Privacy Policy
1. General Provisions

The present personal data processing policy is drawn up in accordance with the requirements of the law of Ukraine of 01.06.2010 No. 2297-VI "on personal data protection" and defines the procedure for processing personal data and measures to ensure the security of personal data taken by LLC "Holon" (hereinafter referred to as the operator).

1.1 Observance of human and civil rights and freedoms when processing personal data, including protection of the rights to privacy, personal and family secrets are set as the most important goal and condition for carrying out the activities by the operator.

1.2. The present policy of the operator regarding processing personal data (hereinafter referred to as the policy) applies to all information that the operator can receive about visitors of the website

2. Basic concepts used in the policy

2.1. Automated processing of personal data - processing of personal data using computer technology;

2.2. Blocking of personal data - temporary termination of processing of personal data (except in cases where processing is necessary to clarify personal data);

2.3. Website - a set of graphic and informational materials, as well as computer programs and databases that ensure their availability on the internet at the network address;

2.4. Personal data Information system - a set of personal data collected in databases, information technologies and technical means that ensure their processing;

2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without using additional information whether personal data belongs to a specific user or other subject of personal data;

2.6. Processing of personal data - any action (operation) or set of actions (operations) performed with or without use of automation tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

2.7. Operator - a state body, municipal body, legal entity or individual that independently or jointly with other persons organizes and (or) processes personal data, as well as determine the purpose of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;

2.8. Personal data - any information related directly or indirectly to a certain or determined user of the website;

2.9. User - any visitor of the website;

2.10. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons;

2.11. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing yourself with the personal data of an unlimited number of persons, including the publication of personal data in the mass media, placement in information and telecommunications networks or providing access to personal data in any other way;

2.12. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state, to an authority of a foreign state, a foreign individual or a foreign legal entity;

2.13. Destruction of personal data - any actions as a result of which personal data is permanently destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and (or) destruction of material carriers of personal data.

3. The operator may process such personal data of the user:

3.1. Last name, first name, patronymic;

3.2. Email address;

3.3. Phone numbers;

3.4. This site also collects and processes depersonalized user data (including cookies) using internet statistics services (Google Analytics, Google Tag Manager, etc.).

3.5. The above data is further united by the general concept of personal data in the text of the policy.

4. Purposes of personal data processing

4.1. The purpose of processing the user's personal data is to inform the user by sending emails; to provide the user with access to the services, information and/or materials contained on the website.

4.2. The operator also has the right to send notifications to the user about new products and services, special offers and various events. The user can always refuse to receive informational messages by sending an email to the operator marked "refusal of notifications about new products, services, and special offers".

4.3. Depersonalized user data collected by means of internet statistics services is used to collect information about user actions on the site, improve the quality of the site and its content.

5. Legal grounds for processing personal data

5.1. The operator processes the user's personal data only if they're filled in and/or sent by the user independently through special forms located on the site by filling out the relevant forms and/or sending their personal data to the operator, the user agrees to this policy.

5.2. The operator processes depersonalized user data if this is allowed in the user's browser settings (including saving cookies and using javascript technology ).

6. Procedure for collection, storage, transfer and other types of personal data processing.

The security of personal data processed by the operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

6.1. The operator ensures the safety of personal data and takes all possible measures that exclude access to personal data of unauthorized persons.

6.2. The user's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of current legislation.

6.3. If inaccuracies in personal data are detected, the user can update them independently by sending a corresponding message to the operator's email address marked "updating personal data".

6.4. The term of processing of personal data is unlimited. The user can withdraw their consent to the processing of personal data at any time by sending the operator a notification by e-mail to the operator's email address marked "revocation of consent to the processing of personal data".

7. Cross-border transfer of personal data

7.1. Before starting cross-border transfer of personal data, the operator must make sure that the foreign state where it's supposed to transfer personal data provides reliable protection of the rights of personal data subjects.

7.2. Cross-border transfer of personal data on the territory of foreign states that don't meet the above requirements may be carried out only if the personal data subject has written consent to the cross-border transfer of his personal data and/or the performance of the agreement to which the personal data subject is a party.

8. Final provisions

8.1. The user can get any explanations on the necessary issues related to the processing of his personal data by contacting the operator by e-mail

8.2. This document will reflect any changes to the operator's personal data processing policy. The policy is valid indefinitely until it's replaced with a new version.

8.3. The current version of the policy is freely available on the Internet at
Kiev, Borisoglibska street., 15B, of. 2, 04070
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