Privacy Policy

Privacy Policy

(Website and SOM Mobile App)

Last updated: 02.05.2026

1. General Provisions

1.1. This Privacy Policy governs the collection, processing, and protection of personal data of users (hereinafter — “Users”) who use the SOM website and the mobile application of the same name (hereinafter collectively — “Services”). The Services are owned and operated by Kivaro Tech.

1.2. By using the Website or the App, you agree to the terms of this Policy. If you do not agree, please stop using the Services.

1.3. We comply with the requirements of the current legislation of Ukraine, in particular the Law “On Personal Data Protection”, as well as the global privacy standards of the App Store (Apple Inc.).

2. What Data We Collect

We collect data from various sources depending on how you use our Services:

2.1. Personal data you provide:

• Name, email address, password (upon registration);

• Phone number (if necessary on the Website);

• Authorization data through third-party services (Google Sign-In, Sign in with Apple).

2.2. Automatically collected data (Website and App):

• IP address, browser type, and operating system (iOS/Web);

• Time and date of visit, Services usage data (crash analytics);

• Unique device identifiers;

• Cookies (more details in section 8).

2.3. Public data from social networks (Service specifics):

• To ensure the operation of the parsing and randomizer functions, the Services temporarily process public data from connected social networks (Instagram, TikTok, Facebook), in particular: commentators’ nicknames and text of comments.

• These data are used exclusively to verify the conditions of the giveaways and determine the winners, are not transferred to third parties, and are not stored with us after the results are generated (except for the winner’s data to save your history).

2.4. Third-party data:

• We may receive your data from partners exclusively within the framework of current legislation.

3. Purpose of Data Processing

We process your data for the following purposes:

3.1. Provision of services, in particular the operation of the randomizer service on the Website and in the App.

3.2. Managing your account and subscriptions (via web payment or Apple StoreKit).

3.3. Improving the functionality of the Services and user experience.

3.4. Sending news, promotions, and important updates (with your consent).

3.5. Protection against fraud and ensuring security.

4. Data Transfer to Third Parties

4.1. We do not sell your personal data to third parties and do not transfer it without your consent, except in cases provided by law.

4.2. To ensure the operation of the Services, we may engage technical partners (hosting providers, Supabase for databases, Apple StoreKit for processing in-app purchases in the App). Confidentiality protection agreements are concluded with them. We do not have access to your full payment details.

5. Data Storage and Deletion (Account Deletion)

5.1. We store your data only as long as necessary to fulfill the purposes specified in this Policy, or as long as your account exists.

5.2. Account deletion:

You have the right to permanently delete your account and all associated personal data at any time. In the mobile application, this can be done in the section «Profile → Security → Delete account». You can also send a deletion request to our email. After initiating the deletion, the data is erased from our servers.

6. Your Rights

In accordance with personal data protection legislation, you have the right to:

6.1. Get access to your data.

6.2. Demand the correction or deletion of data.

6.3. Restrict the processing of your data.

6.4. Withdraw your consent to data processing.

7. Data Security

7.1. We use modern encryption technologies (in particular, Keychain in iOS for access tokens) and information protection to ensure the security of your data.

7.2. Despite all efforts, no system can be absolutely secure, so we recommend using strong passwords and protecting your devices from unauthorized access.

8. Cookies

8.1. The it-som.net website uses cookies and similar technologies. Necessary cookies load immediately. Analytics and marketing cookies load only after your consent via the site banner or the “Cookie settings” link in the footer.

8.2. Cookie categories:

• Necessary — site operation and storing your cookie preferences.
• Analytics — visit statistics (Google Analytics, Google Tag Manager).
• Marketing — advertising and campaign measurement (Meta Pixel, Google Ads via GTM).
• Functional — extra features such as chat or support widgets.

8.3. Cookies the Website may set:

Name	Category	Purpose	Retention	Provider
som_consent	Necessary	Stores your cookie choices	12 months	IT-SOM (it-som.net)
_ga	Analytics	Google Analytics — distinguishes users	up to 2 years	Google LLC
_ga_*	Analytics	Google Analytics 4 — session state	up to 2 years	Google LLC
_gid	Analytics	Google Analytics — distinguishes users	24 hours	Google LLC
_gat, _gat_*	Analytics	Google Analytics — throttles request rate	1 minute	Google LLC
_fbp	Marketing	Meta Pixel — browser ID for ads	3 months	Meta Platforms
_fbc	Marketing	Meta Pixel — Facebook click source	3 months	Meta Platforms
IDE, test_cookie	Marketing	Google Ads / DoubleClick via GTM	up to 13 months	Google LLC

8.4. Analytics and marketing cookies are not set if you choose “Necessary only” or disable the relevant category in settings.

8.5. You can change your choice anytime via “Cookie settings” in the footer or in your browser. Disabling necessary cookies may limit site functionality.

8.6. Learn more: Google Privacy Policy, Meta Privacy Policy.

9. Contact Information

If you have any questions, or if you wish to exercise your rights or submit a request regarding your data, please contact Kivaro Tech: Email: info@it-som.net