Privacy and Personal Data Protection Policy

1. General provisions

1.1. This site (hereinafter – Site) is managed by SPD FO Savytskyi O. A., USREOU code 2574105050, which is registered and operates in accordance with the requirements of Ukrainian legislation (hereinafter – the Company).

1.2. The Company treats with great respect confidential (personal) information of all persons without exception, who visited the Site, as well as those who use the services provided by the Site (hereinafter – Users). In this regard, the Company strives to protect the confidentiality of personal data (information or a set of information about an individual, which is identified or can be specifically identified), thereby creating and ensuring the most comfortable conditions for each User to use the Website and its services.1.3. This Privacy and Personal Data Protection Policy (hereinafter – the Policy) sets out the procedure for the Company to process personal data, the types of personal data that are collected, the purposes for which such personal data is used, the Company’s interaction with third parties, security measures to protect personal data, conditions for access to personal data, as well as contact information for the User to access, modify, block or delete their personal data and to deal with any questions.

2. Collection and use of personal data

2.1. The owner and manager of personal data of Site Users is the Company.

2.2. When using the Site’s services by the User, the Company processes User data, namely: data provided by the User both when filling out registration forms and when using the services; cookies; IP-addresses; parameters and settings of Internet browsers (User-agent).

2.3. The Company only collects personal data (e.g. name and surname, login and password, e-mail address, contact phone number, date of birth, gender, etc.), which are deliberately and voluntarily provided by the User as the subject of personal data for the purpose of using the Site services, which, in accordance with legislation requirements, is the consent of the User’s personal data and the processing of such personal data in accordance with this Policy.

2.4. When visiting the Site, all logins to the Site and User’s actions on the Site are recorded.

2.5. Please note: The Company is limited to collecting the minimum amount of information required solely to fulfill the request of the subject of personal data. In any case, when non-obligatory information is requested, the User will be notified accordingly.2.6. The Company does not collect any information which are contrary to certain requirements established by law, such as: information on racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties and trade unions, criminal convictions or convictions for criminal offenses, as well as data relating to health, sex life, biometric or genetic data (according to Article 7 of the Law of Ukraine “On Protection of Personal Data”).

3. Processing of personal data

3.1. Processing and storage of the submitted personal data are carried out in third-party data centers, where the equipment ensuring the function of the Site services is placed. The submitted personal data is processed and can be stored in the Personal Data Base or in a separate table of the Site Database.

4. Purposes of personal data use

4.1. Personal data is used to ensure the provision of the Site services, information exchange, relations in the sphere of advertising and communication in accordance with and in compliance with the laws of Ukraine, including, but not limited to: “On personal data protection”, “On ratification of the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data and the Additional Protocol to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data regarding supervisory authorities and transborder data flows”, “On information”, “On advertising”, “On telecommunications”, “On information protection in information and telecommunication systems”, “On state support of mass media and social protection of journalists”, as well as in accordance with the Law of Ukraine “On protection of personal data”.

5. Period of personal data storage

5.1 Personal data are stored for a period not exceeding that which is necessary for their processing.

5.2. After the subject of personal data ceases to be a User of the Site by deleting his/her account on the Site, his/her personal data is also automatically deleted.

6. Use of cookies

6.1. A cookie is a text file or files containing a small amount of information that is sent to a web browser and stored on the User’s device. Such devices may include a computer, cell phone, or other devices with which the User visits the Site.

6.2 Cookies may be eternal (called permanent cookies) and stored on a computer until the User deletes them, or temporary (called session cookies), i.e. stored only until the browser is closed. In addition, cookies are divided into basic (set by the site you directly visit) and third-party (set by other sites) cookies.

6.3. Important:

6.3.1. when a User visits the Site again, these cookies are partially updated;

6.3.2. in most cases, the default web browser allows cookies to be automatically saved on your device;

6.3.3. disabling cookies may result in restricted access to the published materials and/or incomplete functioning of the Site services.

6.4. The Company takes care of its users and tries to make the stay at the Site as comfortable as possible. For this purpose the Company shall analyze the User’s behavior, preferences, and interests by means of cookies. Such analysis will help the Company to improve its experience of interaction with the Site, determine the most convenient interface and navigation of the service.

6.5. According to the classification of the International Chamber of Commerce, the Company uses the following categories of cookies:

6.5.1 Strictly necessary cookies – are essential for the User to navigate through the web page and use certain services, for example, to access the protected pages, register, authorize and search the Site. They also perform remembering of the User’s previous actions when going to the previous page in the same session.

6.5.2. Statistics cookies – also known as “performance cookies,” aggregate information about the use of the Site. This data is stored on the User’s device between sessions of the web browser. Examples of such data may be the following metrics: time spent on the Site, most frequently visited pages, understanding what sections and services of the Site were interesting for the user, how effective is this or that advertising and/or marketing campaign, etc.

