Privacy Policy

This Privacy Policy defines the procedure for the processing and protection of personal data on the OceanTheme website located at https://www.oceantheme.org/.

This Policy applies to data that the Website Administration may obtain from visitors and users when they use the Website, register an Account, arrange Access, make payments, submit requests, or otherwise interact with the Website.

1. General Provisions

1.1. For the purposes of this Policy, the Website Administration acts as the person responsible for determining the purposes and means of processing personal data in connection with the Website. Depending on the applicable law and jurisdiction, the Website Administration may be referred to as the data controller, operator, business, owner, or another similar term.

1.2. The Website Administration processes personal data lawfully, fairly, transparently, and only to the extent reasonably necessary for operation of the Website, user registration, provision of Access, handling requests, confirming payments, ensuring security, preventing abuse, sending service and, where agreed by the User or otherwise permitted by law, informational and promotional messages, and fulfilling obligations established by applicable law.

1.3. The Website Administration does not intend to collect unnecessary personal data. However, certain technical, account, payment-related, communication, analytics, and security data may be required for the Website and related services to function properly.

1.4. This Policy applies to all Website visitors, registered users, customers, and persons contacting the Website through forms, email, or other communication channels.

2. What Personal Data May Be Processed

Depending on how the User interacts with the Website, the Website Administration may process the following data.

2.1. Account Data

The following data may be processed:

• email address;
• login, username, display name, or pseudonym, if specified by the User during registration or in the Account;
• service-related account information required for operation of the Website, including account status, access term, activation history, and other technically related account parameters.

2.2. Request Data

If the User contacts the Website through a feedback form, by email, or in any other way, the Website Administration may process:

• name;
• email address;
• subject of the request;
• message text;
• other information that the User provides on their own initiative.

2.3. Data Related to Access Arrangement and Payment

The Website Administration may process information necessary to confirm and support payment, including:

• order, payment, operation, or transaction identifier;
• selected plan or access period;
• date and time of order placement and payment;
• payment amount and status;
• payer’s email address, if transmitted by the payment service or specified by the User;
• other information necessary to verify disputed operations, issue refunds, and fulfill obligations to the User.

The Website Administration does not receive, collect, or store full bank card details of Users on the Website, including card number, CVC/CVV, expiration date, or any similar payment data. Such data is entered directly by the User on secure pages of third-party payment services, which independently process it in accordance with their own rules and the requirements of applicable law.

2.4. Technical Data

When the Website is used, the following may be processed automatically:

• IP address;
• data from cookies and similar technologies;
• information about the browser, device, operating system, and user-agent;
• date and time of the visit;
• addresses of requested pages;
• referrer, if transmitted by the browser;
• session, authorization, and personal account activity information;
• server log data and other technical information necessary for operation, analytics, and protection of the Website.

2.5. Consent and Preference Data

Where the Website uses consent notices, checkboxes, cookie settings, mailing preferences, or similar mechanisms, the Website Administration may store evidence of the User’s choices, including the date and time of consent, email address, IP address, the consent text shown to the User, policy version, and the relevant action performed by the User.

3. Purposes of Personal Data Processing

The Website Administration processes personal data for the following purposes:

• registering the User on the Website and maintaining the Account;
• providing access to the personal account area, repository, materials catalogue, downloads, and other Website functions;
• identifying the User when signing in to the Account and using the Website functionality;
• performing obligations under the Terms of Service and other Website rules;
• confirming payment, granting access after payment, verifying payments, processing refunds, and handling disputed operations;
• sending service notifications related to registration, access, account security, payment, and operation of the Website;
• sending informational and promotional messages about OceanTheme, Website updates, new or updated materials, plans, offers, promotions, and related services, where the User has agreed to receive such messages or where such communication is otherwise permitted by applicable law;
• receiving and processing requests, applications, questions, and claims;
• ensuring Website security, preventing fraud, abuse, unauthorized access, and other unlawful actions;
• maintaining technical logs, backups, and stable operation of the Website;
• analyzing Website use, improving structure, interface, performance, and service quality;
• fulfilling obligations established by applicable law.

