Privacy Policy on Personal Data Processing

1. General Provisions

This Privacy Policy on personal data processing (hereinafter – the Policy) has been developed in accordance with the requirements of the Law "On Personal Data" (hereinafter – the Personal Data Law) and defines the procedure for personal data processing and the measures taken by TOV "PA-GO" (hereinafter – the Operator) to ensure the security of personal data.

1.1. The Operator's most important goal and condition for carrying out its activities is the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal, and family secrecy.

1.2. This Operator's policy regarding personal data processing (hereinafter – the Policy) applies to all information that the Operator may obtain about visitors of the website https://pago.in.ua.

2. Key Concepts Used in the Policy

2.1. Automated Personal Data Processing – processing of personal data using computer technology.

2.2. Blocking of Personal Data – temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).

2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet via the network address https://pago.in.ua.

2.4. Personal Data Information System – a set of personal data contained in databases, and the information technologies and technical means that ensure their processing.

2.5. Anonymisation of Personal Data – actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other personal data subject.

2.6. Personal Data Processing – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematisation, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, destruction of personal data.

2.7. Operator – a state body, municipal body, legal or natural person who independently or jointly with other persons organises and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, the actions (operations) performed with personal data.

2.8. Personal Data – any information related directly or indirectly to a specific or identifiable User of the website https://pago.in.ua.

2.9. Personal Data Permitted for Distribution by the Personal Data Subject – personal data to which access by an unlimited circle of persons is provided by the personal data subject by giving consent to the processing of personal data permitted for distribution by the personal data subject in the manner prescribed by the Personal Data Law (hereinafter – personal data permitted for distribution).

2.10. User – any visitor to the website https://pago.in.ua.

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

2.12. Distribution of Personal Data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing an unlimited circle of persons with personal data, including the publication of personal data in the media, placement in information and telecommunication 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 foreign state authority, foreign natural or foreign legal person.

2.14. Destruction of Personal Data – any actions as a result of which personal data is irrevocably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or the physical carriers of personal data are destroyed.

3. Basic Rights and Obligations of the Operator

3.1. The Operator has the right to:

• receive reliable information and/or documents containing personal data from the personal data subject;

• in case the personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Personal Data Law;

• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided for by the Personal Data Law and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:

• provide the personal data subject, upon their request, with information concerning the processing of their personal data;

• organise the processing of personal data in the manner established by current legislation;

• respond to appeals and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

• notify the authorised body for the protection of the rights of personal data subjects, upon request of this body, of the necessary information within 30 days from the date of receipt of such request;

• publish or otherwise ensure unrestricted access to this Policy regarding personal data processing;

• take legal, organisational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, distortion, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;

• terminate the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;

• perform other duties provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

• receive information concerning the processing of their personal data, except in cases provided for by federal laws;

• demand from the operator the clarification of their personal data, their blocking or destruction if the personal data is incomplete, outdated, inaccurate, illegally obtained, or is not necessary for the stated purpose of processing, and also take measures provided for by law to protect their rights;

• set a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;

• withdraw consent to personal data processing;

• appeal to the authorised body for the protection of the rights of personal data subjects or in court the unlawful actions or inactions of the Operator when processing their personal data;

• exercise other rights provided for by law.

4.2. Personal data subjects are obliged to:

• provide the Operator with reliable data about themselves;

• notify the Operator about the clarification (update, change) of their personal data.

4.3. Persons who provided the Operator with unreliable information about themselves, or information about another personal data subject without the latter's consent, bear responsibility in accordance with the legislation.

5. Personal Data That May Be Processed by the Operator

5.1. The Operator may process the following personal data of the User:

• Surname, name, patronymic.

• Phone numbers.

• Year, month, date, and place of birth.

5.2. The website also collects and processes anonymised data about visitors (including "cookie" files) using Internet statistics services (Yandex Metrica and Google Analytics and others).

5.3. The above data are hereinafter referred to by the general concept of Personal Data.

5.4. The Operator does not process special categories of personal data concerning racial, ethnic origin, political views, religious or philosophical beliefs, intimate life.

5.5. Processing of personal data permitted for distribution:

5.5.1. Processing of personal data permitted for distribution, from among the special categories of personal data specified in Part 1 of the Personal Data Law, is allowed if the prohibitions and conditions provided for by the Personal Data Law are met.

5.5.2. The User's consent to the processing of personal data permitted for distribution is formalised separately from other consents to the processing of their personal data.

