Personal Data Privacy Policy

1. Terms and Definitions

1.1. "Website" (hereinafter – "Site") – an information resource on the Internet located at https://sappers.com.ua and containing text, graphic and other information perceived as a single whole, maintained by a set of system software.

1.2. "Site Owner" (hereinafter – "Owner") – the owner of the website https://sappers.com.ua and the controller of Users' personal data.

1.3. "User" – any individual who has ever accessed the Site.

1.4. "Account" – the User's account created at the time of authorization on the Site.

1.5. "Personal Data" – information or a set of information about the User that is identified or can be specifically identified.

2. Collection and Use of Personal Data

2.1. Use of the Site does not require registration and/or authorization or direct provision of personal data that could identify You.

2.2. When using the Site we may automatically collect information related to Your use of the Site.

2.3. We may collect, store and use the following types of Your personal data:

2.3.1. Information about Your computer, including IP address, geographic location, browser type and version and operating system;

2.3.2. Information about Your visits to and use of this Site, including referral source, visit duration, page views and navigation paths on the Site;

2.3.3. Information generated when using our Site, including when, how often and under what circumstances You use it;

2.3.4. Information contained in any messages You send us by email or through our Site, including its content and metadata;

2.3.5. Any other personal information You send to us.

2.4. Before disclosing another person's personal information to us, You must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with this Policy.

2.5. When You visit the Site, a connection is established, access to data on the Site is made and a log file is created. It may contain:
– date and time of access to the Site;
– IP address from which access to the Site was made;
– data or name of the file You requested on the Site;
– amount of time spent on the Site;
– name and version of the web browser and Your operating system;
– name of the website from which You came to the Site.
This information is used to improve Site performance, for security reasons, to ensure Site stability, and to protect the Site from possible external attacks. In addition, we may perform statistical analysis of this data. Data stored in the log file does not allow us to identify You. Data in the log file is used only for the purpose specified in this Policy.

2.6. We collect only those personal data that You have knowingly and voluntarily provided as a data subject for the use of the Site's services, which in accordance with the requirements of the current legislation of Ukraine constitutes the data subject's consent to the processing of their personal data in accordance with the purpose of their processing set out in this Policy.

2.7. We guarantee that we will not sell or rent User personal data to third parties, except when disclosure of Your personal data is necessary to comply with the requirements of the current legislation of Ukraine.

2.8. We do not collect or process information about Your personal data regarding racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties and trade unions, criminal convictions, or data relating to health, sex life, biometric or genetic data (in accordance with Article 7 of the Law of Ukraine "On Personal Data Protection").

3. Processing of Personal Data

3.1. Processing and storage of the provided personal data is carried out in data centers where the equipment ensuring the functioning of the Site's services is located. The provided personal data is processed and may be stored in the Personal Data Database or a separate table of the Site's Database. The location of storage and processing of personal data is: 04071, Kyiv, Mezhyhirska Street, building 22.

4. Purpose of Use of Personal Data

4.1. We may use Your personal information for the purpose of:

4.1.1. Administering our Site and business;

4.1.2. Personalizing our Site for You;

4.1.3. Enabling You to use the services available on our Site;

4.1.4. Providing third parties with statistical information about our users (in this case third parties will not be able to identify any individual user from this information);

4.1.5. Dealing with enquiries and complaints made by You or about You regarding our Site;

4.1.6. Keeping our Site secure and preventing fraud;

4.1.7. And other types of use

4.2. If You have expressed a desire to provide personal information for publication on our Site, we will publish and otherwise use this information in accordance with the permission and/or license You grant us.

4.3. We will not provide Your personal information to any third party for their direct marketing or any other purposes without Your express consent, except as provided by the current legislation of Ukraine.

5. Retention of Personal Data

5.1. Personal data is stored for no longer than necessary in accordance with the purpose of its processing.

5.2. After You have ceased to be a User of the Site by deleting Your Account on the Site, Your personal data will also be automatically deleted.

6. Site Interaction with Other Resources

6.1. When using our services, the Site pages may contain codes of other Internet resources and third parties, as a result of which such Internet resources and third parties receive Your data. These Internet resources may receive and process information that You have visited these pages, as well as other information transmitted by Your browser.

6.2. The use of these services is necessary for operational analysis of Site visits, internal and external assessment of Site traffic, depth of views, and User activity. We do not store or process data received from these services.

6.3. If for any reason You do not wish the services provided in clause 6.1 of the Policy to have access to Your personal data, You may voluntarily log out of Your Account and clear cookies (through Your browser).

7. Owner's Interaction with Third Parties Regarding Personal Data

7.1. We do not transfer personal data to third parties, except when such transfer is required by the current legislation of Ukraine, at the request of the data subject or in other cases set out in this Policy. We understand that personal information is valuable and an integral part of, among other things, the personal non-property rights of any individual, and therefore we take all possible measures to protect Your personal information.

7.2. Our authorized employees who have given consent to ensure the confidentiality of Users' personal data, as well as third parties who provide us with Site support and administration services and other services related to the Owner's business activities, may have access to Your personal data. Our authorized employees and/or third parties are obliged under agreements concluded with us to comply with all requirements of the current legislation of Ukraine regarding the protection of Users' personal data and their confidentiality.

7.3. The Site may contain links to other websites (for informational purposes only). When following a link to other websites, this Policy will not apply to such sites. In this regard, we recommend that You review the privacy and personal data policy of each website before transmitting any personal data by which You can be identified.

7.4. Personal information that You publish on our Site may be accessible via the Internet worldwide. We cannot prevent the use and misuse of such information by third parties in other countries.

