Limited Liability Company Avtovin-Robotics (hereinafter referred to as “Avtovin-Robotics”, “We”, “Us”, “Company”) appreciates and thanks you for your interest in our company and our products.

Ensuring the protection and security of your privacy when processing personal data is a very important issue for us, which we take into account in the process of carrying out our business activities.

This Notice on the processing of personal data (hereinafter referred to as the “Notice”) has been created in accordance with the terms of the Law of Ukraine “On the Protection of Personal Data” and the General Data Protection Regulation (GDPR) and with the aim of familiarizing you with the process of processing personal data when visiting our Website and the Company’s pages on social networks. networks . In this Notice you will find information about what personal data the Company collects, on what basis and for what purpose it is collected, how it is used and how long it is stored, as well as a description of the measures taken to protect your personal data from breaches.

Avtovin-Robotics Limited Liability Company is responsible for the processing of your personal data, exceptions are explained in this Notice.

Our contact details:
Limited Liability Company "Avtovin-Robotics"
EDRPOU: 44751738
Legal and actual address: Chernivtsi, Komunalnykiv St., building 3A, Chernivtsi region, Ukraine
Representative: Prosiany Oleksiy Valentynovich
Tel. +38 (096) 312-78-29
Email: avtovin.robotics@gmail.com

For a better understanding of the terms that are specific to the field of personal data protection and that we have used in this Notice, we suggest that you familiarize yourself with them below:

• The Law of Ukraine "On Personal Data Protection" is a law that regulates legal relations related to the protection and processing of personal data and is aimed at protecting the fundamental rights and freedoms of man and citizen, in particular the right to non-interference in private life, in connection with the processing of personal data during their processing by automated and non-automated means;
• The General Data Protection Regulation (hereinafter referred to as GDPR) is a regulation that governs the protection of personal data of all individuals within the European Union and the European Economic Area;
• Personal data is any information that identifies a person or can be used to identify a person. For example: name, surname, patronymic, telephone number, email address, etc.;
• A personal data subject is a natural person whose personal data are processed and from whom he or she is identified or can be identified;
• Personal data owner/controller – a natural or legal person, state authority or local government body that determines the purpose and procedure for processing personal data and independently determines what personal data is necessary for the exercise of powers, goods or provision of services, unless otherwise specified by law;
• Personal data controller – a natural or legal person, state authority or local government body, which, by law or pursuant to the permission of the personal data owner/controller, is granted the right to process this data on behalf of the owner/controller;
• Third party – any person, except for the subject of personal data, the owner/controller or manager of personal data and the Commissioner of the Verkhovna Rada of Ukraine for Human Rights, to whom the owner/controller or manager of personal data transfers personal data.
• Processing of personal data is any operation or set of operations performed upon personal data, including, but not limited to, collection, recording, accumulation, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction , including by means of information (automated) systems;
• A notice on the processing of personal data is a document that states what personal data is collected, on what basis and for what purpose it is processed, the rights of the data subject, contact details of the personal data owner/controller, etc.
• Cookies are small text files that are stored on your device when you visit the Website and are necessary for its better functioning, analysis, advertising personalization, etc.
• Cookies Policy is a document that provides information about our use of cookies on the Website , and also informs you about how to limit or disable the use of cookies;
• The consent of the personal data subject is any voluntarily given, specific, unambiguous and informed written indication or indication in the form of a specific action or in another form, which allows to conclude that the individual consents to the processing of his personal data in accordance with the formulated purpose of their processing.
• Restriction of processing of personal data is the designation of stored personal data with the aim of restricting their processing in the future.
• Encryption is a method by which plain text or any other type of data is converted from a readable form into a coded version that can only be decoded by someone who has access to the decryption key.
• Anonymization is the process of permanently removing any personal identifiers from personal data so that the individuals described by that data remain anonymous.
• A breach is any act or omission that leads to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data that a data subject has provided to a controller for processing and storage.
• An IP address is a unique address of a device connected to the Internet.

We ask you to carefully read this Notice, and if you have any additional questions, you can contact us using the contact form located on the Website in the Contacts section .

On our Website and on the Company's social media pages networks may contain links to other websites (for informational purposes only). When you follow links to other websites, this Notice will not apply to them. Therefore, we recommend that you read the Notices on Personal Data Processing / Privacy Policies of each such website before transferring personal data by which you can be identified.
We use technologies that are considered automated decision-making or profiling. We will not make automated decisions about you that significantly affect you, unless such a decision is necessary for the performance of a contract with you, we have obtained your consent, or we are legally obliged to use such technologies. Information about your right to object in this regard can be found below in Section III of the Notice.

I. PERSONAL DATA PROCESSING
If you are located in Ukraine, we will process your personal data in accordance with the current legislation of Ukraine on personal data protection.

If you are located in the European Union (hereinafter referred to as the EU), we will process your personal data in accordance with the General Data Protection Regulation (GDPR).

Personal data of personal data subjects are processed and stored on the territory of Ukraine.
You are not required to provide us with the personal data we request, however, if you refuse to provide it, we may not be able to sell products and provide our services to you, provide high-quality service, or answer your questions.

The personal data we collect comes from a variety of sources, including:

• Personal data that we collect automatically;
• Personal data that you directly provide ;
• Personal data we receive from other sources.

Below we will inform you in detail about each source of personal data, the scope, purpose of processing, legal basis, obligations and data retention period. Automated decision-making in individual cases, including profiling, does not take place.

