Privacy Policy

Privacy Policy of Principles

Last updated December 31, 2024

This Privacy Notice from Bohdan Bats ("I", "me", "my"), describes how and why I might access, collect, store, use, and/or share ("process") your personal information when you use my services ("Services"), including when you:

  • Download and use my mobile application (Principles: Habits for Goals), or any other application of ours that links to this Privacy Notice
  • Use Principles. A personalized app that aims to help users improve areas of their lives, achieve their mission and goals through habits, motivating reminders, and personalized artificial intelligence.
  • Engage with me in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. I am responsible for making decisions about how your personal information is processed. If you do not agree with my policies and practices, please do not use my Services. If you still have any questions or concerns, please contact me at app@principles.top.

SUMMARY OF KEY POINTS

This summary provides key points from my Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using my table of contents below to find the section you are looking for.

What personal information do I process? When you visit, use, or navigate my Services, I may process personal information depending on how you interact with me and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to me.

Do I process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. I may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information I process.

Do I collect any information from third parties? I do not collect any information from third parties.

How do I process your information? I process your information to provide, improve, and administer my Services, communicate with you, for security and fraud prevention, and to comply with law. I may also process your information for other purposes with your consent. I process your information only when I have a valid legal reason to do so. Learn more about how I process your information.

In what situations and with which parties do I share personal information? I may share information in specific situations and with specific third parties. Learn more about when and with whom I share your personal information.

How do I keep your information safe? I have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so I cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat my security and improperly collect, access, steal, or modify your information. Learn more about how I keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by contacting me: app@principles.top. I will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what I do with any information I collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

  1. What information do I collect?
  2. How do I process your information?
  3. What legal bases do I rely on to process your personal information?
  4. When and with whom do I share your personal information?
  5. Do I offer artificial intelligence-based products?
  6. How do I handle your social logins?
  7. Is your information transferred internationally?
  8. How long do I keep your information?
  9. How do I keep your information safe?
  10. What are your privacy rights?
  11. Controls for do-not-track features
  12. Do United States residents have specific privacy rights?
  13. Do I make updates to this notice?
  14. How can you contact me about this notice?
  15. How can you review, update, or delete the data I collect from you?
  16. Account Deletion

1. WHAT INFORMATION DO I COLLECT?

Personal information you disclose to me

In Short:I collect personal information that you provide to me.

I collect personal information that you voluntarily provide to me when you register on the Services, express an interest in obtaining information about me or my products and Services, when you participate in activities on the Services, or otherwise when you contact me.

Personal Information Provided by You. The personal information that I collect depends on the context of your interactions with me and the Services, the choices you make, and the products and features you use. The personal information I collect may include the following:

  • names
  • email addresses
  • passwords
  • gender
  • habits

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, I process the following categories of sensitive information:
  • goals
  • habits
  • life mission
  • main life slogan
  • gender

Social Media Login Data. I may provide you with the option to register with me using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, I will collect certain profile information about you from the social media provider, as described in the section called "HOW DO I HANDLE YOUR SOCIAL LOGINS?" below.

Application Data. If you use my application(s), I also may collect the following information if you choose to provide me with access or permission:

  • Mobile Device Access. I may request access or permission to certain features from your mobile device, including your mobile device's reminders, social media accounts, vibrator, and other features. If you wish to change my access or permissions, you may do so in your device's settings.
  • Mobile Device Data. I automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier. If you are using my application(s), I may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of my application(s) you accessed.

This information is primarily needed to maintain the security and operation of my application(s), for troubleshooting, and for my internal analytics and reporting purposes.

All personal information that you provide to me must be true, complete, and accurate, and you must notify me of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your device characteristics — is collected automatically when an error occurs on your device when you visit my Services.

I automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your device characteristics, operating system, device name, information about how and when you use my Services, and other technical information. This information is primarily needed to maintain the security and operation of my Services, and for my internal analytics and reporting purposes.

The information I collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information my servers automatically collect when you access or use my Services and which I record in log files. Depending on how you interact with me, this log data may include your device information, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
  • Device Data. I collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your device and application identification numbers, location, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Google API

I use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

2. HOW DO I PROCESS YOUR INFORMATION?

In Short: I process your information to provide, improve, and administer my Services, communicate with you, for security and fraud prevention, and to comply with law. I may also process your information for other purposes with your consent.

