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Privacy Policy

We take your privacy very seriously and are committed to protecting your personal data. This Privacy Policy of BIRD IN THE SKY LIMITED LIABILITY COMPANY (hereinafter referred to as “we” or “BIRD IN THE SKY LLC”) explains what personal data is collected and processed when you use websites, software, or mobile applications owned by BIRD IN THE SKY LLC. In this document, we also explain the purposes and grounds for collecting personal data and the choices available to you.

Our website and mobile application may contain links to other websites operated by third parties. This Policy does not apply to those websites. We strongly encourage you to carefully review the privacy policies and statements of any third-party website in order to properly understand their information practices.

Legal grounds for processing personal data

If you are located in the European Economic Area (EEA), the legal basis of BIRD IN THE SKY LLC for processing the personal data received depends on the context in which it is provided to us. In the ordinary course of our business, we will only process personal data that you or our Client have submitted to us through the website or the BIRD IN THE SKY mobile application (hereinafter referred to as BIRD IN THE SKY, the mobile application, or the app).

We will process the personal data received if you have given consent (pursuant to Article 6 of the General Data Protection Regulation (GDPR)) to your data controller, or if the processing of the information is necessary for the purposes of the legitimate interests pursued by the controller or a third party and does not override your data protection interests or fundamental rights and freedoms (pursuant to Article 6 of the General Data Protection Regulation (GDPR)). We may also process your personal data if we have a legal obligation to collect and process personal data and act as the controller of such data (pursuant to Article 6 of the General Data Protection Regulation (GDPR)), or if the processing is necessary to protect your vital interests or the vital interests of another natural person (pursuant to Article 6 of the General Data Protection Regulation (GDPR)).

In cases where we rely on your consent to process personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of processing carried out by BIRD IN THE SKY LLC on the basis of consent obtained previously.

If you provide BIRD IN THE SKY LLC with your personal data in order to comply with legal requirements (for example, working hours) or to perform a contract (for example, an end-user agreement), we will inform you of this at the appropriate time. BIRD IN THE SKY LLC encourages clients, users, and resellers to take measures to minimize the personal data they ask BIRD IN THE SKY LLC to process.

1. Definitions

BIRD IN THE SKY – an application designed for the collection, processing, verification of authenticity, and distribution of informational materials among registered users.

Within the operation of the application, various types of informational materials are created and used, which make it possible to:

  • track the development of events in real time;
  • record factual data and document information from designated sources;
  • collect and systematize information for further processing and analytical review.

BIRD IN THE SKY provides multi-level control of information processes, in particular:

  • control of news flows and their classification by topic;
  • control of the authenticity and compliance of materials with the established publication requirements;
  • creation of statements (claims) in the event that inaccurate or unlawful information is identified.

Management of publication, editing, and archiving processes is carried out in accordance with internal moderation rules and procedures.

2. Personal data we collect about you:

  • identity data;
  • contact data.

3. How do we collect your data?

User registration and editing of user information in the system. When registering a new user, we enter their last name, first name, contact phone number, and email address.

4. Data collected through the mobile application

The mobile application receives the information you provide when signing in to the app.

When signing in to the mobile application, you typically provide (a) your full name, email address, username, and password; (b) information you provide when contacting us for assistance; (c) information you enter into the system while using the mobile application, such as contact information.

We may also use the information provided to contact you from time to time and to provide you with important information and necessary notifications.

If you contact us through the mobile application, you consent to the use of your information for the purposes for which you contacted us, and to its transfer to certain partners and service providers so that we can properly respond to your request.

5. How and why we use your personal data

Purposes of use:

  • to provide our services;
  • legal grounds (in accordance with the legislation of Ukraine, the GDPR, the CCPA, and the LGPD, where applicable).

6. Disclosure of personal data

In some circumstances, we may receive a request from public authorities to disclose personal data in response to a legally binding request in order to meet national security or law enforcement requirements. Accordingly, we may disclose personal data to comply with subpoenas, court orders, or legal processes, or to protect our legal rights and defend against claims. In some cases, we may also share personal data if we believe that unlawful or fraudulent activity has occurred or may have occurred, so that we can investigate, prevent, and take appropriate action regarding such activity, which may pose a potential threat to the physical safety of any person, constitute a violation of our agreements with clients, or in order to comply with the law. If your personal data becomes subject to legally mandated disclosure and we are permitted to do so, we will attempt to notify you of such disclosure if we have your current contact information.

7. Do third parties see and/or have access to the information obtained by the mobile application?

Only aggregated, anonymized data is periodically transmitted to external services to improve the operation of the mobile application and our services. We will share your information with third parties only in the ways described in this privacy document.

We may disclose user-provided information and automatically collected information:

  • as required by law, for example, to comply with a subpoena or similar legal process;
  • to protect our rights, to protect your safety or the safety of others, to investigate fraud, or to respond to a government request;
  • to our trusted service providers who work on our behalf, do not have independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement;
  • if BIRD IN THE SKY LLC is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified by email and/or a prominent notice on our website of any change in ownership or use of this information, as well as any choices you may have regarding this information.

