Preamble
- p1.This Privacy Policy (hereinafter — the "Policy") defines the procedures for collecting, processing, storing, using, and protecting the personal data of Users of the RelaxIOhub Platform (hereinafter — the "Platform", "Website") at https://ua.relaxiohub.com.
- p2.The Platform Operator (hereinafter — the "Operator", "Data Controller") is the rightsholder of the RelaxIOhub software complex. Authorship and date of creation are confirmed by registration in the international Safe Creative registry under №2606086007957. The registration is certified with a Qualified Electronic Signature (QTSP) in accordance with Regulation (EU) No 910/2014 of the European Parliament and of the Council (eIDAS); the hash of the work is recorded on the Ethereum blockchain.
- p3.This Policy is developed in accordance with the Law of Ukraine "On Personal Data Protection" No. 2297-VI dated 01.06.2010, the Law of Ukraine "On Electronic Commerce" No. 675-VIII dated 03.09.2015, the Civil Code of Ukraine (in particular Article 301), and other applicable legislation of Ukraine.
- p4.This Policy is an integral part of the Public Offer pursuant to clause 2.4 of the Offer and becomes effective from the moment of its publication on the Website at https://ua.relaxiohub.com/privacy.
- p5.Current version: v1.0. Effective date: June 6, 2026.
Section 1. Terms and Definitions
- 1.1.Personal data — information or a set of information about a natural person who is identified or can be specifically identified (Article 2 of the Law of Ukraine "On Personal Data Protection").
- 1.2.Processing of personal data — any action or set of actions regarding personal data, including: collection, registration, accumulation, storage, adaptation, modification, renewal, use, distribution, anonymization, destruction (Article 2 of the Law of Ukraine "On Personal Data Protection").
- 1.3.Operator (Data Controller) — the rightsholder of the RelaxIOhub Platform, identified through Safe Creative registration №2606086007957, who determines the purpose and content of personal data processing.
- 1.4.Processor (Data Processor) — a third party that processes personal data on behalf of and under the instruction of the Operator (hosting provider, email provider, payment systems, analytics services).
- 1.5.Data subject — a natural person (User) whose personal data is processed by the Operator.
- 1.6.Consent of the data subject — the voluntary expression of will of a natural person regarding the processing of their personal data in accordance with the stated purpose of such processing (Article 2 of the Law of Ukraine "On Personal Data Protection").
- 1.7.Cookies — small text files stored on the User's device for session identification, analytics, and interface settings.
- 1.8.The terms "Master", "Customer", "User", "Platform", "Portfolio Site", "Account", and others used in this Policy have the meanings defined in the Public Offer, unless the context requires otherwise.
Section 2. Operator and Data Processors
- 2.1.The Data Controller is the Operator of the RelaxIOhub Platform — the rightsholder of the software complex, identified through Safe Creative №2606086007957 (eIDAS QTSP, Ethereum blockchain).
- 2.2.Contact for inquiries regarding personal data processing: [email protected].
- 2.3.The Operator engages the following data processors: hosting provider (database and infrastructure storage); email provider (message delivery, password recovery); payment systems (transaction processing — where applicable); analytics services, including Google Analytics (analysis of User behavior to improve UX).
- 2.4.The Operator enters into agreements with processors that obligate them to ensure confidentiality and protection of personal data in accordance with requirements of the Law of Ukraine "On Personal Data Protection" and this Policy.
Section 3. Data Collected
- 3.1.Mandatory data upon Master registration: surname, first name, patronymic (if applicable); date of birth; email address; phone number; city or region of service provision; verification documents (passport, ID card — stored for no more than 24 hours after verification completion, then deleted).
- 3.2.Optional data provided by the Master at their discretion: profile photo, massage room photos, certificate photos; description of services, qualifications, experience; work schedule; indicative prices.
- 3.3.Customer data upon registration: email address (mandatory); phone number (optional); name or pseudonym (for publishing Reviews).
- 3.4.Automatically collected technical data: IP address; User-Agent; browser type and version; device type (mobile/desktop); operating system; geolocation data (only with explicit User consent in device settings); session identifiers and Cookies.
- 3.5.Communication data: correspondence through the Platform's internal chat between Master and Customer; inquiries to technical support; reviews, ratings, comments.
