Privacy Policy

Last updated: 4 June 2026

This Privacy Policy explains how we collect, use, share and protect your personal data when you use the Digital Specialist app and service (the "Service"), and describes your rights under the EU General Data Protection Regulation (GDPR).

1. Controller

Controller: Vladimir Kozlov (individual). Contact address: Moscow, 129110. Email: vvkozlov.work@gmail.com. Additional channel: Telegram @ds_app.

Where we offer the Service to individuals in the EU/EEA, processing falls under GDPR Art. 3(2).

2. Personal data we collect

• first name, last name, job position;
• email address, phone number;
• profile photo (avatar);
• location data, including current location, background location collection and movement history;
• geo-zone visit logs (entry/exit records);
• content of messages, comments, voice messages and uploaded files;
• usage data: IP address, device type and identifiers, operating system, browser type, diagnostics, cookies;
• data from third-party sign-in (Google, Yandex): name, email address.

We do not process special categories of data or biometric data.

3. Purposes and legal bases (Art. 6)

• Performance of a contract (Art. 6(1)(b)) — providing and maintaining the Service, account management.
• Consent (Art. 6(1)(a)) — analytics cookies and other optional processing; can be withdrawn at any time.
• Legitimate interests (Art. 6(1)(f)) — security, abuse prevention, service improvement.
• For employees of business customers, the customer (employer) acts as controller; we act as processor on their behalf.

4. Recipients / processors

• Yandex — maps, sign-in, web analytics (Yandex Metrica);
• Google LLC (US) — push notifications (FCM), Maps, Google Play, Firebase;
• LiveKit — audio/video calls;
• Groq (US) — AI features;
• Microsoft (US) — web analytics (Clarity).

5. International transfers

Transfers to the United States rely on the EU–US Data Privacy Framework where the recipient is certified (e.g. Google, Microsoft), or on Standard Contractual Clauses with a transfer impact assessment where it is not (e.g. Groq). Details available on request.

6. Retention

We keep personal data only as long as necessary for the purposes above or until you withdraw consent or delete your account. After an account-deletion request, related data is deleted within 30 days, except where law requires longer retention.

7. Your rights

Under the GDPR you have the right to: access; rectification; erasure ("right to be forgotten"); restriction; data portability; objection; and to withdraw consent at any time. You may also lodge a complaint with your local supervisory authority (in Bulgaria — the Commission for Personal Data Protection, CPDP/КЗЛД). To exercise your rights, contact vvkozlov.work@gmail.com.

8. Cookies and analytics

We use cookies and analytics. Non-essential (analytics) cookies load only after you give consent via the consent banner. You can change or withdraw your choice anytime via the "Cookie settings" link.

9. Children

The Service is not intended for individuals under 18. (In Bulgaria the digital-consent age under Art. 8 GDPR is 14.) We do not knowingly collect children's data.

10. Security

We apply appropriate technical and organisational measures (Art. 32) — access control, encryption in transit, logging — to protect personal data.

11. Changes

We may update this Policy. The current version is published on this page with its update date.

12. Contact

Email: vvkozlov.work@gmail.com. Telegram: @ds_app. Address: Moscow, 129110.