Privacy Policy

This Privacy Policy (the “Policy”) sets out the procedures for processing and protecting the personal data of users of the Roonce service (the “User” and the “Service,” respectively) by OsOO “NOVAPEY” (the “Operator”).

Operator: OsOO “NOVAPEY,” 62 Kievskaya Street, Sverdlov District, Bishkek, Kyrgyz Republic; registration number 175671-3301-OOO; taxpayer identification number 9909710276. The Operator’s contact address for personal data matters is support@roonce.com.

When processing the personal data of citizens of the Russian Federation, the Operator is guided by applicable Russian law, including Federal Law No. 152-FZ “On Personal Data.” The requirements of other applicable national laws apply to Users from other countries in the cases and to the extent provided by such laws.

1. General provisions

1.1. This Policy applies to the processing of personal data when a User uses the Roonce service, the roonce.com website, the web.roonce.com control panel, the Telegram bot, and Roonce applications.

1.2. This Policy applies to information received by the Operator directly from the User or when the User uses the Service interfaces. This Policy does not govern the processing of information by third-party resources to which a User may navigate through links in Roonce interfaces. Such processing is carried out by the relevant third parties under their own documents.

1.3. Use of the Service does not, by itself, constitute consent to the processing of personal data where separate consent is required by law. In such cases, the Operator obtains consent separately.

1.4. Failure to provide data required to enter into a contract or use a relevant Service feature may make it impossible to enter into the contract or provide that feature.

2. Categories of personal data processed

2.1. Depending on how the Service is used, the Operator may process the following categories of personal data:

• account data: Telegram account ID, Telegram first name and username, Roonce account ID, email address (if provided by the User), and other information required to create and maintain the account;
• subscription and payment information: whether a payment was made, its amount, currency, date and status, transaction ID, subscription details, and the identifier of a payment token or linked payment method where required to manage the subscription and its automatic renewal;
• technical information: IP address, operating system and application type and version, connection protocol, date and time of access to the Service, and connection performance indicators, to the extent necessary to provide the Service, diagnose faults, and ensure security;
• information contained in support requests and contact details provided by the User for a response.

2.2. The Operator does not receive or store the User’s full bank card details. Payment data and the payment token are processed by the relevant payment provider. The Operator may store a token identifier or linked payment method to the extent necessary to initiate payments and manage the subscription, until the relevant payment data is no longer used or automatic renewal is disabled, unless further retention is required by law.

2.3. When providing the secure connection feature, the Operator does not collect the User’s browsing history or the contents of the User’s Internet traffic. This does not exclude the processing of the technical information listed in Clause 2.1 of this Policy.

3. Purposes of processing personal data

3.1. The Operator processes personal data for the following purposes:

• providing the User with access to Service features and ensuring their technical operation;
• creating and administering the User’s account and identifying the User;
• processing subscriptions and payments and managing automatic renewal in accordance with the Recurring Payments Consent;
• informing the User about subscription status, upcoming payments, maintenance, and material changes to the service terms;
• reviewing User requests and resolving claims;
• ensuring Service security and preventing fraud, abuse, and unlawful use;
• complying with obligations imposed on the Operator by applicable law.

4. Legal grounds and methods of processing

4.1. The Operator processes personal data where a legal basis under applicable law exists, including where processing is necessary to enter into or perform a contract with the User, comply with a legal obligation, or pursue another lawful purpose.

4.2. If applicable law requires the User’s consent to process personal data for a particular purpose, the Operator obtains that consent separately from acceptance of the Public Offer and acknowledgment of this Policy.

4.3. Consent to automatic subscription renewal is a separate expression of the User’s intent concerning recurring payments and does not constitute consent to the processing of personal data. The User may withdraw consent to the processing of personal data where processing is based on such consent. Withdrawal does not affect the lawfulness of processing carried out before withdrawal and does not prevent processing where another lawful basis exists.

