Privacy Policy

This application provides a detailed 3D visualization of the human face, developed for educational purposes in the fields of aesthetic medicine, injectable cosmetology, and surgical anatomy. The application is designed to support professional training and is not a medical device.

We collect and process only the minimum amount of personal data required to provide you with secure access to the application. The app is intended for professional users and students over the age of 16.

The controller responsible for processing your personal data is:

• LLC “TOTIS Distribution“
• 66 Mala Arnautska Street, Odesa, Odesa Oblast, 65012, Ukraine
• Email: osgroupl976@gmail.com
• Privacy Contact: +380 95 743 0155

• Identification Data: your name, used to identify you as a student attending lectures.
• Account Credentials: email address and password (generated for account access). Passwords are stored securely in an encrypted and hashed format and are never shared with third parties.
• Technical Data: device type, operating system, IP address, log files, crash reports.
• Usage Data: information about how you interact with the application (modules accessed, time of use).

We do not collect sensitive categories of personal data such as biometric, health, or medical records.

• Direct Input: name, email, and password provided during account creation.
• Automatic Collection: analytics, crash reporting, and log data generated during app use.
• Third-Party Services: hosting providers, analytics tools (e.g., Google Analytics, Meta tools), or payment processors if used.

• To create and manage your account and provide access to educational content (Art. 6(1)(b) GDPR – performance of a contract).
• To identify students during lecture access and maintain attendance records (legitimate interest – Art. 6(1)(f) GDPR).
• To ensure the security and functionality of the application (legitimate interest – Art. 6(1)(f) GDPR).
• To comply with legal obligations where applicable (Art. 6(1)(c) GDPR).
• To send newsletters or updates if you have explicitly subscribed (consent – Art. 6(1)(a) GDPR).

We may share personal data only with trusted service providers that support our app operations:

• Cloud Hosting Providers (e.g., AWS, Google Cloud, Microsoft Azure).
• Analytics & Crash Reporting Tools (e.g., Google Analytics, Meta Pixel).
• Payment Systems (e.g., PayPal, Stripe) if applicable.

We do not sell or rent personal data to third parties.

7.1 What Are Cookies?

Cookies are small text files placed on your device when you use our application or website. They help us improve functionality, understand user behavior, and provide a better user experience.

7.2 Types of Cookies We Use

• Essential Cookies: Required for the app to function properly (e.g., login, session management).
• Functional Cookies: Remember your preferences, such as display settings.
• Analytical Cookies: Help us understand how users interact with the app (usage statistics, crash reports).
• Marketing Cookies (if applicable): Used only if you consent to receiving personalized advertising.

7.3 Why We Use Cookies

• To ensure proper app functionality.
• To improve user experience and app performance.
• To analyze usage trends and identify errors.
• To provide optional personalized content or marketing (with consent).

7.4 Managing Cookies

You can manage or disable cookies at any time through your device or browser settings. Essential cookies cannot be disabled as they are required for basic functionality. For non-essential cookies (analytics, marketing), you may choose “Accept All,” “Reject All,” or “Customize” through the cookie banner provided.

7.5 Third-Party Cookies

Some cookies may be placed by third-party service providers (e.g., analytics, hosting, social login). These providers process data according to their own privacy policies and must comply with GDPR.

7.6 Updates to Cookie Usage

We may update our use of cookies from time to time. Any changes will be reflected in this Privacy Policy.

• Account data (name, email, password): stored until the account is deleted by the user or upon request.
• Technical and usage data: retained for a limited period for analytics and troubleshooting.
• Marketing data (if consented): deleted upon withdrawal of consent.

• Passwords are stored in encrypted and hashed form.
• Access to personal data is restricted to authorized staff only.
• Data is transmitted over secure (SSL/TLS) connections.

You may request access, correction, or deletion of your account data (name, email, password). You may also exercise the following GDPR rights:

• Right to restriction of processing.
• Right to data portability.
• Right to object to processing.
• Right not to be subject to automated decision-making or profiling.

To exercise these rights, contact us at it@totispharma.com.

This application is not intended for children under the age of 16. We do not knowingly collect data from children. If we learn that a child has provided personal data, we will promptly delete it.

We will only send you newsletters or promotional materials if you have explicitly opted in. Every communication will include an opt-out option. If you unsubscribe, your data will be removed from marketing lists.

We may update this Privacy Policy from time to time to reflect changes in technology, legal requirements, or our practices. Updates will be posted within the app and/or on our official website with a new “last updated” date.

This application is provided for educational purposes only. It should not be used as a substitute for professional medical training, certification, or clinical decision-making.