Privacy Policy

1. General Provisions

1.1. This Privacy Policy defines the procedure for collecting, storing, using, and protecting the personal data of users of the website fortunasmile.net and the Telegram bot @FortunaSmileBot (hereinafter referred to as the “Service”).

1.2. By registering on the website fortunasmile.net, the User agrees to this Privacy Policy and provides consent for the collection, storage, use, and disclosure of their personal data in accordance with the Laws of Ukraine “On Personal Data Protection,” “On Consumer Rights Protection,” “On Information Protection in Information and Telecommunication Systems.” This rule is valid on the territory of Ukraine from the moment of the user's registration on fortunasmile.net.

2. Service Description

The Service provides users with informational and news content about ongoing drawings, competitions, and events from third-party resources. An additional service for club members is the distribution of gifts and the organization of events for which no additional fees are charged.

3. Collection of Personal Data

• Full Name — for sending gifts when participating in events.
• E-mail — for notifications about new publications, events, and news.
• Telegram ID — for automatic verification of subscription and access to news channels.
• Username and password — for logging into the personal account on fortunasmile.net.

4. Use of Personal Data

• Providing and personalizing informational and news content.
• Informing users about the release of new materials and promotions.
• Managing subscriptions through the Fondy system and providing access to closed channels.
• Organizing additional events and sending gifts.

5. Grounds for Processing

• The user's consent when registering and accepting this Policy.
• Performance of the contract (subscription) and fulfillment of obligations to the user.

6. Transfer of Data to Third Parties

• Transfer of data to the payment provider Fondy — only to the extent necessary for processing the payment.
• No other transfers to third parties are made without additional notification and consent from the user.
• Providing information to law enforcement and other government agencies in response to their official requests.
• The user confirms and gives FortunaSmile the right to transfer personal data across the Ukrainian border for the purpose for which this information was collected.

7. Storage and Protection of Data

Servers are located in Germany. Storage period — until the user withdraws consent or deletes their account, but not more than 3 years.

Protection measures: encryption of transmission channels (TLS); encrypted storage of the database; role-based access restriction for employees.

FortunaSmile reserves the right to use the user's personal data for the purposes for which it was collected for one month after deactivating the information to complete the provision of services (refunds, warranty claims, responses to user inquiries).

8. Cookies and Analytics

The Service uses cookies and similar technologies to analyze website traffic and user interactions.

• Google Analytics — data collection through cookies. More details: https://www.google.com/policies/privacy/partners/
• Microsoft Clarity — behavior analysis, heatmaps, and session recordings. More details: https://privacy.microsoft.com/privacystatement

Using the website implies consent to this Data Processing Policy. Users can disable cookies in their browser settings; some features of the Service may become unavailable as a result.

9. User Rights

• Obtain information about their personal data.
• Request correction, blocking, or deletion of data through the support ticket in the “Help” section, via email at support@fortunasmile.net or through the personal account.
• Withdraw consent for data processing and delete their account.

10. Age Restrictions

The Service is intended for individuals over 18 years of age.

11. Policy Changes

Changes take effect from the moment they are published on the website.