8. Protection of Personal Data

8.1. We use generally accepted standards of technological and operational protection of information and personal data from loss, misuse, alteration or destruction, but we do not guarantee absolute protection from any threats that arise beyond our control.

8.2. We ensure the application of all relevant confidentiality obligations, as well as technical and organizational security measures to prevent unauthorized or unlawful disclosure or processing of such information and data, their accidental loss, destruction or damage.

8.3. We have the right to disclose personal data without Your consent in the case determined by the current legislation of Ukraine, and only (if necessary) in the interests of national security, economic well-being and human rights.

8.4. If You have provided/lost access to Your Account, You are fully and solely responsible for the actions of the new User when using the Site and/or Site Services from Your Account.

9. Terms of Access to Personal Data

9.1. The procedure for third party access to personal data is determined by the terms of the User's consent given to the Owner for the processing of such data, or in accordance with the requirements of the law.

9.2. You have the right to obtain any information about Yourself from any subject of relations related to personal data, subject to indicating the surname, first name and patronymic, place of residence (place of stay) and details of the document certifying the individual submitting the request, except in cases established by the current legislation of Ukraine.

9.3. Access to data about Yourself is free of charge. Delay of access to Your personal data is not permitted. Delay of access to personal data by third parties is permitted if the required data cannot be provided within thirty calendar days from the date of receipt of the request. In this case, the total period for resolving issues raised in the request may not exceed forty-five calendar days.

9.4. Notification of the delay shall be communicated to the third party who submitted the request in writing with an explanation of the procedure for appealing such a decision.

9.5. Refusal of access to personal data is permitted, in the manner determined by the current legislation of Ukraine, if access to them is prohibited in accordance with the Law of Ukraine "On Personal Data Protection".

9.6. A decision on delay or refusal of access to personal data may be appealed to the Commissioner of the Verkhovna Rada of Ukraine for Human Rights or to the court.

10. Your Rights as a User (Data Subject)

10.1. You, as a User (data subject) have the right to:
1. Know about the sources of collection, location of Your personal data, the purpose of their processing, the location of the Owner or give appropriate instructions to authorized persons to obtain this information, except in cases established by the Law of Ukraine "On Personal Data Protection";
2. Receive information about the conditions for granting access to personal data, including information about third parties to whom Your personal data is transferred;
3. Access Your personal data;
4. Receive no later than thirty calendar days from the date of receipt of the request, except in cases provided by the Law of Ukraine "On Personal Data Protection", a response as to whether Your personal data is being processed, as well as receive the content of such personal data;
5. Submit a reasoned demand to the Owner objecting to the processing of Your personal data;
6. Submit a reasoned demand for the change or destruction of Your personal data by the Owner, if such data is processed unlawfully or is inaccurate;
7. Protection of Your personal data from unlawful processing and accidental loss, destruction, damage in connection with intentional concealment, non-provision or untimely provision thereof, as well as protection from the provision of information that is inaccurate or defames Your honor, dignity and business reputation;
8. Lodge complaints about the processing of Your personal data with the Commissioner of the Verkhovna Rada of Ukraine for Human Rights or with the court;
9. Apply legal remedies in case of violation of the current legislation of Ukraine on personal data protection;
10. Make reservations regarding the limitation of the right to process Your personal data when giving consent;
11. Withdraw consent to the processing of personal data;
12. Know the mechanism of automatic processing of personal data;
13. Protection from automated decision-making that has legal consequences for You.

11. Cookies

11.1. Our Site uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that a web server sends to a web browser and the browser stores. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies can be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by the web browser and will remain valid until its set expiry date unless You delete it before the expiry date; a session cookie, on the other hand, will expire at the end of Your session when the web browser is closed. Cookies typically do not contain any information that personally identifies You, but the personal information we store about You may be linked to information stored in and obtained from cookies.

11.2. The names of the cookies we use on our Site and the purposes for which they are used are set out below:
we use Google Analytics on our Site to recognize a computer when a User visits our Site.
Most browsers allow You to refuse to accept cookies – for example:
in Internet Explorer (version 10) You can block cookies using the cookie management settings by clicking "Tools", "Internet Options", "Privacy", and then "Advanced";
in Firefox (version 24) You can block all cookies by clicking "Tools", "Options", "Privacy", select "Use custom settings for history" from the dropdown menu and uncheck "Accept cookies from sites"; and
in Chrome (version 29) You can block all cookies by opening the "Customize and control" menu, clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under "Cookies".

11.3. Blocking all cookies will have a negative impact on the usability of the Site. If You block cookies, You will not be able to use all the features of our Site.

11.4. You can delete cookies that are already stored on Your computer. Deleting cookies will have a negative impact on the usability of many websites.
To delete cookies:
in Internet Explorer (version 10) You need to delete cookies manually (instructions for this can be found on the website http://support.microsoft.com/kb/278835);
in Firefox (version 24) You can delete cookies by clicking "Tools", "Options" and "Privacy", then select "Use custom settings for history", click "Show cookies", and then click "Remove all cookies";
in Chrome (version 29) You can delete all cookies by opening the "Customize and control" menu and clicking "Settings", "Show advanced settings" and "Clear browsing data", then select "Delete cookies and other site and plugin data" before clicking "Clear browsing data".

12. Policy Changes

12.1. We reserve the right to publish separate privacy notices, as well as to change and/or supplement the content of the Policy at any time at our discretion.

12.2. In case of material changes to the Policy, we will post a notice on the Site and specify the effective date of such changes. If You do not refuse to accept these changes in writing within the specified period, this will mean that You have agreed to the relevant changes to the Policy.