Personal data we collect automatically

Server log files

When you visit and use our Website, we collect personal data that your browser automatically transmits to us. In so-called server log files, we store the following information:

• The IP address of the device from which you accessed the Website;
• Date and time of access to the Website;
• Site name and URL;
• Your browser type and version;
• The operating system of the device through which you accessed the Website.

Cookies

Our Website uses cookies – small text files that are stored on your device when you visit the website.

We use the following types of cookies:

• Strictly necessary cookies are cookies that ensure the browsing and correct operation of the website, for example, the ability to move between sections of the website and use all its features. The website operator, based on point 6 of part 1 of article 11 of the Law of Ukraine "On the Protection of Personal Data" / article 6 paragraph 1 letter f of the GDPR, has a legitimate interest in storing such cookies in order to provide its services in an optimized manner and without technical errors.

• Functional cookies are cookies that store your preferences and entered data, such as your username, website language, etc., to make your interaction with the website more personalized. These cookies are stored by the website operator on the basis of point 6 of part 1 of article 11 of the Law of Ukraine "On Personal Data Protection" / article 6 paragraph 1 letter f of the GDPR, due to the existence of a legitimate interest in storing such cookies to ensure good performance and operation of all website functionalities.

• Statistical cookies are cookies that collect information about how you use the website, for example, which sections you visited and which links you clicked on. These cookies do not allow you to identify your identity and are stored by the website operator, based on clause 6, part 1, article 11 of the Law of Ukraine "On Personal Data Protection" / article 6, paragraph 1, letter f of the GDPR, due to the existence of a legitimate interest in storing such cookies to ensure good performance and operation of all functionalities of the website. These cookies do not allow you to identify your identity, everything is anonymized and intended only for the website owner.

• Marketing cookies are cookies that track your online activity, provide targeted advertising and advertisements that are relevant to your interests. They are also used to display advertisements or limit the number of times you see an individual advertisement, and measure the effectiveness of advertising campaigns . These cookies collect personal data and are permanently stored on your device and forwarded to other organizations or advertisers.

When you first visit our Website, we will ask you via a cookie banner whether you consent to the use of functional and marketing cookies. In the cookie settings, you can set which of these cookies you accept. You can also withdraw your consent or consent to the use of cookies later in these settings by clicking on the "Cookie settings" link at the bottom of the page. (link)

Personal data that you provide to us directly by filling in forms on the website:

By filling out the feedback form on the main page of the website and in the "Contacts" section, you provide us with the following personal data:

• Name;
• Phone number;
• Other information that you can specify yourself in the "Text" column of the form.

By filling out the feedback form, in the "Equipment" section and in the "Ecology" section, you provide us with the following personal data:

• Name;
• Email address;
• Other information that you can specify yourself in the "Text" column of the form.

By filling out the feedback form in the "License plates" section, you provide us with the following personal data:

• Phone number;
• License plate, a duplicate of which must be made;
• City of residence.

By filling out the feedback form in the "Car Frames" section, you provide us with the following personal data:

• Phone number;
• Company name;
• Company website address or social media links.

All of the above data are processed by us on the basis of clause 3, part 1, article 11 of the Law of Ukraine "On Personal Data Protection" / article 6, paragraph 1, letter b of the GDPR, if your request is related to an offer to purchase a Product or provide a service. In all other cases, the processing is based on our legitimate interest in the effective processing of requests addressed to us ( clause 6, part 1, article 11 of the Law of Ukraine "On Personal Data Protection" / article 6, paragraph 1, letter f of the GDPR ) or on your consent ( clause 1, part 1, article 11 of the Law of Ukraine "On Personal Data Protection" / article 6, paragraph 1, letter a of the GDPR ), if your consent was requested.

Your data will be stored for 6 months after the end of the process for which you submitted your request via the above forms, unless you make a second request within this period, the storage time will be determined from the time of the last request. This is usually done to fulfill legal obligations or to protect against any claims arising from legal regulations. We are then obliged to delete or anonymize your data. In this case, the data is only available to us as so-called metadata without a direct personal reference for statistical evaluations (e.g. number of applications per period, etc.).

If it becomes clear that the data will be needed after the 6-month period (e.g. in connection with a pending or threatened legal dispute), deletion will only occur when the purpose of further storage is no longer relevant.

Personal data we receive from other sources

Through Telegram and WhatsApp messengers

To communicate with our customers and other third parties, we use the instant messaging service Telegram , operated by Telegram Messenger Inc, Commerce House, Wickhams Cay 1, PO Box 3140, Road Town, Tortola, British Virgin Islands VG1110, whose representative in the European Union is the European Data Protection Office (EDPO), Avenue Huart Hamoir 71, 1030 Brussels, Belgium, and WhatsApp , operated by WhatsApp Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland for communication purposes.

In the event that we request permission to communicate with you via the specified messengers, the legal basis for processing is your consent, in accordance with point 1, part 1, article 11 of the Law of Ukraine "On the Protection of Personal Data" / article 6, paragraph 1, letter a GDPR. You can withdraw your consent at any time. In addition, if we do not request your consent and you, for example, contact us on your own initiative, we use messengers in accordance with point 3, part 1, article 11 of the Law of Ukraine "On the Protection of Personal Data" / article 6, paragraph 1, letter b GDPR for the performance of a contract or pre-contractual relationship and in accordance with point 6, part 1, article 11 of the Law of Ukraine "On the Protection of Personal Data" / article 6, paragraph 1, letter f GDPR on the basis of our legitimate interests in quick and effective communication and meeting your needs for communication via messenger.

