EU Privacy Policy Addendum (GDPR)
Supplement to the general Privacy Policy, for EEA / UK / Swiss users · Topchiyska Enterprises LLC (Michigan, USA)
Version 2.0 — Effective date: August 9, 2026
This addendum supplements the general Privacy Policy of Unicornin60.tech and applies specifically to users located in the European Economic Area (EEA), the United Kingdom, and Switzerland (“EU Users”). Where this addendum conflicts with the general Privacy Policy, this addendum controls for EU Users.
Note: This document governs personal-data handling under GDPR. It is separate from, and complements, the AI Transparency & Disclosure Notice, which governs AI Act obligations.
1. Data Controller
Topchiyska Enterprises LLC, a limited liability company organized under the laws of the State of Michigan, USA, is the data controller responsible for your personal data.
Contact: admin@topchiyska.com
2. EU Representative
Topchiyska Enterprises LLC has assessed its processing activities and currently relies on the exemption under Article 27(2) of the GDPR, as its processing of EU personal data is occasional, does not include special category data on a large scale, and is unlikely to result in a risk to the rights and freedoms of data subjects given the current limited scale of EU operations. This assessment will be revisited, and a formal EU representative appointed, as EU customer volume grows.
3. Legal Bases for Processing
We process personal data under the following legal bases:
- Contract performance — to create your account, deliver reports, and provide the subscription service you purchased.
- Consent — for optional cookies, marketing communications, and any AI processing that requires opt-in under local law.
- Legitimate interests — for fraud prevention, service security, and product improvement, balanced against your rights.
- Legal obligation — for tax, accounting, and regulatory recordkeeping.
4. What We Collect
- Account data: name, email, password hash, billing address.
- Business input data: the business ideas, locations, and details you submit to generate reports.
- Usage data: log-in times, feature usage, device/browser metadata.
- Payment data: processed by our payment processor; we do not store full card numbers.
5. Your Rights Under GDPR
As an EU User, you have the right to:
- Access the personal data we hold about you.
- Rectify inaccurate or incomplete data.
- Erase your data (“right to be forgotten”), subject to legal retention requirements.
- Restrict or object to certain processing.
- Data portability — receive your data in a machine-readable format.
- Withdraw consent at any time where processing is based on consent.
- Lodge a complaint with your local Data Protection Authority.
To exercise any of these rights, contact us at: admin@topchiyska.com
We will respond within one month, as required by Article 12(3) GDPR.
6. Data Retention
We retain personal data only as long as necessary to provide the service, comply with legal obligations, and resolve disputes. Account and report data is deleted or anonymized:
Retention: 90 days
7. International Data Transfers
Because Unicornin60.tech is operated from the United States, your data will be transferred outside the EEA. See the separate International Data Transfer Notice for the safeguards we apply.
8. Subprocessors
A current list of subprocessors (hosting, AI model providers, payment processing, analytics, email delivery) is maintained at:
- Vercel — website hosting and deployment
- Supabase — database, authentication, and backend storage
- Resend — transactional and inbound email delivery
- Stripe — payment processing