Privacy Policy

Edition dated 14.07.2025

1. General Provisions

This Privacy Policy (hereinafter – the “Policy”) defines the procedure for collecting, processing, storing, and protecting personal data of users of the Stelo Platform (hereinafter – the “Platform”), owned by Genotrobos LLC, EDRPOU code 44612896, and applies to persons using the Platform, including Clients and Psychologists.

By accepting the terms of this Policy during registration or use of the Platform, you, as a Platform User, give your unconditional and voluntary consent to the collection, processing, storage, and transfer of your personal data to third parties

2. Terms and Definitions

2.1. Platform – a software complex owned and managed by the Organizer and may consist of mobile applications based on Android and iOS operating systems and websites.

2.2. User (hereinafter referred to as “User,” or “You,” or “Your”) – a person who visits and/or uses the Platform, or otherwise has access to the Platform’s functionalities, including but not limited to Client and Psychologist.

2.3. Client – any individual of full legal capacity who has registered on the Platform.

2.4. Psychologist – an individual entrepreneur (single tax group 3) with higher education in Psychology, acting within their competence, not performing diagnosis or treatment of mental illnesses, and adhering to professional ethics, who has registered on the Platform.

2.5. Organizer (hereinafter referred to as “Organizer,” or “we,” or “us”) – Genotrobos LLC, EDRPOU code 44612896, as the owner (including exclusive intellectual property rights to software, code, design, logos, textual and graphic content, databases, interface elements, functionality, and all other components of the Platform) and operator of the Platform.

3. Who Operates Personal Data

The operator of your data is the Organizer:
Genotrobos LLC
EDRPOU code: 44612896
Legal address: 65007, Odessa region, city of Odessa, Novoshchipny Ryad street, building 15/17, office 1
Email for inquiries: [email protected]

4. What Data We Collect and Process

We may collect and process the following categories of personal data:

For Clients/Users:

  •  Full name;
  •  Date of birth;
  •  Email, phone number;
  •  Information provided during booking for services on the Platform;
  •  History of bookings and payments;
  •  History of Psychologist searches and filters;
  •  Information about psycho-emotional requests (with consent).

For Psychologists:

  • Full name;
  • Email, phone number;
  • Diploma, license number (if required);
  • Entrepreneur data (EDRPOU, bank details);
  • Reviews, history of services provided on the Platform;
  • Documents confirming qualifications;
  • Information about practical experience;
  • Reception schedule.

We also use cookies, technical device information, and the User’s IP address.

The above information and/or documentation may be requested and/or collected to activate your account on the Platform and/or any services available on the Platform. Any doubts regarding the validity, authenticity, and genuineness of the documents and information provided by you will be considered sufficient and substantial reason to deny you access to the Platform and/or services on the Platform.
You, as a Platform User, clearly and unconditionally agree, declare, and guarantee that any information provided to us is valid, current, complete, and accurate.
Data is collected from all Users (including unregistered Users).
We may collect and process data during the Platform’s operation and use the information you provide, sent to us through your computer, mobile phone, or other access device, which may include data such as your IP address; device information including, but not limited to, identifier, name and type, operating system information, mobile network information, standard web log information, and other diagnostic data.
We also collect and process information such as User requests for support regarding the operation of the Platform, related services, and other issues.
We reserve the right to request additional information from you to confirm your identity and/or address, and/or information and/or documents received from you before allowing you to use the Platform and its functionalities. We may also receive information about you from third parties.

5. Purpose of Data Collection and Processing

Personal data is collected and processed exclusively for the purpose of:

  • registering you as a User on the Platform and administering your account;
  • performing authentication and data verification;
  • providing access to the Platform and services on the Platform;
  • providing User support, processing their requests, ensuring communication between Client and Psychologist;
  • confirming Psychologists’ qualifications;
  • processing payments via payment systems;
  • technical support and handling inquiries;
  • ensuring security;
  • fulfilling legal obligations;
  • improving the quality of the Platform and service delivery;
  • informing about new features, updates, promotions, or changes in contractual terms, rules, policies, or other conditions;

conducting marketing activities that do not contradict current legislation and only with your consent.

6. Legal Grounds for Data Collection and Processing

Data collection and processing on the Platform is carried out on the basis of:

6.1. Your consent given during:

  • registration on the Platform (including your acceptance of the public offer agreement and other documents);
  • ordering or receiving services on the Platform;
  • activation of paid functions, making payments;
  • confirmation of consent through a checkbox, clicking the “Accept,” “Register,” or similar button indicating acceptance of terms.

6.2. Compliance with applicable laws (including tax, financial, and other obligations to government authorities), specifically:

  • Law of Ukraine “On Personal Data Protection”;
  • Law of Ukraine “On Electronic Commerce”;
  • Tax Code of Ukraine (for payment accounting and reporting);
    other regulatory acts governing electronic services, financial operations, consumer rights protection.

