Privacy policy

ORBERIO is a software brand operated by Pavlo Koval, an individual entrepreneur registered in Ukraine — Фізична особа-підприємець (ФОП).

ORBERIO has no employees, offices or corporate group, and it does not act as a separate legal person.

For the purposes of the EU General Data Protection Regulation (GDPR) and applicable Ukrainian data protection law, the controller is Pavlo Koval, Individual Entrepreneur (Sole Proprietor), Ukraine. ORBERIO is the brand name under which the software is published; it is not a separate legal entity.

This policy explains how personal data is handled when you visit apps.orberio.com. It applies to this website only. The SlightClean application has its own privacy policy, and the two documents are maintained independently.

The developer is established outside the European Union. The GDPR applies only where the processing falls within Article 3(2) GDPR — that is, where it relates to offering goods or services to people in the Union, or to monitoring their behaviour within the Union. confirm with counsel which activities fall within scope, and whether an EU representative under Article 27 GDPR must be appointed.

Where Ukrainian law applies, processing is also subject to the Law of Ukraine “On Personal Data Protection”. confirm the applicable national requirements, including any registration, notification or transfer duties.

This website is a static site. It has no user accounts, no contact forms, no newsletter and no comment sections. It does not load client-side analytics, advertising or tracking scripts, and it does not set cookies.

The only personal data involved in simply reading this site is technical request data processed by the hosting provider so that pages can be delivered securely.

If you write by e-mail, the developer processes your message in order to reply. Nothing is sold, rented or used to build advertising profiles.

Hosting. This site is served through Cloudflare Pages. When you request a page, Cloudflare processes the technical data required to deliver the response and to protect the service. This can include your IP address, request headers, the requested URL, the time of the request and your browser’s user agent.

Server logs. state whether request logs are enabled, where they are stored and for how long. Retention differs between Cloudflare products — confirm the current values in your Cloudflare account.

Legal basis. Where processing is necessary to deliver the website and keep it secure, the developer relies on legitimate interests under Article 6(1)(f) GDPR. Where processing is required by law, Article 6(1)(c) GDPR applies.

E-mail contact. If you write by e-mail, the developer processes your e-mail address and the content of your message in order to answer it. confirm the mailbox provider, the retention period and the deletion practice.

What is not done. No user profiles are built, personal data is not sold, and website data is not combined with data from other sources.

SlightClean is distributed through the Apple App Store under the ORBERIO brand. Its data practices are documented in the SlightClean privacy policy, which is maintained separately from this document.

add a one-paragraph summary of SlightClean’s verified data practices once they are confirmed, or remove this section and rely on the cross-reference.

confirm what SlightClean processes locally, and whether any data leaves the Mac.

Statements about local processing are only published once they have been verified in the shipped build, including any third-party SDKs it contains.

This website does not include analytics, tag managers, heatmaps or session recording. There is no third-party script on any page.

if analytics are added later, document the provider, the data collected, the legal basis, the retention period and the opt-out mechanism here, and update the cookies section.

Diagnostics for SlightClean. confirm whether SlightClean includes crash reporting or diagnostics, and whether Apple’s optional “Share with app developers” setting applies.

Apple may collect diagnostic data relating to the App Store and macOS under its own privacy policy, independently of ORBERIO.

The developer does not carry out automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you.

confirm this once the product scope is final.

The number of third parties involved is kept to the minimum needed to operate the website and distribute the software.

Personal data is not sold and is not shared for advertising purposes.

• Cloudflare — hosting and content delivery for this website (Cloudflare Pages). confirm the current data processing addendum and Cloudflare privacy documentation.
• Apple — distribution of SlightClean through the App Store, including purchase processing, reviews and optional diagnostics.
• add any other processor, for example e-mail hosting, a newsletter provider or an analytics service. If there are none, state that here.

This website sets no cookies and writes nothing to your browser’s local storage. There is no cookie banner because there is nothing to consent to.

re-check this section whenever a third-party script, embedded video, external font service or analytics tool is added — each can introduce cookies or local storage.

Your browser may cache files on its own initiative; that behaviour is controlled by your browser settings, not by this website.

Personal data is kept only for as long as necessary for the purpose described in this policy, or for as long as the law requires.

define concrete retention periods for support e-mails, business correspondence and hosting logs.

Where no retention period can be justified, data is deleted or anonymised. Aggregated, non-identifying information may be kept indefinitely.

This website is served over HTTPS and holds no user data of its own. Access to any system that stores personal data is limited to the developer.

No method of transmission or storage is completely secure. The developer takes reasonable technical and organisational measures, but cannot guarantee absolute security.

describe the actual measures in place, for example two-factor authentication, encrypted storage and backup practice.

This website and the software are not directed at children. Personal data from children is not knowingly collected. If you believe a child has provided personal data, please make contact and it will be deleted.

confirm the age threshold that applies (16 under the GDPR unless a member state sets a lower age; Ukrainian law sets its own threshold).

Where the GDPR applies to you, you have the following rights in relation to your personal data:

• Access — to receive a copy of the personal data held about you (Article 15 GDPR).
• Rectification — to have inaccurate or incomplete data corrected (Article 16).
• Erasure — to have your data deleted where there is no overriding legal reason to keep it (Article 17).
• Restriction — to limit how your data is used (Article 18).
• Portability — to receive your data in a structured, machine-readable format (Article 20).
• Objection — to object to processing based on legitimate interests (Article 21).
• Withdrawal of consent — where processing is based on consent, to withdraw it at any time (Article 7(3)).
• Complaint — to lodge a complaint with a supervisory authority (Article 77).

To exercise any of these rights, write to privacy contact e-mail address. Information may be requested to confirm your identity before a request is acted on.

You have the right to lodge a complaint with a data protection authority, in particular in the EU member state where you live, where you work, or where the alleged infringement took place. confirm the competent authority for the operator’s establishment in Ukraine (the Ukrainian Parliament Commissioner for Human Rights is the national supervisory authority) and document how a complaint can be submitted.

Requests are answered within one month where the GDPR applies. confirm the internal process for handling requests and any extension policy, including under Ukrainian law.

The hosting provider operates a global network, so technical request data may be processed outside the European Economic Area and outside Ukraine.

confirm the transfer mechanism used (for example the EU Standard Contractual Clauses, an adequacy decision, or the safeguards required by Ukrainian law) and the current measures offered by each provider.

This policy may be updated when practices or the law change. The date shown at the top of this page indicates the most recent revision.

set the last-updated date to the publication date.

Material changes will be described on this page. decide whether material changes should also be announced elsewhere, for example in release notes.

Questions about this policy, or about how ORBERIO handles personal data: privacy contact e-mail address.

No postal address is published unless a legal obligation requires one. Address details, where required, appear on the contact page.