I process your personal information for a variety of reasons, depending on how you interact with my Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. I may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. I may process your information to provide you with the requested service.
  • To respond to user inquiries/offer support to users. I may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To save or protect an individual's vital interest. I may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO I RELY ON TO PROCESS YOUR INFORMATION?

In Short: I only process your personal information when I believe it is necessary and I have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill my contractual obligations, to protect your rights, or to fulfill my legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require me to explain the valid legal bases I rely on in order to process your personal information. As such, I may rely on the following legal bases to process your personal information:

  • Consent. I may process your information if you have given me permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
  • Performance of a Contract. I may process your personal information when I believe it is necessary to fulfill my contractual obligations to you, including providing my Services or at your request prior to entering into a contract with you.
  • Legal Obligations. I may process your information where I believe it is necessary for compliance with my legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend my legal rights, or disclose your information as evidence in litigation in which I are involved.
  • Vital Interests. I may process your information where I believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

I may process your information if you have given me specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, I may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If I have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO I SHARE YOUR PERSONAL INFORMATION?

In Short: I may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. I may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for me or on my behalf and require access to such information to do that work. I have contracts in place with my third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless I have instructed them to do it. They will also not share your personal information with any organization apart from me. They also commit to protect the data they hold on my behalf and to retain it for the period I instruct.

The third parties I may share personal information with are as follows:

  • AI Service Providers

    OpenAI and Microsoft Azure AI

  • Cloud Computing Services

    Google Cloud Platform

  • User Account Registration and Authentication

    Google OAuth 2.0 and Sign in with Apple

  • Website Hosting

    Hostinger

  • App Testing

    Google Play Console and TestFlight

  • Server Control Panel

    EasyPanel

I also may need to share your personal information in the following situations:

  • Business Transfers. I may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of my business to another company.

5. DO I OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: I offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of my Services, I offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within my Services.

Use of AI Technologies

I provide the AI Products through third-party service providers ("AI Service Providers"), including OpenAI and Microsoft Azure AI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of my AI Products for purposes outlined in "WHAT LEGAL BASES DO I RELY ON TO PROCESS YOUR PERSONAL INFORMATION?" You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

My AI Products

My AI Products are designed for the following functions:

  • Natural language processing
  • Recommendation of habits

How I Process Your Data Using AI

All personal information processed using my AI Products is handled in line with my Privacy Notice and my agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data's safety.

6. HOW DO I HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to my Services using a social media account, I may have access to certain information about you.

My Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, I will receive certain profile information about you from your social media provider. The profile information I receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

I will use the information I receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that I do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. I recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: I may transfer, store, and process your information in countries other than your own.

My servers are located in France. If you are accessing my Services from outside France, please be aware that your information may be transferred to, stored by, and processed by me in my facilities and in the facilities of the third parties with whom I may share your personal information (see "WHEN AND WITH WHOM DO I SHARE YOUR PERSONAL INFORMATION?" above), in the United States, and other countries.

If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, I will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.

European Commission's Standard Contractual Clauses:

I have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between my group companies and between me and my third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. My Standard Contractual Clauses can be provided upon request. I have implemented similar appropriate safeguards with my third-party service providers and partners and further details can be provided upon request.

8. HOW LONG DO I KEEP YOUR INFORMATION?

In Short: I keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

I will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require me keeping your personal information for longer than the period of time in which users have an account with me.

When I have no ongoing legitimate business need to process your personal information, I will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then I will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO I KEEP YOUR INFORMATION SAFE?

In Short: I aim to protect your personal information through a system of organizational and technical security measures.

I have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information I process. However, despite my safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so I cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat my security and improperly collect, access, steal, or modify your information. Although I will do my best to protect your personal information, transmission of personal information to and from my Services is at your own risk. You should only access the Services within a secure environment.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the me or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting me by using the contact details provided in the section "HOW CAN YOU CONTACT me ABOUT THIS NOTICE?" below.

I will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe I are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If I are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting me by using the contact details provided in the section "HOW CAN YOU CONTACT me ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.
  • To change your password, go to the "Log in" page and tap on “Forgot password?”

Upon your request to terminate your account, I will deactivate or delete your account and information from my active databases. However, I may retain some information in my files to prevent fraud, troubleshoot problems, assist with any investigations, enforce my legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email me at app@principles.top.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, I do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that I must follow in the future, I will inform you about that practice in a revised version of this Privacy Notice.

