Data policy

This Privacy Policy, hereinafter – The policy applies to operations for the processing of personal data that the Administration of the online resource [URL] can receive from individuals persons (subjects of personal data) on the basis of the Constitution of Ukraine and the Law of Ukraine "On the Protection of Personal Data"; dated 06/01/2010 No. 2297-VI (hereinafter – Law), as well as the General Data Protection Regulation (EU) 2016/679 of 04/27/2016 (EU General Data Protection Regulation, hereinafter – GDPR) and other applicable European Data Protection Law, collectively referred to as – Legislation.

You are not required to provide us with personal data, but without certain information about you, we may not be able to provide you with some of our services. In the event that we control the ways in which your personal data is collected and determine the purposes for which these personal data are used, the Administration is the "personal data controller"; for the purposes of the GDPR and other applicable European data protection laws, as well as the "owner of personal data"; in understanding the Law.

  1. Definition of terms

    1. The following terms are used in this Privacy Policy:
      1. Online Service Administration (hereinafter – Administration) – authorized employees who manage the online service [URL]/ , who organize and (or) process personal data, and also determines the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.
      2. Personal data - any information relating to a directly or indirectly identified or identifiable natural person (subject of personal data).
      3. Processing of personal data - any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage , clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
      4. Confidentiality of personal data - a mandatory requirement for the Operator or other person who has access to personal data to prevent their distribution without the consent of the subject of personal data or other legal grounds.
      5. Online service is a collection of interconnected web pages hosted on the Internet at a unique address (URL): [URL], as well as its subdomains.
      6. Subdomains are pages or a set of pages located on third-level domains belonging to the online service, as well as other temporary pages, at the bottom of which the Administration's contact information is indicated.
      7. User – a person who has access to the online service via the Internet and uses the information, materials and products of the online service.
      8. Cookies — a small piece of data sent by a web server and stored on the user's computer, which the web client or web browser sends to the web server in an HTTP request each time it tries to open a page of the site in question.
      9. IP address — a unique network address of a node in a computer network through which the User accesses the online service.
  2. General provisions

    1. The use of the online service by the User means acceptance of this Privacy Policy and the terms of processing the User's personal data.
    2. In case of disagreement with the terms of the Privacy Policy, the User must stop using the online service.
    3. This Privacy Policy applies to the online service of the online store builder and does not control and is not responsible for third-party websites to which the User can follow the links available on the pages of the online service.
    4. The Administration does not verify the accuracy of personal data provided by the User.
  3. Personal data privacy policy Subject

    1. This Privacy Policy establishes the obligations of the Administration to not disclose and ensure the confidentiality of personal data that the User provides at the request of the Administration when registering on the site [URL], when subscribing to an e-mail newsletter or when placing an order.
    2. Personal data authorized for processing under this Privacy Policy is provided by the User by filling out forms on the website [URL] and include the following information:
      1. - Last name, first name, middle name of the User;
      2. - User's contact phone number;
      3. - Email address (e-mail)
      4. - Country of residence (if applicable)
      5. - Photo (if necessary).
    3. The online service protects Data that is automatically transmitted when visiting pages:
      1. - IP address;
      2. - information from cookies;
      3. - browser information 
      4. - access time;
      5. - referrer (address of the previous page).
    4. Disabling cookies may result in the inability to access parts of the site that require authorization.
    5. The online service collects statistics about the IP addresses of its visitors. This information is used to prevent, detect and solve technical problems.
    6. Any other personal information not specified above (visit history, browsers used, operating systems, etc.) is subject to secure storage and non-distribution
  4. Purposes of collection of user's personal information

    The administration can use the User's personal data for the following purposes:

    1. Identification of the User registered on the site [URL]  for further authorization, subscription and other actions.
    2. Giving the User access to the personalized data of the online service.
    3. Establishing feedback with the User, including sending notifications, requests regarding the use of the online service, the provision of services and the processing of requests and applications from the User.
    4. Determining the location of the User to ensure security, prevent fraud.
    5. Confirmation of the accuracy and completeness of personal data provided by the User.
    6. Create an account to use the online service, if the User has agreed to create an account.
    7. User email notifications.
    8. Providing the User with effective technical support in case of problems related to the use of the online service.
    9. Providing to the User, with his consent, special offers, pricing information, newsletters and other information on behalf of the online service.
    10. Performing promotional activities with the consent of the User.
  5. Methods and terms of personal information processing

