Last update:
05/08/2024
This Privacy and Personal Data Protection Policy (hereinafter referred to as the "Policy") establishes the procedure for the collection and processing of personal data by Limited Liability Company "INITIATIVE MEDIA" (hereinafter referred to as "INITIATIVE MEDIA" LLC), the types of personal data collected, the purpose of using such personal data, interaction with third parties, security measures for the protection of personal data, conditions for access to personal data, as well as contact information for users regarding access, changes, blocking, or deletion of their personal data and handling any questions that may arise regarding the storage and protection of personal data. The Policy applies to all information and data that "INITIATIVE MEDIA" LLC may receive about individuals (hereinafter referred to as "Users") during their use of the website http://initiativemedia.com.ua/ (hereinafter referred to as the "Website") of "INITIATIVE MEDIA" LLC.
1. This Policy establishes the terms of access and use of the Website and does not apply to third-party websites that Users may access through links available on the Website.
The use of the Website by Users signifies their unconditional agreement with this Policy and the terms specified herein. In case of disagreement with these terms, Users should refrain from using the Website.
2. Consent to personal data processing
2.1. By filling out forms on the Website, User, as subject of personal data, gives "INITIATIVE MEDIA" LLC (Identification Code 41529491, located at 4 Harmatna Street, Kyiv, 03067) (hereinafter referred to as the "Possessor") consent to process his personal data provided by User when filling out such forms, as well as data obtained by the Possessor in any other way while User uses the Website, in the personal data database for the purpose of fulfilling obligations undertaken by the Possessor, ensuring relations in the field of tax, accounting, statistical reporting, as well as ensuring relations in the field of advertising and business relationships, sending special offers, information about services, and other information about the Possessor to the User, as well as fulfilling the Possessor's obligations to the User or a person whose representative/employee is the User (hereinafter referred to as the "User Company").
2.2. The personal data of Users received and processed by the Possessor under this Policy:
2.2.1. Personal data provided by User himself when filling out forms on the Website or obtained by the Possessor in other ways, including the following personal data of User:
email address
surname, first name
phone number
information provided by User in the "Message Text" field in the feedback form on the Website
2.2.2. Information from the computer/mobile device. Any information about the computer system or other technological device used by User to access the Website (IP address, operating system type, browser type and version, unique mobile device identifier, advertising identifier, geographic location, etc.).
2.2.3. Data about website visit statistics, which may include information about connections, traffic, the user's browser, as well as the date, time, duration of work on the Internet, and the duration of Website visits.
2.2.4. Any other personal data and information voluntarily provided by User to the Possessor, as well as data that may be needed by the Possessor in connection with the implementation of the purpose of personal data processing.
3. Purposes of collecting and processing Users' personal data
3.1. The Possessor collects and stores personal data necessary for providing services to User or the User Company, processed for the purposes and in the ways specified in this Policy, except cases where the legislation of Ukraine requires mandatory storage of personal information for a specified period.
3.2. The Possessor processes Users' personal data, including collection, receipt, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, destruction both using automation tools and without using such tools, as well as by mixed processing for the following purposes:
identifying the User as a representative/employee of the User Company;
establishing feedback with the User, including sending messages, inquiries regarding the use of the Website, processing requests, and applications from the User;
confirming the accuracy and completeness of personal data provided by the User;
providing effective customer support to the User or the User Company for services provided by the Possessor;
technical support for the User in case of issues related to the use of the Website;
monitoring the use of the Website;
sending advertising messages to the User, providing the User with offers, additional opportunities to use the services provided by the Possessor;
improving user experience and service quality, developing new services;
analyzing user data, conducting statistical and other studies of User (User Company) interaction with the Possessor.
4. Conditions for processing Users' personal data and transferring them to third parties
4.1. The processing of Users' personal data is carried out in accordance with the Law of Ukraine "On Personal Data Protection."
4.2. The confidentiality and security of all Users' personal data are maintained.
4.3. The Possessor has the right to transfer Users' personal data and/or delegate their processing to third parties in the following cases:
4.3.1. the data transfer is necessary for the User to use the Website;
4.3.2. to ensure the possibility of protecting the rights and legitimate interests of the Possessor, including for legal proceedings;
4.3.3. if required by applicable law;
4.3.4. in response to a request from a competent law enforcement authority;
4.3.5. transferring User data to the Possessor's successors in case the Possessor or its assets are acquired or merged with another company, including as a result of bankruptcy.
