What this notice covers.
This notice describes what happens to personal data on the Truvoca website. The controller is Onix-Systems, LLC, 76 Tarasa Karpy Street, Kropyvnytskyi 25006, Ukraine, which develops Truvoca.
It covers this website only. It does not describe the Truvoca service itself, which is not generally available and will have its own terms when it is.
If you want to ask anything about this notice, or ask us to correct or delete something we hold about you, write to kela@onix-systems.com. Nothing on this site involves automated decision-making or profiling.
Almost nothing
What this website collects, and what you decide.
Measurement here comes in two layers, and you control the second one.
The first layer runs for everyone and stores nothing on your device. It is Cloudflare Web Analytics, which reports how many people reached a page, which page, roughly which country and which site referred them. It works without cookies and without any identifier on your device, so it cannot single you out or follow you between sites.
The second layer is Google Analytics, loaded through Google Tag Manager. It is present on every page, and what changes when you answer the notice at the bottom is **what it is allowed to keep**.
Before you accept — and for as long as you decline — it stores **nothing on your device**: no cookie, no identifier. It sends Google an anonymous signal that a page was viewed, which cannot be tied to you or followed between sites, and Google uses those signals to estimate the traffic it cannot see in detail. Only if you press Accept does it store a cookie and an identifier, and only then can we see how one visit moves through the site.
Declining costs you nothing. The first layer still counts your visit, and the site behaves identically either way, so we are not asking you to pay for it to work.
Advertising is switched off and stays off whichever you choose. This notice asks about measurement, not advertising, so we do not let it store anything for advertising, and ad identifiers are stripped from what is sent.
Your choice is remembered on your device and nowhere else, and you can change it at any time on this page. If we ever add a different vendor or a different purpose, your old choice stops applying and we ask again.
There are no forms on this site, and the fonts are served from here rather than from a third party.
- Visit counting for everyone, without cookies or identifiers
- Before you accept: anonymous signals only, nothing stored on your device
- After you accept: a cookie and an identifier, so we can follow a visit through the site
- Advertising off in every case, and ad identifiers stripped
- Declining changes nothing about how the site works
What any web server sees
What our host records.
The site is served by Cloudflare Pages. Like any web host, it records standard request information — the IP address the request came from, the browser's user agent, the page requested and the time — and keeps it briefly to serve the site, defend against attacks and diagnose faults.
We do not use those logs to build a profile of you, and we do not combine them with anything else.
Only when you choose to
What happens when you book a demo.
The demo calendar is Google Calendar's appointment scheduling. It loads only after you press a booking button and then confirm on the notice that appears — nothing is requested from Google before that, so simply reading the site does not involve Google at all.
Once you load the calendar, you are using a Google service. Google receives your IP address and browser information, and whatever you enter to make the booking, which is normally your name, your email address and any note you add. Google's own privacy terms apply to that, and the booking itself is confirmed by Google, not by us.
We receive the booking — your name, your email address, the time you chose and any note — so that we can hold the meeting, understand the workflow you want to discuss, and follow up about it. We do not use it for anything else, we do not sell or share it, and we do not add you to a marketing list without asking.
- The calendar loads only after you press a booking button and confirm
- Google receives your name, email, IP and any note you add
- Google's privacy terms apply to your use of its calendar
- We use the booking to hold and follow up on the meeting
Why we are allowed to
The purposes, and the legal basis for each.
We are asked to state not just what we do with personal data but why we are permitted to, so here is each purpose with its basis under the GDPR.
Holding and following up on a demo you booked: because you asked us to, as a step taken at your request before any contract, under Article 6(1)(b). If we later write to you about something you did not ask about, that would be a separate matter and we would ask you first.
Serving the site and defending it against attack, which is what the host's request logs are for: our legitimate interest in running a site that works and is not abused, under Article 6(1)(f).
Counting visits without cookies, the first layer above: our legitimate interest in knowing whether anyone reads these pages, under Article 6(1)(f). It stores nothing on your device, which is why it does not need your consent.
Google Analytics, the second layer, has two parts. **Storing** a cookie and an identifier rests on **your consent**, under Article 6(1)(a), which is why you are asked and why you can withdraw at any time without losing anything. The anonymous signal sent before you answer stores nothing on your device and cannot identify you; we rely on our legitimate interest in knowing roughly how much traffic we are not seeing, under Article 6(1)(f), and it is one of the points this notice is being reviewed on.
Loading the Google calendar: your own deliberate action. Nothing goes to Google until you press the button on the notice, and that press is the point at which you decide.
Where it goes
Who else receives it, and which countries.
Three parties are involved, and no others. Cloudflare hosts the site and provides the visit counting. Google provides the appointment calendar, and — if you accept — Google Tag Manager and Google Analytics. We receive the booking itself, and we are in Ukraine.
That means personal data connected with this site can be processed outside the European Economic Area — in the United States by Cloudflare and Google, and in Ukraine by us. Cloudflare and Google each publish the transfer mechanisms they rely on, including the European Commission's standard contractual clauses, in their own terms. For the booking data that reaches us in Ukraine, the transfer follows from your own request for the meeting.
We do not sell personal data, we do not share it for advertising, and we do not transfer it to anyone not named here.
How long, and what you can ask for
Keeping and deleting what you send.
We keep booking details for as long as we are still in contact about the meeting or the workflow you raised, and delete them when that ends or when you ask us to, whichever comes first.
The host's request logs and the visit counts are kept by Cloudflare for its own limited periods and are not retained by us. The visit counts are aggregate figures and are not linked to you.
Your rights
What you can ask us to do.
You can ask us what personal data we hold about you and get a copy of it. You can ask us to correct it if it is wrong, or to delete it. You can ask us to restrict what we do with it, or object to our using it where we rely on legitimate interests. You can ask for it in a portable form. Where anything rests on your consent — which here means Google Analytics — you can withdraw that consent at any time using the control on this page, and withdrawing it does not affect what was lawful before.
Write to kela@onix-systems.com and we will answer. If you booked through the calendar, you can also cancel or reschedule using the links in the confirmation Google sent you, and you can ask Google directly about the data it holds.
If you think we have got this wrong, you can complain to a data protection supervisory authority. In Ukraine that is the Ukrainian Parliament Commissioner for Human Rights. In the European Economic Area or the United Kingdom, it is the authority for the country you live or work in. You can complain to them whether or not you have raised it with us first, though we would rather you told us and gave us the chance to fix it.
When this changes
Changes to this notice.
If what the site does changes, this notice changes with it and the date at the top changes too. Adding a form, an advertising or profiling script, or anything that stores data on your device would mean a new version of this page, and in the case of device storage, asking your consent first.