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PRIVACY POLICY

Last updated: July 10, 2025

This Privacy Policy (“Policy”) explains the purpose, legal grounds, and methods by which we collect and process your personal data (“Personal Data”), in particular when you:

  • complete online forms or surveys, submit requests, provide feedback, or subscribe to newsletters;
  • contact us by phone, email, or visit our office in person;
  • interact with us in the context of sales, marketing campaigns, or events.

In this context:

Personal Data means any information relating to a natural person that allows or makes it possible to identify that person, in accordance with the Law of Ukraine “On Personal Data Protection”.

Processing of Personal Data means any operation or set of operations, such as collection, registration, accumulation, storage, adaptation, alteration, updating, use.

This Policy covers the following:

  1. What Personal Data do we collect?
  2. How do we process Personal Data?
  3. Are communications with you recorded?
  4. To whom and when do we transfer your Personal Data?
  5. How long do we store your Personal Data?
  6. How do we protect your Personal Data?
  7. What are your rights as a Personal data subject?
  8. Is this Policy updated?
  9. How to contact us regarding privacy issues?


1. What Personal Data do we collect?

We collect Personal Data that you voluntarily provide and data automatically transmitted by your device.

1.1. Voluntarily provided data:

Full name, phone number, email, registration address, permanent or temporary place of residence, date of birth, identity document details, taxpayer registration number (if applicable) or a document confirming exemption from such number, citizenship or stateless status, specimen signature, payment details, image (photos, scanned documents, video), and information from forms, questionnaires, or requests.

1.2. Automatically collected data:

Log files (time, visited pages, system errors), device information (model, OS, browser language and type, IP address), geolocation (if permitted), analytical cookies and similar technologies of third-party services (e.g., Google Analytics), which are used to analyze user interaction with the website.

We do not knowingly process Personal Data of individuals under the age of 18 without parental consent. If such data is detected, it will be deleted.

2. How do we process Personal Data?

2.1. The Personal Data owner (controller) is: PRIVATE JOINT-STOCK COMPANY “POZNIAKY-ZHYL-BUD” (EDRPOU code: 24089818), which determines the purposes, scope, and methods of processing your Personal Data.

Correspondence address: 13B Staronavodnytska St., Kyiv, Ukraine.

2.2. We process Personal Data for the following purposes:

  • to provide information or services you have requested;
  • to enter into and perform contracts;
  • to communicate with you at your initiative (request, message, call);
  • for analytics and service improvement;
  • for staff training and internal quality control;
  • for marketing communications; and
  • to protect the legitimate interests (including security, fraud prevention, and legal compliance).

2.3. Legal grounds for processing are the following:

  • your consent or permission;
  • conclusion and performance of a contract;
  • protection of vital interests;
  • fulfillment of legal obligations; and
  • protection of your legitimate interests, the controller’s, or those of third parties to whom data is transferred.

3. Are communications with you recorded?

Yes. We may record and store telephone conversations, video and audio interactions during online meetings (e.g., Zoom, Microsoft Teams, Google Meet), as well as online or written message exchanges via forms, messengers, messaging platforms, or CRM systems for the purpose of providing high-quality services, internal staff training, professional development, quality control of communications, conflict resolution, detection and prevention of fraud, protection of rights and legitimate interests, and delivery of personalized marketing offers, informational or promotional messages.

Recording and storage are conducted following prior notice. If you continue communication or submit a form after such notice, this is considered informed consent. Initiating a phone call after hearing a recording notice also constitutes consent.

You may withdraw your consent at any time by contacting us using the contact details provided in this Policy.

Access to recordings is strictly limited to authorized personnel and will not be shared with third parties unless required by law or requested by authorized government bodies under the law of Ukraine.

4. To whom and when do we transfer your Personal Data?

We may transfer your Personal Data to affiliated companies, partners providing services (e.g., IT, marketing), legal and financial advisors. We may also transfer your Personal Data to government authorities only when required by law.

5. How long do we store your Personal Data?

We retain Personal Data only for the period necessary to fulfill the purpose of processing or as required by law. For example:

  • data from forms – up to 3 years;
  • marketing contacts – until consent is withdrawn; and
  • communication records – up to 12 months.

After that – deletion or anonymization.

6. How do we protect your Personal Data?

We use the following safeguards:

  • secure storage (servers, cloud infrastructure);
  • access restricted to authorized personnel only; and
  • regular security audits.

7. What are your rights as a Personal data subject?

You have the right to:

  • know what data we store, how it is processed, and to whom it is disclosed;
  • access your data;
  • correct or update it;
  • request deletion or restriction of processing;
  • object to processing;
  • withdraw your consent at any time (except where processing is required by law); and
  • file a complaint and seek legal remedies if your rights are violated.


8. Is this Policy updated?

Yes. This Policy may be updated. The current version is always available on our website.

9. How to contact us regarding privacy matters? You may submit a request for access, correction, deletion, or restriction of your Personal Data. Please send requests to на [email protected]. We will respond within 30 calendar days from the date of receipt.