Privacy Policy
Last updated: August 9, 2026
1. Who processes your data
The data controller is Sole Proprietor Oleksandr Lomaka, Tax ID 3712001990, state register record No. 265126138813, address: Kyiv, Ukraine, e-mail: tempohelp@proton.me ("we", "Seller").
This Policy is an integral part of the Terms of Service and applies to the website tempo.in.ua and the "Tempo Game" web app.
Processing is carried out in accordance with the Law of Ukraine "On Personal Data Protection" No. 2297-VI.
2. What data we collect
2.1. Data you provide yourself:
| Data | When we collect it | Why |
|---|---|---|
| Name | placing an order | correspondence, order identification |
| Email address | placing an order | sending the Product, confirmation, support |
| Contents of support inquiries | correspondence | responding to your request |
| Data you enter in "Tempo Game" | using the app | service functionality |
2.2. Data collected automatically:
- IP address, browser and device type, operating system;
- date, time, and the fact of ticking consent to the Terms, together with the document version (this is recorded as evidence the agreement was concluded);
- order data: number, amount, payment status, date;
- [analytics and cookie data — see section 7].
2.3. Data we do not receive.
We do not receive, process, or store your payment card details. Payment is processed on the side of the WayForPay payment service. We only receive the result of the transaction.
3. Why and on what legal basis
| Purpose | Legal basis (Art. 11 of Law No. 2297-VI) |
|---|---|
| Performance of the contract: delivering the Product, service access, support | conclusion and performance of a transaction to which the data subject is a party |
| Confirming the contract was concluded, handling claims, defense in disputes | performance of the controller's obligation, legitimate interest |
| Issuing payment documents, tax and accounting records | performance of a statutory obligation |
We do not use your data for automated decision-making or profiling that produces legal effects.
4. Who we share data with
Data is shared only to the extent necessary for the service to function:
| Recipient | What we share | Why |
|---|---|---|
| WayForPay | name, e-mail, amount, order number | processing payment |
| Fiscal receipt operator | e-mail, amount, product name | generating and sending the fiscal receipt |
| Email delivery service | name, e-mail | delivering emails |
| Vercel Inc. | technical data storage | running the site and app (hosting) |
| Government authorities | to the extent required by law | upon written request, in cases provided for by law |
We do not sell your data or share it with third parties for marketing purposes.
Cross-border transfer. The site's hosting infrastructure is located in the United States (Vercel Inc.). Transfers are made to countries that ensure adequate protection of personal data, or under agreements with appropriate safeguards.
5. How long we keep it
| Category | Period |
|---|---|
| Order data and source documents | 1095 days (Art. 44 of the Tax Code of Ukraine) |
| Terms-consent logs | 3 years from the order date (statute-of-limitations period, Art. 257 of the Civil Code of Ukraine) |
| Support correspondence | [2 years] from the date of the last message |
| Data in "Tempo Game" | for the duration of access + [30] days for export |
Once these periods expire, data is deleted or de-identified.
6. Your rights
Under Art. 8 of Law No. 2297-VI, you have the right to:
- know what data we process about you, for what purpose, and to whom we disclose it;
- obtain a copy of your data;
- request correction of inaccurate or incomplete data;
- request deletion of data if it is processed unlawfully or the purpose of processing no longer applies;
- withdraw consent to processing — where consent is the legal basis;
- object to processing;
- file a complaint with the Ukrainian Parliament Commissioner for Human Rights.
How to exercise these rights: write to tempohelp@proton.me from the address you used when ordering. We respond within 10 business days, or up to 30 days in complex cases, with prior notice.
Important limitation. We cannot delete data we are legally required to keep under tax law until the periods in section 5 expire. Deleting data necessary to perform the contract means access to "Tempo Game" will be terminated.
7. Cookies and analytics
7.1. Essential cookies — needed for cart, session, and language-preference functionality. The site does not work without them; they do not require consent.
7.2. Analytics and advertising cookies. The site does not currently set any analytics or advertising cookies and does not use trackers. If we add such tools in the future (for example, visit analytics), they will only be enabled after your explicit consent via an on-site banner, and this Policy will be updated in advance.
8. Security
We apply reasonable technical and organizational measures: encrypted connections (HTTPS/TLS), restricted access to databases, [backups, two-factor authentication for administrative accounts].
No system is completely secure. In the event of a data breach that could create a risk to your rights, we will notify you by e-mail and take steps to remediate it.
9. Children
The Site and the Product are not intended for individuals under 18. We do not knowingly collect data from such individuals. If you become aware of such a case, please contact us and we will delete the data.
10. Changes
We may update this Policy; the current version is always available on this page. We notify you of material changes by e-mail no later than 30 days in advance.
11. Contact
Sole Proprietor Oleksandr Lomaka
E-mail: tempohelp@proton.me
Telegram: @tempo_help
Address: Kyiv, Ukraine
Complaints to the supervisory authority: Ukrainian Parliament Commissioner for Human Rights, ombudsman.gov.ua.