Privacy Policy

Last Updated: 18 August 2026

Who we are

This Privacy and Cookie Policy explains in detail how ValsyDev LLC ("ValsyDev", "the Company", "we", "us", or "our") collects, uses, processes, stores, and protects your personal information when you interact with Selba (the "Service"), our AI-powered platform that helps online sellers generate and publish product card content for marketplaces such as Prom.ua, Rozetka, and Epicentr K, available at https://selba.ai and its subdomains (the "Website").

ValsyDev LLC is registered in Delaware, United States, with product, engineering, and support operations carried out in part from Ukraine, serving sellers and businesses primarily in Ukraine and the broader CIS e-commerce market, as well as other jurisdictions. Depending on the category of data and the applicable law, ValsyDev acts either as the "controller" (within the meaning of the GDPR) or as "володілець персональних даних" (within the meaning of the Law of Ukraine "On Personal Data Protection" No. 2297-VI, 2010) responsible for determining how and why your personal data is processed; see the "Roles and Applicable Law" section below.

If you have any questions regarding this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details provided in the "Contact Details" section at the end of this document.

Roles and Applicable Law

Because our users are located primarily in Ukraine, with some users in the EU, UK, and elsewhere, this Policy is written to comply with:

• the Law of Ukraine "On Personal Data Protection" No. 2297-VI (2010), which is the primary applicable law for the majority of our users;
• where you are located in the European Economic Area or the United Kingdom, the GDPR and the UK Data Protection Act 2018;
• where you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the CPRA.

Where these laws use different terminology for the same role, we use them interchangeably: "controller" corresponds to "володілець персональних даних"; "processor" corresponds to "розпорядник персональних даних".

Types and Sources of Personal Data

For the purposes of this Policy, "personal data" (or "personal information") means any information that can directly or indirectly identify a living individual. We may collect, use, store, and transfer the following categories of personal data:

Identity Data. Includes your full name, and, where relevant, your company name and role.

Contact Data. Includes your email address, phone number, and any contact details you submit through registration or the contact form on the Website.

Account and Authentication Data. Includes your login email, password (stored as a secure hash, never in plain text), and, if you sign up using Google Sign-In, the basic profile data (name, email address) shared with us by Google under your authorization.

Financial and Subscription Data. Includes your selected plan (Free, Basic, or Pro), billing cycle (monthly or annual), credit/token consumption history, and payment status. Card and payment details are processed directly by our payment processor; ValsyDev does not store full card numbers on its own servers.

Catalog and Content Data. Includes the product data you upload to generate product cards — such as spreadsheet files (Excel/CSV), product photos, product names, descriptions, prices, and attributes ("Catalog Data"). Catalog Data is primarily business/commercial data about your products; where it happens to include personal data of third parties (e.g., a supplier's contact name embedded in a spreadsheet, or an identifiable individual in a product photo), you are responsible, as the party providing that data, for ensuring you have a lawful basis to share it with us. In this respect, ValsyDev acts as a data processor (розпорядник) on your behalf.

Marketplace Integration Data. Includes account identifiers, API keys, or authorization tokens you provide to connect your Prom.ua, Rozetka, Epicentr K, or other marketplace seller accounts, used solely to publish generated product cards directly to your store on your instruction.

Technical Data. Includes your IP address, browser type and version, operating system, device type, device identifiers, time zone settings, and other technical identifiers required for connectivity and security.

Usage Data. Includes data about how you use Selba — pages visited, features used, number of generations run, and generation success/failure events (relevant to credit refunds).

Communications Data. Includes messages you send us through the contact form (name, email, company, subject/topic, message body) or via our Telegram support channel.

Marketing and Communications Preferences. Includes your preferences regarding product updates, newsletters, and opt-in/opt-out status for marketing communications.

Sources of Data Collection

Information You Provide Directly: creating an account (via email/password or Google Sign-In) and completing your profile; uploading Catalog Data (spreadsheets, photos, product attributes) to generate product cards; connecting a marketplace seller account for direct publishing; completing the contact form on the Website, or messaging us via Telegram or email; selecting a subscription plan and providing billing information.

Information Collected Automatically: each time you visit the Website or use the Service, we automatically collect certain technical and usage data through cookies, server logs, and analytics tools, including browser/device information, pages visited, session duration, and error logs relevant to troubleshooting generation issues.

Information Obtained from Third Parties: Google, if you choose to sign up or log in using Google Sign-In; our payment processor, which shares transaction status and subscription information (not full card data) with us; marketplace platforms (Prom.ua, Rozetka, Epicentr K), limited to the data needed to publish your product cards once you authorize the connection.

