This Privacy Policy (hereinafter — the Policy) describes how Combo Pocket (hereinafter — the Application or the Service) collects, stores, uses, and protects personal data of users who access the Combo Pocket mobile application and the website combopocket.com (hereinafter — the Website).
This Policy has been prepared in accordance with the applicable laws on personal data protection, including the General Data Protection Regulation (GDPR) and the Law of Ukraine “On Personal Data Protection.”
By using the Application and/or the Website, the User confirms that they have read, understood, and agreed to this Policy and consent to the processing of their personal data in accordance with it.
1. Definitions
- “Personal Data” — any information relating to an identified or identifiable natural person.
- “Processing” — any operation performed on personal data, such as collection, recording, organization, storage, modification, retrieval, use, disclosure, or deletion.
- “User” — any individual using the Application or the Website.
- “Operator” — the Combo Pocket developer responsible for collecting and processing Users’ personal data.
2. General Provisions
This Policy governs the relations between the Operator and the User during the collection and processing of personal data when:
- registering a user account on the Combo Pocket Website;
- using the mobile Application;
- enabling data exchange between the Application and the User’s accounting system (such as 1C or BAS) via the official Combo Pocket API.
All data are processed solely for the purpose of providing access to the Service and ensuring its correct and secure operation.
3. Legal Basis and Purpose of Processing
The Operator processes personal data on the following legal grounds:
- the User’s explicit consent provided upon registration or first use of the Application;
- necessity for the performance of a contract (user agreement) between the User and Combo Pocket.
The purposes of data processing include identification, secure access, integration with the User’s accounting system, protection from unauthorized access, and improvement of service quality.
4. Registration and Access Token
To use the Application, the User must first register an account on the Combo Pocket Website. After registration, the User receives a unique access token linked to their account. This token is used exclusively for authentication and data exchange between the Application and the User’s accounting system.
The User is responsible for safeguarding their login credentials and must not share them with third parties.
5. Categories and Principles of Data Processing
The Service may process the following categories of data:
- registration information (name, email, login, password);
- technical data about the device (model, Android version, IP address, language);
- operational data (token, connection parameters, app version);
- anonymized statistical data about Service usage.
Combo Pocket receives data only within the official API described on combopocket.com. All data exchange between the User’s accounting system and the Application occurs solely within an integration initiated by the User and is fully transparent. The User independently determines which data are transferred and bears responsibility for their content and scope.
6. Data Security and Confidentiality
All data transmission between the Application, the Website, and the User’s accounting system is protected via the HTTPS protocol, ensuring encryption and secure communication.
The Operator implements modern technical and organizational measures to protect data from loss, alteration, unauthorized access, or disclosure. Access is available only to authorized Users with a valid token.
7. Disclosure and Transfer to Third Parties
The Operator does not transfer personal data to third parties except when:
- the User has provided explicit consent;
- such disclosure is required by law; or
- third-party technical services (Google Play Services, Google Analytics, Microsoft Clarity) are used under their own privacy policies.
8. Data Retention
Personal data are stored as long as the User’s account remains active. Upon deletion, all data are permanently erased or anonymized within 30 days unless otherwise required by law.
9. Users’ Rights
Each User has the right to obtain information about their data, request corrections or deletions, withdraw consent, and contact the Operator regarding data protection issues.
10. Contact Information
For inquiries about personal data processing, please contact:
Email: support@combopocket.com
Website: https://combopocket.com
11. Amendments to the Policy
The Operator reserves the right to update this Policy without prior notice. The revised version takes effect upon publication on the Website.