California law requires me to let you know how I respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, I do not respond to them at this time.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of, you may have the right to request access to and receive details about the personal information I maintain about you and how I have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to my processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information I Collect

I have collected the following categories of personal information in the past twelve (12) months:

Category Examples Collected
A. Identifiers Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name YES
B. Protected classification characteristics under state or federal law Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data YES
C. Commercial information Transaction information, purchase history, financial details, and payment information NO
D. Biometric information Fingerprints and voiceprints NO
E. Internet or other similar network activity Browsing history, search history, online behavior, interest data, and interactions with my and other websites, applications, systems, and advertisements NO
F. Geolocation data Device location NO
G. Audio, electronic, sensory, or similar information Images and audio, video or call recordings created in connection with my business activities NO
H. Professional or employment-related information Business contact details in order to provide you my Services at a business level or job title, work history, and professional qualifications if you apply for a job with me YES
I. Education Information Student records and directory information NO
J. Inferences drawn from collected personal information Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics NO
K. Sensitive personal Information Account login information YES

I only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. I do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

I may also collect other personal information outside of these categories through instances where you interact with me in person, online, or by phone or mail in the context of:

  • Receiving help through my customer support channels;
  • Participation in customer surveys or contests;
  • Facilitation in the delivery of my Services and to respond to your inquiries.

I will use and retain the collected personal information as needed to provide the Services or for:

  • Category A - As long as the user has an account with me
  • Category B - As long as the user has an account with me
  • Category H - As long as the user has an account with me
  • Category K - As long as the user has an account with me

Sources of Personal Information

Learn more about the sources of personal information I collect in "WHAT INFORMATION DO I COLLECT?"

How I Use and Share Personal Information

Learn more about how I use your personal information in the section, "HOW DO I PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

I may disclose your personal information with my service providers pursuant to a written contract between me and each service provider. Learn more about how I disclose personal information to in the section, "WHEN AND WITH WHOM DO I SHARE YOUR PERSONAL INFORMATION?"

I may use your personal information for my own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

I have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

  • Category B. Characteristics of protected classifications under state or federal law
  • Category H. Professional or employment-related information

The categories of third parties to whom I disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO I SHARE YOUR PERSONAL INFORMATION?"

I have sold or shared the following categories of personal information to third parties in the preceding twelve (12) months:

The categories of third parties to whom I sold personal information are:

The categories of third parties to whom I shared personal information with are:

  • AI Service

    OpenAI and Microsoft Azure AI

Your Rights

You have rights under certain me state data protection laws. However, these rights are not absolute, and in certain cases, I may decline your request as permitted by law. These rights include:

  • Right to know whether or not I are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request the deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with me
  • Right to non-discrimination for exercising your rights
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

How to Exercise Your Rights

To exercise these rights, you can contact me by visiting app@principles.top, by emailing me at app@principles.top, or by referring to the contact details at the bottom of this document.

You can opt out from the selling of your personal information, targeted advertising, or profiling by disabling cookies in Cookie Preference Settings.

Under certain me state data protection laws, you can designate an authorized agent to make a request on your behalf. I may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, I will need to verify your identity to determine you are the same person about whom I have the information in my system. I will only use personal information provided in your request to verify your identity or authority to make the request. However, if I cannot verify your identity from the information already maintained by me, I may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, I may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

13. DO I MAKE UPDATES TO THIS NOTICE?

In Short: Yes, I will update this notice as necessary to stay compliant with relevant laws.

I may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If I make material changes to this Privacy Notice, I may notify you either by prominently posting a notice of such changes or by directly sending you a notification. I encourage you to review this Privacy Notice frequently to be informed of how I are protecting your information.

14. HOW CAN YOU CONTACT ME ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact my Data Protection Officer (DPO) by email at batsbohdan@gmail.com.

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA I COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information I collect from you, details about how I have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to my processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please write me: app@principles.top.

16. ACCOUNT DELETION

Users have the right to delete their account at any time. The following methods are available:

  • Via the website – to initiate account deletion, a user should visit the website and navigate to the Settings section. Within this section, a user will find the "Delete Account" option. To proceed, a user is required to enter account credentials and follow the on-screen instructions to confirm the deletion.
  • Via the mobile app – to delete an account through the mobile application, a user must open the Settings section, tap on the "Delete Account" option, and follow the provided instructions to complete the process.