PRIVACY POLICY

1. INTRODUCTION

The confidentiality of users of our website is of great importance to us, and we make every effort to ensure its protection. We respect your privacy and strive to protect the personal data of all visitors to our site. This Policy explains what data we collect, how we use, store, and protect it.
By using our website or providing us with your data, including by filling out a form on our website, you confirm that you have read this Policy and consent to the processing and use of your personal data within the scope defined below.
By agreeing to the use of cookies upon your first visit to our website, in accordance with this Policy, you grant us permission to use cookies each time you visit our site thereafter.

2. KEY TERMS

Personal data — any information that directly or indirectly identifies an individual (for example, name, phone number, email, IP address, or any other information you provide on our website, including via online forms).
Processing of personal data — any action involving personal data (collection, storage, use, transfer, deletion, etc.) for purposes defined in this Privacy Policy.
Data subject — an individual whose personal data is processed.
Consent — a voluntary, informed, and unambiguous expression of will by a data subject to allow the processing and use of their personal data for a specific purpose defined in this Privacy Policy.

3. PERSONAL DATA WE COLLECT

We may collect the following categories of data:

  1. information about your computer, including your IP address, geographical location, browser type and version, and operating system;
  2. information about your visits to and use of this website, including referral sources, visit duration, pages viewed, and navigation paths;
  3. information about your name, email address, and/or phone number that you provide during registration or when filling out any forms on our website (registration, feedback, service requests);
  4. information entered when creating a profile on our website, such as your name, image, or gender;
  5. information entered when using our website services (e.g., leaving reviews, requesting services);
  6. information generated during your use of our website, including time, frequency, and conditions of use;
  7. information regarding your requests, including text, used services, your name, address, phone number, and email;
  8. information contained in any communications you send us by email or through our website, including message content and metadata;
  9. any other personal information you voluntarily provide to us, including data shared through emails, request forms, or comments.

When filling out a form on our website, you may check a box confirming that you have read and agree with this Privacy Policy, thereby allowing us to use your personal data, including for marketing communications.

4. PURPOSES OF PROCESSING PERSONAL DATA

Personal information you provide through our website will be used for the purposes specified in this Privacy Policy or on relevant website pages. We may use your personal data for:

  1. providing and improving the services we offer;
  2. communicating with you in response to your inquiries;
  3. enabling you to use the services available on our website;
  4. website administration and security;
  5. responding to your inquiries by authorized staff;
  6. fulfilling contractual and legal obligations;
  7. sending you non-marketing communications (invoices, documents, payment reminders, or confirmations);
  8. sending marketing and/or informational communications (such as service offers, news, discounts) — only with your consent;
  9. sending messages you specifically request;
  10. sending marketing information about our business or that of selected third parties — only with your consent;
  11. analytics, statistics, and service improvement (in anonymized form);
  12. providing third parties with statistical information about our users (without identifying individuals);
  13. processing complaints or requests made by or about you related to our website;
  14. ensuring the security of our website and preventing fraud;
  15. verifying compliance with the website’s terms of use (including monitoring private messages sent through the website).

5. LEGAL BASES FOR PROCESSING

We process your personal data on the following grounds:

  1. Consent of the data subject (by checking the box in the website form); and/or
  2. Necessity for contract performance (service provision, invoicing, etc.); and/or
  3. Legitimate interests of our company, provided such processing does not infringe your rights (e.g., request logging or website analytics).

6. USE OF DATA FOR MARKETING PURPOSES

We may send you promotional or marketing communications (news, offers, service information) if you have consented to this (by checking the box in our website form).
You may withdraw your consent at any time by clicking “unsubscribe” in the email.
After withdrawal, we will stop sending marketing messages but may continue to send non-marketing messages necessary to fulfill contractual or legal obligations.
We do not transfer your contact details to third parties for marketing or advertising purposes without your separate consent.

7. DISCLOSURE AND TRANSFER OF DATA

We reserve the right to disclose your personal data to our employees, managers, insurers, professional advisers, agents, suppliers, or subcontractors to the extent reasonably necessary for the purposes set out in this Policy.
We may also disclose your personal data:

  1. as required by the laws of Ukraine;
  2. in connection with current or future legal proceedings;
  3. to establish, exercise, or defend our legal rights (including providing information to prevent fraud);
  4. to authorized employees or contractors (bound by confidentiality agreements) when necessary for service provision;
  5. upon request of a court or government authority;
  6. to protect our legitimate interests.

8. INTERNATIONAL TRANSFERS

Information we collect may be stored, processed, and transferred between countries in which we operate to enable us to use it in accordance with this Policy.
Personal information you publish or consent to publish on our website may be accessible worldwide via the Internet. We cannot prevent its misuse by others.
We ensure that any international transfer of personal data occurs only where an adequate level of data protection is guaranteed, in accordance with Ukrainian law.

9. DATA RETENTION PERIOD

Contact and other personal data obtained for the purposes defined in this Policy are retained until you withdraw your consent.
Data required to fulfill contractual or legal obligations are retained according to Ukrainian tax and accounting laws.
After the retention period or withdrawal of consent, data are deleted or anonymised.

10. PERSONAL DATA SECURITY

We have implemented appropriate technical and organisational measures to protect your personal data from unauthorised access, loss, or destruction.
All personal data you provide will be stored on secure servers.
You acknowledge that transmitting information via the Internet is inherently insecure, and we cannot guarantee complete data protection.
You are responsible for keeping your website access password confidential (if applicable). We will never ask for your password except when logging in.

11. RIGHTS OF DATA SUBJECTS

You have the right to:

  1. request information about the processing of your data;
  2. request correction, update, or deletion of your personal data;
  3. request restriction or object to processing;
  4. withdraw your consent at any time;
  5. exercise other rights provided by Ukrainian law, including the Law of Ukraine “On Personal Data Protection.”
    We will respond to your request within 30 calendar days of receipt.

12. COOKIES

Our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) sent by a web server to a browser and stored there. The identifier is sent back to the server each time the browser requests a page.
Cookies may be “persistent” or “session-based.” Persistent cookies remain stored until expiry or deletion; session cookies are deleted when the session ends or the browser is closed.
Cookies usually do not contain personally identifiable information, but the personal data we store may be linked to information obtained from cookies.
We use cookies to: recognise users, track navigation, enable shopping cart functionality, improve usability, analyse site use, administer the website, prevent fraud, enhance security, personalise content, and deliver targeted advertising.
Most browsers allow you to refuse cookies. Blocking all cookies may affect usability and disable certain website functions.
You can also delete cookies already stored on your computer. Deleting cookies may reduce the usability of many websites.

13. CHANGES TO THIS POLICY

We may periodically update this Privacy Policy.
The date of the latest revision will always appear at the top of the document.

Consulting GroupGolden Share

Ukraine, Kyiv,
str. Mykhailo Omelyanovich-Pavlenko, 4/6, 11th floor
+38 (044) 237 72 76, +38 (093) 188 45 40