Version of [date].
1. Who is responsible for your data
[Full legal name in Latin letters], an individual entrepreneur (sole proprietor) registered in Ukraine. Address: [address]. We decide why and how the data in section 3 is processed (we are the data controller).
Questions about data: [email protected].
2. The main point
The software does not send us your form answers or the files you add to it. They stay only in the browser on your device. The PDF is also built on your device. Your SSN (Social Security number), A-number (your immigration file number, starts with A), answers and photos in the software do not reach us.
Only what is listed in section 3 reaches us. For example, if you send us a letter from USCIS (the U.S. immigration agency) yourself (for the guarantee) or write to support, we see what is in that message.
If you clear your browser data or change devices, the draft is lost. Save the draft file with the "Export" button.
3. What data we receive
Legal basis — why the law lets us use this data. "Performing the agreement" — without it we cannot sell you the software or give you access. "Legitimate interest" — protecting the site from attacks and abuse. "Your consent" — you asked us to.
Paddle is the service you use to pay for the software (more in section 4). We explain the word "fingerprint" under the table.
| What | When | Why | Legal basis |
|---|---|---|---|
| E-mail, which form interests you, state, "ready to pay a deposit" checkbox, e-mail language (Russian or Ukrainian) | You join the waitlist | Tell you about the launch | Your consent |
| E-mail, the document expiry date, e-mail language (Russian or Ukrainian). We do not store the document type, number or your state | Only if you ask for a reminder | Send the reminder on time in your language | Your consent |
| ZIP code and country from the billing address you enter in the Paddle window | You pay for an order. Our server itself requests the billing address of the order from Paddle | Find your state and check whether the software is sold there. State laws require this. In Pennsylvania we use the ZIP code to check that the address is not in the city of Philadelphia itself (suburbs are allowed). From the address we use only the ZIP code and country, and we store nothing from the address. We store only the state we found | Performing the agreement; legal requirements |
| The chosen form, language and a partner code (if you came through a partner link) | You open the payment window. The site passes them to Paddle with the order, and Paddle sends them to us. Your questionnaire answers, including the state and ZIP code in them, are not passed to Paddle | Place the right order; write to you in your language; pay the partner a commission for the order | Performing the agreement; legitimate interest: partner sales records |
| On our server for the partner program: the partner code and the internal order code (no e-mail or other buyer data). Commission amounts. Amounts we took back from the partner or paid back to them after refunds and payment disputes | You pay for an order that came through a partner link | Calculate and pay the partner's commission | Legitimate interest: partner sales records; tax requirements |
| If you are our partner: partner code, the name we show in our records, a fingerprint of your e-mail (only so that we pay no commission on your own purchases; we do not store the address itself), participation status, commissions earned. We do not store payout details on the site server | You become a partner | Count sales through your link and pay you | Performing the partner agreement; tax requirements |
| If you are our partner — outside the site server: your application (name, e-mail, links to your blog or channel, information about your audience), our correspondence, invoices, bank details for payouts. If we ask — a tax form (for example, W-9 or W-8BEN) or a tax residence certificate (a document saying which country you pay taxes in) | You apply, write to us, receive payouts | Review your application; contact you; pay your commission; follow tax rules | Performing the partner agreement; tax requirements |
| From Paddle: payment number, which form you bought, amount, payment and refund status, your e-mail. Paddle may also send other buyer data (for example, name and country) — we do not store it | You pay for an order | Unlock paid steps; refunds; support; income records | Performing the agreement; tax requirements |
| On our server: payment number, which form you bought, order status (paid or refunded), state, e-mail language, your e-mail and its fingerprint, an internal order code. A note about a refund or a bank dispute of the payment (chargeback) and how the dispute ended (open or decided in our favor). A note "the software is not sold in this state, refund needed". Dates of the order, of its changes and of the order e-mail | You pay for an order | Unlock paid steps and confirm the purchase; restore access by e-mail; close access after a refund; refund you if the software is not sold in your state | Performing the agreement; legal requirements |
| The e-mail you enter on the "Restore access" page. We do not store the address itself: we compare its fingerprint with orders | You ask to restore access | Find your order and send you a sign-in link | Performing the agreement |
| E-mail fingerprint, type of e-mail and time sent | We send an e-mail in reply to a site form or about an order | Send no more than 1 e-mail per hour and 3 per day to one address. Stop our site from being used to send e-mails to other people's addresses | Legitimate interest: protection from abuse |
| IP address fingerprint and a request counter. We do not store the IP address itself | You submit a form on the site or open paid access | Limit the number of requests from one address | Legitimate interest: site security |
| The USCIS letter and, if we ask, a form page — with whatever you did not black out | You ask for a guarantee refund | Check whether there was a software error | Performing the agreement (guarantee) |
| Your messages and attachments | You write to support | Reply to you | Performing the agreement; your request |
| Technical data: IP address, browser type, time of visit | Every visit (server logs, which are automatic records of visits, at our hosting provider Cloudflare) | Protect against attacks and find and fix errors | Legitimate interest: site security |
What a fingerprint is. A fingerprint (hash) is a short code we make from an e-mail or IP address with our secret key. The address cannot be read from the fingerprint. Only someone who has the key can check whether it matches a given address. The internal order code is the same kind of fingerprint of the payment number. We write it in server logs instead of the number itself.