6.3. Our legitimate interests, including:

  • ensuring security, including information systems;
  • preventing fraud;
  • improving service quality (analytics, feedback, complaint handling);
  • protecting the rights and interests of the Platform in legal disputes.

6.4. Separate consent for processing certain categories of data (e.g., if the User voluntarily discloses sensitive information during consultation) is given additionally and explicitly, in cases provided by law.

7. Who Has Access to Your Data

7.1. Access to Users’ personal data is granted only to authorized employees of the Organizer and partners who require such data to ensure the Platform’s operation. All persons with access to personal data bear legal responsibility for maintaining confidentiality in accordance with applicable law.

7.2. We may transfer personal data to third parties only in the following cases:

  • to the Psychologist providing or planning to provide services to the Client (only the data necessary for interaction and preparation for the respective consultation);
  • to payment providers (including LiqPay, Tranzzo, etc.) to ensure payment processing. The Platform does not store or process payment details (bank card numbers, CVV, etc.);
  • to IT providers (including hosting, CRM systems, video communication, and analytics providers) – strictly within the scope of technical support for the service;
  • to government authorities in cases and procedures prescribed by applicable law (e.g., by court order or law enforcement request).

7.3. All third parties receiving personal data are obliged to:

  • process it exclusively for providing technical or financial services
  • ensure a level of protection no less than that established by the Platform;
  • not transfer this data to other entities without separate User consent.

8. Retention Period of Personal Data and Deletion Procedure

8.1. Users’ personal data is stored no longer than required by:

  • the purpose of processing;
  • legal requirements;

or until the User withdraws consent for processing.

8.2. The User has the right to send a request for full deletion of their account and all personal data processed by the Organizer. To do this, it is sufficient to contact the email: [email protected] or use the corresponding function in the personal account.

8.3. After confirmation of the deletion request:

  • all User personal data is removed from active databases;
  • data necessary for statistics, business analytics, and platform algorithms is depersonalized (anonymized).

8.4. For 90 (ninety) calendar days after deletion, the account is kept in a secure archive (backup) exclusively for technical recovery and legal reporting purposes.

8.5. After this period expires, the account and all related personal data are irreversibly deleted, including backups, activity logs, and metadata.

9. Protection of Personal Data

We take appropriate technical and organizational measures to protect your data:

  • SSL encryption of all connections;
  • secure access to databases;
  • Backup;
  • role-based access restrictions;
  • access audits;
  • regular software updates.

Despite our efforts, no method of transmission over the Internet or electronic storage is completely secure. Therefore, we cannot guarantee absolute security. In case of a security breach that may pose a high risk to your rights and freedoms, we will notify you in accordance with legal requirements.

You are also obligated to keep your registration data (login, password) confidential and bear full responsibility for all actions performed under your account. In case of unauthorized use or suspicion of hacking – notify us immediately.

10. User Rights

 The User has the right to:

  • know which personal data is collected, processed, and stored;
  • receive a copy of their personal data;
  • correct inaccurate or incomplete information;
  • request modification or deletion of data;
  • withdraw consent for processing;

appeal to the authorized personal data protection authority.

11. Use of Cookies and Other Trackers

11.1. The Platform uses cookies (text files stored on the User’s device) and similar technologies (e.g., pixels, local storage, analytical scripts) for:

  • ensuring proper Platform operation;
  • identifying authorized Users;
  • saving User settings;
  • collecting statistical data about traffic and interaction with the interface;
  • personalizing recommendations.

11.2. Data collected via cookies does not identify a person without additional User actions. It is used solely within the framework of this Privacy Policy.

11.3. The User has the right to manage cookies independently through browser or mobile device settings. Disabling cookies may limit some Platform functions (e.g., authorization or saving settings).

12. Changes to the Policy

12.1. We reserve the right to make changes to this Policy at any time, considering changes in legislation or technical processes of the Platform. Changes (additions) to this Policy are made unilaterally by the Organizer by mandatory posting of such changes (additions) on the Platform. All changes made by the Organizer to the Policy become effective and binding for Users from the moment they are posted on the Platform.

12.2. The current version of the Policy is always published on the Platform, including the official website at: https://steloapp.com/

12.3. In case of significant changes (e.g., changes in the purpose of data processing, circle of recipients, or expansion of Platform rights), Users will be informed via:

  • a pop-up message in the website/app interface of the Platform;
  • email (if available).

12.4. Continued use of the Platform after changes to the Policy is considered User consent to the updated terms.

13. Contact Information

For all personal data protection questions, please contact:

by Email: [email protected]
through the App Support Service (in the app functions)
at the address: 65007, Odessa region, city of Odessa, Novoshchipny Ryad street, building 15/17, office 1.