    1. The processing of the User's personal data is carried out without time limit, in any legal way, including in personal data information systems using automation tools or without using such tools.
    2. The processing of personal data by the Administration is carried out on the basis of the principles:
      1. The legality of the purposes and methods of processing personal data;
      2. The integrity of the Administration, as the owner of personal data, is achieved by complying with the requirements of Ukrainian legislation on the processing of personal data;
      3. Achievement of specific, predetermined purposes of personal data processing;
      4. Compliance of the purposes of processing personal data with the purposes previously defined and declared during the collection of personal data;
      5. Compliance of the list and volume of processed personal data, as well as methods of processing personal data with the stated purposes of processing;
      6. The reliability of personal data, their sufficiency for the purposes of processing, the inadmissibility of processing personal data that is excessive in relation tothe purposes of processing personal data;
      7. Ensuring the processing of personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data.
      8. It is inadmissible to merge databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
      9. Storage of personal data in a form that allows to identify the subject of personal data no longer than required by the purposes of their processing.
      10. Processed personal data is subject to destruction or depersonalization upon achievement of the purposes of processing or if it is no longer necessary to achieve these purposes, unless otherwise provided by the legislation of Ukraine and the GDPR.
    3. The processing of personal data is carried out by the Administration for statistical or other research purposes, subject to the mandatory depersonalization of personal data.
    4. The administration does not process personal data relating to racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties and trade unions, criminal convictions, as well as data on health, sexual life, biometric and genetic data.
    5. The processing of personal data is carried out in compliance with the conditions determined by the legislation of Ukraine and the GDPR.
    6. The user is responsible for his actions performed by you when using the online service, and the actions of persons performed on your behalf using personal identification data.
    7. The User acknowledges that in the event of a negligent attitude to the security and protection of their personal data and authorization data, third parties may gain unauthorized access to your account, personal and other personal data. The administration is not responsible for the damage caused by such access to third parties.
    8. In case of loss or disclosure of personal data, the Administration has the right not to inform the User about the loss or disclosure of personal data.
    9. The Administration takes the necessary organizational and technical measures to protect the User's personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.
  6. Rights and obligations of the parties

    1. The user has the right to:
      1. Make a free decision on the provision of your personal data necessary for the use of the online service and consent to their processing.
      2. Update, supplement the provided information about personal data if this information changes.
      3. Demand from the Administration to clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their right

        If the User finds that some of the personal data that the Administration processes is incorrect or outdated, the User must inform the Administration about it. In this case, the Administration may ask the User to PROVIDE an identity document, including by personal appearance at the location of the Administration.

        If the User wants to correct the personal data that is processed by the administration, the User can make the correction on his own by logging into his personal account in the online service or by contacting the Administration.

        In some cases, the Administration can NOT change the User's personal data. In particular, such a case may be when the User's personal data has already been used in the process of executing the contract and / or they are contained in a tax document that was drawn up in accordance with the Tax legislation.

      4. Withdraw consent to the processing of personal data

        If the Administration processes your personal data on the basis of consent to the processing of personal data (in particular, for the purpose of marketing / advertising mailings), further processing can be stopped at any time. It is enough to withdraw consent to such processing.

        You can also exercise your right to data destruction. In the cases provided for in Article 17 of the GDPR, the Administration will destroy your datapersonal data that it processes, with the exception of personal data that the Administration will be obliged to keep in accordance with the requirements of the law.

        Also in this case, for security purposes, the Administration may ask you to provide an identity document, including directly to the address of the location of the Administration.

    2. The Administration must:
      1. Use the information received solely for the purposes specified in clause 4 of this Privacy Policy.
      2. Ensure the storage of confidential information in secret, not to disclose without the prior written permission of the User, and also not to sell, exchange, publish, or disclose in other possible ways the transferred personal data of the User.
      3. Take precautions to protect the confidentiality of the User's personal data in accordance with the procedure usually used to protect this kind of information in existing business transactions.
      4. To carry out blocking of personal data relating to the relevant User, from the moment of the request or request of the User, or his legal representative or authorized body for the protection of the rights of subjects of personal data for the period of verification, in case of revealing false personal data or illegal actions.
  7. Responsibility of the parties