4. Legal Bases for Personal Data Processing

The Website Administration processes personal data on one or more of the following legal bases:

• processing is necessary for the conclusion and performance of a contract to which the User is a party, including the Terms of Service;
• processing is necessary for compliance with obligations imposed on the Website Administration by applicable law;
• processing is carried out with the User’s consent where such consent is required;
• processing is necessary for the Website Administration’s legitimate interests, including ensuring Website security, preventing fraud, and protecting the rights of the Website Administration and users, provided that the User’s rights and freedoms are not infringed.

Where processing is based on consent, the User may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal and does not affect processing that is required for contract performance, legal compliance, security, dispute handling, or other lawful purposes.

5. Personal Data Processing Procedure

5.1. Personal data may be processed using automation tools, without using such tools, or by mixed means.

5.2. The Website Administration receives personal data:

• directly from the User;
• from forms completed on the Website;
• from data automatically transmitted by the User’s browser and device when the Website is used;
• from payment services to the extent necessary to confirm payment, verify operations, process refunds, and fulfill obligations;
• from technical, hosting, analytics, security, communication, or authorization services connected to the Website;
• from other lawful sources, but only where this is connected with the purposes described in this Policy.

5.3. The Website Administration does not sell personal data and does not disclose it to third parties without lawful grounds, except where this is necessary:

• for operation of the Website and related technical infrastructure;
• for processing payments, refunds, transaction checks, and fulfillment of financial obligations;
• for hosting, content delivery, attack protection, backup, web analytics, anti-spam and anti-fraud protection, email delivery, technical notifications, and supporting operation of the Website;
• for user authentication through third-party services, if the User chooses such method;
• for compliance with legal requirements, court acts, and lawful requests of authorized bodies;
• for protection of the Website Administration’s rights and legitimate interests in the event of a dispute, claim, or abuse investigation.

5.4. Persons and services entrusted by the Website Administration with data processing or granted access to data within relationships permitted by law must ensure confidentiality and security of such data to the extent required by applicable law and contractual obligations.

5.5. If service providers located in other countries are used for operation of the Website, personal data may be transferred and processed outside the User’s country. In such cases, the Website Administration takes reasonable measures to organize such transfer lawfully and securely to the extent required by applicable law.

6. Service, Informational and Promotional Communications

6.1. The Website may send service messages that are necessary for registration, Account operation, paid Access, payment confirmation, security, password recovery, technical notifications, changes to terms, and other matters related to the User’s use of the Website. Such service messages are not considered optional marketing communications.

6.2. The Website may also send informational and promotional messages about OceanTheme, Website updates, new or updated materials, plans, offers, promotions, and related services to the email address provided by the User where the User has agreed to receive such messages during registration, checkout, subscription, or another Website interaction, or where such communication is otherwise permitted by applicable law.

6.3. By registering on the Website and ticking a checkbox that refers to this Privacy Policy, the Terms of Service, and receipt of service, informational and promotional messages, the User confirms their consent to receive such messages at the email address provided by the User.

6.4. The User may opt out of informational and promotional messages at any time by using an unsubscribe link, replying to the message where technically supported, or contacting the Website Administration through the contact details provided on the Website. Opting out of promotional messages does not prevent the Website from sending service messages necessary for the User’s Account, Access, payments, security, or legal notices.

6.5. The Website Administration may keep records of consent and opt-out requests to prove compliance, prevent unwanted communications, and protect its rights in case of disputes or complaints.

7. Analytics and Technical Tools

7.1. The Website may use web analytics services and other technical tools, including tools similar to Google Analytics, Yandex Metrica, server-side statistics, security monitoring, anti-spam tools, and performance diagnostics, if such tools are enabled on the Website.

7.2. When such services are used, technical data may be processed, including IP address, cookies, browser and device data, information about Website actions, traffic source, time of visit, and other statistical parameters.

7.3. The Website Administration uses such data to analyze operation of the Website, improve functionality, identify errors, assess demand for sections, improve service quality, and protect the Website.

7.4. The Website Administration does not intentionally transmit full bank card data, passwords, private correspondence, or other sensitive information to analytics services. Where session recording or behavior analytics tools are used, reasonable measures should be taken to avoid recording passwords, payment credentials, and other data not intended for analytics.

