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Privacy Policy

Effective: March 27, 2026 · Last Updated: March 27, 2026

Gokhshtein Media LLC (“Gokhshtein Media,” “we,” “us,” or “our”) is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our platform, newsletter, and related services (collectively, the “Services”). Please read this policy carefully. By using our Services, you consent to the practices described herein.

1. Information We Collect

1.1 Information You Provide Directly

We collect information you voluntarily provide when you:

  • Create an account: name, email address, username, password (stored in hashed form);
  • Subscribe to our newsletter or services: email address, subscription preferences, payment information;
  • Contact us or submit feedback: name, email address, message content;
  • Participate in community features: sentiment votes, comments, or other user-generated content;
  • Subscribe to push notifications: device token and notification preferences via OneSignal.

1.2 Automatically Collected Information

When you access the Services, we and our third-party partners automatically collect:

  • Log data: IP address, browser type and version, operating system, referring/exit URLs, date and time of access, pages viewed, and duration of visits;
  • Device information: device type, device identifiers, screen resolution, and language settings;
  • Usage data: features used, content viewed, search queries, clicks, and interactions;
  • Location data: general geographic location inferred from IP address (not precise GPS location);
  • Cookie and tracking data: as described in Section 4 below.

1.3 Information from Third Parties

We may receive information about you from third-party sources, including:

  • Social media platforms if you connect your account or interact with our social media presence;
  • Authentication providers if you use single sign-on (SSO) or OAuth login;
  • Analytics and advertising partners who provide aggregated demographic and interest data;
  • Payment processors for subscription billing (note: we do not store full payment card numbers).

2. How We Use Your Information

We use the information we collect for the following purposes:

  • Providing and improving the Services: operating the platform, personalizing your experience, processing transactions, and developing new features;
  • Communications: sending newsletters, push notifications, account notifications, and responding to your inquiries;
  • Analytics and research: understanding how the Services are used, measuring the effectiveness of content, and improving our products;
  • Security and fraud prevention: detecting and preventing unauthorized access, abuse, and fraudulent transactions;
  • Legal compliance: complying with applicable laws, regulations, and legal process;
  • Marketing: sending promotional communications about our Services where you have provided consent or where otherwise permitted by law;
  • Advertising: serving relevant advertising on our platform and measuring ad performance, subject to your cookie preferences.

We rely on the following legal bases under applicable data protection law: (a) contract performance — where processing is necessary to provide the Services you have requested; (b) legitimate interests — where processing is in our legitimate business interests and not overridden by your rights; (c) consent — where you have expressly consented to processing; and (d) legal obligation — where processing is required by applicable law.

3. How We Share Your Information

We do not sell your personal information to third parties. We may share your information in the following circumstances:

3.1 Service Providers

We engage third-party service providers to assist in operating the Services, including cloud hosting providers, payment processors, email delivery services, analytics platforms, and push notification services. These providers access your information only as necessary to perform services on our behalf and are contractually bound to protect it.

3.2 Push Notification Services — OneSignal

We use OneSignal, Inc. to deliver push notifications. When you subscribe to push notifications, OneSignal receives your device token and notification interaction data. OneSignal's privacy practices are governed by its own privacy policy, available at onesignal.com/privacy_policy.

3.3 Analytics Providers

We use analytics tools including Vercel Analytics and potentially others to understand Platform usage. These tools may collect aggregated and de-identified information about user interactions.

3.4 Business Transfers

If Gokhshtein Media is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of its assets, your information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.

3.5 Legal Requirements

We may disclose your information to law enforcement, government authorities, or other third parties if required to do so by law, legal process, court order, or subpoena, or if we believe in good faith that such disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with applicable law.

3.6 With Your Consent

We may share your information with third parties when you have given us explicit consent to do so.

