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Privacy Policy

Last updated: 22 July 2026

1. General provisions

1.1

This Privacy Policy (hereinafter the "Policy") sets out how personal data is collected, processed and protected by individual entrepreneur Dmytrenko Sofiia Dmytrivna (taxpayer ID / RNOKPP: 3770706565), hereinafter "We", "Our", the "Contractor".

1.2

The Policy applies to any information that users (hereinafter "You", the "User", the "Client") provide to us when using the prometeylabs.com website, ordering services or interacting with us in any other way.

1.3

We respect Your right to privacy and undertake to protect personal data in accordance with the Law of Ukraine "On Personal Data Protection" and, where applicable, the European Union's General Data Protection Regulation (GDPR).

1.4

Processing data on behalf of others (Data Processing). When providing services for the development, testing and technical support of the Client's web resources, CRM/CMS systems or other software, We may obtain temporary access to databases for which the Client is the controller. In such cases We act solely as a Data Processor under Article 28 GDPR. We process such data strictly in accordance with the Client's documented instructions, do not use it for our own purposes and undertake to delete or return it after the services are completed.

2. What data we collect

We collect only the amount of data that is objectively necessary to provide our services and ensure proper communication. In particular:

  • Contact and identification data: first name, last name, phone number, email address, company name, job title (which You provide yourself in contact forms, briefs or correspondence);
  • Website usage data: IP address, date and time of visit, device type, operating system and browser. This data is collected automatically by servers and cookies;
  • Analytics information: aggregated data from web analytics services (for example, Google Analytics, Facebook Pixel) about behaviour on the website (pages viewed, session duration, traffic sources).

3. Purposes and legal grounds for processing

3.1

We use Your data solely for the following purposes:

  • concluding and performing contracts for the provision of IT services (website and app development, marketing support, etc.);
  • responding to Your enquiries and providing customer support;
  • carrying out financial transactions and preparing accounting documents;
  • conducting marketing research, scaling and optimising digital advertising campaigns (in particular using the Google Ads platform), and retargeting, provided You have given the relevant consent via cookie settings;
  • analysing and improving the functionality and security of our website;
  • complying with applicable law.

3.2

The legal grounds for processing are: Your consent (when filling in forms on the website or setting cookies); the need to conclude and perform a contract; our legitimate interests (ensuring the security of the web resource); and compliance with legal requirements.

4. Transfer and disclosure of data to third parties

4.1

We do not sell Your personal data or pass it to advertising agencies for spam mailings.

4.2

Data may be transferred to third parties only to the extent necessary to provide services, in particular to:

  • banks and payment services (to process transactions and arrange instalment services);
  • cloud service and hosting providers;
  • web analytics services (in anonymised form).

4.3

Your data may be transferred to and stored on servers located outside Ukraine. When personal data of EU residents is transferred to countries not recognised by the European Commission as providing an adequate level of protection (including Ukraine), We apply appropriate legal safeguards, in particular the Standard Contractual Clauses (SCCs) approved by the European Commission, to ensure the highest security standard.

4.4

Data is disclosed to state or law enforcement authorities only in the cases and in the manner expressly provided for by applicable law.

5. Data retention periods

5.1

We store Your personal data only for as long as necessary to achieve the purposes for which it was collected, or for the period required by the applicable law of Ukraine (in particular, accounting and tax law).

5.2

Web analytics data is stored in accordance with the standard data retention settings of the respective services (Google, Meta).

6. Your rights

As a data subject, You have the right to:

  • know the sources of collection and the location of Your personal data and the purpose of its processing;
  • access Your personal data;
  • request the correction, updating or deletion of Your personal data (the "right to be forgotten");
  • withdraw consent to data processing at any time;
  • file complaints about data processing with the Ukrainian Parliament Commissioner for Human Rights or with a court;
  • request data portability in a structured, commonly used and machine-readable format;
  • request restriction of processing of Your data;
  • object to the processing of Your data for direct marketing or profiling purposes;
  • lodge a complaint with a data protection supervisory authority in the EU member state of Your habitual residence, place of work or place of the alleged infringement.

7. Data protection and limitation of liability

7.1

We apply modern technical and organisational measures to protect Your data from unauthorised access, loss or disclosure (in particular, encryption using the HTTPS protocol and database access control).

7.2

Limitation of liability: We take all commercially reasonable and technical security measures to protect Your data. However, You understand that transmitting information over the Internet carries inherent risks. The Contractor is liable for personal data security breaches only to the extent of its proven fault and in accordance with applicable law.

7.3

Data breach notification: If unauthorised access to, loss or disclosure of personal data is detected that may pose a high risk to the rights and freedoms of data subjects, We undertake to notify the relevant supervisory authorities of the incident (no later than 72 hours after discovery) and the affected users directly, in the manner provided for by the law of Ukraine and the GDPR.

8. Use of cookies

Our website uses cookies to ensure the interface works correctly and to collect analytics. Detailed information about which cookies we use and how You can manage them is set out in our separate Cookie Policy.

9. Contact information

If You have any questions about this Policy or wish to exercise Your rights regarding personal data, please contact us by email: info@prometeylabs.com.

10. Changes to the Policy

We reserve the right to update this Policy periodically. Changes take effect from the moment a new version is published on this page (with the "Updated" date shown at the top of the document). Continuing to use the website after changes are made means You agree to the updated terms.

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