- 3.6.Public data posted by the User: information on the Master's Portfolio Site; Customer Reviews and ratings (public after moderation). The User acknowledges that such data becomes accessible to an unlimited number of persons.
Section 4. Legal Basis for Processing
- 4.1.Personal data is processed in accordance with Article 6 of the Law of Ukraine "On Personal Data Protection" on the following legal bases: consent of the data subject (paragraph 1 part 1 Article 6) — registration, Portfolio Site creation, newsletter subscription; performance of a contract (paragraph 3 part 1 Article 6) — provision of Services under the Public Offer; legitimate interests of the Operator (paragraph 5 part 1 Article 6) — fraud prevention, Platform security, UX analytics; compliance with legal obligations (paragraph 2 part 1 Article 6) — provision of data upon requests from competent authorities.
- 4.2.The Operator does not process personal data concerning racial or ethnic origin, political opinions, religious or other beliefs, membership in public organizations, biometric or genetic data, or data characterizing physiological features that can be used to identify a person — without special permission under Article 7 of the Law of Ukraine "On Personal Data Protection".
Section 5. Purposes of Data Processing
- 5.1.Provision of Platform Services: creation and management of Accounts; placement and display of Master Portfolio Sites; Master search by Customers; messaging between Users.
- 5.2.Security: User identification and authorization; fraud, spam, and abuse prevention; content moderation (Reviews, Portfolio Sites, Images).
- 5.3.Platform quality improvement: analysis of User behavior through Google Analytics; testing of new features; audience needs research.
- 5.4.Marketing and communications: informational message delivery (only with User consent); profile update reminders (for Masters).
- 5.5.Compliance with legal obligations: provision of data to supervisory authorities upon substantiated requests; ensuring compliance with Ukrainian legislation.
Section 7. Data Transfer to Third Parties
- 7.1.The Operator transfers personal data to processors solely to fulfill its obligations: hosting provider — database storage; email provider — message delivery; payment systems — transaction processing (where applicable); Google Analytics — traffic analytics. All processors are obligated to ensure data confidentiality under agreements with the Operator.
- 7.2.Public disclosure of data: the following information becomes public after posting by the Master on the Portfolio Site: name or pseudonym; city of service provision; service description, prices, schedule; profile, room, and certificate photos; Customer Reviews and ratings.
- 7.3.The Operator is obligated to provide personal data upon written requests from competent state authorities (law enforcement, tax, judicial) in accordance with Article 21 of the Law of Ukraine "On Personal Data Protection" and other applicable Ukrainian legislation.
- 7.4.The Operator does not disclose personal data to third parties without the data subject's consent, except as required by Ukrainian legislation or this Policy.
- 7.5.Personal data is currently not transferred outside Ukraine. If international transfer becomes necessary in the future, the Operator will ensure compliance with Article 29 of the Law of Ukraine "On Personal Data Protection" (adequate protection level in the recipient country or data subject consent).
Section 8. Data Retention Periods
- 8.1.User Account and Master Portfolio Site — until Account deletion by the User (legal basis: contract performance).
- 8.2.Verification documents (passport, ID card) — no more than 24 hours after verification completion, then deleted (data minimization principle, Article 7 of the Law of Ukraine "On Personal Data Protection").
- 8.3.Chat messages between Users — 3 years from the date of the last message (dispute resolution).
- 8.4.Reviews and ratings — indefinitely as public data of the reputation system; upon Account deletion may be anonymized.
- 8.5.Access logs (IP address, User-Agent) — 90 days (Platform security).
- 8.6.Analytics Cookies — up to 2 years (Platform UX analytics).
- 8.7.Technical support inquiries — 5 years (legal obligations, archive).
- 8.8.Upon expiration of retention periods, personal data is deleted or anonymized unless further retention is required by Ukrainian legislation.
Section 9. Data Subject Rights
- 9.1.Right of access (Article 8 paragraph 1 of the Law of Ukraine "On Personal Data Protection"): the User has the right to obtain confirmation of whether their personal data is being processed and to receive a copy of such data. Implementation: request to [email protected] with identity verification.
- 9.2.Right to rectification (Article 8 paragraph 2 of the Law of Ukraine "On Personal Data Protection"): the User has the right to request correction of inaccurate or completion of incomplete personal data. Implementation: through Personal Account or request to [email protected].
