Privacy Policy

This Privacy Policy (hereinafter referred to as the “Policy”) applies to the processing of personal data and ensuring the protection of personal data of Users (subjects of personal data) while using the REDLUX website located on the website: https://redlux.agency/ , on the basis of the Constitution of Ukraine and the Law of Ukraine “On the Protection of Personal Data” dated June 1, 2010 No. 2297-VI (hereinafter referred to as the Law), as well as the General Data Protection Regulation (EU) 2016/679 dated April 27, 2016 ( EU General Data Protection Regulation, hereinafter referred to as the GDPR) and other applicable European data protection legislation, collectively referred to as the Legislation.

This Privacy Policy applies to the website: https://redlux.agency/ (hereinafter referred to as the Site). Before viewing REDLUX, be sure to read the text containing the Privacy Policy of the Site you are using.

The administration undertakes to take all necessary measures to prevent the abuse of your personal data that becomes known to us. The processing of your personal data is carried out in accordance with the requirements of the applicable Legislation and only if there are legal grounds for such processing.

 

  1. Terms and definitions.

1.1. Personal data – any information relating directly or indirectly to a specific or identifiable natural person (subject of personal data).

1.2. The subject of personal data is a natural person to whom personal data relates and who can be identified by these personal data, or who has already been identified.

1.3. Site Administration (hereinafter referred to as the Administration) – authorized employees acting on behalf of Ukrtech-Info Limited Liability Company, who organize and (or) carry out the processing of personal data, and also determine the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.

1.4. Processing of personal data – any action or set of actions performed with or without the use of automation tools with personal data, including collection, accumulation, storage, adaptation, modification, restoration, use and distribution (distribution, sale, transfer), depersonalization, destruction of personal data.

1.5. Dissemination of personal data – actions to transfer information about an individual with the consent of the subject of personal data.

1.6. Blocking of personal data – temporary suspension of the processing of personal data (except when processing is necessary to clarify personal data).

1.7. Use of personal data – any actions of the Administration for the processing of these data, actions to protect them, as well as actions to grant partial or full rights to process personal data to other subjects of relations related to personal data, performed with the consent of the subjects of personal data or in accordance with applicable law .

1.8. Destruction of personal data – actions, as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed.

1.9. Depersonalization of personal data – the withdrawal of information that allows you to directly or indirectly identify a person.

1.10. User – a subject of personal data who has access to the site via the Internet and uses the Site https://redlux.agency/.

1.11. Site – a website located at: https://redlux.agency/., owned by the Site Administration on the Internet.

1.12. Policy – this Privacy Policy located at: https://redlux.agency/.

 

  1. General provisions

2.1. This Policy is a public contract, according to which the User fully confirms his agreement with the conditions listed below.

This Policy applies only to this Site. The Site Administration does not control and is not responsible for third-party sites to which the User can follow the links available on the Site.

2.2. This Policy applies to all personal data of Users that may be obtained by the Site Administration in the process of providing services to the User.

This Policy applies to personal data received both before and after the entry into force of this Policy.

2.3. If you disagree with this Privacy Policy, please stop using this Site.

2.4. The Site Administration does not verify the accuracy of the personal data provided by the User, does not have the ability to assess its legal capacity. However, the Administration assumes that the User acts in good faith, prudently, provides reliable and sufficient personal information and makes every effort to keep such information up to date.

2.5. By agreeing to the terms of this Policy, you confirm that at the time of collecting personal data, you are notified of the persons to whom personal data is transferred, the content and purposes of collecting personal data. You confirm (guarantee) that the personal data that is transferred to us for processing is transferred with the consent of the owners of personal data and within the framework of the Legislation.

2.6. Consent to the processing of personal data may be withdrawn by the subject of personal data. If the subject of personal data withdraws consent to the processing of personal data, the Administration has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Legislation.