Telegram and WhatsApp are messengers that use end-to-end encryption of the content (i.e. the content of your message and attachments), which means that the content of the messages cannot be viewed even by the messenger providers themselves. They cannot see the content, but they can learn when you are communicating with us, as well as technical information about the device you are using to communicate, and, depending on the device settings, location information is also processed.

For additional information on the processing of personal data in Telegram , you can read the Privacy Policy.
For additional information about the processing of personal data in WhatsApp , you can read the Privacy Policy.
WhatsApp is certified under the EU-US Data Privacy Framework (DPF), an agreement between the European Union and the United States that aims to ensure that European data protection standards are met when processing data in the United States. DPF certification commits companies to comply with these data protection standards.
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Through email, phone calls

You can contact us by email or phone call. If you contact us by phone, we will register and record your call.

In particular, the following data is recorded:

• Call start and end time;
• The number from which the call was made;
• The last name is the patronymic of the person making the request.
• The number to which the call was made;

All calls made to the numbers listed on the Website are recorded. Recordings are made in a predetermined manner. Recording begins after the call is answered and ends with a completion signal.

The data we receive during communication by e-mail or telephone conversation are processed by us on the basis of point 3 of part 1 of Article 11 of the Law of Ukraine "On the Protection of Personal Data" and Article 6, paragraph 1, letter b of the GDPR , if your request is related to the performance of a contract or is necessary to take pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of requests addressed to us ( point 6, part 1, article 11 of the Law of Ukraine "On the Protection of Personal Data" and Article 6, paragraph 1, letter f of the GDPR ) or on your consent ( point 1, part 1, article 11 of the Law of Ukraine "On the Protection of Personal Data" / Article 6, paragraph 1, letter a of the GDPR ), if it was requested. Consent can be withdrawn at any time.

The data sent to us through contact requests will remain with us until you request its deletion, revoke your consent to the storage, or the purpose of the data storage no longer applies (e.g. after processing your request). Mandatory legal provisions, in particular statutory retention periods, remain unaffected.

We have no influence on the retention period of your data stored by messenger and email operators. For more information, you can contact the operators directly.


Through video surveillance

We carry out video surveillance in our work areas and sales areas for the personal safety and for the safety of employees, customers and our property. Video surveillance is carried out in compliance with strict security and confidentiality rules using modern technology and equipment.

Video surveillance, processing and storage of the received data, in particular biometric data (facial images), is carried out on the basis of Clause 4, Part 1, Article 11 of the Law of Ukraine "On Personal Data Protection" and Article 6, Paragraph 1, Letter d of the GDPR.

Video surveillance recordings are stored in our systems for 14 (fourteen) calendar days.

Through Social Media

The company is present on the following social networks: Facebook, Instagram, LinkedIn, TikTok. These social networks can analyze your behavior in detail, in particular, if you are logged in and visit our profile, the operator of this social network will be able to track your visit. If you are not even logged in, the operator may also process your personal data, such as your IP address. The operator aggregates data from your profile, which stores your preferences and interests, and uses it to display personalized advertising.
If you visit our page on one of the social networks, we are jointly responsible for the processing of personal data with the operator of this social network. However, despite our joint responsibility for the processing of personal data, we cannot fully influence the personal data processing operations on these social networks. You can find out more about how your personal data is processed and what personal data these social networks transmit to us below.

Our presence on social networks aims to ensure the most complete online presence in accordance with point 6 of part 1 of article 11 of the Law of Ukraine "On the Protection of Personal Data" / article 6 paragraph 1 letter f GDPR . The analysis processes carried out by social network operators may be based on different legal bases, which must be determined by the respective providers.

Facebook and Instagram page
Our Company has profiles on social networks Facebook and Instagram , which are managed by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland (hereinafter referred to as Meta).

As personal data is collected when interacting with our profiles and on our website and transmitted to Facebook, Instagram, we and Meta Platforms Ireland Limited are jointly responsible for this data processing, in accordance with Art. 26 GDPR. The joint responsibility is limited solely to the collection of data and its transmission to Meta. Meta's processing of data after transmission is not part of the joint controller. Our joint obligations have been set out in a joint processing agreement. According to this agreement, we are responsible for providing information on data protection when using Meta tools and for implementing the tool on our website in a secure manner, in accordance with data protection law. Meta is responsible for the data security of Meta products. The agreement also regulates which security measures Meta must comply with and how data subjects can assert their rights against Meta. You can assert your rights, in particular regarding a request for information, regarding the data processed by Meta, directly on Faceook or Instagram. If you assert your data subject rights with us, we are obliged to transfer them to Meta.

Meta processes your personal data on the basis of your consent, in accordance with clause 1 of part 1 of article 11 of the Law of Ukraine "On Personal Data Protection" / article 6, paragraph 1, letter a GDPR, to create reports on advertising campaigns, track conversions, clicks and interaction with targeted advertising outside our website, using - HTTP headers (including IP address), device and browser characteristics, URL, your identity, click behavior, optional values (e.g. conversions, page type), form field names (e.g. "email", "address", "quantity" for purchasing a product or service). Meta does not provide us with any personal information, but only anonymous reports on the effectiveness of the advertising campaign, its target group, etc. You can opt out of receiving interest-based advertising from Facebook and Instagram by changing your advertising settings on the Facebook and Instagram websites.

For additional information on the processing of personal data on the social networks Facebook and Instagram, you can read the Privacy Policy.

Meta reports that the collected data is also transferred to the USA and other third countries. The transfer of data to the USA is based on the EU Commission's standard contractual clauses.

