF THE DATA SUBJECT

17.1. Under Ukrainian law you have the right:

• to know the sources of collection, the location of your data, the purposes of processing and the recipients;
•  to access your data and obtain a copy of it;
•  to submit a reasoned request for the rectification or erasure of data;
•  to object to processing and to withdraw consent;
•  to protection against unlawful processing;
• to lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or with a court.

17.2. Where the GDPR applies, you also have the right to restriction of processing, to data portability in a structured, machine-readable format, not to be subject to a solely automated decision with significant effects, and to lodge a complaint with a supervisory authority, in particular in the EU/EEA country of your habitual residence, place of work or place of the alleged infringement.

17.3. The right to erasure has limits: Typeonics may retain data necessary to comply with tax obligations, handle complaints or protect rights for the periods set out in Section 15 — you will be informed of this in the response.

17.4. Where particular processing is carried out by an independent supplier as a separate controller, rights in respect of such processing are also exercised directly against that supplier. Where Typeonics and another person are joint controllers within the meaning of applicable law, you may exercise your rights in the manner provided by such law, irrespective of the internal allocation of obligations between the controllers.

18. HOW TO SUBMIT A REQUEST

18.1. To exercise your rights, write to [email protected] with the subject line “Personal data”, stating the substance of your request and the details by which you can be identified.

18.2. To protect your data, we may ask you to send the request from the email address or messenger account specified when placing your order, or to provide other reasonable proof of identity.

18.3. Under Ukrainian law, a request for access to personal data is examined as to whether it can be granted within no more than 10 working days; within this period the requester is informed whether the request will be granted, or is given the reasons for refusal in the cases provided by law. Where the request is granted, it is fulfilled within 30 calendar days of receipt, unless otherwise provided by law. Where the GDPR applies, information on the action taken is provided without undue delay and, as a rule, no later than one month from receipt of the request; this period may be extended by up to two further months where permitted by the GDPR, and the data subject is informed of the extension and its reasons within the first month of receipt of the request.

18.4. If your request concerns processing carried out by an independent supplier in its own name as a separate controller, Typeonics will provide the available contact details of that supplier and, where appropriate and technically feasible, may forward the request to it. This does not limit your right to contact such supplier directly.

19. MINORS

19.1. Services to minors are provided with the participation of parents or a legal representative in accordance with Section 20 of the Agreement and the requirements of applicable law. A minor’s data may be obtained from the legal representative and/or directly from the minor within the agreed Service and is processed only for defined lawful purposes.

19.2. Typeonics does not use the fact of a minor’s participation for marketing and does not seek to collect children’s data via the Website outside lawfully organised Products or other defined purposes. If you become aware that a minor has provided Typeonics with personal data without the appropriate participation or consent of a legal representative where such participation or consent is required by law, please write to us. After reasonable verification of the requester’s identity, the circumstances in which the data was obtained and the available legal bases, we will delete the relevant data or restrict its processing if there is no proper basis for further processing.

20. AUTOMATED PROCESSING AND PROFILING

20.1. The Website automatically processes technical data and form data for technical and service purposes.

20.2. Typeonics does not make solely automated decisions that produce legal or similarly significant effects on you. The typological conclusion is formed by a human.

20.3. Typeonics results should not be used by the Customer or third parties as the sole basis for medical, legal, financial, employment or other decisions with significant consequences (Sections 16 and 19 of the Agreement).

21. THIRD-PARTY LINKS AND SERVICES

21.1. The Website contains links to Typeonics pages on social networks (Facebook, Instagram, YouTube, TikTok, Telegram) and may contain other third-party links and embedded content. Once you follow such a link, data is processed by the relevant owner under its own rules, which Typeonics does not control.

22. CONFIDENTIALITY OF CONSULTATION CONTENT

22.1. Under the standard model, information you disclose during an individual Consultation is confidential. It may be accessed by the Contractor and the specialists or other persons engaged by the Contractor only to the extent objectively necessary to provide the relevant Product and perform their function, under confidentiality obligations. Other disclosure is permitted only in the cases provided for in Section 23 of the Agreement and applicable law, in particular where required by law, to protect rights, with your consent or after proper anonymisation.

22.2. Under the platform mode, information you disclose directly to an independent supplier in order to receive its main Service is processed by that supplier in accordance with its actual legal role and confidentiality obligations. Typeonics does not have automatic access to the full content of such Consultation or materials and processes them only when and to the extent necessary for a defined Typeonics function and on a proper legal basis.

22.3. Participants in group programmes must not disclose information about other participants.

23. CHANGES TO THE POLICY

23.1. Typeonics may update the Policy in connection with changes in legislation, the Website, Products, the platform model, engaged persons or providers. The new version is published on the Website with an indication of its effective date.

23.2. Typeonics additionally gives notice of material changes that significantly affect the rights of individuals or the conditions of ongoing processing of their personal data, through an available channel, where required by law or where the nature of the change reasonably calls for such notice and we hold current contact details for the relevant person. This may concern not only persons with a current Agreement or subscription, but also other data subjects whose data continues to be lawfully processed at the time of the change. Where the law requires new consent, it is obtained separately.

23.3. Previous versions are retained and provided on request.

24. LANGUAGE VERSIONS

24.1. The Policy may be published in Ukrainian, Russian, English and other languages. The primary legal version is the Ukrainian version, published at https://typeonics.com/uk/privacy-policy/, unless mandatory provisions of applicable law require otherwise. This English text is a translation provided for convenience; in the event of any discrepancy, the Ukrainian version prevails.

25. DATA CONTROLLER’S DETAILS

Individual Entrepreneur (FOP) Ihor Anatoliiovych Derysh (ФОП Дериш Ігор Анатолійович)

Taxpayer ID (RNOKPP): 3056416652

Registered address: **1, Promyslova St., building **, block **, apt. **, Odesa, Odesa region, Ukraine

Email for personal data matters: [email protected]

Official website: https://typeonics.com/

This Policy is published at: https://typeonics.com/en/privacy-policy/

This version of the Policy is effective from 08.09.2026.