    1. In case of loss or disclosure of Confidential Information, the Administration is not responsible if this confidential information:
      1. Became public domain until lost or disclosed.
      2. Was received from a third party before it was received by the Resource Administration.
      3. Was disclosed with the consent of the User.
    2. The user is fully responsible for compliance with the requirements of the law, including laws on advertising, on the protection of copyright and related rights, on the protection of trademarks and service marks, but not limited to the above, including full responsibility for the content and form of materials.
    3. The user acknowledges that the person who provided such information.
    4. The User agrees that the information provided to him as part of the online resource may be an intellectual property object, the rights to which are protected and belong to other Users, partners or advertisers who place such information on the online resource. 
    5. The user may not modify, rent, loan, sell, distribute or create derivative works based on such content (in whole or in part), unless such actions have been expressly authorized in writing by the owners of such content in accordance with the terms of a separate agreement. 
    6. The Administration is not liable to the User for any loss or damage incurred by the User as a result of the deletion, failure or inability to save any Content and other communication data contained on the online service or transmitted through it.
    7. The administration is not responsible for any direct or indirect losses that occurred due to: the use or inability to use the site, or individual services; unauthorized access to the User's communications; statements or conduct of any third party on the site.
    8. The administration is not responsible for any information posted by the user on the online service, including, but not limited to: information protected by copyright, without the express consent of the copyright owner.
  8. Implementation of personal data protection

    1. The activities of the Administration for the processing of personal data in information systems are inextricably linked with the protection by the Administration of the confidentiality of the information received, if this does not contradict the current legislation.
    2. The personal data protection system includes organizational and (or) technical measures determined taking into account actual threats to the security of personal data and information technologies used in information systems. The administration updates these activities with the advent of new technologies, if necessary.
    3. The exchange of personal data during their processing in information systems is carried out through communication channels protected by technical means of information protection.
    4. When processing personal data in information systems, the Administration provides:
      1. Carrying out activities aimed at preventing unauthorized access to personal data and (or) transferring them to persons who do not have the right to access such information;
      2. Timely detection of facts of unauthorized access to personal data;
      3. Prevention of impact on technical means of automated processing of personal data, as a result of which their functioning may be disrupted;
      4. The possibility of immediate recovery of personal data modified and destroyed due to unauthorized access to them;
      5. Constant monitoring of the level of protection of personal data.
    5. Personal information is kept confidential, except when the technology of the online service or the settings of the software used by the User provide for an open exchange of information with other Users of the online service or with any Internet users.
    6. The administration implements the following requirements of Ukrainian legislation in the field of personal data:
      1. Requirements for the confidentiality of personal data;
      2. Requirements to ensure the exercise by the subject of personal data of their rights;
      3. Requirements to ensure the accuracy of personal data, and, if necessary, relevance in relation to the purposes of processing personal data (with the adoption (ensuring the adoption) of measures to delete or clarify incomplete or inaccurate data);
      4. Requirements for the protection of personal data from unauthorized or accidental access to them, destruction, distortion, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
      5. Other requirements of the Law.
    7. In accordance with the Law, the Administration independently determines the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the legislation in the field of personal data from unauthorized or illegal processing and from unintentional loss, destruction or damage. 

      The administration adheres to the principle of minimizing personal data. The Administration processes only the information about the User that is necessary, or information that the User, by his consent, will provide to the Administration. In addition, the Administration has configured all interfaces of the Online Service and applications for the provision of services in such a way that the maximum possible confidentiality is observed, the settings of which can be adjusted at your discretion. When transferring personal data to state bodies, the Administration always uses the most secure and proven ways of transferring such data.

  9. Cookies and other tracking technologies.

    Cookies are small text files that are stored by websites on a computer or mobile devices at the moment when the User starts using them. Thus, the site will remember the actions that the User performed for some time, including so that the User does not have to re-enter data. Cookies by themselves do not identify an individual User, but only identify the computer or mobile device that the User is using.

    Cookies and other tracking technologies in our online service can be used in a variety of ways, such as for the operation of the online service, traffic analysis or advertising purposes. The Administration uses cookies and other tracking technologies, in particular, to improve the quality and efficiency of services.

    For more information about what cookies are, how they work, how to manage them or how to delete them, go to www.allaboutcookies.org .

    Please be informed that in the settings of some Internet browsers you can set the prohibition of cookies and other tracking technologies. At the same time, the User must understand that if cookies are disabled, the functionality of the online service may be limited and the User will not be able to use all its advantages, and some pages may not work correctly.

  10. Personal data storage location

    Storage of personal data byUsers is carried out on the secure servers of the Online Service or on the servers of trusted contractors with whom appropriate agreements on data storage and protection have been concluded.

  11. Additional conditions

    1. The Administration has the right to make changes to this Privacy Policy without the consent and notification of the User.
    2. The new Privacy Policy takes effect from the moment it is posted on [URL], unless otherwise provided for by the new edition of the Privacy Policy.
    3. All suggestions or questions regarding this Privacy Policy should be reported to the address indicated on the company's website [URL]
    4. The current Privacy Policy is posted on the page at [URL]/data-policy

Updated: 08 March 2023

Kyiv