Privacy Policy

1. Who is responsible for your data

Data controller (the one who decides how and why data is processed): VSIM SVOIM.

For any question about your data, write to support@vsimsvoim.com or to support through the bot @vsimsvoim_bot (Profile → Help). We answer in Ukrainian, Russian or English.

2. What data we receive

From Telegram, when you open the bot or the app:

• your numeric Telegram ID, first name, last name and username, exactly as you set them in Telegram;
• the language of your Telegram app and a link to your profile photo, if Telegram provides one;
• the tag of the link you came through (for example a friend's invitation, a partner's link or an ad campaign).

When you sign in to the website with Google: your Google account identifier, your email address (only if Google has verified it) and your name. We do not take your Google photo. We never see your Telegram or Google password: you sign in on those services' own pages.

What you add yourself:

• listings: text, photos, videos, category, city, address, price and the contacts you provide;
• your author profile, reviews, events, requests and posts in the community sections;
• reports about listings and messages to support (the text and, if you attach one, a screenshot);
• settings: country, city, language, theme, subscriptions to new listings and favourites.

What happens as you use the service:

• which listings you opened and which contacts you tapped (a tap means an intention to get in touch, not a message sent);
• your last ten search queries;
• usage events: which action was taken, in which section and country, and whether from the bot or the app;
• whether you allowed the bot to message you and whether its messages are delivered.

Visiting the website without signing in. To count visitors, we turn your IP address and browser details into a one-off encrypted fingerprint. Its key changes every day and is never written down, so the address cannot be recovered from it, and the next day the same visitor is no longer recognisable. We do not store the IP address itself in our database. To protect against excessive requests, the server keeps the IP address in memory for a few minutes. Technical server logs may contain the request address and time.

Members of our Telegram groups. If you join a VSIM SVOIM group, the bot sees and records your ID, name, username, the group's name and when you joined, even if you have never opened the bot.

Location. If you allow the app to determine your location to show nearby listings, it stays on your device and is not sent to our server.

Voice. If voice input is switched on and you use it, the recording is sent for transcription (see section 5). We do not keep the audio.

We do not ask for or collect passport details, bank card numbers, health or religious information or other especially sensitive data. Please do not put them in listings.

3. Why we do this and on what legal basis

The legal bases come from Article 6 of the EU General Data Protection Regulation (GDPR).

• To provide the service: signing in, your account, publishing and showing listings, subscriptions, favourites, the bot's replies. Basis: performance of our contract with you, that is, these Terms of Use (Art. 6(1)(b)).
• To keep the platform safe: checking listings before publication, handling reports, fighting fraud, spam and abuse, limiting request rates. Basis: our legitimate interest and that of other users (Art. 6(1)(f)).
• To understand what works: statistics of visits and actions, and where new users came from (including for settling with partners who bring people in). Basis: legitimate interest (Art. 6(1)(f)). We use as little data as possible for this and build no advertising profiles.
• To send you messages in the bot: about your listings' status, new listings matching your subscriptions, important changes to the service. Basis: the contract, and legitimate interest for optional messages; you can opt out of any of them (see section 10).
• To comply with the law: answering binding requests from authorities and keeping what the law requires us to keep. Basis: legal obligation (Art. 6(1)(c)).

Where the basis is legitimate interest, you may object to the processing; we will weigh your reasons and stop unless we have more compelling grounds.

4. What other people see

• Listings are public: they appear in the app, in the bot, on the website and in the Telegram group of the relevant country, where the bot posts approved listings. Listing pages on the website may appear in search engines.
• Contacts in a listing are shown only to people who have signed in, with Telegram or Google. A website visitor who has not signed in does not see the contacts, exact address or map point, and phone numbers or links written into the text itself are replaced with a mark.
• Posts in Telegram groups show the listing's title, key details and description; the contact from its own field is not included, and a button opening the listing in the app stands in its place. If you wrote a contact into the description itself, group members will see it.
• Your Telegram name is shown as the listing's author. On the website, people who have not signed in see only your first name.
• An author's public page exists only if you have opened it yourself, and it shows only the contacts you marked as public.

5. Artificial intelligence and automated decisions

Some features use language models from OpenAI:

• automatic checking of a listing before publication: the model receives the whole listing, contacts included;
• «Paste a ready post»: the model receives the text you pasted (phone numbers, links and usernames in it are replaced with marks first) and up to three attached photos;
• voice input: a voice recording, to turn it into text;
• checking comments on articles in the «Info» section.

Administrators switch these features on and off, so at any given time some of them may be inactive. The AI never rejects listings or blocks people: it can only approve straight away a listing it is confident about, and everything else is decided by a human moderator. We make no solely automated decisions that have legal or similarly significant effects on you.

