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Last updated:
December 29th, 2023

Privacy Policy

Introduction

In this Privacy Policy references to Yuliia Verhun, or to "We", "Us", "Our", "Ours", "the Company" are to Yuliia Verhun, the individual entrepreneur, registered in Ukraine, who is the owner of this Website. 

This Privacy Policy establishes the terms and conditions, based on which We will process Your Personal Data — certain information that identifies You as a specific individual or can be used to contact or identify You. By using the Website You agree to be bound by the Privacy Policy stated herein.

Unless otherwise defined all of the definitions in this Privacy Policy have the same meaning as in the Terms of Service.

1. Categories of Your Personal Data We Collect and Process

a) Automatically collected data

  • How did You find Us – this includes Your URL data.
  • Location data – this includes the geographic area where You use Your computer and/or mobile devices (as indicated by an Internet Protocol (IP) address or similar identifier) when interacting with our Website.
  • Device information – this includes data from Your computer and/or mobile device, such as the type of hardware and software You are using (for example, Your operating system and browser type).
  • Usage data – this includes the way You interact with Our Website – We log Your taps on certain areas of the interface and pages, the content You interact with, the time and duration of Your sessions, etc.
  • Cookies – small text files, containing small amounts of information, which are downloaded to Your browsing device when You visit the Website. Please find more information about cookies in Our Cookie Policy.

b) Data You Provide to Us

  • "Contact Us" form - when You use "Contact Us" form or other request forms, available on Our Website, to send Us Your request, We will ask You to give Us Your name and email. We need this information to respond to Your request and provide You with information about Our services.

2. Why We Need Your Personal Data

We collect and process only the data which is needed for certain purposes and according to the legal grounds provided by the law.

The processing based on Our legitimate interest
We may process Your Personal Data based on Our legitimate interest (legal basis: GDPR Article 6-1-(f)).
We use Automatically collected data for analytical purposes, so that We can understand what categories of users are the most interested in Our services and develop or improve Our services, and improve the usability of Our Website, taking into account such information. All of these reasons constitute Our legitimate interest.
Please note that such processing of Your Personal Data will not harm any of Your rights and interests and We will not use Your Data for any other purposes.
If We process Your Personal Data on the basis of Our legitimate interest, We will consider and balance any potential impact on You and Your rights under data protection and any other relevant laws.

Processing based on Your consent
In certain specific situations, We may process Your Personal Data based on Your consent (legal basis: GDPR Article 6-1-(a)).
We will ask You to provide Us with Your name and email during the submission of the "Contact Us" form.
We will use Your name and email to provide You with a reply to Your request in cases when You send Us the requests through the "Contact Us" form on the Website.

3. How We Collect Your Personal Data

We receive data directly from You when You submit the "Contact Us" form through the Website.
Certain categories of data as described above are collected automatically during Your usage of the Website.

4. Withdrawing Your Consent

If We collect and process Your Personal Data under Your consent as a legal basis, You can withdraw Your consent at any time. In order to do this You can use the "Contact Us" form, or simply contact Us via email generalcounsel@verhun.com.
In case of withdrawal, We will stop processing Your Personal Data subject to such consent. But in case We are required to retain Your Personal Data for legal reasons Your Personal Data will be restricted from further processing and only retained for the term required by law.
Please note that withdrawing Your consent will not affect the lawfulness of any processing activities We conducted prior to Your withdrawal. And We still can process Your Personal Information on legal grounds other than consent.

5. How We Use and Share Your Personal Data

We disclose Your Personal Data to third parties when We are obliged by law or other applicable legislation.
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about You to the government or law enforcement officials only if it is necessary or appropriate to respond to claims and legal process, at the request of governmental authorities or other third parties conducting an investigation, to protect the property and rights of Us or a third party, to protect the safety of the public or any person, or to prevent or stop activity We may consider to be illegal, fraudulent or unethical. We are entitled to share Your Personal Data for such purposes under clause 6.1.c) of the GDPR.
Please note that Your Personal Data is also being processed by Our hosting provider UAHosting which utilizes servers provided by OVH SAS in Poland.

6. How We Store Your Personal Data

Your Personal Data is hosted by UAHosting and stored on servers provided by OVH SAS in Poland. The OVH infrastructure puts strong safeguards in place to protect Your Personal Data. All data is stored in highly secure OVH data centers.
The following is a partial list of assurance programs with which OVH complies:

  • SSAE18 Type 2 certificates: SOC 1, SOC 2 & SOC 3;
  • PCI DSS Level 1;
  • ISO 27001, ISO 27017, ISO 27018;
  • ISO 27701 Certification and PIMS relating to personal data processing security management; You may find the full list of OVH data security certifications and security measures here.

7. How We Protect Your Personal Data

To protect Your Personal Data from unauthorized access, unlawful processing or disclosure, accidental loss, modification, or destruction, We use appropriate technical and organizational measures. We implemented encryption during the processing of Your Personal Data to ensure security. Transfers of Your data are encrypted via SSL. SSL is an industry standard which establishes an encrypted link between a web server and a browser. We also use HTTPS strict transport security to add an additional layer of protection.

8. Retention Period

According to the storage limitation principle of data processing, We will store Your Personal Data only as long as it is necessary to fulfill the purposes set out under this Privacy Policy and Terms of Service, or until You withdraw Your consent (if We process the data under Your consent), but no longer than 3 (three) years.
However, if We are required by law or any mandatory regulation to retain Your Personal Data longer or if We need Personal Data to assert or defend against legal claims, We will retain Your Personal Data until the end of the relevant retention period or until the claims in question have been settled.

9. Your Rights

You have the following privacy rights related to Your Personal Data processing:

  • Right to be informed
    This right means that You can get the information from Us on how We use Your Personal Data.
  • Right to access
    This right entitles You to verify the Personal Data held by Us, and get informed on the ways it is used, and the purposes of the processing.
  • Right to rectification
    You can edit Your Personal Data submitted to Us.
  • Right to erasure, "right to be forgotten"
    This right means that You can request the removal of Your Personal Data We hold and process, but please pay attention that We can delete Your Personal Data only if there is no legal or regulatory obligation to retain it.
  • Right to restriction of processing
    This right means that You can ask Us to stop processing Your Personal Data.
  • Right to object and right to withdraw consent
    If You provide any data to Us based on Your consent, You can refuse to continue to provide this data to Us. In order to do it You can use the "Contact Us" form, or simply contact Us via email generalcounsel@verhun.com.
  • Right of data portability
    This right means that You can ask Us to transmit Your Personal Data to another data controller. You can exercise all these privacy rights by sending Us the request through the "Contact Us" form or by contacting Us via email generalcounsel@verhun.com.

10. Changes to this Privacy Policy

We encourage You to check the updates to this Privacy Policy as We may update this Privacy Policy in the future if needed to provide compliance with data protection laws and regulations. The updates become legally binding after the posting of the renewed version on the Website. We will always use Your Personal Data in accordance with GDPR requirements and in a manner consistent with the Privacy Policy.

11. Contact Details

If You have any questions related to this Privacy Policy or the processing of Your Personal Data, please contact Us by email generalcounsel@verhun.com.

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