{"effective_date":"2026-10-11","role_model":{"feedback_controller":"individual_requester","feedback_processor":"MB Inista IT","account_administration_controller":"MB Inista IT"},"purpose":"Voluntary independent professional development of the individual requester.","contacts":{"inista_privacy":"inista.it@gmail.com"},"complaint_route":"You may lodge a complaint with the Lithuanian State Data Protection Inspectorate (VDAI) at https:\/\/vdai.lrv.lt\/en\/ or ada@ada.lt.","data_flow":["A feedbacker submits plain text through a cookie-free public form for the individual requester\u2019s independent professional development.","Symfony validates the text, nonce, permitted-purpose prompt, and rolling channel quota before PostgreSQL stores a conversation and message atomically.","A secret return link is shown after the first accepted submission and remains usable until it is revoked or the conversation is deleted; after 24-hour retry material expires, only its lookup hash remains.","The authenticated individual requester reads and replies through an owner-scoped inbox.","An optional requester-authored report sends an opaque reference and description through the configured Symfony Mailer transport to the private report mailbox without copying feedback automatically.","An authenticated requester who opens paid-plan or subscription-management surfaces interacts with Stripe-hosted Pricing Table, Checkout, or Customer Portal pages; Stripe\/Link is the merchant of record for Managed Payments transactions."],"subprocessors":[{"name":"Hostinger","legal_entity":"Hostinger International Ltd., 61 Lordou Vironos Street, 6023 Larnaca, Cyprus","purpose":"EU-hosted application, PostgreSQL, network, and rolling VPS snapshots","processing_location":"European Union, under the approved VPS service configuration","transfer_safeguard":"Approved provider transfer terms, including Standard Contractual Clauses where required","status":"Candidate for live service; production terms, location, logging, snapshot, and retention controls remain launch-time verification gates"},{"name":"Google","legal_entity":"Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland","purpose":"Requester OAuth and, when an approved Google mailbox is configured through Symfony Mailer, report or Enterprise-message delivery","processing_location":"European Economic Area and additional locations covered by the approved provider terms","transfer_safeguard":"Approved provider transfer terms, including Standard Contractual Clauses where required","status":"Candidate for live service; production provider terms and the ordinary Gmail deviation require explicit owner approval before launch"}],"retention":[{"data":"Feedback messages","rule":"Each message expires no later than 12 months after its own receipt unless an earlier valid deletion instruction or documented legal hold applies; the requester cannot extend this maximum."},{"data":"Conversation and return-secret material","rule":"Retained while a message remains; live deletion is immediate, while snapshots may retain and restore prior data for up to 30 days."},{"data":"Form and idempotency hashes","rule":"No longer than 24 hours after their operational purpose ends."},{"data":"Daily quota usage","rule":"31 days."},{"data":"Requester OAuth identity and editable public display name","rule":"Active account lifetime, then verified closure or erasure within 30 days unless a narrow legal obligation applies."},{"data":"Requester-authored feedback report descriptions","rule":"Potentially sensitive support data retained under the approved support-record policy; mailbox retention remains policy-owned and is not enforced or periodically verified by the application."},{"data":"Permanent operator audit events","rule":"Retained indefinitely without feedback text or direct identity under the approved minimized-audit policy; residual linkability is an accepted limitation."}],"operator_claims":["Reverse-proxy diagnostics record only numeric HTTP and upstream statuses, including error responses; request metadata and unredacted proxy error logging are disabled.","Application and infrastructure logs do not retain feedback content, bearer secrets, public tokens, source addresses, referrers, or user agents from public routes.","The application increments aggregate daily operational counters without retaining public-route event records; the manual retention command removes counter rows older than 90 days.","The named operator runs retention and privacy checks manually; the MVP has no scheduler or external monitoring service."],"limitations":["An older Hostinger snapshot can resurrect an anonymous self-deletion because the MVP has no independent erasure ledger.","Permanent opaque audit identifiers may remain structurally linkable after selected mapping deletion.","Report-mailbox retention is policy-owned and is not enforced or periodically verified by the application.","Stripe-side payment, tax, dispute, invoice, and subscription records are governed by Stripe\/Link as merchant of record and are not deleted by application retention or erasure commands."]}