1. General Provisions

This Personal Data Processing Policy is compiled in accordance with the requirements of the Federal Law of July 27, 2006. No. 152-FZ “On Personal Data” (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Kuklyak Oleg Yurievich (hereinafter referred to as the Operator).

1.1. The Operator sets as its most important goal and condition for carrying out its activities the observance of the rights and freedoms of man and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

1.2. The Operator’s present Personal Data Processing Policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://www.kykil.com.

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 cessation of processing of personal data (except for cases where processing is necessary to clarify personal data).

2.3. Website – a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://www.kykil.com.

2.4. Information system of personal data – a set of personal data contained in databases, and ensuring their processing by information technologies and technical means.

2.5. Depersonalization of personal data – actions as a result of which it is impossible to determine without using additional information the belonging of personal data 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 the use of automation tools or without the use of such tools with personal data, including 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) carries out the processing of personal data, and also determines the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.

2.8. Personal data – any information that relates directly or indirectly to a specific or determined User of the website https://www.kykil.com.

2.9. Personal data permitted by the subject of personal data for dissemination – personal data, access to which is granted to an unlimited number of persons by the subject of personal data by providing consent to the processing of personal data permitted by the subject of personal data for dissemination in accordance with the procedure provided for by the Law on Personal Data (hereinafter referred to as personal data permitted for dissemination).

2.10. User – any visitor to the website https://www.kykil.com.

2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an unspecified number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publishing personal data in the media, posting on information and telecommunications networks or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a government body of a foreign state, to a foreign individual or to a foreign legal entity.

2.14. Destruction of personal data – any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoration of the content of personal data in the personal data information system and (or) the material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right:
– to receive from the subject of personal data reliable information and / or documents containing personal data;
– in the event of withdrawal by the subject of personal data of consent to the processing of personal data, the Operator has the right to continue the processing of personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;
– to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Operator is obliged:
– to provide the subject of personal data with information regarding the processing of his personal data at his request;
– organize the processing of personal data in accordance with the procedure established by the current legislation of Ukraine;
– respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
– report to the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 30 days from the date of receipt of such a request;
– publish or otherwise provide unlimited access to this Policy on the processing of personal data;
– take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, distortion, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in relation to personal data;
– terminate the transfer (distribution, provision, access) of personal data, terminate the processing and destroy personal data in the manner and in cases stipulated by the Law on Personal Data;
– perform other obligations stipulated by the Law on Personal Data.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:
– receive information regarding the processing of their personal data, except for cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except for cases where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
– require the Operator to clarify their personal data, block or destroy them if the personal data are incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
– impose the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
– to withdraw consent to the processing of personal data;
– to appeal to the authorized body for the protection of the rights of personal data subjects or in court against the Operator’s unlawful actions or inaction in the processing of his personal data;
– to exercise other rights provided for by the legislation of Ukraine.

4.2. Personal data subjects are obliged to:
– provide the Operator with reliable data about themselves;
– notify the Operator of the clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with unreliable information about themselves, which is information about another personal data subject without the latter’s consent, are liable in accordance with the legislation of Ukraine.

5. The Operator may process the following personal data of the User

5.1. Surname, patronymic.

5.2. Telephone numbers.

5.3. The site also collects and processes depersonalized data about visitors (including cookie files) using Internet statistics services (Yandex Metrics and Google Analytics, etc.).

5.4. The data listed above are hereinafter referred to as Personal Data.

5.5. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, or intimate life.

5.6. Processing of personal data permitted for dissemination from among the special categories of personal data specified in Part 1 of Article 10 of the Personal Data Law is permitted if the prohibitions and conditions stipulated in Article 10.1 of the Personal Data Law are observed.

5.7. The User’s consent to the processing of personal data permitted for dissemination is issued separately from other consents to the processing of his personal data. In this case, the conditions stipulated, in particular, in Article 10.1 of the Law on Personal Data are observed. Requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.7.1 The User shall provide the Operator with consent to the processing of personal data permitted for distribution directly.

5.7.2 The Operator shall be obliged, no later than three business days from the date of receipt of the User’s consent, to publish information on the terms of processing, on the existence of prohibitions and conditions for the processing by an unlimited number of persons of personal data permitted for distribution.

5.7.3 The transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution shall be terminated at any time at the request of the personal data subject. This request must include the surname, first name, patronymic (if available), contact information (telephone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this request may be processed only by the Operator to whom this action is directed.

5.7.4 Consent to the processing of personal data permitted for the purpose of irection, ceases to be valid from the moment the Operator receives the request specified in clause 5.7.3 of this Policy regarding the processing of personal data.

6. Principles of personal data processing

6.1. Personal data processing is carried out on a lawful basis of openness and fairness.

6.2. Personal data processing is limited to achieving specific, predetermined and legitimate purposes. Personal data processing that is incompatible with the purposes of collecting personal data is not allowed.