The company is certified under the EU-US Data Privacy Framework (DPF), an agreement between the European Union and the United States that aims to ensure that European data protection standards are met when processing data in the United States. Certification under the DPF obliges companies to comply with these data protection standards.

Meta Pixel (formerly Facebook Pixel)

Our Website uses Meta Pixel, which is managed by Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.

Meta Pixel is used for conversion measurement, which allows you to track the behavior of site visitors after they have been redirected to the provider's website by clicking on a meta ad. This allows you to evaluate the effectiveness of meta ads for statistical and market research purposes, as well as to optimize future advertising activities.

The data collected by Meta Pixel is transmitted to us in an anonymous form, but is stored and processed by Meta to be able to connect it to the respective user profile on Facebook or Instagram, and Meta may use the data for its own advertising purposes in accordance with Meta's data usage policy. This allows Meta to allow advertising on Facebook or Instagram pages and other advertising channels. We have no influence on this use of data.

The use of this service is based on clause 1, part 1, article 11 of the Law of Ukraine "On Personal Data Protection" / article 6, paragraph 1, letter a GDPR - consent. Consent can be withdrawn at any time.

You can also deactivate the Custom Audiences remarketing feature in the Ads Settings section. To do this, you must be logged in to Facebook.

If you do not have a Facebook or Instagram account, you can opt out of Meta usage-based advertising on the European Interactive Digital Advertising Alliance website.

LinkedIn page

Our Company has a profile on the LinkedIn social network, which is managed by LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland.

LinkedIn processes your personal data on the basis of consent ( clause 1 of part 1 of article 11 of the Law of Ukraine "On Personal Data Protection", article 6, paragraph 1, letter a GDPR) , agreement (clause 3 of part 1 of article 11 of the Law of Ukraine "On Personal Data Protection" and article 6, paragraph 1, letter b GDPR) and "legitimate interests" (clause 6 of part 1 of article 11 of the Law of Ukraine "On Personal Data Protection" / article 6, paragraph 1, letter f GDPR) to help other people / companies find your profile, suggest contacts and provide you with the opportunity to invite other people and establish contact with you.

LinkedIn does not share your personal data with any third party, except for: hashed identifiers or device identifiers; your specific permission to share data; or data that can be viewed by any LinkedIn user (e.g., your profile). Also, if you view or click on an ad, the advertiser is notified that someone visited the page on which the ad was displayed and can determine that it was you using mechanisms such as cookies.

For more information on the processing of personal data on the LinkedIn social network, please refer to the Privacy Policy.
LinkedIn informs that the personal data collected is transferred to and processed in the USA and other third countries. The transfer of data to the USA is based on the EU Commission's Standard Contractual Clauses. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs .
The company is certified under the EU-US Data Privacy Framework (DPF), an agreement between the European Union and the United States that aims to ensure that European data protection standards are met when processing data in the United States. Certification under the DPF obliges companies to comply with these data protection standards.

TikTok page

Our Company has a profile on the TikTok social network, which is managed by TikTok Technology Limited, 2 Cardiff Lane Grand Canal Dock DUBLIN, D02 E395 Ireland and TikTok Information Technologies UK Limited, Kaleidoscope, 4 Lindsey Street, London, EC1A 9HP, United Kingdom.

TikTok uses your personal data to improve, maintain, and administer TikTok, personalize content, promote, and customize ads for products that are relevant to your interests. TikTok collects information about your IP address, mobile carrier, time zone settings, advertising identifiers, your device model, device system, network type, device identifiers, screen resolution, and operating system, names and types of applications and files, keystroke patterns or rhythms, battery status, sound settings, and connected audio devices.

TikTok also shares information about which users viewed the ad or post, and how many views and conversions were made.
TikTok processes your personal data based on your consent, in accordance with clause 1, part 1, article 11 of the Law of Ukraine "On Personal Data Protection" / article 6, paragraph 1, letter a of the GDPR.

For additional information on the processing of personal data on the TikTok social network, you can read the Privacy Policy.

Page on the OLX.ua service

Our Company has a profile on the OLX.ua service, which is managed by LLC "EMARKET UKRAINE", 01104, Ukraine, Kyiv, Bolsunovska St., 13-15, OLX Global BV, Gustav Mahlerplein 5, Symphony Offices, 1082 MS Amsterdam, The Netherlands.

LLC "EMARKET UKRAINE" provides us with depersonalized information in order to better understand which advertisements or services may be of interest to users, to improve the overall quality and efficiency of services on the OLX.ua service. LLC "EMARKET UKRAINE" does not provide us with any personal information, except for information that is public or that you have provided to us yourself.

For additional information on the processing of personal data on the OLX.ua service, you can read the Privacy Policy.

Page on the Prom service

Our Company has a profile on the Prom service, which is managed by UAPROM LLC, address: 02121, Kyiv, Kharkivske highway, building 201-203, room 4G.

UAPROM LLC does not provide us with any personal information, except for information that is public or that you have provided to us yourself.

For additional information regarding the processing of personal data on the Prom service, you can read the Privacy Policy.

The data we collect directly through your social media presence will be deleted from our systems as soon as you request its deletion, revoke your consent to its storage, or the purpose of the data storage no longer applies. Mandatory legal provisions, in particular statutory retention periods, remain unaffected.

We have no influence on the retention period of data collected by social networks. For detailed information, please contact the social network operators directly.

