LEGAL

Privacy Policy

Effective: 20 September 2026

Personal data controller: SINKAI LLC (Ukrainian company code EDRPOU 39579920), 266 Shevchenka Blvd., office 5, Cherkasy, Ukraine (the "Platform", "we", "us").
Contact for personal data matters: support@sinkai.com.ua

1. General provisions

1.1. This Policy explains which personal data we collect, for what purpose, on what legal basis, how we store it, with whom we share it, and what rights you have.

1.2. This Policy has been prepared in accordance with the Law of Ukraine "On Personal Data Protection" and, for users in the EU/EEA, with regard to the General Data Protection Regulation (GDPR).

1.3. By using the Platform (the administration panel at https://sinkai.net and related services) you confirm that you have read this Policy.

1.4. This Policy applies to individuals who register and administer websites on the Platform ("administrators"). The processing of data of visitors and customers of websites created on the Platform is governed by the policies of the respective website owners; for such data the Platform acts as a processor on behalf of the website owner.

2. What data we collect

2.1. Administrator account data

Data	Source	Required
First name (and last name, if provided)	registration form or social network profile	yes
Email address	registration form or social network profile	yes
Phone number	form / profile	no
Password (as an irreversible hash)	registration form	only for password sign-in
Date of birth	Facebook profile (user_birthday permission)	no
Gender	Facebook profile (user_gender permission)	no
Interface language, time zone, appearance settings	you choose them in the admin panel	no

2.2. Sign-in data from social networks (Google, Facebook, Apple)

When you sign in or register through a third-party provider, we receive from it and store:

the permanent identifier of your account at the provider (Google/Apple sub, Facebook user ID), so that we can recognize you on later sign-ins;
your email address, display name and a link to your avatar;
for Facebook only, and only if you granted the corresponding permissions: date of birth (user_birthday) and gender (user_gender). We use them once, to pre-fill your profile during registration.

We do not receive your password for the social network, we do not post anything on your behalf, and we have no access to your friend list, feed or messages.

2.3. Technical data

IP address, date and time of sign-in, browser and operating system type, and logs of actions in the admin panel (audit), for security, diagnostics and compliance with legal requirements.

2.4. Payment data

Payments for Platform services are processed by third-party payment providers. We do not see or store full card details; we receive only the status and amount of the payment.

3. Purposes and legal bases

Purpose	Basis (Law / GDPR)
Creating and authenticating an account, providing access to the admin panel	performance of a contract (Art. 6(1)(b) GDPR)
Contacting you about the operation of the service, security notifications	performance of a contract / legitimate interest
Protection against unauthorized access, investigation of incidents, keeping an audit trail	legitimate interest (Art. 6(1)(f) GDPR)
Invoicing, accounting and tax records	compliance with a legal obligation
Pre-filling your profile with Facebook data (date of birth, gender)	your consent, given in the Facebook authorization dialog
Improving the service, anonymized statistics	legitimate interest

We do not use your data for advertising and we do not sell it to third parties.

4. Who we share data with

Infrastructure providers (hosting, storage, email delivery), to the extent necessary for the service to work;
Payment providers, to process payments;
Domain registrars, when you register or transfer a domain through the Platform;
Public authorities, only on the basis of a reasoned legal request.

All contractors act under a contract that obliges them to protect the data.

5. International transfers

Some providers may process data outside Ukraine/the EEA. In such cases we ensure appropriate safeguards (standard contractual clauses or an adequacy decision).

6. Retention period

Account data: for as long as the account exists and for up to 90 days after its deletion (technical backups), after which it is destroyed or anonymized.
Audit and security logs: up to 12 months.
Accounting documents: for the period established by law (usually at least 1095 days).

7. Your rights

You have the right to:

access your data and obtain a copy of it;
request correction of inaccurate data;
request deletion of your data ("right to be forgotten"): see the data deletion instructions;
restrict or object to processing;
withdraw consent (where processing is based on consent); this does not affect the lawfulness of processing before withdrawal;
data portability;
lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or with the supervisory authority of your country.

To exercise your rights, write to support@sinkai.com.ua. We will respond within 30 days.

8. Revoking Facebook permissions

You can disconnect Facebook from your account at any time in the "Profile → Sign-ins" section of the admin panel, and also remove the app's access on the Facebook side: Settings → Security and Login → Apps and Websites.

9. Cookies

We use only strictly necessary cookies (sign-in session, CSRF protection, saving interface settings). There are no advertising or tracking cookies in the admin panel.

10. Security

Passwords are stored as an irreversible hash. The connection is protected by TLS. Only authorized employees have access to the data. We keep a log of administrative actions.

11. Children

The service is not intended for persons under 18. We do not knowingly collect data of children.

12. Changes to this Policy

We may update this Policy. We will notify you of material changes by email or by a notification in the admin panel. The current version is always available at this address.

13. Contacts

SINKAI LLC
Address: 266 Shevchenka Blvd., office 5, Cherkasy, Ukraine
Email: support@sinkai.com.ua