This Privacy Policy (the “Privacy Policy”) sets out the confidentiality regime for information that becomes available to the Website Administration at https://botvinov.pro when Users visit or use the website and/or fill in its forms. This English version is provided for convenience; in case of any discrepancy, the Russian version prevails.
1. Definitions
1.1. Website Administration — the Website Owner and persons authorised by the Owner who administer the Website or have access to the email, messengers, phones and other means of communication listed on the Website for contact.
1.2. Website — https://botvinov.pro.
1.3. Confidentiality — a special regime of access to and processing of Confidential Information, implying a limited circle of persons entitled to access it and special rules for processing, storing, transferring and destroying Confidential Information, intended to protect it from transfer to third parties without the consent of the person concerned, except where such transfer is required by law.
1.4. Confidential Information — any information about the User (including Personal Data) that the Website Administration may obtain when the User visits the Website or fills in its forms.
1.5. Processing of Personal Data — any action or set of actions such as collection, registration, accumulation, storage, adaptation, alteration, updating, use and dissemination (distribution, sale, transfer), anonymisation and destruction of Personal Data, including by means of information (automated) systems.
1.6. Personal Data — any information relating directly or indirectly to an identified or identifiable User who uses (visits, leaves Personal Data on, etc.) the Website.
1.7. User — an individual who uses the Website, including one who visits it without the aim of ordering services.
1.8. Website Owner — individual entrepreneur Oleg Botvinov.
1.9. Cookies — a small piece of data sent by a web server and stored on the User's computer, which the web client or browser sends back to the web server in an HTTP request each time it tries to open a page of the relevant site.
1.10. IP address — a unique address of a node in a computer network built on the IP protocol.
2. General Provisions
2.1. By starting to visit the Website, the User agrees to the Privacy Policy.
2.2. If the User disagrees with the Privacy Policy, the User must stop using the Website and take no active actions on it (filling in forms, leaving comments, contacting the Website Administration).
2.3. This Privacy Policy applies only to the Website. The Website Owner does not control and is not responsible for third-party sites that the User may reach via links on the Website.
2.4. The Website Administration does not verify the accuracy of Personal Data provided when ordering information services on the Website.
2.5. The Privacy Policy applies to all Confidential Information that the Website Administration may obtain about the User when the User uses the Website and its programmes and products.
2.6. The Privacy Policy is also intended to protect Personal Data, which is part of Confidential Information; therefore any rules governing the protection of Confidential Information apply equally to Personal Data.
3. Subject of the Privacy Policy
3.1. The Website Administration undertakes not to disclose Confidential Information, to restrict access to it by outsiders, to ensure its reliable and secure storage and to take all necessary and possible measures to keep it confidential. With regard to Personal Data, the Website Administration additionally undertakes to comply with Ukrainian personal data protection legislation and, for EU citizens, with the GDPR.
3.2. Without the User's consent, Confidential Information may not be transferred, disclosed or published except in the cases provided for by the Privacy Policy, the legislation of Ukraine or the GDPR.
3.3. Confidential Information includes:
3.3.1. the User's Personal Data;
3.3.2. technical information, including data about the device and browser and about how the Website is used, including which pages (sections) the User visits, when and from which IP addresses;
3.3.3. the fact that a service agreement has been concluded on the Website;
3.3.4. other information that may reasonably be considered Confidential Information.
3.4. Information is not Confidential Information if it:
3.4.1. is generally known and publicly available;
3.4.2. has been published by third parties or by the User;
3.4.3. is disseminated with the User's consent.
3.5. Personal Data is provided by the User by filling in a form on the Website when ordering information services. The form contains the following Personal Data fields:
3.5.1. the User's surname, name and patronymic (if any);
3.5.2. the User's contact phone number;
3.5.3. the User's email address;
3.5.4. the User's residency;
3.5.5. the User's bank details.
3.6. Any other personal information (Confidential Information) not specified above (order history, browsers and operating systems used, etc.) is subject to secure storage and non-disclosure in the same way as Confidential Information.
4. Purposes of Processing Confidential Information
4.1. The User's Confidential Information may be used, only for the following purposes and only to the extent necessary:
4.1.1. communication with the User, including sending notices and requests concerning the use of the Website and the provision of services (sending invoices) and processing requests and forms submitted by the User;
4.1.2. drawing up, concluding and performing the public offer agreement for information services;
4.1.3. providing the User with effective customer and technical support in case of problems with using the Website;
4.1.4. providing the User, with their consent, with information about special offers, prices, newsletters and other information about the information services on behalf of the Website;
4.1.5. improving the Website, personalising it and giving the User access to the services, information and/or materials on the Website.
5. Methods and Periods of Processing
5.1. Confidential Information is processed (including stored) in a form that allows the User and the service ordered to be identified, for no longer than the purposes of processing require, unless retention periods are set by applicable law.
5.2. Processed Confidential Information is destroyed or anonymised once the purposes of processing are achieved or are no longer needed.
