Personal Data Processing Policy

1. General Provisions

1.1.This Policy defines the procedure for processing personal data and measures to protect them, applied by LLC "Unitee Spase" (hereinafter — Operator).

1.2.The Policy applies to all information about users of the "Stikify me!" service, available through the Telegram mini-app at https://t.me/StikifyMeBot/start as well as through the information website https://stikify.me (hereinafter — Service).

1.3.The Operator aims to comply with the rights and freedoms of individuals when processing their personal data, including the right to privacy, personal and family secrets.

1.4.The Service is not intended for persons under 18 years of age. If processing of data of a minor without proper grounds is detected, the Operator shall terminate the processing and delete such data.

1.5.The use of the Service is also regulated by the Telegram Privacy Policy and the data processing policy of third-party Telegram services: https://telegram.org/privacy-tpa Telegram is an independent personal data operator and processes user data independently of the Operator.

2. Terms

The following basic terms are used in this Policy:

personal data;
processing of personal data;
personal data operator;
provision of personal data;
distribution of personal data;
depersonalization of personal data;
blocking of personal data;
destruction of personal data;
personal data information system;
cross-border transfer of personal data.

3. Principles of Personal Data Processing

Processing of personal data is carried out on the basis of the following principles:

legality and fairness of processing;
limitation of processing to achieving specific purposes;
prohibition of processing data incompatible with the purposes of their collection;
processing only necessary data;
ensuring accuracy and relevance of data;
storing data no longer than required for the purposes of processing;
ensuring the security of personal data.

4. Sources of Personal Data

4.1. Personal data may be provided directly by the User when using the Service, including registration, uploading images, using generation functions, and contacting support.

4.2. Authentication Provider.

User authentication in the Service is carried out through the Telegram platform.

When using Telegram to log in to the Service, the User transfers some data from their Telegram profile to the Operator.

The Telegram platform is an independent personal data operator and processes data in accordance with its privacy policy.

Data transmitted by Telegram may include technical and identification parameters defined by Telegram policies and is transferred within the framework of the Mini Apps platform.

5. Composition of Data, Purposes and Grounds for Processing

5.1. Account and Authentication

5.1.1. The following data may be processed during registration, login, and use of the Service: Telegram user ID, Telegram username, first and last name specified in the Telegram profile, Telegram profile picture (if available), as well as technical data of the device and session.

5.1.2.The purposes of processing the specified data are the registration and authentication of the User in the Service, provision of access to the Service functions, linking the User's account to their Telegram profile, ensuring the security of the Service, and preventing unauthorized access and abuse.

5.1.3.The grounds for processing the specified data are the necessity of fulfilling the user agreement between the User and the Operator, as well as the legitimate interest of the Operator related to ensuring the security and operability of the Service.

5.2. Communications with the User

5.2.1. The Operator may process the following data: email address, content of appeals, requests, statements, and other messages from the User.

5.2.2. The purposes of processing the specified data are the consideration of the User's appeals, provision of technical support, provision of answers and clarifications, sending service notifications, as well as resolution of disputed situations.

5.2.3. The grounds for processing the specified data are the necessity of fulfilling the user agreement, the legitimate interest of the Operator related to ensuring interaction with the User, as well as the User's consent in cases where it is required.

5.3. User Content

5.3.1. Within the framework of using the Service, the Operator may process content uploaded by the User, including images, photographs, text queries, text descriptions, and other materials.

5.3.2. The purposes of processing such content are the provision of the Service's services, generation of stickers and other results, storage and display of generation results in the User's account, content moderation, ensuring the security of the Service, as well as dispute and incident resolution.

5.3.3. The grounds for processing the specified content are the necessity of fulfilling the user agreement, as well as the legitimate interest of the Operator related to ensuring the quality, stability, and security of the Service.

5.4. Photographs and Images with Faces

5.4.1. In case the User uploads photographs or images containing a face, the Operator may process such images to the extent necessary for the functioning of the Service.

