Privacy Notice

Publication Date: 27/08/2025

Fifteen Soft LLC (“Fifteen”, “us” or “we”) welcomes you. This Privacy Notice (“Privacy Notice”) applies to this website, where you read this document (“https://www.appfifteen.com/”) and our mobile application Fifteen App (“App”) available in the App Store / Google Play.

The Privacy Notice describes which of your personal data App collects, how it stores, processes, and uses it, and what happens when you use the App.

Content

  1. About Us

  2. About You

  3. Entire Agreement

  4. Personal Data

    4.1. Sources of Data

    4.2. Lawful Bases for Processing

    4.3. Users’ Data

    4.4. Registered Users’ Data

    4.5. Buyers’ Data

    4.6. Winners’ Data

    4.7. Newsletter Subscribers’ Data

    4.8. Data Received from Third Parties

  5. Data Sharing with Third Parties

  6. Data Protection

  7. Data Subjects Rights

  8. Privacy Notice Updates

About us

We are the controller of your personal data processed through the App. This means that we determine the purposes and means of personal data processing.

Name Fifteen LLC
USREOU code 45715067
Address 01024, Ukraine, Kyiv City, Velyka Vasylkivska Street, building 6, apartment 17
Email contact@appfifteen.com – for general inquiries
privacy@appfifteen.com – for privacy inquiries

About you

When you visit the App or Website, you become our user (“User”). 

We divide the Users into categories so you can easily find details about the processing of your personal data. Pay attention that you can fall into several categories depending on your actions.

Type of User Description
Registered User A user who has registered on the App
Buyer Registered User who buys Fifteen’s products on the App
Winner Registered User who is determined to be the Winner according to the appropriate Rules of Contest, accessible on the App
Newsletter subscriber User who fills out our opt-in form for email newsletters on the Website / App
Please note! We do not knowingly process the personal data of Users under the age of 18. If you are such a User or the legal representative of such a User, please contact us.

Personal data

Sources of data

We receive your data when you visit the App and interact with it, depending on your actions on the App. 

You can change your personal data by exercising your right to rectification. Please note that the same lawful basis and storage terms apply to the changed data.

We may also (although we do not necessarily do so) receive data from third parties. It depends on your settings and the features you use.

Lawful bases for processing

To process your personal data, we rely on the following lawful bases:

  • performance of the contract — for the processing of personal data necessary for the negotiation, conclusion, and performance of a contract (mainly, the Terms of Service) with you;

  • legitimate interest — for the processing necessary for the development of our services, taking into consideration your interests, rights, and expectations;

  • legal obligation — for the processing as required by applicable laws (for example, to comply with tax or KYC/AML regulations) or if requested by a law enforcement agency, court, supervisory authority, or another state-authorised public body;

  • consent — for additional specific purposes.

If we collect personal data on the basis of legitimate interest or performance of the contract, we can use it for another purpose after checking that the new purpose is compatible with the original purpose.

When your data processing is based on a legal obligation or performance of the contract, you are obliged to provide your personal data. We need this data to comply with legal requirements or to properly provide you with our services. The failure to provide such data may have negative consequences, such as tax liability, inability to enter into a contract or provide services to you, etc.

Users’ data

When you visit the Website or access the App, we collect some data automatically. We collect some technical data about the Users to optimise performance, debug issues, and enhance features while ensuring security and privacy to improve the overall user experience.

Most of the technical data we collect is anonymous, but some data is associated with your IP address and device ID. Please read about personal technical data below.

Data Reasons for Processing Lawful Basis
Information about the coarse location (IP address, country)

Technical device information and network information (including IP address, HTTP user agent, browser or device type (depending on if you access the Website or the App), Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks, tracking pixel, authentication token, session identifiers, caching mechanism, such as Azure CosmoDB (ETag), Redis) 		The optimization of the performance, debugging, enhancement of the features’ proper functioning, administering, and improvement of the Website and the App Legitimate interest
Data Storage
We store the data for 3 years from its collection.

Registered Users’ data

We collect your personal data when you register on our App

Data Reasons for Processing Lawful Basis
Name To identify you and personalise your experience in the App Performance of the contract
Surname To identify you and personalise your experience in the App Performance of the contract
Date of birth To verify that you are at least 18 years old and eligible to use our App according to our Terms of Service Performance of the contract
Phone number To provide security features for your account Performance of the contract
Password To provide security features for your account Performance of the contract
Username To personalise your experience in the App and to display your username on the leaderboard (If you want it to be displayed on the leaderboard, please visit the “Settings” tab in the App to change your preferences). Performance of the contract
Data Storage
We store the data for 3 years from the deletion of the account.