For the guarantee: send only what is needed. Black out the A-number, receipt number, SSN, date of birth and address. We only need the letter date, the form name and the reason for rejection or return.
What we do not receive: form answers, files and photos you add to the software, addresses and ZIP codes from your form answers, card details. You enter your card in the Paddle window, and Paddle processes it. We receive the ZIP code from the billing address in the Paddle window only to check your state and do not store it.
We do not use analytics now. If we add it, we will update this page.
4. Who we share data with
- Paddle.com. Orders are placed through Paddle.com, an online reseller that sells our software in its own name. Paddle.com is the Merchant of Record (the official seller) for all our orders: it takes the payment, not us. Paddle receives payment data, including card details, and processes it under its own policy: https://www.paddle.com/legal/privacy. Before payment the site passes Paddle the chosen form, language and a partner code (if any) — Paddle keeps them with the order. You enter your billing address directly in the Paddle window. Paddle passes us the order data listed in section 3.
- Hosting: Cloudflare, Inc. (US; Pages, Workers and D1 are the site itself, its server code and its database) — stores the site, the waitlist, reminder and order database, internal counters with fingerprints, and server logs. It also forwards e-mails sent to [email protected] to our mailbox.
- Bot protection (against automated programs): Cloudflare Turnstile — checks that a person submits the form. It sees your IP address and browser data. For this check our server also passes your IP address to Turnstile.
- Sending e-mail: Resend, Inc. (US) — sends confirmation e-mails, reminders, the launch e-mail, order e-mails and access-restore links. After sending, it keeps a copy of the e-mail for up to 30 days.
- Mailbox at Google (Gmail) — Cloudflare forwards e-mails sent to [email protected] to this mailbox. Support and guarantee e-mails, partner applications and partner correspondence are kept there.
- Our sole proprietor's bank — receives a partner's bank details to make the transfer. Partner invoices, bank details and tax forms are kept in the sole proprietor's accounting records, not on the site server.
- Authorities — only when the law requires it.
We do not sell your data and do not share it for advertising.
These services may have servers in the US, the EU or other countries.
5. How long we keep data
- Waitlist: if you did not confirm by the link in our e-mail — 7 days. A confirmed e-mail — until launch and 12 months after, or until you unsubscribe.
- Reminder: if you did not confirm it by the link in our e-mail — 7 days. A confirmed one — until we send the reminder (we delete it right after sending), or until you unsubscribe. If the e-mail cannot be delivered, we delete it 7 days after the last attempt.
- E-mail and its fingerprint in an order — 730 days (2 years) after payment, then deleted automatically. After that, access cannot be restored by e-mail.
- The rest of the order record (payment number, form, state, status, refund notes, dates) — as long as Ukrainian tax rules require a sole proprietor to keep it: [period from the accountant].
- Data kept by Paddle — under Paddle's policy.
- Partner code in your browser — 30 days.
- Partner commission records and partner data on the site server — [period: owner decision / accountant].
- Partner applications and correspondence, invoices, bank details and tax forms (in our mailbox and accounting records) — [period from the accountant].
- E-mail fingerprints used to limit e-mails — 2 days.
- IP address fingerprints and request counters — up to 2 days.
- Guarantee letters and attachments — 12 months after our reply, then deleted. The record of the refund itself is kept like the order record.
- Server logs at Cloudflare (may contain IP addresses) — up to 3 days.
- Copies of sent e-mails at Resend — up to 30 days.
- Support messages — 12 months.
6. Your rights
You can:
- find out what data we hold about you;
- correct it;
- delete it (except data we must keep by law);
- unsubscribe from the waitlist and reminders — every such e-mail has a link. Order e-mails (access, access restore, refund notice) are sent only when needed and have no unsubscribe link;
- withdraw consent to reminders or the waitlist.
Write to [email protected]. We reply within 30 days. You can also complain to a data protection authority. In Ukraine this is the Ukrainian Parliament Commissioner for Human Rights.
7. Cookies and browser storage
Cookies are small files that a site saves in your browser. Our site uses only necessary browser storage:
- the form draft;
- the color theme (light or dark);
- an access record after payment: an access code, an access renewal code and their expiry. Access codes contain the internal order code, not the payment number;
- the payment number — only until the first payment check, then it is erased;
- a partner code if you came through a partner link: kept 30 days and sent with the order;
- an internal note that stops a page from reloading in a loop.
We use no advertising cookies. The Paddle checkout window may set its own cookies under Paddle's policy.
8. Security
The site works only over HTTPS (a secure connection). The server keeps the minimum of data. Only [full legal name] has access to it. Form answers are not stored on the server at all. Our code does not write e-mails or IP addresses into its own server log entries. Cloudflare's service logs may contain IP addresses and are kept for up to 3 days.
9. Children
The software is for adults (18 and older). A parent or guardian fills in a form for a minor. We do not knowingly collect data of children under 13.
10. Changes
The new version will be posted on this page with a date. We will e-mail you about important changes if we have your e-mail.
This policy exists in Russian, Ukrainian and English. If the versions differ, the Russian version prevails.
Svoim USA is not a substitute for the advice or services of an attorney. Not affiliated with USCIS.