1. Personal Data Operator

The personal data operator is: the administrator of the MultiLaunchess service, acting as the owner and operator of the MultiLaunchess online platform and software, email: multilaunchess@gmail.com (the “Operator”, “we”).

2. General Provisions

1. The Operator processes personal data in accordance with applicable laws and regulations governing personal data protection.
2. By using the MultiLaunchess service (registration, software installation, account login), the User confirms that they have read this Policy, understand its contents, and agree to the processing of personal data under the terms of this Policy.

3. What Data We Process

• Registration data: email address, password (in encrypted form), service settings (language, time zone, etc.).
• Subscription and payment data: subscription plan type, subscription status, transaction information received from the payment provider, tax-related data where required. The Operator does not store bank card details.
• Technical and statistical data: IP address and approximate location; browser, device, and OS data; dates and times of access; technical logs (errors, statuses, load) required to operate service features.
• Configuration and automation data: user-created profiles, settings, and configurations; launch parameters for automations and scenarios provided by the Operator; task execution logs.
• Integration and token data: API keys, tokens, and identifiers voluntarily connected by the User; parameters of connected integrations. The User independently manages tokens on the side of third-party services, including deletion, rotation, and permission changes.
• Support request data: message contents; attachments such as logs, screenshots, and similar materials submitted as part of support processing.
• Cookies and similar technologies: session identifiers; authorization and analytics parameters.

4. Purposes of Personal Data Processing

• Contract conclusion and performance: account registration and maintenance; providing access to functionality; storing configurations and automation data; executing tasks on behalf of the User.
• Billing and payments: processing payments; managing subscriptions; accounting and tax compliance where required.
• Security: preventing unauthorized access; detecting suspicious activity; protecting technical infrastructure.
• Service improvement: analysis of anonymized data; testing new features; optimizing stability and performance.
• Communication: support replies; technical notifications; newsletters where consent is provided.
• Legal compliance: responding to requests from authorized authorities; protecting the rights and legitimate interests of the Operator and Users.

5. Legal Grounds for Processing

• Conclusion and performance of a contract, including the Terms of Service.
• Consent of the data subject, where such consent is required.
• Compliance with legal obligations.
• Legitimate interests of the Operator, including service improvement and security.

6. Disclosure of Data to Third Parties

1. The Operator may transfer personal data to the following categories of persons: payment providers for payment processing; hosting and infrastructure providers for service operation; analytics and mailing services for technical notifications; third-party services connected by the User, only to the extent necessary for the integration to function.
2. Persons processing data on behalf of the Operator undertake to maintain confidentiality and ensure the protection of personal data.
3. Disclosure of data to public authorities is carried out only where required by law.
4. In the event of a sale of the service or a change of ownership, data may be transferred to a legal successor subject to the preservation of data protection obligations.

7. Cross-Border Transfer

1. The Operator’s servers and contractors may be located outside the Russian Federation.
2. Where cross-border transfer takes place, the Operator complies with the applicable legal requirements governing such transfer.

8. Retention Periods

1. Data is retained while the account exists; after deletion, data may be retained for periods required by law, including tax, accounting, and limitation periods.
2. Once the purposes of processing are achieved, data is deleted or anonymized unless the law requires otherwise.

9. Data Protection Measures

The Operator applies necessary legal, organizational, and technical measures, including:

• restriction of access to data;
• use of secure transmission channels such as HTTPS;
• backup procedures;
• security event monitoring;
• regular software updates.

10. User Rights

The User has rights provided by applicable personal data protection law, including:

• Right to information. The User may request confirmation of processing, purposes, legal grounds, retention periods, categories of data, and sources of collection where applicable.
• Right to rectification and deletion. The User may request correction, blocking, or deletion of data if it is outdated, inaccurate, unlawfully obtained, or no longer necessary for processing purposes.
• Right to withdraw consent. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
• Right to complain. The User may file a complaint with the competent authority or a court. The Operator may request identity verification.

11. Cookies

1. Cookies are used for authorization and sessions, saving settings, and statistics.
2. Disabling cookies may affect the operation of the service.

12. Data of Minors

1. The service is not intended for persons under 18 years of age.
2. If such data is provided, it will be deleted once discovered.

13. Changes to the Policy

1. The Operator may update this Policy.
2. The current version is published on the website.
3. Continued use of the service means acceptance of the updated version.

14. Operator Contact Details

For questions related to personal data processing, please contact: multilaunchess@gmail.com.