- 9.3.Right to erasure (Article 8 paragraph 3 of the Law of Ukraine "On Personal Data Protection"): the User has the right to request deletion of their personal data in the absence of legal grounds for further processing. Implementation: Account deletion through Personal Account or request to [email protected]. Exception: public Reviews may remain anonymized to preserve reputation system integrity.
- 9.4.Right to restriction of processing (Article 8 paragraph 4 of the Law of Ukraine "On Personal Data Protection"): the User has the right to request temporary suspension of processing of their personal data. Implementation: request to [email protected].
- 9.5.Right to data portability: the User has the right to receive their personal data in a structured, machine-readable format (JSON or CSV). Implementation: request to [email protected]; response provided within 30 days.
- 9.6.Right to object (Article 8 paragraph 6 of the Law of Ukraine "On Personal Data Protection"): the User has the right to object to processing of personal data based on the Operator's legitimate interests, including marketing communications. Implementation: unsubscribe via email link or through Personal Account.
- 9.7.Right to withdraw consent: the User has the right to withdraw previously given consent to personal data processing. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Implementation: request to [email protected].
- 9.8.Right to lodge a complaint: the User has the right to contact the Ukrainian Parliament Commissioner for Human Rights (supervisory authority under the Law of Ukraine "On Personal Data Protection") — ombudsman.gov.ua, or to a court. Secretariat: 01008, Kyiv, Instytutska Street, 21/8.
- 9.9.The Operator's response time to data subject requests is 30 days from receipt of the request (Article 8 of the Law of Ukraine "On Personal Data Protection").
Section 10. Personal Data Security
- 10.1.Technical security measures: data transmission encryption (HTTPS/TLS); password hashing (bcrypt or Argon2) without reverse recovery capability; database access control based on the principle of least privilege; protection against unauthorized access (firewall, DDoS protection); regular software updates; daily encrypted database backups.
- 10.2.Organizational security measures: confidentiality agreements with persons having access to personal data; regular access log audits; password complexity requirements; two-factor authentication (2FA) for administrative access.
- 10.3.In case of a personal data security breach (data breach), the Operator undertakes to: notify the Ukrainian Parliament Commissioner for Human Rights within 72 hours (Article 22 of the Law of Ukraine "On Personal Data Protection"); notify affected Users within 30 days if the breach poses a risk to their rights and freedoms.
- 10.4.The User is responsible for maintaining the confidentiality of their Login and Password. The Operator is not liable for damages caused by unauthorized Account access resulting from the User's negligent handling of their account credentials.
Section 11. Minors' Data
- 11.1.The Platform is not intended for persons under 18 years of age. Master registration is available only to persons who have reached 18 years of age (clause 6.3 of the Public Offer).
- 11.2.If the Operator determines that personal data of a minor was collected without parental or legal guardian consent, such data is immediately deleted.
Section 12. Changes to the Privacy Policy
- 12.1.The Operator reserves the right to amend this Policy unilaterally.
- 12.2.A new version of the Policy is published on the Website at https://ua.relaxiohub.com/privacy. Material changes affecting User rights are communicated to Users via email to the address provided during registration no later than 14 days before such changes take effect.
- 12.3.Changes take effect from the moment of publication on the Website, unless otherwise specified by the Operator.
- 12.4.If the User disagrees with the changes, they have the right to discontinue use of the Platform by deleting their Account.
Section 13. Contacts
- 13.1.For inquiries regarding personal data processing, exercise of data subject rights, and consent withdrawal: [email protected]. Email subject: "Personal data: [nature of request]".
- 13.2.Supervisory authority (complaints regarding personal data processing): Ukrainian Parliament Commissioner for Human Rights. Website: ombudsman.gov.ua. Address: 01008, Kyiv, Instytutska Street, 21/8.
Section 14. Final Provisions
- 14.1.This Policy is an integral part of the Public Offer pursuant to clauses 2.4 and 10.1 of the Offer.
- 14.2.Terms used in this Policy have the same meanings as in the Public Offer, unless the context requires otherwise.
- 14.3.The Policy is available in Ukrainian and English. In case of discrepancies between versions, the Ukrainian version takes precedence.
- 14.4.This Policy and the relationship between the Operator and Users regarding personal data processing are governed by the laws of Ukraine. Matters not regulated by the Policy shall be resolved in accordance with applicable Ukrainian legislation.