Privacy policy

We, Individual Entrepreneur Y.A. Dubinska, take a responsible approach to the processing and storage of personal data of our service users.

Personal data means information or a set of information about an individual, which is identified or can be specifically identified in accordance with the Law of Ukraine on Personal Data Protection.

This Privacy Policy ("Policy") describes the types of personal information we collect from our website users and our customers.
The Policy is an integral part of the Public Service Offer Agreement of Individual Entrepreneur Y.A. Dubinska.

Data Administrator/Data Operator means Individual Entrepreneur Y.A. Dubinska, identification code 2707506163.

Website (Administrator's Site) means a set of hypertext information, software, information tools, logically related to each other, designed in the form of separate pages and available on the Internet. The website can be found on the Internet at vip.sv.club.

Content means information presented on the site, including, but not limited to, text, software, music, sounds, photos, graphics, video, messages, and other materials.

Visitor means an Internet user who has accessed the site, but has not completed the appropriate form as a User/Customer.

User/Customer means an individual, a representative of an individual entrepreneur or a legal entity, who has read the Public Offer Agreement and filled in the form on the site in order to receive the Services.

Form Filling means legally significant actions of the User/Customer, consciously and voluntarily performed on the site, associated with the introduction of accurate personal data, as well as expressing his/her consent to the Offer (Agreement) proposed for reading.

Below please, find a detailed description of the purposes, ways and methods of collecting and processing your personal data and guarantee the confidentiality and safe keeping of your personal data.

We collect and process information that you voluntarily provide to us as follows:

• name, surname and patronymic of the User/Customer;
• passport details;
• identification code;
• bank details;
• mailing address and address of registration;
• email address;
• contact phone number;
• social media data.

Key principles:

• legality, fairness and transparency – availability of legal grounds for data collection and use, non-violation of any laws, openness, end-to-end integrity regarding the personal data use;
• specific purposes – the processing is limited to what has been declared to the data subject. All specific purposes are enshrined in the privacy policy and are strictly respected;
• data minimization - using the minimum amount of data required to meet the objectives;
• accuracy – personal data must be accurate and not misleading; erroneous data must be corrected;
• specific data storage term – the data is stored no longer than required, the data is audited from time to time and unused data is deleted;
• integrity and confidentiality/security – the data is stored in a secure location and sufficient attention is paid to data safe keeping;
• accountability – responsibility for the personal data processing and compliance with all other principles of the European Union General Data Protection Regulation, including the records on confidentiality, protection, use, and verification of data.

The Data Administrator/Data Operator shall process (including the use, storage, systematization, accumulation, etc.) the personal data solely in order to perform its obligations related to the provision of services to the User/Client, and to implement the actions required in accordance with applicable laws of Ukraine and the European Union General Data Protection Regulation.

The Data Administrator/Data Operator shall process personal data in compliance with the personal data processing requirements established by applicable laws of Ukraine, in particular the Law of Ukraine on Personal Data Protection and the European Union General Data Protection Regulation.

By posting your personal data on the site, you thereby confirm that you do so voluntarily, and that you voluntarily provide them to the Data Administrator/Data Operator for processing and transfer, if required, to the third parties in accordance with the Law of Ukraine on Personal Data Protection and the European Union General Data Protection Regulation. If you do not agree with the above terms, you should not fill in the relevant forms on the site or should delete your data and use the site solely for browsing in the Visitor mode.

We only collect data that you provide to us voluntarily for the purpose of interacting with us. For example, we may collect personal data (information from your publicly available social media account) in order to get feedback from you about our services. Either, we may request information about your location to provide you with a relevant form to fill in on the site and, therefore, to provide services or to invite you to participate in promotions. You shall be entitled to refuse to provide this information to us, but in this case our site and services may not work properly for you or their functionality may not be available to you.

Moreover, when you visit our website, we may receive certain information about you automatically. Such information includes: (a) your IP address, (b) your computer/mobile device operating system, (c) your browser type, (d) your device type, (e) your mobile device's unique device identifier (UDID)/mobile equipment identification number (MEID), (f) the website address where you linked to us, and (g) information about the pages and sections you visited on our website.

