PRIVACY & COOKIES

Last updated: August 22, 2025

1) Controller identity

Primary controller: Us (site operator), Georgia — azows@tuta.io.

If MoR is activated (e.g., Paddle): the MoR acts as an independent controller for checkout and invoicing (we do not store card data).

2) Data we process

Account/identity: name, email, country, any information you choose to share (e.g., bio, alias, preferences).

Technical/usage: logs, IP, device, pages viewed, events (purchase, access).

Support: messages you send to support.

Payment: order references, amount, currency, status (via MoR/PSP). We do not store card data.

3) Purposes & legal bases

Contract performance: create the account, deliver content, invoice at the time access is granted.

Legitimate interests: security, anti‑fraud/abuse, service improvement, internal statistics.

Legal obligation: accounting, tax, replies to authorities.

Consent: marketing (opt‑in), non‑essential cookies (if ever used).

4) Recipients & transfers

MoR/PSP (payments, taxes, invoicing).

Hosting/Cloud, analytics, email/support tools.

International transfers may occur; safeguards: SCCs (Standard Contractual Clauses) and technical measures.

5) Retention

Account: while the account is active, then immediate deletion upon request via support, subject to legal duties.

Billing / legal obligations: 6 years (minimum common requirement for relevant accounting/tax records in Georgia).

Technical logs: 3 months (strictly necessary for security and diagnostics).

6) Your rights

Access, rectification, erasure, restriction, objection, portability, and withdrawal of consent (where processing is based on consent). Requests: azows@tuta.io. You may lodge a complaint with the competent authority.

7) Security

We use reasonable technical and organisational measures; no system is 100% secure.

8) Minors

The service is not for users under 18. If we learn data relates to a minor, we will delete it and close the account.

9) Cookies

We use essential cookies only (e.g., authentication and security). If we ever add non‑essential cookies (analytics/marketing), we will display a consent banner and provide a preference centre.

10) Changes

Any update will be posted with a new "Last updated" date.