4.4. The Website may contain links to other websites (third-party websites) that the Possessor does not control and is not responsible for their content, privacy policies, or actions. Therefore, the Possessor recommends User to get acquainted with the privacy and personal data policies of each website before providing personal data.
5. Measures taken to protect Users' personal data
5.1. When processing personal data, the Possessor takes necessary legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, distortion, blocking, copying, provision, dissemination, as well as other unlawful actions regarding Users' personal data in accordance with the requirements of the legislation on the protection of such data.
5.2. The processing and storage of Users' personal data are carried out on equipment that ensures the functioning of the Website's services and provides secure storage of Users' personal data by the Possessor.
5.3. Users' personal data are processed and may be stored in the personal data database or a separate table of the Website's database.
6. Obligations of the Possessor and the User
6.1. User is obliged to provide the Possessor with accurate personal information when filling out forms on the Website.
6.2. The Possessor is obliged:
6.2.1. to use the personal data received from User solely for the purposes specified in this Privacy Policy;
6.2.2. to ensure the confidentiality of Users' personal data;
6.2.3. to fulfill other obligations specified in this Policy and the legislation of Ukraine.
7. Users' rights
7.1. User has the right to receive any information about himself from any subject of relations related to personal data, provided they specify their surname, first name, place of residence (location), and details of the document that identifies the individual making the request, except in cases provided by law. User access to data about himself is provided for free.
7.2. User, as subject of personal data, has the following rights provided by the Law of Ukraine "On Personal Data Protection":
7.2.1. to know about the sources of collection, location of his personal data, the purpose of their processing, the location or place of residence (stay) of the possessor or controller of personal data or to give an appropriate instruction regarding obtaining this information to authorized persons, except in cases established by law;
7.2.2. to receive information about the conditions for access to personal data, in particular information about third parties to whom his personal data are transferred;
7.2.3. to access to his personal data;
7.2.4. to receive no later than thirty calendar days from the date of receipt of the Possessor's request, except in cases provided by law, a response about whether his personal data are being processed, and also to receive the content of such personal data;
7.2.5. to present a reasoned demand to the possessor of personal data with objections to the processing of his personal data;
7.2.6. to present a reasoned demand regarding changes or destruction of his personal data by any possessor or controller of personal data if these data are processed unlawfully or are inaccurate;
7.2.7. to protect his personal data from unlawful processing and accidental loss, destruction, damage in connection with intentional concealment, failure to provide or untimely provision, as well as to protect against providing information that is inaccurate or tarnishes the honor, dignity, and business reputation of an individual;
7.2.8. to file complaints about the processing of his personal data to the Ukrainian Parliament Commissioner for Human Rights or to the court;
7.2.9. to apply legal remedies in case of violation of legislation on personal data protection;
7.2.10. to make reservations regarding the restriction of the right to process his personal data during consent;
7.2.11. to withdraw consent to the processing of personal data;
7.2.12. to know the mechanism of automatic processing of personal data;
7.2.13. to protect against an automated decision that has legal consequences for him.
7.3. To update, access, amend, block, or delete personal data, or to withdraw consent for the processing of personal data provided by the User in accordance with this Policy, please contact by email at info@initiativemedia.com.ua or in writing at the following address: 4 Harmatna Street, Kyiv, 03067.
8. Additional conditions
8.1. The Privacy Policy is posted on the Possessor’s website at http://initiativemedia.com.ua/.
8.2. Users' personal data may be used by the Possessor for the period necessary to achieve the aforementioned purposes of processing such data or to comply with applicable law. Personal data may be destroyed in cases provided by the current legislation of Ukraine or in accordance with a written request from the User within 30 calendar days from the moment the Possessor receives such a request.
8.3. The User accepts the terms of this Privacy Policy and acknowledges that this Privacy Policy may be updated from time to time without prior notice to the User. Changes made to the Privacy Policy will be published on the Possessor's website at http://initiativemedia.com.ua/ and will enter into force from the moment they are posted on the Possessor's website, unless otherwise specified by the new version of the Policy. The User should periodically review the Policy to stay informed of any changes or additions.
8.4. If the User disagrees with the changes made to this Policy, he must stop using the Website. The continued use of the Website by the User after the Possessor has made changes to this Policy constitutes the User's confirmation of agreement and acceptance of the respective changes/updated version of this Policy.
9. Location of personal data
9.1. The Possessor and controller of the personal data provided by the User through the Website is "INITIATIVE MEDIA" LLC.
9.2. Personal data is stored in the Possessor's automated systems and electronic media.