MyFunction

Legal documents

Privacy Policy

Version v2.0 · effective 16 October 2026

Controller (data controller): Daniil Polinovskyi, natural person (private individual), Norway, Moss
Data-protection contact: [email protected]

Who the Controller is. The Controller is a natural person (a private developer), not a company. This does not set aside GDPR: the "personal/household purposes" exemption (GDPR Art. 2(2)(c)) does not apply, because the Service is publicly available.
Applicable law. The Controller is located in Norway, which is part of the EEA, so the processing of personal data is governed by the GDPR (Regulation (EU) 2016/679), as implemented by the Norwegian Personal Data Act (Personopplysningsloven). If the Service is used by a person in Ukraine, the Law of Ukraine "On Personal Data Protection" also applies (Section 16).

This document describes what data we collect, on what basis, how we store and protect it, to whom we transfer it, and how you can exercise your rights under the GDPR.

1. General provisions

1.1. This Policy applies to all data the Controller receives through the Service: the web application (Flutter Web) on the domain myfunction.app, the public profile pages myfunction.app/s/…, and related server components.

1.2. Under the GDPR, the Controller acts as the data controller; the service providers engaged act as data processors on the Controller's behalf (Section 7).

1.3. Processing is carried out only to the extent minimally necessary to operate the Service (the minimisation principle, GDPR Art. 5(1)(c)).

2. Key concepts

3. What data we process

3.1. Account data

3.2. Profile data

3.3. What we do not collect

The Controller does not request precise geolocation, contacts, or access to the camera and gallery, except where the User themselves uploads an image of their own choice. Card payment details are not passed directly to the Controller.

3.4. Technical data and security

3.5. Data that becomes public (important)

When a Specialist publishes their profile, the following data becomes available to any internet visitor on the page myfunction.app/s/<slug> and in the card inside the app: name, city, category, avatar, headline and description; contacts (phone, email, Telegram) if the Specialist provided them; portfolio images and captions (via temporary signed links).

Do not publish data you do not want to disclose publicly. Contacts are shown to third parties only after the profile is published. The legal basis is your consent, which you can withdraw by unpublishing.

4. Purposes and legal bases (GDPR Art. 6)

PurposeDataBasis (Art. 6)
Registration, sign-in, account managementemail, password (hash), idconsent; contract — (a),(b)
Profile and onboardingprofile, role, regioncontract — (b)
Publishing a Specialist profilepublic fields, contacts, portfolioconsent — (a)
Catalog and specialist searchpublic fieldscontract — (b)
Service and transactional emailsemailcontract — (b)
Security, abuse and spam preventionaccess log, anti-bot datalegitimate interest — (f)
Service improvementanonymised statisticslegitimate interest — (f)

Where the basis is consent, you may withdraw it at any time (this does not affect the lawfulness of processing before the withdrawal).

5. Special categories and profiling

5.1. The Controller does not request special categories of data (GDPR Art. 9: health, ethnicity, religious and political views, etc.). Please do not place them in public profile or portfolio fields.

5.2. The Controller does not use automated decision-making (GDPR Art. 22). The catalog/search consists of simple filter-based queries.

6. Cookies, local storage, and cache

7. Transfers to processors and third parties

The Controller engages processors on its behalf (GDPR Art. 28), with a DPA in place:

The Controller does not sell personal data. Transfers are possible only to the processors above, on a lawful request from public authorities, or with the User's consent.

8. Transfers outside the EEA (Chapter V)

Data is stored on servers within the EEA (including the Supabase database hosting region — Europe). The Controller does not carry out targeted transfers of personal data outside the EEA. If in the future a processor places servers outside the EEA, the transfer will be carried out only where appropriate safeguards exist (adequacy / SCC 2021/914).

9. Data storage and protection

10. Retention periods (Art. 5(1)(e))

11. Account deletion and the right to erasure

The User may delete the account themselves: "Settings → Delete account". The profile, contacts, portfolio, uploaded files, and sign-in data are irreversibly deleted. This implements the right to erasure (GDPR Art. 17).

12. Your rights under the GDPR

A response to a request is provided within 1 month (may be extended up to 3 months).

Right to lodge a complaint:
Norway — Datatilsynet (datatilsynet.no) · another EEA country — your local supervisory authority · Ukraine — see Section 16.

13. Minors

The Service is intended for persons aged 16 and over. The age of 16 is chosen by the Controller as the minimum threshold (in Norway the basic "digital age of consent" is 13, GDPR Art. 8). Data of persons below the threshold is not knowingly collected; if identified, it is deleted.

14. Changes to this Policy

A new version is published on this page with a date and takes effect upon publication unless otherwise stated. The Controller aims to notify of material changes through the Service.

15. Contact

Controller: Daniil Polinovskyi, natural person, Norway, Moss
Data-protection email: [email protected]

16. Ukraine

16.1. If the Service is used by a person in Ukraine, the Law of Ukraine "On Personal Data Protection" No. 2297‑VI additionally applies.

16.2. Data-subject rights: to know the composition of the data; to obtain access; to request modification/deletion; to withdraw consent; to contest processing.

16.3. The supervisory authority in Ukraine is the Ukrainian Parliament Commissioner for Human Rights (Ombudsman for personal data protection).

16.4. Data is processed on servers within the EEA (see the data-location section). If applicable Ukrainian law requires additional measures (for example, database localisation), the Controller will adopt them and reflect them in this Policy.

This document is a standard template adapted to the actual data processing and does not constitute legal advice. Before publication — review by a lawyer (GDPR / personopplysningsrett).