Personal Data Processing Policy

1.1. This Personal Data Processing Policy (the Policy) has been drawn up in accordance with the Law of Ukraine “On Personal Data Protection” No. 2297-VI of 01.06.2010 and the Model Procedure for Processing Personal Data approved by Order No. 1/02-14 of the Ukrainian Parliament Commissioner for Human Rights of 08.01.2014, and sets out how the personal data of personal data subjects are processed and protected by individual entrepreneur Lovkaites Vitalii Serhiiovych (RNOKPP 3535505898; 62002, Kharkiv region, Bohodukhiv district, urban-type settlement of Krasnokutsk, Horianska Street, building 13) (the Operator).

1.2. The Operator makes respect for human rights and freedoms in the processing of personal data, in particular the right to the inviolability of private and family life, the principle and main aim of its activity.

1.3. This Policy applies to all information the Operator may obtain about visitors to the website https://setvos.com (the Users).

2.1. automated processing of personal data – processing of personal data by means of computer technology;

2.2. blocking of personal data – temporary suspension of the processing of personal data (other than where processing is needed to clarify personal data);

2.3. website – the set of graphic and information materials, and of computer programs and databases, that make them available on the Internet at the network address https://setvos.com;

2.4. depersonalisation of personal data – actions as a result of which it becomes impossible, without using additional information, to determine whether specific personal data belong to a User or another personal data subject;

2.5. destruction of personal data – actions as a result of which personal data are deleted irreversibly, with no possibility of later restoring them in the personal data information system, and/or all material carriers on which specific personal data are recorded are destroyed;

2.6. User – a visitor to the website who is a natural person and acts in their own name or is authorised to represent a legal entity;

2.7. processing – any action (operation) or set of actions (operations), including use and dissemination, depersonalisation, blocking and destruction of personal data, in particular by automated means;

2.8. Operator – the natural person who, alone or jointly with other authorised persons, organises and/or carries out the processing of personal data and determines its purpose, procedure and the composition of the personal data;

2.9. personal data – any information about an identified or directly or indirectly identifiable person who is a user of the website;

2.10. cross-border transfer of personal data – transfer of personal data across the national border of Ukraine by any means.

3.1. The Operator may process the following personal data of a User:

- surname, first name, patronymic;

- location and means of contact (email; telephone number);

- information about the business entity that the User is or represents, including its location or place of residence.

3.2. The website may also collect, for further processing, depersonalised data of visitors (including “cookie” files) by means of web statistics services where the User’s browser settings allow it.

4.1. The purposes of processing a User’s personal data are:

- concluding and performing transactions involving the User, and taking the steps that precede their conclusion;

- informing the User by sending emails (messages).

4.2. The Operator has the right to send the User messages about new products, services and special offers, and other events. The User for their part may refuse to receive further messages by sending the Operator an email marked “Refusal to receive messages”.

4.3. Depersonalised data about visitors’ actions on the website, collected by means of web statistics services, are intended to improve its quality and content.

5.1. Personal data are processed on the basis of the consent of their subject – the User – given for the creation and proper performance of obligations governed by civil and commercial legislation and by international treaties to which Ukraine is a party (the Consent).

5.2. The User gives the Consent voluntarily, for achieving the purpose of processing personal data – without limitation.

5.3. The Operator processes personal data after the User has sent them on their own initiative using electronic forms on the website or other official means of communication.

5.4. By providing personal data to the Operator in any form, the User accepts the terms of this Policy.

5.5. The User, as a personal data subject, has the right:

- to know the sources of collection and the location of their personal data, the purpose of their processing, and the location or place of residence (stay) of the Operator;

- to receive information on the conditions of access to personal data, in particular information about third parties to whom their personal data are transferred;

- to access their personal data;

- to receive, no later than thirty calendar days from the day a request is received, except in cases provided by law, an answer as to whether their personal data are being processed, and to receive the content of such personal data;

- to submit a reasoned demand to the Operator objecting to the processing of their personal data;

- to submit a reasoned demand to any controller or processor of personal data for the change or destruction of their personal data if these data are processed unlawfully or are inaccurate;

- to the protection of their personal data from unlawful processing and accidental loss, destruction or damage in connection with intentional concealment, failure to provide or untimely provision of them, and to protection from the provision of information that is inaccurate or discredits the honour, dignity and business reputation of a natural person;

- to lodge complaints about the processing of their personal data with the Ukrainian Parliament Commissioner for Human Rights or with a court;

- to use legal remedies in the event of a breach of personal data protection legislation;

- to make reservations restricting the right to process their personal data when giving the Consent;

- to withdraw the Consent;

- to know the mechanism of automatic processing of personal data;

- to protection from an automated decision that has legal consequences for them.

6.1. The Operator ensures the security of the personal data processed, in particular by implementing a set of technical, organisational and legal measures required by personal data protection legislation.

6.2. The Operator ensures the safekeeping of personal data and takes all possible measures to exclude access to them by unauthorised persons.

6.3. Personal data are not transferred to any third parties unless such transfer is covered by the Consent or is an exception provided by current legislation.

6.4. If the User discovers inaccuracies in personal data provided earlier, they may update them by sending an email to the Operator marked “Update of personal data”.

6.5. The period of processing personal data is determined by the achievement of its purpose.

6.6. The User may withdraw their Consent early by sending an email to the Operator marked “Withdrawal of consent to the processing of personal data”.

6.7. Grounds for ending the processing of personal data may include, in particular, achievement of the purpose for which they were processed, expiry of the period set by the Consent, withdrawal of the Consent in the manner set by the Policy, and other cases expressly provided by law.

7.1. Before carrying out a cross-border transfer of Personal data, the Operator must make sure that the foreign state to whose territory the transfer is intended ensures proper protection of the rights of the User as a personal data subject.

7.2. A cross-border transfer of personal data may be carried out if the User’s Consent to the transfer is obtained in writing, or in other cases established by the legislation of Ukraine.

8.1. The User may obtain any explanations on all matters related to the processing of their personal data by contacting the Operator at the email address: [email protected].

8.2. Any changes to the procedure by which the Operator processes personal data take effect from the moment they are made to the Policy, which is valid indefinitely.

8.3. The current version of the Policy is published in open access on the Internet at the relevant address of the website https://setvos.com.