The personal data operator is GreenCats MMC (hereinafter “TheTochka”, “we”, “us”). This Privacy Policy describes what data TheTochka collects and processes when you use the TheTochka mobile application and the related website (collectively — the “Service”).
| Data category | Examples | Legal basis | Retention period |
|---|---|---|---|
| Account identification data | Email, username, UID | Contract | Until account deletion + 30 days |
| Premium subscription data | Status, entitlement, App Store transaction ID | Contract | Until account deletion + 5 years |
| Device technical data | OS, app version, Device ID | Legitimate interest | 90 days |
| Catalog usage data | Viewed cards, filters, comparisons | Legitimate interest | 12 months |
| Quote requests (CP) | Request ID, selected Provider, timestamp | Contract / consent | 24 months |
| Support chat correspondence | Messages related to quote requests | Contract | 24 months |
| Security logs | IP address, sign-in time, access recovery attempts | Legitimate interest / security | 90 days |
To use TheTochka you must register with a verified email address. Email is used for:
Data you enter in the catalog (saved comparisons, favorites) is stored in your account and is not shared with Providers without your explicit action (sending a quote request).
TheTochka automatically collects the minimum technical data needed to keep the Service working and secure:
Important limitations:
When you purchase, use, or cancel a TheTochka Premium subscription, we process the following data:
| Data | Purpose of processing | Basis |
|---|---|---|
| TheTochka account email and UID | Linking the subscription to the account; restoring purchases | Contract |
| Subscription status (active / expired / cancelled) | Providing Premium features; tracking quote-request quotas | Contract |
| Entitlement (access type) from RevenueCat | Unlocking Premium features in the app | Contract |
| Technical App Store transaction IDs | Purchase verification; user support; anti-fraud | Legitimate interest |
| Subscription status change history | Dispute resolution; access recovery; accounting | Legitimate interest / legal obligation |
Data we do not process under Premium: full bank card details, Apple account balance, or data about other App Store purchases outside TheTochka. That data is processed exclusively by Apple.
To manage subscriptions, TheTochka uses RevenueCat, Inc. (RevenueCat privacy policy). RevenueCat receives from us a user identifier and technical App Store transaction data. RevenueCat is a sub-processor and acts under a data processing agreement (DPA).
If you cancel auto-renewal through Apple, past transaction data is retained for accounting and possible dispute resolution for the period required by applicable law (typically 5 years). Functional Premium access ends when the paid period expires.
TheTochka may disclose user data to the following categories of recipients:
| Recipient | Purpose | Legal basis |
|---|---|---|
| Providers from the catalog | Delivering the user’s quote request | Consent (user action) |
| RevenueCat, Inc. | Managing subscriptions and entitlements | Contract / DPA |
| Apple Inc. | IAP payment processing, purchase verification | Contract / App Store terms |
| Cloud infrastructure providers | Hosting and running TheTochka backend | Contract / DPA |
| Analytics services | Aggregated usage statistics | Legitimate interest |
| Law enforcement authorities | Only when legally required | Legal obligation |
TheTochka does not sell users’ personal data and does not share it with ad networks, data brokers, or other commercial third parties outside the categories listed above.
Some processors (RevenueCat, Apple, cloud providers) may process data outside the user’s country of residence. TheTochka ensures such transfers rely on appropriate legal mechanisms (EU standard contractual clauses / adequacy decisions / other mechanisms depending on applicable law).
TheTochka applies technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction:
If a personal data breach that may harm users is discovered, TheTochka will notify affected users and regulators within the timeframes required by applicable law.
Retention periods are listed in the §2 table. After the period ends, data is deleted or anonymized.
Depending on applicable law, you may have the following rights regarding personal data processed by TheTochka:
To exercise your rights, contact privacy@thetochka.com. Response time is 30 days, extendable to 60 days for complex requests.
If you believe processing of your data violates applicable law, you may lodge a complaint with the data protection authority in your country of residence.
The TheTochka mobile app does not use traditional “cookies”, but may use similar technologies (App Tracking Transparency, Device ID). On first launch the app requests the relevant permissions in line with Apple’s ATT Framework.
The TheTochka website may use technical cookies required for the site to work. Analytics or marketing cookies are set only with the user’s explicit consent, which you may withdraw via browser settings or a consent management banner.
The TheTochka Service is not intended for persons under 18 (or another age of majority set in the user’s country). TheTochka does not knowingly collect children’s personal data. Detailed rules are in a separate Children’s Policy. If you learn that a minor registered an account, notify privacy@thetochka.com (subject: MINOR ACCOUNT) — we will delete the account within 72 hours.
TheTochka may update this Policy. For material changes (processing purposes, new data categories, new recipients) we will notify you by email and/or push notification at least 14 days before the changes take effect.
Continued use of the Service after that date means acceptance of the updated Policy. If you disagree with the changes, you may delete your account before the effective date.
The current English version of this Policy is always available at https://thetochka.com/privacy_en.html. The Russian version is at https://thetochka.com/privacy.html.
Operator: GreenCats MMC
Address: Azerbaijan — current operator address on request: legal@thetochka.com