8. Cookies

8.1. The Website uses cookies and similar technologies necessary for proper operation of the Website, saving user settings, analyzing Website usage, ensuring security, and, where applicable settings exist, improving marketing and analytics functions.

8.2. The Website may use the following categories of cookies:

• strictly necessary cookies — for operation of the Website, authorization, security, sessions, and basic functionality;
• functional cookies — for saving certain user settings and improving usability;
• analytics cookies — for assessing traffic, performance, and user behavior on the Website;
• marketing cookies — if used, for assessing advertising effectiveness, personalizing offers, and limiting repeated display of ads.

8.3. Some cookies are technically necessary. Disabling such cookies in the User’s browser may result in incorrect operation of the Website, inability to sign in to the Account, and malfunction of authorization, forms, and certain functions.

8.4. Cookies that are not strictly necessary for operation of the Website may be used after obtaining the User’s consent where such consent is required by applicable law. In other cases, the Website may rely on another lawful basis available under applicable law.

8.5. The User may manage cookies through the cookie banner or settings tool, if available on the Website, and through browser settings, including restricting, disabling, or deleting cookies.

8.6. If the User refuses or disables certain cookies, some Website functions, analytics, personalization, or convenience features may be limited or unavailable.

9. Personal Data Retention Periods

9.1. Personal data is stored no longer than required by the purposes of processing, the terms of contractual relations, the requirements of applicable law, and the need to protect the Website Administration’s rights and legitimate interests.

9.2. In particular:

• account data may be stored for the duration of the Account and for a reasonable period after its termination, unless otherwise required by law or necessary for dispute resolution;
• payment and transaction data may be stored for the periods necessary for accounting, confirmation of operations, refunds, resolution of claims, and compliance with legal requirements;
• requests and correspondence may be stored for the period necessary to review the request and protect the interests of the parties;
• technical journals and logs may be stored for the period justified by security, diagnostics, and stable operation of the Website.

9.3. Once the purposes of processing have been achieved, or when such purposes are no longer needed, personal data shall be deleted, destroyed, or anonymized unless otherwise provided by applicable law.

10. User Rights

10.1. In the cases and to the extent provided by applicable law, the User has the right to:

• obtain information about the processing of their personal data;
• request rectification of their personal data if it is incomplete, outdated, or inaccurate;
• request deletion, restriction of processing, or provision of a copy of their personal data where lawful grounds exist;
• object to certain types of processing in cases where such right is provided by law;
• withdraw consent to personal data processing in cases where processing is based on consent;
• opt out of informational and promotional communications;
• submit a request regarding personal data processing using the Website Administration’s contact details.

10.2. The User’s rights are not absolute and may be limited in cases where the Website Administration is entitled or obliged to continue processing data in order to perform a contract, comply with legal requirements, ensure security, prevent fraud, establish, exercise, or defend legal claims, as well as in other cases provided by applicable law.

10.3. If the User does not provide data necessary for Account registration, payment, security, or provision of Access, certain Website functions or the entire service may be unavailable.

11. Personal Data Protection Measures

The Website Administration takes necessary legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, dissemination, provision, copying, and other unlawful actions.

Such measures may include:

• access control and segregation;
• use of authorization and authentication tools;
• application of protection mechanisms at the CMS, server, hosting, and software-environment level;
• backup procedures;
• monitoring of security events and technical logs;
• other measures reasonably necessary to protect data and ensure stable Website operation.

12. Requests Regarding Personal Data

12.1. For issues related to personal data processing, data clarification, withdrawal of consent, restriction of processing, deletion of an Account, and other requests, the User may contact the Website Administration by email address and contact form indicated on the Website.

12.2. The Website Administration may request information sufficient to confirm the applicant’s identity and verify authority where this is necessary for proper handling of the request.

12.3. The Website Administration shall review requests within a reasonable period or within the period expressly provided by applicable law.

13. Changes to the Policy

13.1. The Website Administration may amend this Policy.

13.2. A new version of the Policy enters into force from the moment it is posted on the Website, unless another effective date is specified in the new version.

13.3. The current version of the Policy must always be available on the Website.