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Privacy Policy

Updated 14 October 2026

1. Who we are and whom this Policy covers

1.1 The controller of personal data is [legal name], [registration number], [address] (hereinafter “Znovu”, “we”).

1.2 This Policy applies to:

1.3 Znovu is an AI agency accountable for results: it launches and runs brands’ apps, repeat sales and customer acquisition. The apps run on the SalesBox platform. If you are a customer of a brand and use its app, that brand is the controller of your data. Znovu and SalesBox process such data only on the brand’s behalf (see the Data Processing Agreement) and do not use it for their own purposes. Please direct requests concerning such data to the brand. If you contact us, we will forward your request to the brand within 5 business days.

1.4 We process data in accordance with Regulation (EU) 2016/679 (GDPR) and, where applicable, the Law of Ukraine “On Personal Data Protection”.

2. What data we collect

CategoryData
Applicationbrand name, website, country, revenue and advertising budget (as a range), store platform, number of physical stores, email, WhatsApp / Telegram
Traffic sourceUTM parameters, referring page, ad click identifiers (fbclid, gclid, wbraid, gbraid), Meta identifiers (_fbp, _fbc) — only if they are already present in your browser
TechnicalIP address, browser and device type, request time — in hosting and attack-protection logs
Communicationscorrespondence, messenger messages, notes from audits and calls
Contractualbrand’s company details, contracts, invoices, payment history. We do not receive payment card data

The mandatory application fields are brand name and email: without them we cannot respond. All other data is provided at your discretion.

3. Purposes and legal bases

PurposeLegal basis (Art. 6 GDPR)
Responding to applications, selection for the Program, free advertising auditsteps prior to entering into a contract at your request — Art. 6(1)(b)
Entering into and performing the contract, support, reportingcontract — Art. 6(1)(b)
Accounting and tax recordslegal obligation — Art. 6(1)(c)
Understanding which advertising an application came from (UTM, click identifiers)legitimate interest in evaluating our own advertising — Art. 6(1)(f)
Website security, prevention of spam and fraudlegitimate interest — Art. 6(1)(f)
News, useful materials, event invitationsconsent — Art. 6(1)(a); may be withdrawn at any time

We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects.

4. Whom we share data with

We do not sell personal data. We share it only with providers that help us operate, and only to the extent necessary:

RecipientPurpose
Cloudflarewebsite hosting, content delivery, attack protection
CRM system (Twenty)tracking applications and deals
Calendlybooking an audit, if you choose a time slot
Email services and messengerscorrespondence with you
AI services (including OpenAI)assistance in processing requests and texts; data submitted via the API is not used to train models
Banks, accounting and legal adviserspayments, accounting, protection of rights
Public authoritiesonly upon a lawful request

5. Transfers outside the EEA

Some members of our team may work from outside the EEA, including from Ukraine, and some providers (Cloudflare, Calendly, OpenAI) operate from the United States. We work only with providers that ensure GDPR compliance. For such transfers we apply the safeguards provided for in Art. 44–49 GDPR: the Standard Contractual Clauses approved by the European Commission (Commission Implementing Decision (EU) 2021/914) or the provider’s certification under the EU-U.S. Data Privacy Framework. A copy of the relevant safeguards is available on request.

6. Retention periods

DataPeriod
Applications that did not result in a client relationship2 years from the last contact
Clientsterm of the contract + 3 years (limitation period)
Accounting recordsthe period required by law
Technical logsup to 1 year
Marketing consentsuntil withdrawn

7. Your rights

Under Art. 15–21 GDPR, you have the right to:

How to exercise your rights: write to privacy@znovu.ai. We respond without undue delay and in any event within one month.

8. Data protection

9. Cookies

The website znovu.ai currently does not set analytics or advertising cookies. Fonts are loaded from our own server, without requests to third-party services. If you go to the Calendly page, it may use its own cookies in accordance with its own policy.

If we add analytics or advertising pixels, they will be activated only after you give consent in the banner, and this Policy will be updated.

10. Changes

The current version is always available on this page. We notify clients of material changes by email 30 days in advance.

11. Contacts

[legal name], [address]

Personal data enquiries: privacy@znovu.ai

Responsible person: Andrii Stakhov, founder