PRIVACY POLICY Last updated: February 7, 2025 This Privacy Policy (hereinafter referred to as the “Policy”) explains how the Service at https://spyowl.icu / https://app.spyowl.icu (hereinafter referred to as “we,” “our,” “Administrator”) processes and protects the personal data (hereinafter referred to as “Data”) of users (hereinafter referred to as “you,” “User”), as well as how we comply with the General Data Protection Regulation (GDPR) and other applicable laws. 1. WHO WE ARE • Data Controller: (Name of the individual entrepreneur or company) • Contact E-mail: support@spyowl.icu 2. WHAT DATA WE COLLECT 2.1. Personal Data You Provide: • Username (login) • E-mail • Password (stored in encrypted form; we do not have access to the original password) • Other data that you voluntarily provide when using the Site or when contacting us 2.2. Data Collected Automatically: • IP address, device type, OS version, and other technical data automatically collected when visiting the Site • Cookies and similar technologies (see our Cookie Policy for more information) • Server logs (date and time of visits, pages requested, etc.) 2.3. Sensitive (Special) Categories of Data We do not knowingly collect or process information relating to race or ethnicity, political opinions, religious beliefs, health conditions, etc. Please refrain from providing such information to us. 3. PURPOSES AND LEGAL BASES OF DATA PROCESSING • Registration and Account Management. To create and manage your account, and to provide you with access to free/paid features of the Service. Legal basis: performance of a contract (Art. 6(1)(b) GDPR). • Order/Purchase Processing. For invoicing, receiving payments, and granting access to paid plans. Legal basis: performance of a contract, fulfillment of legal obligations (Art. 6(1)(b)(c) GDPR). • Technical Support. To respond to your inquiries. Legal basis: performance of a contract, legitimate interest. • Security and Fraud Prevention. To protect our users, resources, and investigate potential abuses. Legal basis: legitimate interest (Art. 6(1)(f) GDPR). • Sending Informational Messages (e-mails, SMS, push notifications) relating to the Service’s operation, including advertising (with your consent). Legal basis: consent or legitimate interest (Art. 6(1)(a)(f) GDPR). • Service Improvement and Analytics. To collect statistical data for optimizing the Site and analyzing traffic. Legal basis: legitimate interest or consent (if required). 4. WHOM WE SHARE YOUR DATA WITH 4.1. Third-Party Providers (acting as data processors) who assist us in processing data or providing services: • Hosting provider AWS • E-mail delivery service — Resend • CDN/DDoS protection — Cloudflare • Payment systems (if you accept online payments) • Analytics services (Google Analytics or others) 4.2. Law Enforcement and Government Agencies — where there is a legal requirement to do so. 4.3. Cross-Border Data Transfer (if applicable) occurs only if there are appropriate legal safeguards (Standard Contractual Clauses, adequacy decisions, etc.). 5. DATA RETENTION PERIOD We store personal data only for as long as necessary to fulfill the purposes of processing or to comply with legal requirements. After this period, the data will be deleted or anonymized unless further storage is required by law. 6. DATA SUBJECT RIGHTS Under the GDPR (subject to applicable law), you have the right to: • Access your data • Rectify inaccurate or incomplete data • Erase your data (“right to be forgotten”), unless its retention is required by law • Restrict the processing of your data • Data portability • Object to the processing • Withdraw consent (if the processing is based on consent) To exercise these rights, please contact us at support@spyowl.icu. You also have the right to lodge a complaint with the data protection authority in your country. 7. SECURITY We take reasonable measures (technical and organizational) to protect data from unauthorized access, alteration, disclosure, or destruction. However, no method of transmitting data over the internet or electronic storage is completely secure. 8. LINKS TO THIRD-PARTY WEBSITES Our Site may contain links to third-party resources. We are not responsible for the content or privacy policies of such resources. We recommend reviewing their policies separately. 9. CHANGES TO THIS POLICY We may periodically update this Policy. The current version will always be available on our Site, indicating the date it takes effect. By continuing to use the Service after changes have been made, you agree to the new terms. 10. CONTACT US • E-mail: support@spyowl.icu If you have any questions about this Policy or the way we process your personal data, please contact us at the email address above.