1. Who is responsible for your data?
The controller of personal data processed through this website is VIACHESLAV SHKURYCHEV, operating as Napoka Systems (referred to below as “Napoka Systems”, “we”, “us” or “our”).
For privacy questions or requests, email napoka.systems@gmail.com.
2. What this policy covers
This policy covers the NapokaSystems studio website. The AffirmateMe mobile app has a separate privacy policy.
3. Data processed when you visit
The website is delivered as static files through Cloudflare Workers. When your browser requests a page, Cloudflare necessarily processes technical request data such as your IP address, the date and time, the requested address, HTTP headers, browser or device information, referrer information and the response status. This is needed to deliver the website, keep it secure, prevent abuse and diagnose technical problems.
We do not use this information to build visitor profiles or for behavioural advertising. We do not maintain a separate visitor database.
The legal basis is our legitimate interest in operating a secure, reliable website under Article 6(1)(f) GDPR.
4. Cookies, browser storage and analytics
This website does not use non-essential cookies, local storage, advertising pixels or behavioural analytics. It therefore does not ask for cookie consent.
Cloudflare may use strictly necessary cookies if a security feature or challenge must distinguish legitimate traffic from malicious traffic. These cookies are used only to provide and protect the service, not for advertising.
Bricolage Grotesque and Instrument Sans are hosted locally on this website. Loading a page does not send a font request to Google.
5. When you contact us
If you email us, we process your email address, message, any information you choose to include, and ordinary email metadata. We use it to respond and manage the correspondence.
The legal basis is our legitimate interest in responding to messages under Article 6(1)(f) GDPR. Where your message concerns steps before entering into a contract, the basis may instead be Article 6(1)(b) GDPR. Providing this data is voluntary, but we cannot reply without it.
6. Service providers and international transfers
Cloudflare, Inc. provides website delivery, network security and related infrastructure services. Cloudflare may process request data through its global network and may engage subprocessors.
Google provides the Gmail service used for correspondence sent to napoka.systems@gmail.com. Google processes the message content and ordinary email metadata on its infrastructure.
Where personal data is transferred outside the European Economic Area, Cloudflare and Google state that they rely, as applicable, on the EU–US Data Privacy Framework and the European Commission’s Standard Contractual Clauses, with supplementary safeguards. See Cloudflare’s Privacy Policy and Data Processing Addendum, and Google’s Privacy Policy and data transfer frameworks.
We may also disclose data if required by law or when reasonably necessary to establish, exercise or defend legal claims.
7. How long data is kept
Technical request data is retained only for as long as reasonably necessary for website delivery, security, troubleshooting and compliance, subject to the Cloudflare service configuration and applicable policies.
Email correspondence is kept for as long as needed to deal with your message and, where necessary, until relevant legal claims can no longer be brought or must be retained under law.
8. Your rights
Depending on the circumstances, the GDPR gives you the right to request access to, correction or deletion of your personal data; restriction of processing; data portability; and to object to processing based on legitimate interests.
You can exercise these rights by emailing napoka.systems@gmail.com. We may need to verify your identity before acting on a request.
You have the right to lodge a complaint with a competent data protection supervisory authority.
9. Automated decisions and external links
We do not use your data for automated decision-making or profiling.
This website links to external services, including Google Play. Following an external link takes you to a service governed by that provider’s own privacy information.
10. Changes to this policy
We may update this policy if the website, our service providers or applicable requirements change. The current version and its update date will remain available on this page.