Lawful Bases for Processing Personal Data

Legal grounds include:

• Performance of a Contract — to create and manage your account, generate product cards, process subscription billing, and enable marketplace publishing;
• Legitimate Interests — to secure and improve the Service, prevent fraud and abuse of the credit system, and analyze usage patterns;
• Consent — for marketing communications, optional integrations, and use of your Catalog Data to improve or train our AI models (see below), which you may withdraw at any time;
• Legal Obligations — for accounting, tax, and regulatory compliance.

Use of Your Data to Improve or Train Our AI Models

Selba's generation engine includes a model that ValsyDev has fine-tuned on product-card data. Unless you opt out in your account privacy settings, we may use your Catalog Data, in anonymized or aggregated form, to evaluate, improve, and fine-tune this model and other models underlying the Service. We do not use identifiable personal data embedded in your Catalog Data (such as a named individual's contact details or an identifiable photo of a person) for this purpose; such elements are filtered or removed before any data is used for model improvement. [ПЛЕЙСХОЛДЕР: to be confirmed with the product/engineering team — exact anonymization method and whether raw Catalog Data is ever used prior to anonymization.]

You can withdraw your consent to this use, or object to it on legitimate-interest grounds, at any time in your account privacy settings, without affecting your ability to use the Service. Withdrawing consent does not remove any effect already incorporated into a model version trained before your withdrawal. Further detail is available in our Data Processing Addendum at [LINK / ПЛЕЙСХОЛДЕР].

Our Legitimate Interests

We rely on legitimate interests to:

• operate, secure, and improve Selba's product-card generation engine;
• detect and prevent abuse of free-tier credits or fraudulent account creation;
• analyze aggregate usage to improve generation quality and marketplace compatibility;
• manage internal operations, support, and dispute resolution.

Sharing of Personal Data

We share personal data only when necessary and under appropriate safeguards, with the following categories of recipients:

• Payment Processor ([ПЛЕЙСХОЛДЕР: name, e.g., Stripe]) — to process subscription payments (we do not receive or store your full card number);
• Cloud Hosting and Infrastructure Providers ([ПЛЕЙСХОЛДЕР: name(s) and hosting region(s)]) — to host the Service and your Catalog Data;
• AI Model Providers ([ПЛЕЙСХОЛДЕР: name, if a third-party model provider is used in addition to our own fine-tuned model]) — Catalog Data you submit is processed through underlying AI models to generate product card content; these providers process the data solely to return generation results and do not use it to train their own models on your behalf, except where you have separately agreed otherwise;
• Marketplace Platforms (Prom.ua, Rozetka, Epicentr K) — only when you authorize a connection, and only the product data needed to publish your listings;
• Professional Advisors — legal, accounting, and compliance consultants bound by confidentiality;
• Regulatory and Law Enforcement Authorities — where disclosure is required by law.

We do not sell, rent, or trade your personal information to third parties for monetary consideration. In the 12 months preceding the Last Updated date above, we have not sold personal information as defined under the CCPA/CPRA, and have not shared personal information for cross-context behavioral advertising. If this changes, we will update this Policy and provide the disclosures and opt-out mechanism required by the CCPA/CPRA.

We do not collect "sensitive personal information" as defined under the CCPA/CPRA in the ordinary course of providing the Service.

International Data Transfers

Your data may be processed or stored outside your country of residence, including in the United States, Ukraine, and other regions where our infrastructure, AI processing, and support partners operate ([ПЛЕЙСХОЛДЕР: list specific countries/regions once infrastructure is confirmed]).

• For users located in the EEA or UK: we use appropriate safeguards for such transfers, including the European Commission's Standard Contractual Clauses (SCCs) or the UK International Data Transfer Addendum, as applicable.
• For users located in Ukraine: transfers of your personal data outside Ukraine are made in compliance with the Law of Ukraine "On Personal Data Protection," including, where required, verifying that the recipient country ensures an adequate level of protection or is a party to Council of Europe Convention 108, or otherwise on the basis of your consent or another basis permitted by that law.

Data Retention

We retain personal data only for as long as necessary for the purposes described in this Policy:

• Account and Authentication Data: for as long as your account remains active, and for [ПЛЕЙСХОЛДЕР: proposed 12 months] after account closure, to allow reactivation and resolve disputes.
• Catalog Data (spreadsheets, photos): for as long as your account remains active; deleted within [ПЛЕЙСХОЛДЕР: proposed 90 days] of account closure, or sooner upon your request.
• Financial and Subscription Data: for the period required by applicable accounting and tax law ([ПЛЕЙСХОЛДЕР: proposed 3 years under Ukrainian accounting requirements — to be confirmed with our accountant] following the end of the relevant tax year).
• Contact-form and support communications: for as long as necessary to resolve your inquiry, and for [ПЛЕЙСХОЛДЕР: proposed 12 months] afterward for quality and record-keeping purposes.
• Data used for AI model improvement: once anonymized, this data is no longer linked to your identity and is not deleted on a per-account basis; you may opt out of future use as described above.

