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Privacy Notice

This Privacy Notice outlines how we collect, use, and are responsible for certain personal information about users of the website.

I. DEFINITIONS

1.1. The terms used herein are defined as follows:

  1. “website” - the website available under the link: https://www.invest-in-ukraine.tech/; 

  2. "“user” (as well as relevant pronouns such as “you”, “your”, etc.) – any legally capable natural person (data subject), who uses the website;"

  3. “Controller” (as well as relevant pronouns such as “we”, “our”, etc.) - group of Ukrainian citizens, residing in Kyiv"

  4. “services” - any services advertised and/or provided via the website, including but not limited to access to this website and all its features (registration, browsing, account creation, use of forums, etc.), by us or our affiliates;

  5. “affiliates” - any entity that directly or indirectly controls, is controlled by, or is under common control with another entity.

1.2. All other terms used herein are defined under the UK GDPR and the Data Protection Act 2018.

II. CONTROLLER

2.1. The Controller is the entity that determines the purposes and means of the processing of user’s personal data.

III. PURPOSES AND BASIS OF THE PROCESSING

3.1. Personal data (information). Personal data is any information relating to an identified or identifiable user, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, etc.

3.2. Below, you can see a general overview of the personal data categories processed and purposes, as well as the legal basis of the processing:

  1. We process your name (first and/or last name), e-mail address, to:

    1. provide you with services or notify you of the availability of services based on performance of a contract, to take steps at the user's request prior to entering contract or our legitimate interest to notify you of services you were interested in;

    2. provide marketing communications requested by you (solicited marketing) based on legitimate interests to provide information to the user regarding services or any related services that might be of the user’s interest (considering that the user has the ability opt-out);

    3. provide marketing communication (unsolicited marketing) based on user’s consent, when obtained;

    4. contact you in regard to services or access and use of the website based on our legitimate interests in providing information to the user as to cooperation possibilities or media inquiries and providing up-to-date information regarding our services;

  2. We process your occupation/place of work/title, country, and general Google®  or Facebook® profile information, provided when sign-in to: 

    1. provide you with services or notify you on the availability of services based on the performance of a contract, to take steps at the user's request prior to entering contract or our legitimate interest to notify you of services, you were interested in;

    2. provide marketing communications requested by you (solicited marketing) based on our legitimate interests to provide information to the user regarding services or any related services that might be of the user’s interest (considering that the user has the ability opt-out);

  3. We process your phone number to:

    1. provide you with services or notify you on the availability of services based on the performance of a contract, to take steps at the user's request prior to entering contract or our legitimate interest to notify you of services, you were interested in;

    2. contact you in regard to services or access and use of the website based on the legitimate interest in providing information to the user as to cooperation possibilities or media inquiries.

  4. We process your profile picture to: 

    1. provide you with services, in particular ability to set the profile picture based on the performance of a contract, to take steps at the user's request prior to entering contract or our legitimate interest to notify you of services, you were interested in;

  5. We process your personal LinkedIn® profile link to:

    1. contact you in regard to services, access and use of the website based on our legitimate interests in providing information to the user as to cooperation possibilities or media inquiry;

    2. provide marketing communication (unsolicited marketing) based on the user’s consent, when obtained;

  6. We process your metadata (e.g., date, time when the user communicated with us, cookies, IP address, and other tracking information, as detailed in our Cookies Notice) to:

    1. contact you in regard to services or access and use of the website based on user’s consent and/or legitimate interests to improve our services, collect statistics, adapt the website to your region, and provide up-to-date information regarding services.

3.3. We may process any additional personal information that the user voluntarily provides. The user is not obliged to provide personal data by law or under any agreement; however, our services and general access to the website might not be available or might be impossible to render without some types of personal data.

3.4. Retention period. We will keep your personal information for as long as you have an account on the website or we provide you with services, including access to and use of the website. Thereafter, we will keep your personal information for as long as is necessary:

  1. to respond to any questions, complaints or claims made by you or on your behalf;

  2. to show that we treated you fairly; or

  3. to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Notice. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

3.5. Child privacy. We neither solicit nor collect personal data from anyone under the age of 16 (sixteen) or under the legal age of your country if it is different.

IV. PROCESSING OF PERSONAL DATA

4.1. We collect most of your personal information directly from you — by telephone, text, and/or email, and when you complete an online form via website. However, we may also collect information by observation (e.g., using automated data capture software) and/or from cookies. We do not collect personal data from publicly accessible sources.

4.2. We process user’s personal data by automated means. The personal data is kept in electronic form on the website servers, on computers,  to which only authorised employees and/or contractors have access.

4.3. Automated decision-making. Your personal data is not subject to automated decision-making, including profiling.

V. PERSONAL DATA TRANSFER

5.1. Recipients. Your personal data may be transferred to such categories of processors (subprocessors):

  1. our contractors and subcontractors (marketing manager, IT specialist, customer support manager, etc.);

  2. hosting providers;

  3. our affiliates;

  4. any other user of the website, if you chose to publish your personal information via forum;

  5. purchaser during M&A process or during a restructuring. In such cases, we will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations;

  6. law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

5.2. We only allow our subcontractors to handle your personal information if we are satisfied they take appropriate measures to protect it. We also impose contractual obligations on subcontractors to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts. 

5.3. International transfer. In cases where your personal data is transferred outside the UK, we enforce the appropriate legal documents that ensure the safeguarding of personal information, including data processing agreements, standard contractual clauses, and international data transfer agreements.

VI. USER’S RIGHTS

6.1. Your rights under the UK GDPR:

  1. Right to access. The right to be provided with a copy of your personal information.

  2. Right to rectification. The right to require us to correct any mistakes in your personal information.

  3. Right to be forgotten. The right to require us to delete your personal information - in certain situations.

  4. Right to restriction of processing. The right to require us to restrict processing of your personal information - in certain circumstances, e.g., if you contest the accuracy of the data.

  5. Right to withdraw consent. You can withdraw your consent provided to us for the processing of your personal data.

  6. Right to complain. You have the right to lodge a complaint with a supervisory authority (UK Information Commissioner's Office (ICO)).

  7. Right to data portability. The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party - in certain situations.

  8. Right to object. The right to object:

    1. at any time to your personal information being processed for direct marketing;

    2. in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.

  9. Right not to be subject to automated individual decision-making. The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you.

6.2. For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the General Data Protection Regulation.

6.3. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please email/write to us at info@invest-in-ukraine.tech.

VII. OTHER PROVISIONS

7.1. Changes to this Privacy Notice. This Privacy Notice was published on July 20, 2023, and last updated on July 20, 2023. We may change this Privacy Notice from time to time–when we do, we will inform you via email.

7.2. Contact us. Please contact us by post, email, or telephone if you have any questions about this Privacy Notice or the information we hold about you.

Our contact details are shown below:

info@invest-in-ukraine.tech.

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