DeTo Svitlo — Privacy Policy
This Policy explains what data the DeTo Svitlo app collects, why, and how you can control it. We do not require registration and we do not sell personal data. If the versions differ, the Ukrainian version prevails.
1. Who processes your data
1.1. The data controller is FOP Ivan Oleksiiovych Ziubin, tax ID 3647903259, address: 3 Derevianka St., Kharkiv, Ukraine, email: info@artmarketing.com.ua (“we”).
1.2. This Policy applies to the DeTo Svitlo mobile app for iOS (the “App”). It forms part of the Terms of Use and the User Agreement.
1.3. We process data under the Law of Ukraine “On Personal Data Protection”. For users in the EU, the General Data Protection Regulation (GDPR) also applies.
1.4. The App does not require registration. We do not collect your name, phone number or payment details, and we do not sell personal data.
2. What data we collect and why
We collect only the data needed to run the App, show ads and provide the subscription.
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Selected address, outage queue (group), region | Showing schedules and alerts, sending notifications | Performance of the User Agreement | Until you change them or delete the App; on the server, up to 30 days after last activity |
| Push notification token (Apple) | Delivering schedule and alert notifications | Performance of the Agreement; your iOS permission | While notifications are enabled |
| Location [if used] | Automatically choosing your region or address | Your consent (iOS permission) | Not stored: used once |
| Advertising identifier (IDFA) | Personalised ads and ad measurement | Your consent in the App Tracking Transparency prompt | Under the ad network’s rules |
| Technical data: device model, iOS version, language, IP address, crash logs | App operation and security, fixing bugs, non-personalised ads | Our legitimate interest | Up to 14 months |
| Subscription status, date and App Store transaction ID | Access to paid features, restoring purchases | Performance of the Agreement; tax obligations | Subscription term plus the period required by tax law |
| Your email and message content | Replying to questions and claims | Your consent; performance of the Agreement | Up to 2 years after the last message |
Payment details (card number etc.) are processed only by Apple; we never receive them.
3. Ads, analytics and third parties
3.1. We share data only with these recipients and only as far as their function requires:
- Apple — push notifications, payments and subscriptions;
- ad network [e.g. Google AdMob] — showing ads in the free version;
- analytics and crash reporting [e.g. Firebase Crashlytics];
- server hosting [provider] — storing selected addresses and notification tokens.
3.2. The ad network collects device data itself under its own privacy policy ([link]). If you decline tracking, ads will be non-personalised. The subscription version has no ads.
3.3. We may disclose data in response to a lawful request from Ukrainian authorities, as provided by law.
3.4. International transfers. Servers of Apple, ad networks and analytics providers may be located in the USA and the EU. Such transfers comply with Article 29 of the Law “On Personal Data Protection” and these providers’ standard contractual clauses.
4. Data security
We transmit data only over encrypted connections (HTTPS), restrict access to our servers and collect the minimum data needed. No method of protection is absolutely secure; we will notify you in the App of any data breach that affects you.
5. Children
The App is not intended for children under 14, and we do not knowingly collect their data. If you believe a child has sent us data, write to info@artmarketing.com.ua and we will delete it.
6. How to delete your data
- turn off notifications — the token stops working;
- disable tracking in Settings → Privacy & Security → Tracking;
- delete the App — local data is removed, and server data is deleted after 30 days of inactivity;
- or write to info@artmarketing.com.ua — we will delete your data within 30 days.
7. Your rights
Under Article 8 of the Law “On Personal Data Protection” (and the GDPR for users in the EU), you have the right to:
- know what data about you is processed, why and who receives it;
- access your data;
- have your data corrected or deleted;
- object to or restrict processing;
- withdraw consent at any time (this does not affect the lawfulness of earlier processing);
- complain to the Ukrainian Parliament Commissioner for Human Rights or a court (in the EU, to your national data protection authority).
Send requests to info@artmarketing.com.ua. We reply within 30 days.
8. Changes to this Policy
The current version is published at https://detosvitlo.artmarketing.com.ua/en/privacy. We will notify you in the App of material changes. If a change requires new consent, we will ask for it separately.
9. Contact
FOP Ivan Oleksiiovych Ziubin, tax ID 3647903259
Address: 3 Derevianka St., Kharkiv, Ukraine
Email: info@artmarketing.com.ua
Version dated: 9 November 2026