Privacy Policy and Protection and Processing of Personal Data
This Privacy and Personal Data Protection and Processing Policy (hereinafter – “Policy”) has been developed by individual entrepreneur Savchenko Nataliia Vadymivna, acting on the basis of an Extract from the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organizations (registration number in the register: 2 005 530 0000 00017497, registration date: 18.11.2022) Unified State Register of Enterprises and Organizations of Ukraine code: 3541910880 (hereinafter – “Seller”) in accordance with current legislation of Ukraine, including, but not limited to, the Law of Ukraine "On Personal Data Protection" No. 2297-VI of June 1, 2010, for its use in the process of carrying out entrepreneurial activities and establishes the procedure for obtaining, collecting, accumulating, storing, processing, using, ensuring the protection and disclosure of personal data (hereinafter – “Data”) of Users of the website https://hvoya.ua (hereinafter – “Website”).
This Policy sets out the procedure for the Seller to process personal data, the types of personal data collected, the purposes and principles of using such personal data, the Seller's interaction with third parties, security measures for personal data protection, terms of access to personal data, as well as contact information for the User regarding access, modification, blocking or deletion of their personal data and addressing any questions that the latter may have regarding personal data protection.
Data processing means any actions with Data, including, but not limited to: access, provision, distribution, collection, systematization, storage, accumulation, recording, transfer, blocking, deletion, clarification, updating and/or modification, anonymization and other methods of Data use by the Seller.
This Policy covers the Seller's activities both online and offline, including Personal Data that the Seller collects through various channels, such as websites, applications, social networks, etc. This Policy does not apply to websites accessed via hyperlinks posted on the Website.
The owner and administrator of Personal Data is individual entrepreneur Savchenko Nataliia Vadymivna (EDRPOU Code: 3541910880).
The personal data processed may include information about:
The personal data processed may include information about:
• personal contact information that the User provides to the Seller, which will allow to contact such User, such as name, postal address, email address, social network data or phone number;
• User's account login data, including phone number, email address, login and password, other Data necessary for servicing Site Users, communication with Users, including when the User contacts the Site's support service;
• demographic information that describes the User's demographic and behavioral characteristics. For example, their date of birth, age or age range, gender, geographic location;
• any information that the User voluntarily shares with the Seller about their experience using services and other products by leaving reviews, comments, customer support requests, complaints, claims and other requests;
• any information from social networks that the User shares publicly on a social network, or information that is part of the User's profile on a social network (for example, on Facebook, Instagram, etc.). To opt out of providing such information on a social network, the User must visit the website of the respective social network;
• payment information that is necessary for the Seller to fulfill orders, or that the User uses to place an order (purchase) on the Site, for example, debit or credit card data (cardholder's name, card number, validity period, etc.) or other forms of payment (if available). In any case, the Seller processes payment and financial information in accordance with applicable law, rules and security standards;
• information that Users provide to the Seller when concluding contracts by accepting a public offer posted on the Site and/or concluding agreements for the provision of additional services on the Site.
Cookies are small text files stored on User's devices when visiting the website https://hvoya.ua. The Site may use cookies to understand what content interests the User and to remember it if they use the Site again. The Seller stores cookies to ensure a technically optimized provision of goods sales (realization) services and/or use of the Site as a whole. Cookies that may be used by the Seller cannot harm User's devices. If the User gives consent to the processing of personal data, this automatically allows the Seller to use cookies each time the former uses the website https://hvoya.ua.
The purposes of processing (collecting) personal data are:
• administering the Website, ensuring its updates and technical support;
• creating a User account, registering and/or identifying it;
• for contacting Users to provide services, sell goods, process payments,
conducting settlement operations, creating and implementing user protection programs, sending mailings by post, email, including for the purpose of sending commercial offers, notifications about promotions and other news from the Seller;
• evaluating and analyzing the market, products, services and offerings provided by the Seller, as well as improving the quality of such services and offerings, forming ratings, analyzing user activity, performing keyword searches, managing website traffic, analyzing and predicting user preferences and interests;
• processing requests and complaints left by Users regarding the use of the Website;
• ensuring Website security and preventing fraud;
• verifying compliance with the terms governing the use of the Website (including monitoring
messages sent through the Website's service, if the User is provided with the opportunity to exchange messages);
• direct provision of services and sale/delivery of goods ordered by the User;
• sending emails that Users may request;
• any other purposes to the extent sufficient for the quality provision of services and ensuring the implementation of civil, economic, and tax relations.
