Privacy Policy

1. Introduction and Data Controller

This Privacy Policy explains how GiveawayOK collects, uses, and shares information about you when you use our website and services (collectively, the "Services").

The controller of your personal data and the operator of the Service is Individual Entrepreneur Нечаєва Галина Григорівна (RNOKPP 1973109344) (hereinafter — "we", "us", or "our"). Full details (including the postal address) are provided in the Terms of Service.

We respect your privacy and are committed to protecting your personal data. Please read this Privacy Policy carefully to understand our practices regarding your personal data.

Our Services are provided to help Instagram creators easily manage their giveaways. We focus on supporting Ukrainian users, while we are happy to welcome creators from around the world, except from the aggressor country, the russian federation, to join our platform.

2. Information We Collect

2.1 Information You Provide to Us

When you register for and use our Services, we may collect the following information:

Email address and account credentials
Information about the Instagram Professional Account that you authorize us to access
Communications you send to us
Country/region information for service localization

2.2 Information We Collect Automatically

When you use our Services, we may automatically collect certain information, including:

Log information (such as IP address, browser type, referring/exit pages, operating system)
Device information (such as device ID, device type)
Usage information (such as how you use our Services)
Location data (country/region level only)
Cookies and similar technologies

2.3 Information From Instagram and the Meta API

When you connect your Instagram Professional Account, we access the following information through the Meta API:

Basic account information
The content of the post or reel you select for your contest
Comments on the selected post or reel

We only access the information necessary to provide our Services and in compliance with Meta's Platform Terms and Developer Policies.

3. How We Use Your Information

We use the information we collect for the following purposes:

To provide, maintain, and improve our Services
To manage your account and provide customer support
To communicate with you about our Services
To provide localized experiences based on your region
To comply with legal obligations
To protect our rights and prevent misuse
To analyze and improve our Services

4. Legal Bases for Processing

We process your personal data on the following legal bases (for users to whom the EU General Data Protection Regulation (GDPR) applies — in accordance with Article 6 of the GDPR):

Performance of a contract — to provide the Services, manage your account, and process payments (processing is necessary for the performance of a contract to which you are a party).
Consent — to access your Instagram account data through the Meta API, for optional cookies, and for marketing communications. You may withdraw your consent at any time.
Legitimate interest — to ensure the security of the Service, to prevent misuse and fraud, and for analytics and improvement of the Services, where this is not overridden by your rights and interests.
Compliance with a legal obligation — to comply with tax, accounting, and other legal requirements (for example, retaining records of transactions).

We do not sell your personal information to third parties. We may share your information in the following circumstances:

5.1 Service Providers (Processors)

We engage third-party service providers (personal data processors) who process data on our behalf and in accordance with our instructions. The categories of such providers include:

Meta Platforms (Instagram Graph API) — to connect to your Instagram professional account and process contest data;
Payment providers — to process payments (we do not store full payment card details);
Hosting and cloud infrastructure providers — to host and operate the Service;
Email delivery services — for transactional and service communications;
Analytics services — to understand and improve the use of the Service.

Upon request sent to [email protected], we can provide an up-to-date list of the specific providers.

5.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

5.3 Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

We may share your information with third parties when you have given us your consent to do so.

6. Data Retention

We retain your personal information only for as long as necessary for the purposes set out in this Policy. In particular:

Account and profile data — for the duration of your account and a reasonable period after its closure;
Data obtained from Instagram/Meta (posts, comments, access tokens) — for the time necessary to conduct the relevant giveaway, after which it is deleted or anonymized;
Payment and accounting records — for the periods established by the tax and accounting legislation of Ukraine;
Logs and analytics data — for a limited period for security purposes and to improve the Services.

Upon expiry of the relevant retention period, the data is deleted or anonymized, except in cases where its further retention is required by law.

7. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

7.1 Rights of Users in Ukraine

In accordance with the legislation of Ukraine on the protection of personal data, you have the following rights:

Access: You can request a copy of the personal information we hold about you.
Correction: You can request that we correct inaccurate or incomplete information.
Deletion: You can request that we delete your personal information in certain circumstances.
Restriction: You can request that we restrict the processing of your information in certain circumstances.
Data Portability: You can request a copy of the information you have provided to us in a structured, commonly used, electronic format.
Objection: You can object to our processing of your personal information in certain circumstances.

7.2 European Economic Area (EEA) and United Kingdom Users

If you are located in the EEA or the United Kingdom, you have rights under the GDPR and UK data protection law, in particular the rights listed in Section 7.1, as well as the right to withdraw any consent given at any time and the right to lodge a complaint with the data protection supervisory authority in your country of residence.

7.3 Other Jurisdictions

If you are located in other jurisdictions, you may have rights under applicable local data protection laws. Please contact us to learn more about your rights.

To exercise these rights, please contact us using the information provided in the "Contact Us" section.

7.4 How to Request Data Deletion

We are committed to providing you with clear and easy ways to request the deletion of your personal data. You can request data deletion through the following methods:

Manual Data Deletion Requests

You can request the deletion of your personal data by:

Email Request: Send an email to [email protected] with the subject line "Data Deletion Request" and include:
- Your full name
- The email address associated with your account
- The specific data you want deleted (or request complete deletion)
- The reason for deletion (optional)

What Data Will Be Deleted

When you request data deletion, we will delete:

Your account information and profile data
All data collected from your connected Facebook and Instagram accounts, including:
- Business page information
- Business manager data
- The content of posts and reels we accessed
- Comments we collected for giveaway purposes
- access tokens
Usage logs and analytics data associated with your account
Communication history with our support team

Data Deletion Timeline

Standard Requests: Personal data will be deleted within 30 days of receiving your request
Complex Requests: May take up to 90 days for complete deletion if technical complexities arise
Legal Obligations: Some data may be retained if required by law, but only for the minimum period necessary

Confirmation

We will confirm completion of your data deletion request via email within the specified timeframe. If you do not receive confirmation, please contact us again.

8. Data Security

We have implemented appropriate technical and organizational measures to protect your personal information from unauthorized access, loss, misuse, or alteration. However, no method of transmission over the Internet or method of electronic storage is 100% secure, and we cannot guarantee absolute security.

9. International Data Transfers

We are based in Ukraine, and the information we collect may be stored and processed in Ukraine or in other countries where we or our service providers maintain facilities.

Please note that, as of the date of this Policy, the European Commission has not adopted an adequacy decision regarding the level of data protection in Ukraine. Therefore, in cases where we receive personal data from the European Economic Area or the United Kingdom and transfer it to Ukraine or other countries outside the EEA, we ensure that appropriate safeguards provided for by law are applied (in particular, the Standard Contractual Clauses (SCC) approved by the European Commission, or other lawful transfer mechanisms) to protect your information.

10. EU/UK Representative

In cases where this is required by Article 27 of the GDPR or the relevant legislation of the United Kingdom, we will take steps to appoint a representative in the EU and/or the United Kingdom. If such a representative is appointed, their contact details will be published in this Policy. Until then, you may address all data protection matters directly to us at [email protected].

11. Children's Privacy

Our Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete such information as soon as possible.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you as required by applicable law, which may include posting the new Privacy Policy on our website and updating the "Last Updated" date at the bottom of the page.

13. Third-Party Links and Services

Our Services may contain links to third-party websites, apps, or other services. We are not responsible for the privacy practices of these third parties, and we encourage you to read their privacy policies before providing any information to them.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Data controller: Individual Entrepreneur Нечаєва Галина Григорівна (RNOKPP 1973109344) Email: [email protected]

Full details are provided in the Terms of Service.

Last Updated: July 05, 2026