2.7. The Administration, having received personal data from the User, does not assume the obligation to inform the subjects (their representatives), whose personal data has been transferred to it, about the start of processing personal data, since the obligation to carry out appropriate information when concluding an agreement with the subject of personal data and / or when obtaining consent to such a transfer, is borne by the User who transferred personal data.

2.8. The processing of your personal data is carried out in accordance with the requirements of the Law. The processing of personal data of persons located in the EU or who are EU citizens is regulated in particular by the EU General Data Protection Regulation 2016/679. Also, the legislation of other countries may establish additional requirements.

2.9. No one under the age of 18 should provide us with personal information through the Site. We do not knowingly collect personal information from persons under the age of 18. Parents and guardians should constantly supervise the related activities of their children.

 

  1. Composition of personal data

3.1. The Site Administration, in order to carry out its activities and fulfill its obligations, processes the User’s personal data provided by them at the request of the Site Administration: https://redlux.agency/.

3.2. The User’s personal data includes: last name, first name, patronymic of the User, e-mail address, as well as other data received from the subject of personal data in the process of using the functionality of the Site.

The Site Administration asks to provide only those personal data that are necessary to provide the service you have chosen, receive newsletters or respond to your special request / claim. At the same time, if you decide to provide us with additional personal data, we will also be able to process it with the necessary level of protection.

3.3. The Site Administration has the right to establish requirements for the composition of personal data that must be provided when using the Site. If certain information is not marked by the Administration as mandatory, its provision or disclosure is carried out by the User at his own discretion.

3.4. Data that is automatically transmitted to the Administration when using the Site by the User using the software installed on the device: IP address, information about the browser and the type of operating system of the device, hardware and software specifications, date and time of access to the Site.

 

  1. Grounds and purpose of personal data processing

4.1. The grounds for the processing of personal data are:

4.1.1. consent of the subject of personal data to the processing of his personal data by the Administration;

4.1.2. conclusion and execution of an agreement, one of the parties of which is the subject of personal data or which is concluded in favor of the subject of personal data, or for the implementation of measures preceding the conclusion of the contract at the request of the subject of personal data;

4.1.3. the need for the Administration to fulfill the requirements stipulated by the Legislation;

4.2. The purpose of personal data processing is:

4.2.1. implementation of the functions assigned to the Administration in accordance with the legislation of Ukraine and the GDPR;

4.2.2. collection, storage and processing of personal data received on the Site within the framework of the Law and the GDPR;

4.2.3. to send the User commercial (marketing) notifications containing additional information about the services, current promotions and special offers relating to the services provided by the Administration through the Site;

4.2.4. identification of the subject of personal data when using the Site;

4.2.5. communication with the subject of personal data, if necessary, including sending offers, information materials, messages, information and requests, advertising, as well as processing requests from the subject of personal data;

4.2.6. improving the quality of the Site, its usability, developing new functionality and improving the quality of service;

4.2.7. improving the professional skills and qualifications of the User;

4.2.8. conducting statistical and other research based on depersonalized data;

4.2.9. fulfillment by the Administration of contractual and other obligations to the User on transactions concluded between the Administration and the User or third parties in the interests of the User.

 

  1. Basic principles of personal data processing

5.1. The processing of personal data by the Administration is carried out on the basis of the principles:

5.1.1. The legality of the purposes and methods of processing personal data;

5.1.2. The integrity of the Administration, as the owner of personal data, is achieved by complying with the requirements of the legislation of Ukraine and the GDPR regarding the processing of personal data;

5.1.3. Achievement of specific, predetermined purposes of personal data processing;

5.1.4. Compliance of the purposes of processing personal data with the purposes predetermined and declared when collecting personal data;

5.1.5. Compliance of the list and volume of processed personal data, as well as methods of processing personal data with the stated purposes of processing;

5.1.6. Reliability of personal data, their sufficiency for the purposes of processing, inadmissibility of processing personal data that is excessive in relation to the purposes of processing personal data;

5.1.7. Ensuring, when processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data.

5.1.8. The inadmissibility of combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other;

5.1.9. Storage of personal data in a form that allows to identify the subject of personal data, no longer than required by the purposes of their processing.