5.3. The User agrees that the Website Administration may transfer Personal Data to public authorities upon their lawful request.
5.4. The Website Administration takes the necessary organisational and technical measures to protect the User's Confidential Information from unlawful or accidental access, destruction, alteration, blocking, copying and dissemination, and from other unlawful actions of third parties.
5.5. The Website Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or unauthorised disclosure of the User's Confidential Information.
6. Procedure for Processing Confidential Information
6.1. When processing Confidential Information, the Website Administration undertakes to:
6.1.1. allow only authorised persons to process Confidential Information, with whom agreements (employment or civil-law) containing non-disclosure provisions, or non-disclosure agreements, have been signed;
6.1.2. at intervals determined at its discretion, delete Confidential Information about the User if the purposes of Section 4 have been achieved or are no longer relevant;
6.1.3. at the User's request, inform the User whether Confidential Information about them exists and what it contains, and delete it at the User's request;
6.1.4. at the User's request, provide information about the persons who had access to Confidential Information about that User;
6.1.5. take the necessary measures to protect Confidential Information (licensed antivirus software, data encryption).
6.2. The Website protects data transmitted automatically when advertising blocks are viewed and when pages with a statistics script (“pixel”) are visited:
6.2.1. IP address;
6.2.2. information from Cookies;
6.2.3. information about the browser (or other program used to display advertising);
6.2.4. access time;
6.2.5. address of the page containing the advertising block;
6.2.6. referrer (address of the previous page).
6.3. Disabling Cookies may make sections of the Website that require authorisation inaccessible.
6.4. The Website collects statistics on the IP addresses of its Users (visitors). This information is used to identify and solve technical problems.
7. Rights and Obligations of the Parties
7.1. The User has the right to:
7.1.1. receive information about the processing of their Confidential Information;
7.1.2. require the Website Administration to correct, block or destroy Confidential Information about them if it (including Personal Data) is incomplete, outdated, inaccurate, unlawfully obtained or unnecessary for the stated purposes, and take legal measures to protect their rights;
7.1.3. withdraw consent to the processing of Personal Data.
7.2. The User must:
7.2.1. when ordering information services on the Website, provide the Personal Data needed to contact the User and process the order;
7.2.2. if the Personal Data submitted in the form changes, notify the Website Administration accordingly;
7.2.3. if acting on behalf of a third party, obtain that party's consent in advance to provide their Personal Data to the Website Administration.
7.3. The Website Administration has the right to:
7.3.1. receive accurate Confidential Information from the User;
7.3.2. amend the Privacy Policy to further improve the security system in accordance with applicable law.
7.4. The Website Administration must:
7.4.1. use the Confidential Information received solely for the purposes set out in Section 4 of this Privacy Policy;
7.4.2. keep Confidential Information confidential and not sell, exchange, publish or otherwise disclose the User's Confidential Information;
7.4.3. take measures to protect the confidentiality of the User's Confidential Information in accordance with generally accepted standards and applicable law;
7.4.4. carry out the action requested by the User with respect to their Confidential Information and report on such actions.
8. Liability of the Parties
8.1. If the Website Administration fails to perform its obligations and this causes losses, it is liable in accordance with applicable law.
8.2. The Website Administration is not liable if the User provides inaccurate, incomplete or distorted Personal Data, or for any consequences that may arise from this.
8.3. A User who provides inaccurate, incomplete or distorted Personal Data, or Personal Data of third parties without their consent, is liable for the resulting consequences, including compensating all losses incurred by the Website Owner.
8.4. The Website Administration is not liable for the loss or disclosure of Confidential Information if such information:
8.4.1. became public before its loss or disclosure;
8.4.2. was received from a third party before the Website Administration received it;
8.4.3. was disclosed with the User's consent or by the User;
8.4.4. was disclosed as a result of unlawful actions of third parties (unlawful copying or theft of databases, hacker attacks, etc.).
9. Dispute Resolution
9.1. Before going to court over a dispute arising from the relationship between the User and the Website Administration, a claim (a written proposal for pre-trial settlement) must be submitted.
9.2. Within 30 (thirty) calendar days of receiving a written (including electronic) claim, the recipient notifies the claimant of the outcome of its consideration.
9.3. If no agreement is reached, the dispute is referred to a court in accordance with the current legislation of Ukraine at the defendant's location.
9.4. This Privacy Policy and the relationship between the User and the Website Administration are governed by the current legislation of Ukraine.
10. Additional Terms
10.1. The Website Administration may amend this Privacy Policy without the User's consent.
10.2. A new Privacy Policy takes effect when published on the Website, unless otherwise provided by the new version and/or the current legislation of Ukraine.
10.3. This Privacy Policy is published at https://botvinov.pro.
10.4. The Privacy Policy ceases to apply to a User who has concluded a Confidentiality Agreement with the Website Owner.
Contact for privacy requests: botvinovpro@gmail.com