Through analytics and advertising tools

Google

Our Company uses advertising services from Google, which are managed by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

As part of the provision of advertising services, Google provides us with anonymous reports on the effectiveness of the advertising campaign: number of clicks on an ad, number of impressions on an ad, ratio between the number of impressions and the number of clicks, average cost per click, cost, average target score per conversion, average target return on advertising spend, advertising interactions, advertising interaction rate, search impression rate, impression rate, conversions - purchase and sale, registration, leads, contacts, conversion value, conversion cost, conversion rate.

For additional information about the processing of personal data on Google services, please see the Privacy Policy.

The information collected by Google about your use of the website is usually transmitted to a Google server in the USA and stored there.

Data transfers to the USA are based on the EU Commission's Standard Contractual Clauses. Details can be found here: https://policies.google.com/privacy/frameworks and https://business.safety.google/controllerterms.

The company is certified under the EU-US Data Privacy Framework (DPF), an agreement between the European Union and the United States that aims to ensure that European data protection standards are met when processing data in the United States. Certification under the DPF obliges companies to comply with these data protection standards.

You can prevent Google from collecting and processing your data by downloading and installing the browser plug-in.

We also use the following Google products:

Google Tag Manager

Google Tag Manager is a tool that helps us implement tracking or statistical tools and other technologies on our website. However, it does not create user profiles, does not store cookies, and does not perform independent analysis. It is only intended to manage and distribute the tools integrated through it. However, Google Tag Manager records your IP address, which may also be transmitted to Google's parent company in the United States.

The use of Google Tag Manager is based on point 6 of part 1 of Article 11 of the Law of Ukraine "On the Protection of Personal Data" / Article 6 paragraph 1 letter f GDPR. Website operators have a legitimate interest in the quick and easy integration and management of various tools on their website. If the corresponding consent has been requested, the processing will be carried out exclusively on the basis of point 1 of part 1 of Article 11 of the Law of Ukraine "On the Protection of Personal Data" / Article 6 paragraph 1 letter a GDPR, since the consent includes the storage of cookies or access to information on the user's end device within the meaning of the TDDDG. The consent can be revoked at any time.

Google Analytics

Google Analytics allows the website operator to analyze the behavior of website visitors. The website operator receives various data about the use of the website, for example: page views, duration of stay, which operating system is used on the device from which the website is viewed and the origin of the user. Google Analytics does not assign identifiers to users, but uses technologies that allow user recognition for the purpose of analyzing their behavior.

Additionally, Google Analytics records mouse movements, scrolling, and clicking, uses various modeling approaches to supplement the collected data sets, and uses machine learning technologies to analyze the data.

The use of this service is based on clause 1, part 1, article 11 of the Law of Ukraine "On Personal Data Protection" / article 6, paragraph 1, letter a of the GDPR - consent. Consent can be withdrawn at any time.

Our website has activated Google Analytics IP anonymization - this means that your IP address will be shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website activity and internet usage. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data stored by Google.

To learn more about how Google Analytics processes user data, please see Google's privacy policy.

Google Ads

Google Ads allows us to display ads on Google search or on third-party websites when you enter certain search terms into Google (keyword targeting). In addition, targeted ads may be displayed based on user data available to Google (e.g. location and interest data) (target group targeting). This allows us to evaluate this data quantitatively, for example, to analyze which search terms led to the display of our ads and how many ads resulted in corresponding clicks.

The use of Google Ads is based on our legitimate interest in marketing our service products as effectively as possible, in accordance with point 6 of part 1 of Article 11 of the Law of Ukraine "On the Protection of Personal Data" / Article 6 paragraph 1 letter f GDPR. If consent is requested, the data will be processed solely on the basis of your consent in accordance with point 1 of part 1 of Article 11 of the Law of Ukraine "On the Protection of Personal Data" / Article 6 paragraph 1 letter a GDPR. Consent can be withdrawn at any time.

Google reCAPTCHA

On this website we use reCAPTCHA to check whether data, for example in a contact form, has been entered by a person or by an automated program. Google reCAPTCHA works automatically, in the background, and analyzes the behavior of website visitors based on various characteristics as soon as a visitor visits the website. The data collected during the analysis, such as the IP address, the length of time the visitor stays on the website or the mouse movements made, is sent to Google.

The storage and analysis of data is based on our legitimate interest in protecting our web offers from malicious automated espionage and SPAM, in accordance with point 6 of part 1 of Article 11 of the Act of Ukraine "On the Protection of Personal Data" / Article 6 paragraph 1 letter f GDPR. If consent is requested, the data will be processed exclusively on the basis of your consent in accordance with point 1 of part 1 of Article 11 of the Act of Ukraine "On the Protection of Personal Data" / Article 6 paragraph 1 letter a GDPR, as consent includes the storage of cookies or access to information on the device within the meaning of the TDDDG. Consent can be revoked at any time.

Google Maps

With this service we can integrate maps into our website. To use the functions of Google Maps, your IP address must be saved. This
The information is usually transmitted to a Google server in the USA and stored there, but we have no influence on this data transfer. If Google Maps is activated, Google can use Google Fonts to display fonts uniformly. When you access Google Maps, your browser loads the necessary web fonts into the browser cache in order to display texts and fonts correctly.

The use of Google Maps is based on our legitimate interest in the attractive presentation of our online offers and in facilitating the search for the places we have indicated (clause 6 part 1 article 11 of the Law of Ukraine "On the Protection of Personal Data" / article 6 paragraph 1 letter f GDPR). If the corresponding consent is requested, the data will be processed exclusively on the basis of your consent in accordance with clause 1 part 1 article 11 of the Law of Ukraine "On the Protection of Personal Data" / article 6 paragraph 1 letter a GDPR. Consent can be revoked at any time.

