1. Controller
Varsyra
E-Mail: support@varsyra.com
2. Data we process
Email address (account, login links, transactional email), Telegram username (service delivery), payment metadata (subscription status, period, billing interval — card data is processed exclusively by Stripe), server logs (IP address, timestamp, requested page; for security and debugging).
3. Purposes and legal bases
Contract performance and account management (Art. 6(1)(b) GDPR), legal retention obligations (Art. 6(1)(c) GDPR), security and abuse prevention (Art. 6(1)(f) GDPR).
4. Processors and recipients
Payments are processed by Stripe; content is delivered via Telegram. Beyond that, we use carefully selected service providers as processors in the following categories (Art. 13(1)(e) GDPR): transactional email delivery (EU-hosted), web hosting, and database hosting (EU region). Data processing agreements (DPAs) are in place where applicable; a list of the specific processors is available on request.
5. Transfers to third countries
Individual providers may process data in the USA, based on the EU-US Data Privacy Framework and/or Standard Contractual Clauses (SCC). Telegram delivery takes place to perform the contract (Art. 49(1)(b) GDPR where applicable).
6. Retention
Account data for the duration of the contract; billing-relevant data per statutory retention periods (up to 10 years, § 147 AO); server logs normally no longer than 30 days.
7. Cookies
Only technically necessary cookies are used (session, language, checkout verification, referral code). No tracking, no advertising.
8. Your rights
You have the rights of access, rectification, erasure, restriction, data portability and objection (Art. 15–21 GDPR), and the right to lodge a complaint with a supervisory authority. Contact: support@varsyra.com.