All information collected through operational cookies is intended for statistical and analytical purposes. Some of these cookies may be shared with third parties who are authorized by the web resource and solely for the above purposes.

6.5.3 Preferences cookies – also known as “functionality cookies,” Used to store settings or configurations that are stored on a User’s device between sessions of the web browser. Examples of such data may be the following metrics: User name, photo in profile, information on comments left, language of the Site, location, information about whether the User has been provided with any information or selected benefits previously, as well as other Site settings.

These cookies also allow Users to watch videos, participate in interactive activities (surveys, polls) and interact with social networks.

To make the experience more enjoyable once you visit a resource, these cookies remember the information you provide, making the interaction with the Site more efficient.

Some of these cookies may be shared with third parties who have permission from the Site and solely for the above purposes.

6.5.4 Marketing cookies – These cookies are used to provide content that may be of interest to you. This data is stored on the User’s device between sessions of the web browser. Examples of such data may include the following metrics: tracking recommended text, graphics, audio, and video content to avoid reruns, managing targeted ads, evaluating the effectiveness of advertising campaigns, information about the User’s visit to other resources during transitions, and other Site settings.

The Site may share this information with other parties, including media clients, advertisers, agencies, and related business partners, in order to provide high-quality targeted advertising.

7. Cookies of third-party services and analytics services

7.1. The Company uses services owned by other third-party companies such as Facebook, Twitter, Instagram, Alphabet Inc., Gemius, and others for the prompt delivery, better display, and detailed analysis of the content on the Site.

7.2. The companies listed as examples may use cookies on the User’s device while working on the Site.

7.3. Please note that the Site cannot affect the operation of cookies, which are used by these services. All necessary information about their use can be found by visiting the appropriate resource.

7.3.1. Terms of use of Google Analytics – https://marketingplatform.google.com/about/analytics/terms/us/.

7.4 The main web browsers (listed below) are configured to automatically accept cookies. To disable them, use the help function in your browser. Help can be accessed via the menu or by pressing the F1 button.

7.4.1. Microsoft Edge – https://privacy.microsoft.com/en-us/privacystatement.

7.4.2. Mozilla Firefox – https://www.mozilla.org/en-US/privacy/websites/#cookies.

7.4.3. Google Chrome – https://support.google.com/chrome/answer/95647?hl=en.

7.4.4. Opera – https://help.opera.com/en/latest/web-preferences/.

7.4.5. Safari – https://www.apple.com/legal/privacy/en-ww/ 

7.5. Important:

7.5.1. The configuration of cookie settings for web browsers of mobile devices may differ;

7.5.2. It is necessary to remind that the full work with the Site is available only when using cookies;

7.5.3. Disabling cookies may result in restricted access to the content and incomplete operation of the Website services.

7.6. To contact the Company regarding the use of cookies, please send an e-mail to o.s@digital-r-evolution.com.

7.7. If the User does not enable cookies or intentionally deletes all cookies from his web browser, the user will be prompted to re-enable and use cookies when he continues to visit the Site.

7.8. User information obtained through the use of cookies is not sold or shared publicly and is the property of the company that owns the resource.

8. Interaction of the Site with Other Resources

8.1. When the User uses the Services, the Website pages may contain codes of other internet resources of third parties, as a result of which such internet resources and third parties receive data. Consequently, these internet resources may receive and process information that the User has visited these pages, as well as other information, which is transmitted by the User’s browser. Such internet resources may be:

8.1.1. Banner display systems (for example, DoubleClick for Publishers, Admixer, AdRiver, etc.);

8.1.2. Social network plug-ins (for example, Discus, Facebook, Twitter, TikTok); and

8.1.3. Other services.

8.2. The use of the mentioned services of the Company is necessary for the operative analysis of visits to the Site, internal and external evaluation of site attendance, depth of viewing, User activity. The data obtained from the mentioned services are not saved and processed by the Company.8.3. Accordingly, if the User for any reason does not want the said services to gain access to his personal data, the User can, at his own discretion, log out of his account or profile, clear the cookies (through his browser).

9. Security of minors

9.1. The site is not intended for minor users. The Company takes security issues very seriously, especially with regard to minors, and the Company, for its part, calls upon parents to explain to their children internet security issues, their specific purpose, and need to use certain services on the Site.

10. The Company’s interaction with third parties regarding personal data

10.1. The Company does not transfer personal data to third parties, except when such transfer is a legal requirement, at the request of the personal data subject or in other cases set out in this Policy. The Company understands that personal information is a value and integral content, including personal non-property rights of any individual, so it takes all possible measures to protect personal information of Users, voluntarily and knowingly transmitted by the latter to the Company.

