Datenschutzrichtlinie

1. Data controller

The party responsible for processing personal data is:

2. What data we collect

2.1. Registration data

When an account is created, we collect:

• Email — for identification, sign-in and communication

Sign-in is performed via:

• OAuth (Google, Microsoft, LinkedIn) — we receive only the email address and name from the provider’s profile. Passwords are NOT stored
• Email OTP — a one-time code is sent to your email. Passwords are NOT stored

2.2. Dashboard data

The Customer may voluntarily provide:

• Phone number — for contact
• Website URLs — to configure the products

2.3. Invoice data

2.4. Technical data

Collected automatically:

• IP addresses — security and analytics
• Browser and device type — optimization
• Date and time of access — analytics
• Cookies — functionality

2.5. Payment data

Depending on the dashboard interface language, payments are processed by JSC Universal Bank (monobank) for payments in UAH (Ukrainian and Russian) or by the Creem payment platform (creem.io), which acts as the Merchant of Record, for payments in USD (other languages). Card details are entered on the checkout page of the bank or Creem and processed by them. We do NOT receive or store card details. From the payment provider we receive only the data needed to manage the subscription: email, name, country, and the amount and status of payments and the subscription. Creem processes your data under its own privacy policy published at creem.io, and such data may be processed outside Ukraine. For invoice payments, the payment goes directly to the Contractor's bank account.

2.6. Affiliate program data

For affiliate program participants, we additionally collect:

• Referral code
• Number of referred customers
• Details for commission payouts

3. Data of visitors to the Customer’s Website

3.1. Accessibility Panel (Widget)

3.2. Accessibility Audit

When the Customer's Website is scanned:

• Only publicly accessible pages are scanned (in the same way as search engine bots)
• Only audit results (issues, score, recommendations) are stored, NOT page content
• Scan results are available only to the Customer via the dashboard
• Scanning is performed by an automated browser on the Contractor’s servers

3.3. AutoFix

AutoFix is connected with two tags placed before </head> on the Customer's Website: a stylesheet and a script. Website traffic does not pass through the Contractor's servers — fixes are applied in the visitor's browser.

3.4. AI processing (GPT-4o)

To generate image alt text:

• Image URLs and page context are sent to OpenAI (GPT-4o Vision)
• Only publicly accessible images are sent
• OpenAI processes the data in accordance with its own privacy policy
• Generated alt texts are stored in the InclusiveWeb database

4. Purposes of processing personal data

Personal data is used to:

• Create and manage the account
• Provide access to the Service and its features
• Process payments and issue invoices
• Provide technical support
• Send important service notifications (pricing changes, feature updates, maintenance)
• Improve and optimize the Service
• Ensure security and prevent fraud
• Comply with legal requirements

5. Legal bases for processing

• Performance of a contract — provision of services under the terms of the public offer
• Consent — given upon registration and use of the Service
• Legitimate interests — improvement of the Service, security, fraud prevention
• Compliance with a legal obligation — compliance with the requirements of Ukrainian law

6. Data retention

• Data is retained for as long as the Service is actively used
• After the account is deleted or the subscription ends, data is retained for 30 days and then deleted
• Data may be retained longer to comply with legal requirements (accounting records)
• Data is stored on secure servers with restricted access

7. Data sharing with third parties

We do not sell, transfer or disclose personal data, except to:

• JSC Universal Bank (monobank) — payment processing
• Creem (creem.io) — processing of USD payments, taxes and refunds as the Merchant of Record
• Cloudflare, Inc. — CDN for delivering the Panel and AutoFix scripts
• OpenAI — AI generation of alt text (public images and context only)
• OAuth providers (Google, Microsoft, LinkedIn) — authentication (only when OAuth sign-in is chosen)
• Hosting provider — storage of data on servers
• Public authorities — in cases provided for by the laws of Ukraine

All third parties are required to ensure adequate data protection.

8. Cookies

The Service uses:

• Strictly necessary cookies — authentication, basic functionality
• Functional cookies — saving preferences (interface language)
• Analytics cookies — usage analysis to improve the Service

You can configure your browser to block cookies, but this may affect functionality.

9. Data security measures

• Encryption in transit (HTTPS/SSL)
• Hashing (for sensitive data)
• Restricted access to personal data
• Regular backups
• Server security monitoring
• 2FA support (TOTP — Google Authenticator, Authy)

No method of transmitting data over the internet is completely secure. We take all reasonable measures to protect your data.

10. User rights

Under the Law of Ukraine “On Personal Data Protection”, you have the right to:

• Know the sources of collection — and the location of your data
• Receive information — about the conditions of access to the data
• Access — your personal data
• Rectification — of inaccurate or incomplete data
• Erasure — of personal data
• Restriction — of processing
• Objection — to processing
• Withdrawal — of consent
• Complaint — regarding actions related to data protection

To exercise your rights, contact: [email protected] (response time — 30 days).

11. Children

The Service is not intended for persons under 18. We do not knowingly collect children's data. If such data is identified, it will be deleted.

12. Changes to this policy

• This policy may be updated
• We notify of material changes via the website and/or email
• Continued use after the changes constitutes acceptance of the updated terms

13. Contact information

If you have any questions about this Privacy Policy or wish to exercise your rights, contact us: