Privacy Policy

1. General Provisions

This personal data processing policy is prepared in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” and defines the procedure for processing personal data and the measures taken by Litvinov Andrey Alexandrovich (the Operator) to protect personal data.

1.1. The Operator’s key goal and operating condition is respecting human and civil rights and freedoms when processing personal data, including the right to privacy, personal privacy, and family privacy.

1.2. This Policy applies to all information that the Operator may receive about visitors of https://wappy.space and users of the Wappy service.

2. Terms Used in This Policy

2.1. Personal data means any information directly or indirectly related to an identified or identifiable user.

2.2. Processing of personal data means any action or set of actions performed with personal data, including collection, recording, storage, updating, retrieval, use, transfer, blocking, deletion, and destruction.

2.3. Website means the set of materials and software available at https://wappy.space.

2.4. User means any visitor of the website or person using Wappy.

2.5. Operator means the person who organizes and/or performs personal data processing and determines the purposes, scope, and actions performed with personal data.

3. Rights and Obligations of the Operator

3.1. The Operator may request accurate information and documents containing personal data and may continue processing personal data without consent where permitted by applicable law.

3.2. The Operator must provide information about personal data processing upon request, process personal data in accordance with applicable law, respond to user requests, publish this Policy, and take legal, organizational, and technical measures to protect personal data.

4. Rights and Obligations of Data Subjects

4.1. Data subjects may receive information about processing, request correction, blocking, or deletion of personal data, withdraw consent, request termination of processing, and appeal unlawful actions or inaction of the Operator.

4.2. Data subjects must provide accurate data and notify the Operator of updates or changes.

5. Principles of Personal Data Processing

5.1. Personal data is processed lawfully and fairly.

5.2. Processing is limited to specific, predetermined, and lawful purposes.

5.3. Only personal data that corresponds to the stated purposes is processed.

5.4. The content and volume of processed personal data correspond to the stated purposes and are not excessive.

5.5. Personal data is stored no longer than required by the processing purposes unless another period is established by law or contract.

6. Purposes of Personal Data Processing

Wappy user data

This is data of the Wappy customer who owns a Telegram bot or form.

Processing purposes: account creation and support, authentication, Telegram bot connection, form and lead management, service settings, and Wappy service communications.

Personal data: email address, Telegram ID, first name, last name, username, avatar, language, time zone, technical session data, and information submitted to support.

Form end-user data

This is data of the Wappy customer’s client who opens a Telegram Mini App and submits a form response.

Processing purposes: displaying the form, receiving and transferring the response to the form owner, storing the lead in Wappy, protecting against duplicate or invalid submissions, and supporting the connected Telegram bot.

Personal data: Telegram ID, first name, last name, username, language, and any data requested by the form owner in form fields, including phone, email, date, time, comment, selected service, product, and other answers.

Legal grounds

Consent of the data subject, performance of a contract or steps prior to entering into a contract, Federal Law No. 149-FZ “On Information, Information Technologies and Information Protection”, and other grounds permitted by applicable law.

Types of processing

Collection, recording, systematization, accumulation, storage, updating, retrieval, use, transfer to the form owner or integrations connected by the form owner, anonymization, blocking, deletion, and destruction of personal data.

7. Conditions of Personal Data Processing

7.1. Personal data is processed with the consent of the data subject or on other legal grounds established by applicable law.

7.2. Processing may be necessary to perform a contract, comply with legal obligations, exercise lawful rights and interests, or process publicly available personal data.

8. Collection, Storage, Transfer, and Other Processing

8.1. The Operator protects personal data and takes reasonable measures to prevent unauthorized access.

8.2. Personal data is not transferred to third parties except where required by law, with the data subject’s consent, or when necessary to provide Wappy functionality selected by the user or form owner.

8.3. A user may update personal data by sending a request to litvinov.andreiy@proton.me with the subject “Personal data update”.

8.4. A user may withdraw consent by sending a request to litvinov.andreiy@proton.me with the subject “Withdrawal of consent to personal data processing”.

8.5. Third-party services process data under their own user agreements and privacy policies. The Operator is not responsible for actions of such third parties.

9. Actions Performed with Personal Data

9.1. The Operator may collect, record, systematize, accumulate, store, update, retrieve, use, transfer, anonymize, block, delete, and destroy personal data.

9.2. The Operator may perform automated processing with or without receiving and/or transferring information over telecommunications networks.

10. Cross-Border Transfer

10.1. Before cross-border transfer of personal data, the Operator will comply with notification and information collection requirements established by applicable law.

11. Confidentiality

The Operator and other persons who receive access to personal data must not disclose or distribute personal data without the consent of the data subject unless otherwise provided by law.

12. Final Provisions

12.1. Questions about personal data processing may be sent to litvinov.andreiy@proton.me.

12.2. Changes to this Policy will be reflected in this document. The Policy remains valid until replaced by a new version.

12.3. The current version of the Policy is publicly available at https://wappy.space/privacy/en.