YouTube with enhanced data protection

This website contains videos from the YouTube website, which is operated by Google Ireland Limited Gordon House, Barrow Street, Dublin 4, Ireland.

When you visit our website, which has integrated YouTube, a connection is established to the YouTube servers. If you are logged in to your YouTube account, you allow YouTube to analyze your behavior directly in your personal profile. You can prevent this by logging out of your YouTube account.

We use YouTube in enhanced privacy mode, in which the videos played and the ads are not used to personalize the viewing experience on YouTube. Also, in enhanced privacy mode, cookies are not set, but so-called local storage elements, such as cookies, are stored, which contain personal data and can be used for recognition.

After activating the YouTube video, further data processing operations may be initiated, which we can influence.
We use YouTube in the interest of an attractive presentation of our online offers, in accordance with the legitimate interest in accordance with point 6, part 1, Article 11 of the Law of Ukraine "On the Protection of Personal Data" / Article 6, paragraph 1, letter f GDPR. If consent is requested, the data will be processed exclusively on the basis of your consent in accordance with point 1, part 1, Article 11 of the Law of Ukraine "On the Protection of Personal Data" / Article 6, paragraph 1, letter a GDPR. Consent can be revoked at any time.

Google and all others store data related to cookies, user IDs or advertising IDs. This data is stored for two months and then anonymized or deleted.

II. GROUNDS FOR PROCESSING PERSONAL DATA

The company collects and processes personal data on the following legal grounds:

• consent of the personal data subject to the processing of his or her personal data (clause 1 of part 1 of article 11 of the Law of Ukraine "On Personal Data Protection" / article 6 paragraph 1 letter a of the GDPR);
• for the conclusion and performance of a contract (transaction) and the implementation of measures preceding the conclusion of a contract (transaction), providing answers to your requests (clause 3 of part 1 of article 11 of the Law of Ukraine "On Personal Data Protection" / article 6 paragraph 1 letter b of the GDPR);
• to fulfill legal obligations to which we are subject (clause 5, part 1, article 11 of the Law of Ukraine "On Personal Data Protection" / article 6, paragraph 1, letter c of the GDPR);
• to protect the legitimate interests of the personal data owner/controller or a third party to whom the personal data are transferred, except in cases where the needs to protect the fundamental rights and freedoms of the personal data subject in connection with the processing of their data outweigh such interests (clause 6 of part 1 of article 11 of the Law of Ukraine "On Personal Data Protection" / article 6 paragraph 1 letter f GDPR).

III. RIGHTS OF PERSONAL DATA SUBJECTS

In connection with the processing of personal data, you as a data subject have rights that you can exercise at any time.

A personal data subject residing in Ukraine has the following rights in accordance with Article 8 of the Law of Ukraine "On Personal Data Protection":

1. to know about the sources of collection, location of their personal data, purpose of their processing, location or place of residence (stay) of the owner or manager of personal data or to give the appropriate instruction to obtain this information to persons authorized by him, except in cases established by law ;
2. receive information about the conditions for providing access to personal data, in particular information about third parties to whom his personal data is transferred;
3. to access your personal data;
4. receive no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, a response on whether his personal data is being processed, as well as receive the content of such personal data;
5. submit a reasoned request to the personal data controller objecting to the processing of their personal data;
6. to submit a reasoned request for the modification or destruction of their personal data by any controller and processor of personal data if these data are processed unlawfully or are inaccurate;
7. to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of such data, as well as to protect against the provision of information that is unreliable or defamatory of the honor, dignity and business reputation of an individual;
8. to file complaints about the processing of their personal data with the Commissioner of the Verkhovna Rada of Ukraine for Human Rights in the Field of Personal Data Protection or to the court;
9. apply legal remedies in case of violation of personal data protection legislation;
10. to make reservations regarding the restriction of the right to process their personal data when providing consent;
11. withdraw consent to the processing of personal data;
12. know the mechanism of automatic processing of personal data;
13. to protect against automated decision-making that has legal consequences for him/her.

To exercise rights that require active action on our part, you can leave a request via email or via the contact form located on the Website in the Contacts section, indicating there:

1. surname, first name and patronymic, place of residence (place of stay) and details of the document identifying the person submitting the request (for an individual - applicant) ;
2. name, location of the legal entity submitting the request, position, surname, first name and patronymic of the person certifying the request; confirmation that the content of the request corresponds to the authority of the legal entity (for a legal entity - the applicant);
3. surname, first name and patronymic, as well as other information that allows identification of the individual about whom the request is made;
4. information about the personal data base in respect of which the request is submitted, or information about the controller or manager of the personal data;
5. list of personal data requested for access / for restriction of processing / change / addition / deletion;
6. the purpose and/or legal basis for the request.

We, in turn, undertake to review the request for its satisfaction within 10 (ten) business days and notify you of the result of the consideration. The request will be satisfied within 30 (thirty) calendar days from the date of receipt, unless otherwise provided by law.
The exercise of the rights of the personal data subject is free of charge.

If you are located in the EU, you have the following rights as defined in the GDPR:

1. Right of access to personal data (Article 15 GDPR)

You have the right to receive clear, transparent and user-friendly information from us about how we process your personal data.
You also have the opportunity to learn:

• For what purposes is your personal data used?
• To whom your personal data may be transferred;
• How long is your personal data stored?
• About the source of personal data, if it was not collected by us;
• Is your personal data used for automated decision-making?
• About your rights as a personal data subject;
• About the right to file a complaint with the competent authority in case of violations in the field of personal data protection.