5.4.2. The purposes of processing the specified images are the generation of stickers and other results based on the uploaded images, content moderation, ensuring the security of the Service, applying automatic checks for prohibited content, as well as dispute and incident resolution.

5.4.3. The grounds for processing the specified images are the necessity of fulfilling the user agreement and the legitimate interest of the Operator related to ensuring the quality of the service provided and the security of the Service.

5.4.4. The Operator does not carry out the identification of the User and does not form biometric templates.

5.5. Technical Data and Analytics

5.5.1. During the use of the Service, technical data may be processed, including session identifiers, interface usage events, information about the device, browser, operating system, access time, and technical logs.

5.5.2. The purposes of processing the specified data are to ensure the correct operation of the Service, analyze the use of functionality, improve the interface and user experience, diagnose technical errors, ensure information security, and prevent abuse.

5.5.3. The grounds for processing the specified data are the necessity of fulfilling the user agreement, as well as the legitimate interest of the Operator related to the development and protection of the Service.

5.6. Payment-Related Data

5.6.1. When using the paid functions of the Service, transaction data may be processed, including transaction identifier, payment amount, and payment status.

5.6.2. The purposes of processing the specified data are the provision of paid functions of the Service, accounting for payments, confirmation of payment, and processing of inquiries regarding payment.

5.6.3. The grounds for processing the specified data are the necessity of fulfilling the user agreement and providing paid functions of the Service.

5.6.4. Payment for paid functions is carried out through the infrastructure of the Telegram platform using the virtual currency Telegram Stars. The Operator does not receive or store full payment details of Users.

5.7. Use of Content and Algorithm Training

5.7.1. User content and generation results are not published by the Operator outside the User's account and are not used for algorithm training without obtaining separate consent from the User.

5.7.2. The purpose of data processing within this clause is solely to provide the functionality of the Service.

5.7.3. The grounds for processing are the necessity of fulfilling the user agreement and the User's consent where required.

6. Cookies and Local Storage

Technical cookies and browser local storage may be used when using the website https://stikify.me.

They are used to ensure the operation of the site, maintain user sessions, and ensure security.

7. User Rights

The User has the right to:

receive information about their personal data;
request clarification or deletion of personal data;
withdraw consent to the processing of personal data;
appeal the actions or inaction of the Operator.

Requests should be sent to the email address:
[email protected]

8. Terms of Processing and Transfer of Data

8.1. The security of personal data is ensured by organizational and technical measures.

8.2. The Operator does not transfer personal data to third parties, except in cases where the transfer is necessary for the functioning of the Service, compliance with legislation, or protection of the Operator's rights.

8.3. Third-party technological services and infrastructure may be used to ensure the operation of the Service.

8.4. Automatic moderation algorithms may be used to ensure the security of images.

9. Cross-border Transfer

Cross-border transfer of personal data may occur when using certain technological services.

The Operator takes necessary measures to protect such data.

10. Data Retention Periods

10.1. Personal data is stored no longer than required for the purposes of processing.

10.2. Basic retention periods:
account data — for the duration of the account;
correspondence — up to 3 years;
security logs — up to 1 year.

10.3. Original uploaded images may be stored for no more than 30 days, after which they are deleted or anonymized.

11. Exercising User Rights

Requests for access, correction, or deletion of personal data should be sent to the email address:

[email protected]

Account and related data deletion is carried out within 7 business days.

12. Data Protection Measures

The Operator applies personal data protection measures, including:

access limitation;
encryption;
backup;
security monitoring;
internal data processing regulations.

13. Policy Changes

The policy is valid indefinitely until a new version is adopted.

The current version is posted on the website https://stikify.me

14. Operator Contacts

LLC "Unitee Spase"

Republic of Kazakhstan
Almaty
Bostandyk district
Miras microdistrict, 157/4, apt. 16

BIN: 251240031238

Website https://stikify.me

Mini-app https://t.me/StikifyMeBot/start

E-mail [email protected]