4. Cookies and Tracking Technologies

4.1 What We Use

We and our partners use cookies, web beacons, pixel tags, local storage, and similar tracking technologies to collect information about your use of the Platform. These fall into the following categories:

  • Strictly Necessary: Essential for the Platform to function, such as authentication tokens and session cookies. These cannot be disabled.
  • Functional: Remember your preferences, such as cookie consent choices, notification settings, and display preferences.
  • Analytics: Measure how you interact with the Platform to help us improve it (e.g., pages visited, time spent, error events).
  • Advertising/Targeting: Used to serve relevant advertising and measure ad performance. Subject to your consent preferences.

4.2 Your Choices

You may control non-essential cookies through our cookie consent banner or your browser settings. Most browsers allow you to block or delete cookies, though doing so may affect Platform functionality. For opt-out tools regarding interest-based advertising, visit optout.aboutads.info or optout.networkadvertising.org.

5. Data Retention

We retain your personal information for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. Specifically:

  • Account information is retained for the duration of your account plus up to 3 years after deletion;
  • Newsletter subscriber data is retained until you unsubscribe, plus a reasonable period thereafter for legal compliance;
  • Log and analytics data is typically retained for 24 months;
  • Payment transaction records are retained as required by applicable tax and financial regulations (typically 7 years).

When your information is no longer required, we will securely delete or anonymize it.

6. Your Rights and Choices

6.1 All Users

Regardless of your location, you have the right to: opt out of marketing emails at any time using the unsubscribe link in any email; opt out of push notifications through your device settings or our notification preferences; and request that we correct inaccurate information about you.

6.2 California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”):

  • Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you;
  • Right to Delete: Request deletion of personal information we have collected, subject to certain exceptions;
  • Right to Correct: Request correction of inaccurate personal information;
  • Right to Opt Out of Sale or Sharing: We do not sell personal information. We do not share personal information for cross-context behavioral advertising without your consent;
  • Right to Limit Use of Sensitive Information: Request that we limit use of any sensitive personal information to the extent required by applicable law;
  • Right of Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise these rights, contact us at privacy@gokhshtein.com. We will respond within 45 days. We may require verification of your identity before processing requests.

6.3 EEA, UK, and Swiss Residents (GDPR)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (“GDPR”) or applicable national law, including the right to access, rectify, erase, restrict, or object to processing of your personal data, the right to data portability, and the right to withdraw consent at any time where processing is based on consent. You also have the right to lodge a complaint with your local supervisory authority.

For transfers of personal data from the EEA to the United States, we rely on Standard Contractual Clauses and other appropriate safeguards as required by applicable law.

Our Data Protection contact is: privacy@gokhshtein.com.

7. Children's Privacy

The Services are not directed to children under the age of 13 (or such higher age as required by applicable law). We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13 without verifiable parental consent, we will take steps to delete such information promptly. If you believe we have inadvertently collected information from a child, please contact us at privacy@gokhshtein.com.

8. Data Security

We implement industry-standard technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These include encryption of data in transit (TLS/HTTPS), hashed storage of passwords, access controls, and regular security assessments. However, no security system is impenetrable. We cannot guarantee the absolute security of information transmitted over the internet. In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and relevant authorities as required by applicable law.

9. International Data Transfers

Gokhshtein Media is based in the United States. Your information may be transferred to, stored in, and processed by us and our service providers in the United States and other countries, which may have different data protection laws than your country of residence. By using our Services, you acknowledge and consent to the transfer of your information to the United States and other applicable countries. Where required by applicable law, we ensure appropriate safeguards are in place for such transfers.

10. Third-Party Links

The Platform may contain links to third-party websites, applications, and services that we do not operate. This Privacy Policy does not apply to third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. We are not responsible for the privacy practices of third parties.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will provide notice of material changes by posting the updated policy on the Platform with a new effective date and, where required by applicable law, by notifying you via email. Your continued use of the Services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Gokhshtein Media LLC
Privacy Team
Email: privacy@gokhshtein.com
New York, NY

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