8. International data transfers

BIRD IN THE SKY LLC stores data about mobile application users and intermediaries on cloud servers located in Europe. From time to time, we may also store data on cloud servers located in other countries. BIRD IN THE SKY LLC operates on a global level, and we may transfer and receive such personal data from different parts of the world, including countries where BIRD IN THE SKY LLC has clients and carries out certain operations. BIRD IN THE SKY LLC stores the data of European clients on servers located within the EEA. However, data (including personal data) may be transferred across national borders for load balancing, availability assurance, or other reasons. We have entered into the EU Standard Contractual Clauses with our cloud provider in order to comply with the strictest privacy laws.

Transfer of personal data outside the EEA (applicable to the EEA)

In cases where BIRD IN THE SKY LLC is the controller of your personal data and you reside in the EEA, please note the following. We may transfer some of your personal data to an international organization or a country where data protection laws may not provide a level of protection equivalent to the laws in your jurisdiction. As required by applicable law, we will ensure an adequate level of protection for your personal data using various means, including:

  • relying on official decisions of the European Commission confirming that a particular country provides an adequate level of personal data protection;
  • entering into appropriate data transfer agreements based on wording approved by the European Commission, such as the Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC);
  • applying appropriate physical, technical, and organizational security measures to protect personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and any other unlawful processing;
  • taking other measures to ensure an adequate level of data protection in accordance with applicable law.

Any onward transfer is subject to the applicable onward transfer requirements under the law.

9. Your rights under the GDPR and how to exercise them

Clients may change or update information associated with their BIRD IN THE SKY accounts by signing in to these services and editing their profiles. You can independently delete the personal data we store by selecting the dedicated option in your user profile. If you have not received the expected results, you may contact our customer support service at support@bird-in-the-sky.com. BIRD IN THE SKY LLC reserves the right to verify requests to confirm their legitimacy and to refer the issue back to your intermediary. Requests received are usually processed within 10 days.

A person wishing to access, change, correct, or delete inaccuracies in personal data stored or processed by BIRD IN THE SKY LLC may direct such requests to the customer support service at support@bird-in-the-sky.com. We store and process personal data on behalf of clients, their intermediaries, and users of the mobile application for as long as is necessary to carry out operational activities in BIRD IN THE SKY. Information (including personal data) will be retained and used as necessary to fulfill our legal obligations, resolve disputes, support our clients and intermediaries, and to perform and enforce our agreements.

We maintain technological and organizational measures to protect your information. We do so during the transfer, use, and storage of information.

10. Data retention policy, managing your information

We will retain user-provided data for the entire period of use of the mobile application and for a reasonable period thereafter. If you would like us to delete the user-provided data you have submitted, please contact us at support@bird-in-the-sky.com, and we will respond within the established time frame. Please note that some or all of the user-provided data may be necessary for the proper functioning of the mobile application.

BIRD IN THE SKY LLC will retain your personal data for as long as necessary to fulfill the purposes for which the data was provided. BIRD IN THE SKY LLC will delete or anonymize your personal data when we no longer have a legitimate business need for it or in accordance with applicable law. If deletion is not possible, for example due to archival storage, we will keep the personal data in secure storage and isolate it from further processing until deletion becomes possible.

With respect to personal data that we process on behalf of intermediaries and client users, we will retain such personal data in accordance with the instructions provided to us, under the terms of our agreement with them and applicable law.

11. Children

We do not knowingly or intentionally collect or process any personal data of children under the age of 16. If you are under 16 years of age, do not submit any personal data through our website or through the mobile application. Parents and legal guardians are encouraged to monitor their children's use of the internet and to help us ensure compliance with this Policy by teaching their children never to provide personal data through our mobile application. If you have reason to believe that personal data of a child under the age of 16 may have been provided to us, please contact us at support@bird-in-the-sky.com and report the issue so that such information can be deleted.

12. Security

We care about keeping your information confidential. We apply physical, electronic, and procedural security measures to protect the information we process and store. For example, we restrict access to this information to authorized employees and contractors who need this information to operate, develop, or improve our mobile application. Please be aware that although we strive to ensure the security of the information we process and store, no security system can prevent all potential security breaches. We therefore recommend that you exercise caution when transmitting any personal data over the internet. When disclosing any information online, it is worth remembering that such information may become publicly accessible and may therefore be collected and used by others without your consent. You should also be aware that the use of the internet and any other means of communication with us is at your own risk.

13. Changes

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and by notifying you via email or text messages on the website or in the mobile application.

14. Contact us

If you have any questions regarding this Privacy Policy or questions about our activities, please contact us at support@bird-in-the-sky.com or using the following contact details: BIRD IN THE SKY LIMITED LIABILITY COMPANY; Address: 24 Vasylkivska St., 03022, Kyiv, Ukraine.

Updated by LLC "BIRD IN THE SKY" on July 6, 2026