Buyers’ data

We collect your personal data when you make a purchase in the Store tab on our App

Data Reasons for Processing Lawful Basis
Payment data (transaction ID, amount, date, and status of transaction) To identify who made a transaction, for what item and whether it was successful Performance of the contract
User ID
Data Storage
We store the data for 3 years from the deletion of the account.

Winners’ data

We request your personal data when you win something in the contest according to the appropriate Rules of Contest, accessible at our App.

Data Reasons for Processing Lawful Basis
Name, surname, patronymic,
date of birth, place of
residency, email address 		To identify you as individual for transaction purposes and store the data about you for KYC (“Know your client”) purposes When you first send your information for us to transfer the gift, data is stored on the basis of performance of the contract.

For all other purposes we process the data based on legal obligation.
Passport and residency extract photo and data (date of issue and expiry date, number of the document)
Registration number of the taxpayer’s record card (Tax code) Because we act as tax agent, we have to report your income to the tax authorities
Data Storage
We store the data for 3 years from the deletion of the account or from the transfer of gift (for the term from the mentioned which is longer).

Newsletter subscribers’ data

When you leave an email on our opt-in form for email newsletters, we process the following data.

Data Received from Third Parties

We may receive some personal data from third parties.

The amount of data collected, the purposes, and the lawful basis for processing are determined by the respective privacy documents of these third parties.

Category of data Third party Privacy documents
Payment data Google Inc. / Apple Inc. Google Pay Privacy Policy / Apple Pay & Privacy
Identification and tracking data (for tracking in-app user engagement, phone Authentication, and Cloud Messaging for notifications) Firebase (Google Inc.) Privacy & Security at Firebase
Tracking data Google Analytics Privacy Policy
Google Admob
Meta Privacy Policy
Tiktok Privacy Policy
X (formerly Twitter) Privacy Policy

Data Sharing with Third Parties

We can share your personal data with third parties without any harm to you and in full compliance with applicable law. In addition, we have implemented organisational and technical measures to ensure the security of personal data during data transfer to third parties.

Third parties Description
Analytics and marketing tools We use analytics tools to understand and promote our business, such as Google Analytics, Google Admob, Firebase, Facebook and Instagram Ads, TikTok Ads, X Ads.
Payment services We use payment services to process your payments and other transactions, namely Google and Apple for Play Market and App Store respectively.
Social networks We use various social networks to spread information about our activities, such as Tiktok.
Data storage services We use various cloud services, such as Microsoft Azure, that allow us to securely store data on remote servers.
Contractors, service providers on App We cooperate with service providers and contractors to provide you with their services, operate, develop, and improve the features and functionality of the App, fulfill your support requests, complete payment transactions, etc.
Providers of the services our team use We use CRM systems, messengers, and other services in our organisation to provide you with our services.
State authorities, courts, law enforcement agencies, etc We may be obliged to transfer some of your data to tax authorities, courts, law enforcement agencies, and other governmental bodies:
  • to comply with a government request, court order, or applicable law;
  • to prevent unlawful use of the App;
  • to protect against claims of third parties;
  • to help prevent or investigate fraud.
To get a detailed list of the third-party recipients of your personal data, contact us.

To share your data, we rely on the following lawful bases, depending on the case: consent, compliance with the law, and performance of a contract.

Data protection

We apply a variety of security measures appropriate to the possible risks.

Organizational measures
Staff training Internal policies and instructions
Non-disclosure agreements (NDA) Regular testing of the effectiveness of measures to ensure the security of the processing
Internal IT and IT security governance and management.
Technical measures
Implementation of HTTPS Backups
Firewalls Encryption of data during transmission and storage

Data subjects rights

You, as a data subject (individual), have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them depending on your residency.

To exercise your rights, contact us.

Right Description
Right to access You can request information on whether personal data is being processed, and, where that is the case, access to this personal data and the information required by law.
Right to rectification You can change the data if it is inaccurate or incomplete.
Right to erasure You can send us a request to delete your personal data from our systems. We will remove them unless otherwise provided by law.
Right to restrict the processing You may partially or completely prohibit us from processing your personal data in cases provided by law.
Right to data portability You can request all the data you provided to us and request to transfer the data to another controller.
Right to object You may object to the processing of your personal data that is collected on the basis of legitimate interest.
Right to withdraw consent You can withdraw your consent at any time.
Right to file a complaint If your request was not satisfied, you could file a complaint to the regulatory body.
We will answer your request within one month. If your request is not satisfied, you can submit a complaint to the Ukrainian Parliament Commissioner for Human Rights here.

Privacy Notice updates

This Privacy Notice is developed according to the Law of Ukraine “On protection of personal data”, other applicable privacy laws, and best privacy practices.

Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on the App.

If there are material changes to the Privacy Notice or the App that affect your data privacy rights, we will notify you by displaying information on the App and, if necessary, ask for your consent.