10.2. The Site may contain links to other websites (for information purposes only). If you click on a link to other websites, this Policy will not apply to such websites. Therefore, the Company recommends that you review the privacy and personal data policy of each website before submitting any personal data.

11. Privacy of personal data subject activity on the Website

11.1. Information about activity (traffic) on the Website of users who pass through the network, or user’s e-mail is protected in accordance with the law. In other words, the Company in no way or way violates the secret of the user’s “activity” when using the latest services of the Website.

12. Protection of personal data

12.1. The Company uses generally accepted standards of technological and operational protection of information and personal data from loss, misuse, alteration or destruction. However, despite all efforts, the Company can not guarantee absolute protection from any threats arising outside the Company’s regulation.

12.2. The Company ensures application of all relevant obligations on confidentiality, as well as technical and organizational security measures to prevent unauthorized or illegal disclosure or processing of such information and data, their accidental loss, destruction, or damage.

12.3. The Company provides access to information and personal data only to authorized employees who have agreed to ensure confidentiality of such information and data in accordance with the Company’s requirements.

12.4. The dissemination of personal data without the consent of the personal data subject or the person authorized by him/her is allowed in the cases defined by law and only (if necessary) in the interest of national security, economic well-being, and human rights.

13. Conditions of access to personal data

13.1. The procedure of access to personal data of third parties is determined by the conditions of the User’s consent given to the personal data owner for the processing of such data or in accordance with the requirements of the law.

13.2. The User has the right to receive any information about himself from any subject of the relations connected with personal data, provided that the surname, first name and patronymic name, place of residence (place of stay), and details of the document certifying the physical person submitting the request are indicated, except for the cases stipulated by law.

13.3 The access of the User to the data about him/her is free of charge.

13.4 Postponement of the User’s access to his/her personal data is not allowed.

13.5 Postponement of access to personal data of third parties is allowed if the necessary data cannot be provided within 30 calendar days from the date of the request. In this case, the total period of time for solving the issues raised in the request may not exceed 45 calendar days.

13.6. Notification of the delay is brought to the notice of the third party, who submitted the request, in written form with an explanation of the procedure of appeal against such decision.

13.7. Decision on postponement or denial of access to personal data can be appealed to the Authorized Human Rights Representative of the Verkhovna Rada of Ukraine or in court.

14. Rights of the subject of personal data

14.1. The Company informs the User about his rights as a subject of personal data, which are regulated by the Law of Ukraine “On Protection of Personal Data”, namely:

14.1.1. to know about sources of collection, location of its personal data, purpose of their processing, location or places of residence (stay) of the owner or manager of personal data or to give the corresponding order on receiving this information to the persons authorized by him/her, except the cases established by the law;

14.1.2. to receive information about the conditions of access to personal data, including information about third parties to whom his personal data is transmitted;

14.1.3. to access his personal data;

14.1.4. to receive not later than 30 calendar days from the date of the request, except for the cases stipulated by the law, the answer on whether his personal data is processed and also to receive the content of such personal data;

14.1.5. to submit a motivated request to the personal data holder with the objection to the processing of his personal data;

14.1.6. to present the motivated requirement on change or destruction of the personal data by any owner and manager of the personal data, if these data are processed illegally or are unreliable;

14.1.7. to protect his/her personal data from illegal processing and accidental loss, destruction, damage in connection with intentional concealment, non-provision or untimely submission, as well as to protect from submission of information, which is unreliable or defaming honour, dignity and business reputation of the physical person;

14.1.8. to appeal to the Authorized Human Rights Representative of the Verkhovna Rada of Ukraine or to the court with complaints on processing of their personal data;

14.1.9. to apply legal remedies in case of violation of legislation on personal data protection;

14.1.10. to make reservations about restriction of the right on processing of personal data when giving consent;

14.1.11. to revoke the consent to personal data processing;

14.1.12. to know the mechanism of automatic processing of personal data; and

14.1.13. to be protected from an automated solution, which has legal consequences for it.14.2. To update, access, modify, block or delete your personal data, withdraw your consent to the processing of personal data provided by the User of the Company in accordance with this Policy, or in the case of any comments, suggestions, or claims regarding personal data processed by the Company, you should contact the Company by e-mail or at the following address: 04050, Ukraine, Kyiv, 103, Sichovyh Striltsiv Street, apt. 25.

15. Policy change

15.1. This Policy may be amended from time to time and without prior notice to the user, including in the event of changes in legal requirements.

15.2. In the case of material changes in this Policy, the Company will post a notice on the Site and indicate the effective date of such changes. If within the specified period of time the User does not refuse to accept them in writing, it will mean the consent to the corresponding changes of the Policy.

15.3. Please review the Policy from time to time in order to be aware of any changes or additions.