6.3. The combination of databases containing personal data processed for purposes incompatible with each other is not allowed.

6.4. Only personal data that meet the purposes of their processing are subject to processing.

6.5. The content and volume of processed personal data meet the stated purposes of processing. The redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing personal data are ensured. The Operator takes the necessary measures and / or ensures their adoption to delete or clarify incomplete or inaccurate data.

6.7. Personal data is stored in a form that allows identifying the subject of personal data for no longer than is required by the purposes of processing personal data, unless the term for storing personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data are destroyed or depersonalized after achieving the purposes of processing or in the event of the loss of the need to achieve these purposes, unless otherwise provided for by federal law.

7. Purposes of processing personal data

7.1. The purpose of processing the User’s personal data:
– informing the User by sending e-mails;

– providing the User with access to services, information and/or materials contained on the website https://www.kykil.com.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending a letter to the Operator to the email address okuklyak@gmail.com with the mark “Refusal of notifications about new products and services and special offers”.

7.3. Depersonalized user data collected using Internet statistics services are used to collect information about user actions on the site, improve the quality of the site and its content.

8. Legal grounds for processing personal data

8.1. The legal grounds for processing personal data by the Operator are:
– agreements concluded between the operator and the subject of personal data;
– federal laws, other regulatory legal acts in the field of personal data protection;
– consent of users to the processing of their personal data, to the processing of personal data permitted for dissemination.

8.2. The Operator processes the User’s personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://www.kykil.com or sent to the Operator by e-mail. By filling in the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this policy.

8.3. The Operator processes depersonalized data about the User if this is permitted in the User’s browser settings (including saving cookies and using JavaScript technology).

8.4. The personal data subject independently decides to provide their personal data and gives consent freely, of their own free will and in their own interest.

9. Terms of personal data processing

9.1. Personal data processing is carried out with the consent of the personal data subject to the processing of their personal data.

9.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of Ukraine or by law, to exercise the functions, powers and obligations assigned to the operator by the legislation of Ukraine.

9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, which are subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.

9.4. The processing of personal data is necessary for the execution of a contract to which the subject of personal data is a party or a beneficiary or a guarantor, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or a guarantor.

9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.

9.6. Personal data is processed, access to which is granted to an unlimited number of persons by the subject of personal data or at his request (hereinafter referred to as the publicly available personal data).

9.7. Personal data subject to publication or mandatory disclosure is processed in accordance with federal law.

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

10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

10.3. In case of detection of inaccuracies in personal data, the User can update them independently by submitting a corresponding message to the Operator to the Operator’s email address okuklyak@gmail.com with the mark “Update of personal data”.

10.4. The term of processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another term is provided for by the agreement or applicable law.

The User may at any time withdraw his consent to the processing of personal data by sending a message to the Operator via email to the Operator’s email address okuklyak@gmail.com with the mark “Withdrawal of consent to the processing of personal data”.

10.5. All information collected by third-party services, including payment systems, communication means and other service providers, is stored and processed by the specified persons (Operators) in accordance with their Agreement and Privacy Policy. The subject of personal data and / or the User is obliged to independently familiarize himself with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. The prohibitions established by the subject of personal data on the transfer (except for granting access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing of personal data in the state, public and other public interests, as defined by the legislation of Ukraine.

10.7. When processing personal data, the Operator ensures the confidentiality of personal data.

10.8. The Operator stores personal data in a form that allows identifying the subject of personal data for no longer than required by the purposes of processing personal data, unless the term of storage of personal data is established by federal law, an agreement to which the party, beneficiary or guarantor of which the subject of personal data is a party.

10.9. The condition for terminating the processing of personal data may be the achievement of the purposes of personal data processing, the expiration of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the detection of unlawful processing of personal data.

11. List of actions taken by the Operator with the received personal data

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (dissemination, provision, access), depersonalizes, blocks, deletes and destroys personal data.

11.2. The Operator carries out automated processing of personal data with or without receipt and/or transmission of the received information via information and telecommunications networks

12. Cross-border transfer of personal data

12.1. Before commencing the cross-border transfer of personal data, the operator must ensure that the foreign state to which the personal data is to be transferred provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only if there is written consent from the personal data subject to the cross-border transfer of his or her personal data and/or performance of an agreement to which the personal data subject is a party.

13. Confidentiality of personal data
The operator and other persons who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the personal data subject, unless otherwise provided for by federal law.

14. Final provisions

14.1. The User may obtain any necessary clarifications on the processing of his/her personal data by contacting the Operator by e-mail okuklyak@gmail.com.

14.2. This document will reflect any changes to the Operator’s personal data processing policy. Policy is valid indefinitely until replaced by a new version.

14.3. The current version of the Policy is freely available on the Internet at https://kykil.com/en/privacy-policy-eng/.