5.5.3. The User provides consent to the processing of personal data permitted for distribution to the Operator directly.

5.5.4. The Operator is obliged, no later than three working days from the moment of receiving the specified consent of the User, to publish information about the terms of processing, the existence of prohibitions and conditions for processing by an unlimited circle of persons of personal data permitted for distribution.

5.5.5. The transfer (distribution, provision, access) of personal data permitted for distribution by the personal data subject must be terminated at any time upon the request of the personal data subject. This requirement must include the surname, name, patronymic (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is subject to termination.

5.5.6. Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the requirement specified in clause 5.5.5 of this Policy regarding personal data processing.

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.

6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for mutually incompatible purposes.

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

6.5. Redundancy of processed personal data in relation to the stated purposes of their processing is not allowed.

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

6.7. Personal data is stored in a form that allows identifying the personal data subject for no longer than required by the purposes of personal data processing. Processed personal data is destroyed or anonymised upon achieving the processing goals or in case of losing the necessity to achieve these goals.

7. Purposes of Personal Data Processing

7.1. The purpose of processing the User's personal data is:

• Informing the User by sending emails;

• Conclusion, execution, and termination of civil law contracts;

• Clarification of order details.

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 the Operator an email to pago.in.ua@gmail.com with the note "Refusal of notifications about new products, services and special offers."

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

8. Legal Grounds for Personal Data Processing

8.1. The legal grounds for personal data processing by the Operator are:

• Statutory (constituent) documents of the Operator;

• Federal laws, other regulatory legal acts in the field of personal data protection;

• Users' consents to the processing of their personal data, to the processing of personal data permitted for distribution.

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://pago.in.ua or sent to the Operator via email. By filling out 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 anonymised data about the User if this is allowed in the User's browser settings (saving "cookie" files and using JavaScript technology is enabled).

8.4. The personal data subject makes a decision on the provision of their personal data freely, of their own will, and in their own interest.

9. Conditions for Personal Data Processing

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

9.2. Personal data processing is necessary to achieve the goals provided for by an international treaty of Ukraine or law, for the exercise of the functions, powers, and duties assigned by the legislation of Ukraine to the operator.

9.3. Personal data processing is necessary for the administration of justice, execution of a judicial act, act of another body or official.

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

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

9.6. Personal data, to which unrestricted access is provided by the personal data subject or at their request, is processed (hereinafter – publicly available personal data).

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

10. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by implementing legal, organisational, 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 be transferred to third parties, except in cases related to the execution of current legislation or if the personal data subject has given consent to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.

10.3. In case of inaccuracies in personal data, the User can update them independently by submitting a corresponding notification to the Operator's email address pago.in.ua@gmail.com with the note "Personal Data Update."

10.4. The personal data processing period is determined by achieving the purposes for which the personal data was collected. The User can withdraw their consent to personal data processing at any time by sending the Operator a notification via email to pago.in.ua@gmail.com with the note "Withdrawal of consent to personal data processing."

10.5. All information collected by third-party services (payment systems, communication means, and other service providers) is stored and processed by these persons (Operators) in accordance with their Agreement and Privacy Policy. The Operator is not responsible for the actions of third parties.

10.6. Prohibitions established by the personal data subject on the transfer, as well as on the processing or conditions of processing of personal data permitted for distribution, do not apply in cases of personal data processing in state, public, and other public interests defined by the legislation of the Russian Federation.

10.7. The Operator ensures the confidentiality of personal data during processing.

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

11. List of Actions Performed by the Operator with the Received Personal Data

11.1. The Operator carries out the collection, recording, systematisation, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymisation, blocking, deletion, and destruction of personal data.

11.2. The Operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

12. Cross-Border Transfer of Personal Data

12.1. Before starting the cross-border transfer of personal data, the Operator must ensure that the foreign state to whose territory the personal data is intended to be transferred provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only if there is written consent of the personal data subject for the cross-border transfer of their personal data and/or the execution of a contract to which the personal data subject is a party.

13. Confidentiality of Personal Data

The Operator and other persons who have obtained access to personal data are obliged not to disclose personal data to third parties and not to distribute it without the consent of the personal data subject, unless otherwise provided by federal law.

14. Final Provisions

14.1. The User can obtain any necessary clarifications regarding the processing of their personal data by contacting the Operator via email at pago.in.ua@gmail.com.

14.2. Any changes to the Operator's personal data processing policy will be reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.

14.3. The current version of the Policy is publicly available on the Internet at https://pago.in.ua/privacy.