In addition, the Seller uses Users' personal data for marketing purposes in accordance with the legislation of Ukraine. When using Users' personal data for direct marketing (commercial newsletters and marketing messages about new products, goods, services, and offers), the Seller includes a link, by clicking on which the User has the right to unsubscribe from such messages in the future.
Pursuant to part two of Article 8 of the Law of Ukraine "On Personal Data Protection", the User, as a personal data subject, has the right to:
• to know about the sources of collection, location of their personal data, the purpose of their processing, the location or place of residence (stay) of the owner or administrator of personal data, or to give a corresponding instruction to persons authorized by them to receive this information, except in cases established by law;
• to receive information about the conditions for granting access to personal data, in particular, information about third parties to whom their personal data are transferred;
• to have access to their personal data;
• to receive, no later than thirty calendar days from the date of receipt of the request, except in cases provided by law, a response as to whether their personal data are being processed, and also to receive the content of such personal data;
• to submit a motivated demand to the owner of personal data with an objection to the processing of their personal data;
• to submit a motivated demand for the modification or destruction of their personal data by any owner and administrator of personal data, if these data are processed illegally or are inaccurate;
• to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, non-provision or untimely provision thereof, as well as to protect against the provision of information that is inaccurate or defames the honor, dignity and business reputation of an individual;
• to file complaints about the processing of their personal data with the Human Rights Commissioner of the Verkhovna Rada of Ukraine or with the court;
• to apply legal remedies in case of violation of personal data protection legislation;
• to make reservations regarding the restriction of the right to process their personal data when giving consent;
• to withdraw consent to the processing of personal data;
• to know the mechanism of automated processing of personal data;
• to protection from an automated decision that has legal consequences for them.
The Seller obtains Data from or about the User from the following sources:
• the website https://hvoya.ua, operated by the Seller under its own domains/URL addresses and pages launched by the Seller on social networks such as Facebook, Instagram, YouTube, etc.;
• email, text, and other electronic messages;
• electronic registration forms or similar forms collected by the Seller via email or direct use of the website https://hvoya.ua.
Personal Data Protection.
Processed personal data is transferred to third parties with the consent of the personal data subject. The transfer of processed personal data to third parties without the consent of the personal data subject or an authorized person is permitted in cases defined by law, and only (if necessary) in the interests of national security, economic well-being, and human rights.
The Seller is not responsible for the functioning of servers, Internet access service providers, the work of third parties due to which access to the Site may be impossible or limited, possible information leakage due to third parties, as well as for the User's disclosure of their personal data, including authorization data on the Seller's Site, in application programming interfaces and applications.
The User acknowledges that in case of their negligent attitude to the security and protection of their Data, third parties may gain unauthorized access to the User's account and Data. The Seller is not responsible for damages caused by such access.
In this regard, the Seller recommends reviewing the Privacy Policy, the procedure for transferring and processing personal data of each website before transmitting any personal data by which the User can be identified.
Changes to the Privacy Policy and Protection and Processing of Personal Data.
This Policy may be amended and supplemented periodically and without prior notice to Users, including when legislative requirements change. If the Seller changes the way Users' Personal Data is processed, the Seller will update this Policy. The Seller also reserves the right to change the approaches to Data processing and this Policy at any time.
In the event that any provisions of this Policy, clauses or parts thereof are found to be contrary to the current legislation of Ukraine, or to be invalid, this does not affect other provisions of this Policy, they remain fully valid and continue to apply in full and are valid, and any other invalid provision or provision that cannot be enforced, without further action by the Parties, is considered amended, corrected to the extent necessary to ensure its validity and enforceability.
User Agreement.
By registering, logging in, or filling out any forms on the website https://hvoya.ua, application programming interfaces, and applications, the User confirms that they have read and agree to these terms, including the purpose of personal data processing, as well as the rights granted to Users (personal data subjects) in accordance with current Ukrainian legislation, and the use of personal data by the Seller, by giving consent – activating the "Order" button through the website form (checkbox) and/or ticking the box in the "I agree with the Privacy Policy and Personal Data Protection and Processing" field.
The User is not permitted to use the website https://hvoya.ua if they do not agree to these terms.
To update, access, modify, block, or delete their personal data, revoke consent to the processing of personal data previously given to the Seller by the User, or in case of any comments, wishes, or claims regarding personal data processed by the Seller, the User must send a corresponding request to e-mail: hello@hvoya.ua.
At the same time, the operation of some Site features that require the User's personal data may be terminated from the moment of their deletion.
The Seller ensures the application of all relevant obligations regarding confidentiality, as well as technical, operational, and organizational security measures to prevent unauthorized or unlawful disclosure or processing of information and Data, their accidental loss, destruction, or damage.