You can exercise your right to receive a copy of your personal data and receive answers to the above questions by sending us a request.

We will respond to your request within 1 month. In certain cases, we may inform you that additional time is needed to respond to your request, but not more than 2 months. Providing a copy of your personal data and answers to your questions is free of charge. We may charge a reasonable administrative fee if we receive a request from you for additional copies or if your request is “manifestly unfounded or excessive”.

2. Right to rectification (Art. 16 GDPR)

You have the right to ask us to correct information that is outdated, inaccurate, incomplete or that you believe is inaccurate.
To correct information, you must send us a request stating:

• That you have doubts about the relevance, accuracy, completeness or reliability of the personal data we hold about you and you wish to correct it;
• Clearly indicate how personal data needs to be corrected or supplemented;
• Confirm your identity.

We will respond to your request within 1 month. In certain cases, we may inform you that additional time is needed to respond to the request, but not more than 2 months. Correction and completion of personal data is free of charge. We may charge a reasonable fee for administrative costs if your request is “manifestly unfounded or excessive”.

3. Right to erasure ("right to be forgotten") (Article 17 GDPR)

You have the right to ask us to delete your personal data if the following grounds exist:

• You withdraw your consent to the processing of your personal data and there are no other grounds for processing it;
• You object to the processing of personal data and there are no other overriding legitimate grounds for further processing;
• Your personal data is no longer needed for the purposes for which it was collected;
• The processing of your personal data was carried out unlawfully;
• If your personal data needs to be erased to comply with a legal obligation
• Your personal data must be erased to comply with a legal obligation.

You can exercise your right to erasure by sending us a request, stating your wish and justifying the reason for erasure of your personal data. Erasure of your personal data is free of charge. We may charge a reasonable fee for administrative costs if your request is “manifestly unfounded or excessive”.

However, please note that we are not obliged to comply with such a request, in particular if the processing is necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

4. Right to restriction of processing (Article 18 GDPR):

You have the right to ask us to restrict the processing (but retain) of your personal data, if the following grounds exist:

• You contest the accuracy of the personal data so that we can verify the accuracy of the personal data;
• You believe that the processing of your personal data is unlawful, but you do not want it deleted;
• We no longer need your personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
• You object to the processing of personal data, but we are conducting an analysis of whose legitimate interests prevail;

To exercise the right to restrict the processing of personal data, you must send us a request stating:

• That you want to restrict the processing of your personal data;
• Clearly indicate which personal data you wish to restrict processing.

We will respond to your request within 1 month. In certain cases, we may inform you that additional time is needed to respond to the request, but not more than 2 months. Restriction of processing of personal data is free of charge. We may charge a reasonable fee for administrative costs if your request is “manifestly unfounded or excessive”.

5/ Right to personal data portability (Article 20 GDPR):

You have the right to request that we provide you or another controller with personal data concerning you, in a structured, commonly used and machine-readable format. This right may be exercised where the processing is based on your consent or for the performance of a contract, is carried out by automated means and there is a technical possibility to transfer the personal data.

You can exercise your right to erasure by sending us a request. We will respond to your request within 1 month. In certain cases, we may inform you that additional time is needed to respond to your request, but not more than 2 months. Providing personal data to you or another controller is free of charge. We may charge a reasonable fee for administrative costs if your request is “manifestly unfounded or excessive”.

6. Right to object to processing (Art. 21 GDPR)

You have the right to object at any time to the processing of personal data, taking into account your particular situation, if:

• Personal data is used for direct marketing purposes, profiling;
• The processing is based on our legitimate interests or those of third parties, unless we demonstrate compelling legitimate interests that override your interests.

To exercise your right to object to the processing of your personal data, you must send us a request stating that you object to the processing. We will respond to your request within 1 month. In certain cases, we may inform you that additional time is needed to respond to your request, but not more than 2 months. Objecting to the processing of your personal data is free of charge. We may charge a reasonable fee for administrative costs if your request is “manifestly unfounded or excessive”.

7. Right to withdraw consent (Article 7 (3) GDPR):

You have the right to withdraw your consent to the processing of personal data at any time, if the processing was carried out on this basis. The withdrawal of consent will not affect the lawfulness of the processing of personal data before the withdrawal.

You can exercise your right to withdraw your consent to the processing of your personal data by sending us a request. We will respond to your request within 1 month. In certain cases, we may inform you that additional time is needed to respond to your request, but not more than 2 months. Withdrawal of consent to the processing of your personal data is free of charge. We may charge a reasonable fee for administrative costs if your request is “manifestly unfounded or excessive”.

8. Right to lodge a complaint with a supervisory authority (Article 77 GDPR):

You have the right to lodge a complaint with a supervisory authority in the Member State of your habitual residence, place of work or place of the infringement if you believe that the processing of your personal data infringes the provisions of the GDPR.

9. Law related to automated decision-making

You have the right not to be subject to decisions based solely on automated processing and which may have significant legal or other consequences. In particular, you have the right to: request human intervention in the automated decision-making process; express your opinion; receive explanations regarding automated decisions; and contest automated decisions.

If you still have questions about your rights and how to exercise them, you can send us a request or contact us by email.