4.4. Depending on the purposes of processing, the Operator may collect, record, organize, accumulate, store, update, use, provide access to, block, delete, and destroy personal data. Processing may be carried out with or without the use of automated means.

5. Use of the Telegram bot and web control panel

5.1. Registration, subscription management, payment, and submission of support requests may be carried out through the official Roonce Telegram bot and the web control panel available at web.roonce.com.

5.2. When a User interacts with the Telegram bot, the Operator receives from the Telegram platform information required to operate the bot, including the account ID, first name, and username. Telegram processes data as an independent platform provider in accordance with its own documents and privacy policy.

6. Disclosure of personal data to third parties

6.1. The Operator does not sell Users’ personal data.

6.2. To provide and maintain the Service, the Operator may entrust the processing of personal data to, or disclose necessary data to, payment providers and aggregators, hosting and technical infrastructure providers, and support tool providers. Data is provided to the extent necessary for the relevant service, under a contract and subject to confidentiality and security requirements.

6.3. Payment providers and platform providers may process certain data as independent data controllers in accordance with their own rules and applicable law.

6.4. The Operator may disclose personal data to government authorities where a lawful request has been submitted in accordance with the procedure established by law.

7. Retention and storage location. Cross-border transfers

7.1. Personal data is retained no longer than required for the purposes of processing or by applicable law. Account data is processed while the account exists. After the purposes of processing have been achieved or the account has been deleted, data is deleted or anonymized within the time limits established by law and the Operator’s internal procedures, unless further retention is required, including for accounting or tax purposes or to resolve a dispute.

7.2. When personal data of citizens of the Russian Federation is collected via the Internet, the Operator ensures the recording, systematization, accumulation, storage, updating, and retrieval of such data using databases located in the Russian Federation, except as otherwise provided by law.

7.3. The Operator may use technical infrastructure with certain components located outside the Russian Federation. Before initiating a cross-border transfer of personal data, the Operator submits the notification required by law to the competent authority and complies with applicable restrictions and other requirements of Russian law. A cross-border transfer does not waive the statutory requirements for primary processing of data.

8. Personal data protection measures

8.1. The Operator takes the organizational and technical measures necessary to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, disclosure, and other unlawful actions.

8.2. Access to personal data is granted only to persons who need it to perform duties related to the operation of the Service. Such persons are required to maintain the confidentiality of personal data.

9. User rights and requests

9.1. To the extent provided by law, the User may obtain information about the processing of their personal data, request its correction, blocking, or deletion, withdraw consent where processing is based on consent, and lodge a complaint with a competent authority or court.

9.2. To exercise these rights, the User may send a request to support@roonce.com. The request must contain information sufficient to identify the User and determine the nature of the request. To prevent disclosure to an unauthorized person, the Operator may request additional verification of the applicant’s identity.

9.3. Withdrawal of consent does not stop the processing of personal data where another lawful basis for processing exists. If a particular service cannot be provided without data that the Operator is lawfully entitled to continue processing, provision of that service may be discontinued in accordance with the law.

10. Cookies

10.1. The Roonce website may use technical cookies and similar technologies necessary for the website’s operation, saving settings, and security. The Operator does not use analytics or advertising cookies.

10.2. The User may restrict the use of cookies through browser settings. Disabling necessary cookies may affect the availability or operation of certain website features.

11. Changes to this Policy

11.1. The Operator may amend this Policy. The current version is published on Roonce’s official resources and takes effect upon publication, unless a later effective date is specified in that version.

11.2. If a change to the processing procedures requires new consent from the User, the Operator will request that consent separately.

12. Operator details and contact information

• Personal Data Operator: OsOO “NOVAPEY”
• Address: 62 Kievskaya Street, Sverdlov District, Bishkek, Kyrgyz Republic
• Registration number: 175671-3301-OOO
• Taxpayer identification number: 9909710276
• Email: support@roonce.com

Requests concerning personal data may also be submitted through the support chat. The terms of service are set out in the Public Offer, and the procedure for automatic payments is set out in the Recurring Payments Consent.

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