Privacy Policy
Ukrainian Law Compliance
This Privacy Policy complies with the Law of Ukraine №2297-VI "On Protection of Personal Data" and ensures proper handling of your personal data in accordance with Ukrainian legislation.
1. Data Controller Information
Data Controller: zyulik
Address: Bannyi Lane, 1, Kharkiv, 61000, Ukraine
Contact Email: nikflipflop@gmail.com
Business Registration: Delaware Corporation, EIN: 12-3456789
2. Personal Data We Collect
Data Minimization Principle
We only collect personal data that is necessary for the specified purposes outlined in this policy.
2.1 Contact Information
- Full name and job title
- Email address
- Phone number
- Company name and address
- Professional background information
2.2 Technical Information
- IP address and device information
- Browser type and version
- Operating system information
- Website usage data and analytics
- Cookies and similar tracking technologies
2.3 Business Information
- Project requirements and specifications
- Communication preferences
- Feedback and testimonials
- Service usage patterns
3. Legal Basis for Processing
Under Ukrainian Law №2297-VI and international data protection standards, we process personal data based on:
3.1 Consent
You have given explicit consent for specific processing purposes (Article 6, Law №2297-VI)
3.2 Contract Performance
Processing is necessary for the performance of a contract or to take pre-contractual steps (Article 7, Law №2297-VI)
3.3 Legitimate Interest
Processing is necessary for legitimate interests, except where overridden by your rights (Article 8, Law №2297-VI)
3.4 Legal Obligation
Processing is necessary for compliance with legal obligations (Article 9, Law №2297-VI)
4. Purposes of Processing
| Purpose | Legal Basis | Data Categories |
|---|---|---|
| Service provision and client communication | Consent, Contract | Contact, Business info |
| Marketing and promotional communications | Consent | Contact info |
| Website analytics and improvement | Legitimate interest | Technical data |
| Legal compliance and record keeping | Legal obligation | All categories |
5. Your Data Protection Rights
Under Ukrainian Law №2297-VI, you have the following rights regarding your personal data:
Right to Information
Right to know what data we collect and how it's processed (Article 12, Law №2297-VI)
Right of Access
Right to obtain confirmation of data processing and access to your data (Article 14, Law №2297-VI)
Right to Rectification
Right to have inaccurate data corrected and incomplete data completed (Article 16, Law №2297-VI)
Right to Erasure
Right to request deletion of your personal data under certain conditions (Article 17, Law №2297-VI)
Right to Portability
Right to receive your data in a structured, commonly used format (Article 18, Law №2297-VI)
Right to Object
Right to object to processing based on legitimate interests (Article 19, Law №2297-VI)
Exercising Your Rights
To exercise any of these rights, please contact our Data Protection Officer using the information provided in Section 12. We will respond within 30 days as required by Ukrainian law.
6. Consent and Withdrawal
6.1 Consent Requirements
Under Article 6 of Ukrainian Law №2297-VI, we require explicit, informed consent for processing personal data:
- Consent must be freely given, specific, informed, and unambiguous
- Consent must be a clear affirmative action (e.g., checkbox)
- Consent cannot be bundled with other services
- You have the right to refuse or withdraw consent at any time
6.2 Withdrawal of Consent
Important: Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
To withdraw consent, you can:
- Use the unsubscribe link in marketing emails
- Contact our Data Protection Officer directly
- Update your preferences in your account settings
- Contact us using the forms on our website
7. Data Retention
| Data Type | Retention Period | Reason |
|---|---|---|
| Contact information | Duration of business relationship + 3 years | Contract performance, legal compliance |
| Marketing data | Until consent withdrawn | Consent-based processing |
| Website analytics | 26 months | Legitimate interest in service improvement |
| Technical logs | 90 days | Security and troubleshooting |
We review and delete personal data that is no longer needed for the purposes for which it was collected, in accordance with Ukrainian legal requirements.
8. International Data Transfers
Transfer Notice
Your personal data may be transferred to and processed in countries outside of Ukraine, including the United States and European Union.
8.1 Adequate Protection
When transferring personal data internationally, we ensure adequate protection through:
- European Commission adequacy decisions
- Standard Contractual Clauses (SCCs)
- Binding Corporate Rules
- Certification schemes and codes of conduct
8.2 Transfer Safeguards
All international transfers are conducted with appropriate safeguards to ensure your personal data receives the same level of protection as required under Ukrainian law.
9. Security Measures
We implement appropriate technical and organizational measures to protect your personal data:
Technical Measures
- Encryption in transit and at rest
- Secure server infrastructure
- Regular security assessments
- Access controls and authentication
- Backup and recovery systems
Organizational Measures
- Staff training on data protection
- Confidentiality agreements
- Incident response procedures
- Regular policy reviews
- Third-party security assessments
Breach Notification: In case of a data breach that may affect your rights, we will notify the relevant supervisory authority within 72 hours and inform you without undue delay.
10. Third-Party Services
We may share your personal data with trusted third-party service providers who assist us in:
Service Providers
- Cloud hosting and data storage
- Email and communication services
- Customer relationship management
- Analytics and website optimization
- Payment processing (if applicable)
Data Processing Agreements
All third-party service providers are bound by data processing agreements that ensure they protect your personal data in accordance with this Privacy Policy and applicable law.
12. Complaints and Contact Information
Data Protection Officer Contact
Name: Data Protection Officer
Email: nikflipflop@gmail.com
Phone: +380-50-97-38-170
Address: Bannyi Lane, 1, Kharkiv, 61000, Ukraine
12.1 Supervisory Authority
If you believe we have not adequately addressed your concerns, you have the right to lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights (Ombudsman):
Website: ombudsman.gov.ua
Address: 21/8 Instytutska Street, Kyiv, 01008, Ukraine
Phone: +380 44 253-75-93
13. Policy Changes
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will:
- Notify you via email or prominent website notice
- Update the "Last Updated" date at the top of this policy
- Provide a summary of significant changes
- Obtain your consent for material changes that significantly affect your rights
Version Control: This Privacy Policy is version 1.0. Previous versions are available upon request.
Questions or Concerns?
If you have any questions about this Privacy Policy or our data protection practices, please don't hesitate to contact us.