We may use this information to administer, maintain and customize our site and services in order to provide timely and high-quality services to you.

Personal data is processed using computers and/or automation tools in accordance with the procedures and methods that are appropriate to the data collection purpose.

In some cases, the personal data collected may be available to certain categories of responsible persons designated by Individual Entrepreneur Y.A. Dubinska as the Data Administrator/Data Operator as a result of the site operation (such as company administration, sales department, marketing department, call center, legal department, system administrators) or third parties (such as independent technical service providers, postal organizations, hosting service providers, information technology companies, communications services, legal advisers, etc.). You have the right to ask us for a list of the persons performing these functions.

The data is processed in our office and other places, where the responsible persons designated by Individual Entrepreneur Y.A. Dubinska and responsible for its processing are located. For more information, please contact the Data Administrator/Data Operator by sending a relevant email to the address specified in the last section of this Policy.

The Data Administrator/Data Operator may use and process your personal data internally by to provide the services.

Your personal data shall be used by the Data Administrator/Data Operator in accordance with this Policy, applicable laws of Ukraine, and the European Union General Data Protection Regulation. We may send you messages containing marketing/promotional information about our products and services, promotional offers, etc. from time to time.

We may engage the other companies to provide services and arrange advertising campaigns. These companies may also have access to some of your personal data, but only to the extent required to perform their functions in order to provide you with high-quality services. However, they may not use it for any other purpose.

The User/Customer, in accordance with the Law of Ukraine on the Personal Data Protection, shall grant his/her consent for the Data Administrator/Data Operator to transfer his/her personal data to the third parties in order to perform the Public Offer Agreement, provided that the third party recipient undertakes to process such personal data under the same conditions as defined herein and in accordance with applicable laws of Ukraine and the European Union General Data Protection Regulation.

We take all commercially reasonable actions to prevent unauthorized access to personal data obtained through the use of our site or our services. While we strive to protect your personal data, we encourage you to take all precautions available to you to protect your personal data during transmission. To do this, change your passwords frequently, use combinations of letters and numbers when generating passwords, and use a secure browser when surfing the Internet.

We do not knowingly collect personal information from children or anyone under the age of 18, nor do we send them any personal information inquiries. We are not responsible for the actual collection of personal data from this category of persons in cases where representatives of such age groups have given false information about their age when filling in the form (for example, in order to obtain access to restricted parts of the site and the information posted there or our services).

You have full control over all personal data you provide to us. You can update/change the personal information we have received from you at any time.

You have the right to ask us to remove all information collected at any time, i.e. you have the right to be forgotten. You can exercise this right by sending a relevant email to the address specified in the last section of this Policy; in this case, however, our website and services may not work properly for you, or their functionality will not be available to you.

The Website collects information about your behavior on our site and about your visits to our site pages in order to: (a) obtain statistics about visits and the effectiveness of our site usage; (b) create a personalized approach and tailor our services to the interests of each User/Customer.

We do this through various technologies, one of which is cookies. Cookies mean the data that a website may send to your browser, which will be saved on your computer for the further identification by the website.

Cookies are usually used to assess the websites effectiveness (for example, to measure the number of visitors and the duration of their stay on the site), to identify the most interesting and visited topics and sections, and to ensure easy navigation and use of the site, without collecting any personal data. Cookies can also be used to form a personalized approach based on the user's previous experience with the site. Over time, this information allows improving his/her experience.

If you no longer wish to receive cookies, or if you wish to be informed when you receive cookies, configure your web browser accordingly. However, if you disable all cookies, you will not be able to use some services and features of the site.

We may change this Policy at any time by posting the revised Policy in a relevant section of the site.

If you disagree with any updated made to the Policy, you must stop using our site and services. You also shall be entitled to request deletion of your personal data by sending a relevant email to the address specified in the last section of this Policy; in this case, however, our website and services may not work properly for you or their functionality will be unavailable to you.

This Policy shall apply to all personal data of Users/Customers on our site, regardless of the method of its collection and the way it is obtained.