General Terms & Scope

Defines key terms (e.g., personal data, data controller, consent) and confirms that the Policy applies to the responsible person and employees with access to these data.

Database Inventory

The seller owns a single database of personal data belonging to counterparties.

Purpose of Data Processing

Data are processed to manage civil-law relations and transactions for goods and services, in compliance with the Tax Code and Law on Accounting and Reporting.

Consent & Notification

  • Consent must be voluntary and informed.

  • It can be provided via paper documents, electronic documents with e-signature, or recorded electronically.

  • During contract conclusion, the data subject must be informed about inclusion in the database, their rights, purposes, and potential data recipients.

  • Special categories of data (e.g., ethnicity, religion, health) are not processed.

Location of Data Storage

All personal data are stored at the seller's registered address.

Disclosure to Third Parties

  • Personal data is shared only with consent or as permitted by law.

  • Third parties must commit to legal compliance.

  • Requests for access must include identification info, purpose, and data categories.

  • Seller must respond within 10 working days and fulfill requests (or deny) within 30 calendar days. Extensions allowed up to 45 days with written notice.

Data Protection

  • The controller employs technical and organizational measures per standards.

  • A responsible person oversees compliance and internal procedures.

  • Access to data is limited and each employee is bound to confidentiality, even post-employment.

  • Data retention does not exceed purpose or consent period.

Rights of Data Subjects

They can:

  • Know database location, purpose, and data controllers.

  • Access their data and information about third-party recipients.

  • Object to processing, request correction or deletion.

  • Seek protection and remedies through state or court mechanisms.

Processing Subject Queries

  • Requests can be made without stating purpose and free of charge.

  • Response time: initial acknowledgement within 10 working days, full response within 30 calendar days unless legally extended.

State Registration

The data database is registered per Article 9 of Ukraine’s Law on Personal Data Protection.