Apex Digital

Privacy Policy

How we collect, use, and protect your data

Effective date: April 6, 2026

This Privacy Policy describes the procedures for collecting, processing, storing, and protecting personal data of users of services provided by the ПП "ТЕХСПРИЯННЯ" (tax ID: 30949979), hereinafter "Provider" or "We", operating under the trade name Apex Digital.

By using our Services, making a payment, or providing your personal data, you confirm that you have read this Policy and consent to the processing of your personal data in accordance with the terms set forth below.

1. General Provisions

1.1. This Privacy Policy is an integral part of the Public Offer Agreement and governs the relationship between the Provider and the User regarding the processing of personal data.

1.2. Apex Digital provides IT outsourcing, growth marketing, design, and consultancy services. Our services are not medical, legal, or financial advisory services.

1.3. Personal data processing is carried out in accordance with the Law of Ukraine "On Personal Data Protection", the EU General Data Protection Regulation (GDPR), and other applicable legal acts.

2. What Personal Data We Collect

2.1. Data provided directly by you:

Email address — for sending order confirmations, receipts, deliverables, and communication with support
Full name — if provided during payment (optional)
Phone number — if provided during payment or contact form (optional)
Company name — if provided during order placement (optional)

2.2. Payment data:

Bank card data — card number (masked), expiration date, issuing country
Transaction history — date, time, payment amount, transaction status
IP address — for fraud protection and payment system requirements

Important: Full bank card data (number, CVV, PIN) is stored exclusively by the WayForPay payment system in encrypted form in accordance with PCI DSS security standards. The Provider does not have access to your full card data.

2.3. Technical data:

IP address — for security and fraud prevention
Device type and browser — for website optimization
Service interaction data — pages visited, forms submitted

3. How We Use Personal Data

3.1. Contract execution:

Processing payments and confirming orders
Processing regular automatic charges for active subscriptions (recurring payments)
Storing bank card data for automatic subscription renewal
Delivering services and work results
Sending notifications about subscriptions and upcoming charges
Processing support inquiries

3.2. Legal obligations:

Providing electronic receipts per tax legislation
Storing transaction data per legal requirements
Fraud and financial crime prevention

3.3. Legitimate interests:

Analyzing service usage to improve quality
Preventing terms of use violations
Protection against abuse and chargebacks
Using data for legal protection in cases of disputes, claims, or chargebacks
Providing evidence of proper service delivery to banks and payment systems
Improving user experience

Important: In the event you initiate a chargeback, we have the right to use your personal data (transaction history, service usage data, support correspondence) to protect our legitimate interests and provide evidence to the bank.

3.4. Based on separate consent:

Sending informational newsletters
Marketing communications about promotions and special offers
Using Facebook Pixel for displaying relevant advertising

You may withdraw consent for marketing communications at any time by clicking the "Unsubscribe" link in any email or contacting our support.

4. Legal Basis for Data Processing

Contract execution — to provide you access to Services and process payments
Consent — you provide consent to data processing by making payment
Legitimate interests — for fraud protection, service improvement
Legal obligations — per tax and financial legislation

5. Who We Share Your Data With

Important (GDPR): Payment systems and third-party services act as separate personal data controllers and bear independent responsibility for data processing according to their own privacy policies. We do not control data processing by these services after transfer.

WayForPay (separate controller): for payment processing, card data storage, and recurring charges
Google Analytics: for website traffic analysis and user behavior insights
Facebook Pixel: for conversion tracking and relevant advertising display (with consent)

We do not sell, rent, or exchange your personal data with third parties for their marketing purposes without your explicit consent.

6. How We Store and Protect Your Data

6.1. Storage periods:

Transaction data — 5 years (per tax legislation of Ukraine)
Service access data — during the subscription period and 30 days after expiration
Support data — 3 years
Marketing consent — until consent is withdrawn

6.2. Security measures:

Data encryption during transmission (SSL/TLS)
Restricted access to personal data
Regular data backups
Use of certified payment systems (PCI DSS)
Unauthorized access monitoring

7. International Data Transfer

7.1. Your personal data may be transferred and stored outside of Ukraine: WayForPay (Ukraine), Google Analytics, Facebook (USA and other countries).

7.2. When transferring data outside Ukraine, we ensure compliance with GDPR requirements and apply appropriate data protection safeguards.

8. Cookies and Tracking Technologies

8.1. We use cookies and similar technologies for: technical cookies — website functionality; analytical cookies — traffic analysis; marketing cookies (Facebook Pixel) — with consent.

8.2. You can configure or disable cookies in your browser settings. Disabling certain cookies may affect website functionality.

9. Your Rights

Right of access — obtain confirmation of data processing and access to your data
Right to rectification — request correction of inaccurate or incomplete data
Right to erasure ("right to be forgotten") — in cases provided by law. Limitation: transaction data is stored for 5 years per tax legislation
Right to restriction of processing — in certain cases
Right to data portability — receive your data in a structured format
Right to object — against data processing for marketing purposes
Right to withdraw consent — at any time

To exercise your rights, send a request to info@apexdigital.icu. We will review your request within 30 calendar days.

10. Children

10.1. Apex Digital services are intended for individuals aged 18 and over.

10.2. We do not knowingly collect personal data from individuals under 18. If you learn that a person under 18 has provided us with personal data, please notify us at info@apexdigital.icu.

11. Changes to the Privacy Policy

11.1. We reserve the right to amend this Policy at any time.

11.2. The new version takes effect from the moment it is published on the website.

11.3. In case of significant changes, we will notify you via email.

11.4. We recommend periodically reviewing this Policy.

12. Complaints and Appeals

12.1. If you believe that the processing of your personal data violates the law, you have the right to file a complaint with the Ukrainian Parliament Commissioner for Human Rights.

12.2. Contact: ombudsman.gov.ua

Contact Information

Personal data controller: ПП "ТЕХСПРИЯННЯ", ЄДРПОУ: 30949979

For questions regarding personal data processing, please contact:

Email: info@apexdigital.icu
Email (business): info@apexdigital.icu

Last updated: April 6, 2026. Document version: 1.0

This Privacy Policy is an integral part of the Public Offer Agreement and has equal legal force.