IV. PERSONAL DATA PROTECTION MEASURES

The company takes measures to ensure the protection of personal data through organizational and technical measures.
Organizational activities include:

1. Control of access to personal data of personal data subjects, employees, authorized persons;
2. Keeping records of employees and authorized persons who have access to personal data;
3. Levels of employee access to data subjects have been implemented, where each of these employees has access only to those personal data (parts thereof) that are necessary for him to perform his job duties. All other employees of the Company have the right to full information only regarding their own personal data.
4. Mandatory signing of written obligations on non-disclosure of personal data by employees/authorized persons who have access to personal data in connection with the performance of their work duties. Such obligation remains valid after the termination of their employment related to personal data, except as otherwise provided by law.
5. Automatic recording of personal data when processed using an automated system. In the case of performing relevant actions with personal data in paper form, their accounting is carried out by recording such actions and operations (for example, regarding personnel issues, business transactions, etc.), within the framework of which the relevant processing of personal data is carried out, by drawing up documents that are usually drawn up by the Company in connection with such actions and operations.
6. Personal data is stored by the Company for six months from the end of the year in which the specified transactions were carried out, unless otherwise provided for by the legislation of Ukraine.
7. Taking all necessary measures to prevent third parties from gaining access to the personal data of subjects.
8. An action plan has been developed in case of unauthorized access to personal data, damage to technical equipment, and emergency situations.
9. Conducting an audit of its security systems, infrastructure and ensuring ongoing protection against malware and modern cyber threats, in order to identify opportunities to improve the secure storage and use of personal data.
10. Transfer of collected personal data exclusively in encrypted form
11. Development and implementation of internal rules regarding work with personal data, which provide for the levels of access of employees/authorized persons to personal data, and the secure exchange of such data within the Company.
12. Organization of training for employees/authorized persons involved in personal data processing processes to increase awareness of international legal standards and provisions of national legislation in the field of personal data protection, effective implementation and compliance with the Company's internal rules regarding the collection, storage, use or performance of other actions constituting the processing of personal data.

The Company has implemented such a technical measure for personal data protection as equipment with system and software-technical means and means of communication, which makes it impossible to cause losses, theft, unauthorized destruction, distortion, forgery, copying of information and which meet the requirements of national and international standards. Also, software products used by the Company in the process of processing personal data have built-in mechanisms for protecting information from unauthorized access to ensure the identification of subjects, the integrity of electronic documents, etc.

The Company also complies with the requirements of the Standard Procedure for Processing Personal Data, approved by Order of the Verkhovna Rada of Ukraine dated January 8, 2014 No. 1/02-14, to the extent that it specifically concerns personal data.

Unfortunately, the transmission of information over the Internet is not completely secure. Although we make every effort to protect your personal data, we cannot guarantee the security of your personal data transmitted via our website, platforms on which the Company has social media pages.

V. TRANSFER OF PERSONAL DATA TO THIRD PARTIES

The company may transfer and distribute personal data to third parties in the following cases:

• to ensure and protect the safety, rights and interests of the Enterprise and other entities;
• to prevent fraud and illegal activities;
• in the event of a security threat, in particular to prevent death or direct harm to health;
• in the event of a change in the business structure of the Enterprise, in particular in the event of: merger, acquisition, bankruptcy proceedings, liquidation, reorganization, sale of some or all assets, raising investments, public issuance of securities, acquisition of the Enterprise or its part, in similar transactions and procedures;
• in connection with the submission of a request to law enforcement and authorities, pre-trial investigation bodies and courts to obtain personal data .

The transfer of personal data in the above cases will take place in accordance with Article 14 of the Law of Ukraine "On Personal Data Protection" / Article 6, paragraph 1, letters c, d , e , f GDPR .

The Company also provides personal data to delivery services and postal operators, in the event that the delivery of goods is carried out using such services. For such purposes, we collect and transfer to them the following personal data: telephone number and surname, patronymic (if any) of the recipient, delivery address. In this case, the collection and transfer of personal data occurs for the performance of the contract between us, in accordance with clause 3 of part 1 of article 11 of the Law of Ukraine "On Personal Data Protection" / article 6 paragraph 1, letter b of the GDPR.

You are not required to provide any personal data necessary for the delivery of the goods. However, if you do not provide us with such information, delivery of the goods is not possible.

We only work with carefully selected service providers with whom we have concluded contracts for the processing of personal data in accordance with Article 14 of the Law of Ukraine “On Personal Data Protection” / Article 28 of the GDPR and ensure an appropriate level of data protection through technical and organizational measures. In exceptional cases, processing may also take place outside the European Union and the European Economic Area, for example in the USA. In such a case, your personal data is transferred and processed with your consent in accordance with Article 29 of the Law of Ukraine “On Personal Data Protection” / Article 49 paragraph 1 letter a of the GDPR.

When transferring data to third parties, we undertake to ensure the security and protection of your data at the same level as described in this Notice. In the event that personal data is transferred to third parties located outside the European Union, in a country with an inadequate level of personal data protection, we take all necessary measures to protect your personal data. In particular, we ensure that such transfer of personal data is governed by mechanisms such as: adequacy decisions, binding corporate rules, standard contractual clauses, periodic reviews of the effectiveness of such mechanisms. Where necessary, we also ensure the provision of additional guarantees of a contractual, technical and organizational nature.

VI. CHANGES TO THE NOTICE ON PROCESSING OF PERSONAL DATA

We may update our Notice from time to time as we adapt it immediately after a change in our data processing. We will notify you of any changes by posting a new Notice on this page and updating the “Last Updated” date at the top of this Notice.

We encourage you to review this Notice regularly for any changes. Changes to this Notice will be effective upon posting on this page.
Where we provide addresses and contact information for the Company in this Notice, please note that addresses may change over time and we ask that you check the information before contacting us.