Your Data Protection Rights

You have the right to:

• Access — request a copy of the personal data we hold about you;
• Rectification — correct inaccurate or incomplete data;
• Erasure — request deletion of your data, including your account and Catalog Data, where legally permissible;
• Restriction — request that we limit processing of your data;
• Object — object to processing based on legitimate interest or direct marketing;
• Portability — request your data in a machine-readable format;
• Withdraw Consent — at any time, without affecting the lawfulness of prior processing.

If you are a California resident, you additionally have the right to know the categories and specific pieces of personal information we hold, to request deletion, to correct inaccurate information, to limit the use of sensitive personal information (though we do not collect it in the ordinary course), and to non-discrimination for exercising any of these rights — we will not deny you the Service, charge different prices, or provide a different level of quality solely because you exercised a CCPA right.

To exercise these rights, contact us using the details below. We may need to verify your identity before processing your request.

Right to Lodge a Complaint

• Users in Ukraine may lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights (Уповноважений Верховної Ради України з прав людини), who oversees compliance with the Law of Ukraine "On Personal Data Protection."
• Users in the EEA or UK may lodge a complaint with their local data protection supervisory authority.
• Users in California may contact the California Privacy Protection Agency or the California Attorney General's office.

We encourage you to contact us first so we can try to resolve your concern directly.

Automated Processing

Selba's product-card generation relies on AI models that process the Catalog Data you provide to produce structured product descriptions. This process is not used to make legal or similarly significant decisions about you as an individual; it is a content-generation tool operating on the product data you submit, and generated output should be reviewed by you before publishing.

Cookies and Similar Technologies

The Website uses cookies and similar technologies to operate correctly, remember your preferences, and understand how visitors use the site:

• Essential Cookies — required for login, session management, and core site functionality; these are set without requiring consent, as permitted by applicable law;
• Analytics Cookies — help us understand usage patterns and improve the Website and Service;
• Functional Cookies — remember settings such as language (Ukrainian/English);
• Marketing Cookies — where enabled, used to measure the performance of our marketing campaigns.

For Analytics, Functional (beyond strictly necessary session settings), and Marketing cookies, we request your prior consent through a cookie banner presented on your first visit, with the option to accept, reject, or configure preferences by category. You may withdraw or change your consent at any time through the cookie settings link in the Website footer. Browser-level controls remain available as an additional means to manage cookies, but do not replace the consent mechanism described here.

Integrations and Third-Party Data Use

When you connect a Google account (for sign-in) or a marketplace seller account (Prom.ua, Rozetka, Epicentr K) to Selba, we access only the data required for the requested functionality — authentication for Google Sign-In, or listing/publishing access for marketplace connections. We do not use this data for advertising, do not share it with third parties beyond what is needed to perform the integration, and do not retain it longer than necessary for that purpose.

Children's Privacy

The Service is not directed at, and we do not knowingly collect personal data from, individuals under 13 years of age or, where applicable, a higher minimum age required by local law. If we become aware that we have collected personal data from someone below the applicable minimum age without the legally required consent, we will delete that data and, where applicable, close the associated account. If you believe a child has provided us with personal data, please contact us using the details below.

If You Choose Not to Provide Certain Information

If you decline to provide data required for account creation, billing, or marketplace publishing, you may be unable to use the corresponding features of the Service.

Changes to This Privacy Policy

We may update this Policy periodically to reflect changes in our practices or legal requirements. Updates will be posted on this page with a revised "Last Updated" date. Continued use of the Service after changes take effect constitutes acceptance of the revised Policy. Where a change materially expands how we use your personal data (for example, a new category of sub-processor or a new purpose of processing), we will notify you by email or in-app notice before the change takes effect.

Contact Details

ValsyDev LLC

EIN Number: 30-1452842

Address: 16192 Coastal Highway, Lewes, Delaware 19958, County of Sussex, USA

Tel: +380 93 935 05 35

Email: accounts@valsydev.com

Telegram Support: https://t.me/aicell_ecom_bot

Ukrainian Parliament Commissioner for Human Rights (Уповноважений Верховної Ради України з прав людини): 21/8 Instytutska St., Kyiv, 01008, Ukraine.

© 2026 ValsyDev LLC. All rights reserved.