Under OpenAI's terms, data sent through its API is not used to train models and is kept by OpenAI for up to 30 days for abuse monitoring.

6. Who we share data with

We do not sell personal data or pass it to advertisers. Data reaches only those without whom the service cannot work:

• Telegram: delivering the bot's messages, storing listing photos and videos, posting in groups;
• OpenAI: the features in section 5;
• Google: signing in with Google, if you choose it;
• OpenStreetMap (the Nominatim service): the address you give in a listing, to place it on the map;
• the company that provides the servers the platform runs on;
• VSIM SVOIM administrators and moderators, to the extent their work requires;
• authorities, only where the law requires it.

The website loads Telegram's service script from telegram.org, without which the app inside Telegram cannot work; Telegram receives the technical details of that request, as from any website. We serve fonts and the site's other files from our own server. There are no third-party counters, advertising pixels or Google Analytics on the website.

7. Transfers outside the EU

OpenAI and Google process data in the United States among other places; Telegram operates in various jurisdictions, including outside the EU. Such transfers rely on European Commission adequacy decisions (in particular the EU–US Data Privacy Framework for certified companies) or on the Commission's standard contractual clauses, which these companies include in their terms.

8. How long we keep data

• account, settings, favourites and subscriptions: while you use the service or until you ask us to delete them;
• listings: until you delete them; listings that are no longer current are taken off display but stay in your «My listings» section, where you can delete them;
• an unfinished «Paste a ready post» draft: up to 7 days, or until it is published or deleted;
• service records of photos uploaded from the app: up to 2 days;
• an unfinished website sign-in: 10 minutes;
• a website session: 30 days from its last use, or until you sign out;
• search history: only the last ten queries;
• views of a listing: until that listing is deleted;
• statistics, reports, reviews and moderation history: while your account exists; once it is deleted we erase them or anonymise them so they no longer point to you;
• technical server logs: for a limited time, after which the system overwrites them.

9. Cookies and browser storage

The website uses only two strictly necessary cookies, without which signing in is impossible:

• __Host-vsim_session keeps you signed in and lasts 30 days from its last use;
• __Host-vsim_login exists for 10 minutes while a Telegram or Google sign-in is in progress.

Both are readable only by our server, travel only over a secure connection and are not accessible to scripts on the page. In addition, your browser's storage keeps your choices: country, language, theme, unfinished form drafts and which tips you have already seen. This data stays on your device.

There are no advertising or analytics cookies, so we do not show a consent banner: the law does not require consent for strictly necessary cookies. If we ever add optional cookies, we will ask for your consent first.

10. Your rights

You have the right to:

• find out what data we hold about you and get a copy of it;
• correct inaccurate data (you can change most of it yourself in your profile and listings);
• have your data erased (see section 11);
• restrict processing or object to it;
• receive the data you gave us in a machine-readable format;
• withdraw consent where processing relies on it;
• lodge a complaint with the data protection authority of the country where you live or work, or where you believe the infringement took place.

To exercise these rights, write to support@vsimsvoim.com or to support through the bot. We reply within one month; if a request is complex, we may extend this by two more months and will tell you so. Before replying we may ask you to confirm the account is yours, for example by writing from the same Telegram account.

To stop the bot messaging you, simply stop or block it in Telegram. You can unsubscribe from new-listing alerts in the alert itself or in the settings.

11. How to delete your account and data

You can delete your listings, reviews, events, search history and profile photo yourself in the app or the bot at any time.

To delete your account entirely, write to support@vsimsvoim.com or to support through the bot from the Telegram account (or the Google address) to be deleted. Within 30 days we will:

• delete your profile, listings, favourites, subscriptions, search history and sign-in links;
• remove your listings from posts in Telegram groups, if you ask us to;
• anonymise statistics so they no longer point to you.

We may keep only what the law obliges us to keep, or what is needed to prevent fraud or handle a dispute (for example a record of a ban for a violation), and only for as long as truly necessary. Messages you yourself sent to other people in Telegram are stored by Telegram and are outside our control.

12. How we protect data

The website and the app work only over a secure connection (HTTPS). We establish who a user is on the server from data signed by Telegram or Google and never trust what the page says about itself. Website sign-in keys are stored only as hashes. Only designated people have access to the admin panel. If a breach threatens your rights, we will notify the data protection authority and, where required, you.

13. Children

The service is not intended for children under 16. If you learn that a child has given us their data, write to us and we will delete it.

14. Changes to this policy

If we change what we process or how, we will update this page and the version date at the top. We will announce significant changes in advance in the bot or on the website.