DRAFT — pending approval. This text is a working draft and not yet final. It is not a substitute for review by a qualified lawyer. Last updated 28 September 2026.
1. Controller
The operator of PreBreakoutX is the data controller. Contact: support@prebreakoutx.com. (Legal entity name and business ID to be added before publishing.)
2. Data we process
- Account: email address and sign-in records.
- Payments: subscription status, plan, period dates and Stripe customer/payment references. Card and bank details are handled by Stripe and never stored by us.
- Telegram access: your Telegram user ID and username when you join the PRO channel, so access can be approved and removed when PRO ends.
- Support and feature requests: the email and message you submit.
- Newsletter: your email and the time you consented.
- Assistant chat: conversation history for signed-in users.
- Technical data: basic server logs needed for security and troubleshooting.
3. Why and on what legal basis
- Providing the Service and PRO access — performance of contract.
- Bookkeeping of payments — legal obligation.
- Security, abuse prevention and support — legitimate interest.
- Newsletter — consent, which you can withdraw at any time.
4. Processors
We use service providers for hosting and database, payments (Stripe), messaging (Telegram) and AI-assisted chat. They process data only on our behalf. Some may process data outside the EU/EEA under appropriate safeguards such as Standard Contractual Clauses.
5. Retention
Account data is kept while your account exists. Payment records are kept as long as accounting law requires (in Finland, generally 6 years after the end of the financial year). Support requests are kept up to 24 months. Newsletter data is deleted when you unsubscribe. Telegram membership records are kept while you are a member and for up to 12 months after removal.
6. Your rights
You may request access, correction, deletion, restriction, portability, or object to processing by emailing support@prebreakoutx.com. You also have the right to complain to the Finnish Data Protection Ombudsman (tietosuoja.fi).
7. No sale of data
We do not sell personal data and do not use it for third-party advertising.
8. Changes
Material changes to this policy are announced on the site or by email.