5.1.10. The processed personal data is subject to destruction or depersonalization upon achievement of the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by the legislation of Ukraine and the GDPR.

5.1.11. We must also take into account the periods for which we may need to retain your personal data in order to comply with our legal obligations to you or regulatory authorities.

5.1.12. We may minimize the personal data we use about you over time, or we may even make your data anonymous so that it can no longer be associated with you personally. In this case, we may use this information for statistical or other purposes without further notice to you, as such information ceases to be personal data.

5.2. The processing of personal data is carried out by the Administration for statistical or other research purposes, subject to the mandatory depersonalization of personal data.

5.3. The administration does not process personal data related to racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties and trade unions, criminal convictions, as well as data related to health, sexual life, biometric and genetic data.

5.4. The processing of personal data is carried out in compliance with the conditions determined by the legislation of Ukraine and the GDPR.

 

  1. Terms of personal data processing

6.1. The terms for processing personal data are determined based on the purposes of processing, but no longer than it is determined by the Legislation.

6.2. Personal data whose processing (storage) period has expired must be destroyed or anonymized, unless otherwise provided by the Law. The storage of personal data is carried out in a form that allows to determine the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by the Law. The processed personal data is subject to destruction or depersonalization upon achievement of the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by the Law. We must also take into account the periods for which we may need to retain your personal data in order to comply with our legal obligations to you or to regulatory authorities (in accordance with EU Regulation 261/2004).

6.3. We may minimize the personal data we use about you over time, or we may even make your data anonymous so that it can no longer be associated with you personally. In this case, we may use this information without further informing you.

 

  1. Rights of the subject of personal data

7.1. The rights of subjects of personal data in accordance with the legislation of Ukraine:

7.1.1. Know about the sources of collection, the location of their personal data, the purpose of their processing, the location of the processor of personal data or give an appropriate instruction to obtain this information to authorized persons, except as otherwise established by the Law;

7.1.2. Receive information about the conditions for granting access to personal data, including information about third parties to whom his personal data is transferred;

7.1.3. To access your personal data;

7.1.4. Receive no later than 30 (thirty) calendar days from the date of receipt of the request, except as otherwise provided by the Law, an answer on whether his personal data is being processed, and which ones;

7.1.5. Submit a reasoned demand to the Administration for an objection to the processing of their personal data;

7.1.6. Submit a reasoned request to change or destroy your personal data if the data is processed illegally or is unreliable;

7.1.7. To protect their personal data from illegal processing and accidental loss, destruction, damage due to deliberate concealment, failure to provide or untimely provision of them, as well as to protection from the provision of information that is unreliable or discrediting the honor, dignity and business reputation of an individual;

7.1.8. File complaints about the processing of their personal data to the Administration to the Commissioner of the Verkhovna Rada of Ukraine for Human Rights or to the court;

7.1.9. Apply legal remedies in case of violation of legislation on the protection of personal data;

7.1.10. Make reservations about limiting the right to process your personal data when giving consent;

7.1.11. Withdraw consent to the processing of personal data;

7.1.12. The Administration has the right to entrust the processing of personal data to a third party with the consent of the subject of personal data, unless otherwise provided by the legislation of Ukraine, on the basis of an agreement concluded with a third party, the condition of which is confidentiality and non-disclosure of personal data.

7.1.13. Representatives of public authorities (including regulatory, supervisory, law enforcement and other bodies) get access to personal data processed by the Administration in the amount and in the manner determined by the legislation of Ukraine.

7.2. Other rights of data subjects under the GDPR:

In addition to Ukrainian legislation on the protection of personal data, the Administration is attentive to ensuring your rights established by the GDPR. You have the right:

7.2.1. Get access to your personal data that we hold.

In accordance with Article 15 of the GDPR, Users have the right to access, which entitles them to receive a copy of their personal data, as well as other additional information. This helps Users understand how and why companies use their data and check if it is legal.

7.2.2. Request correction of incorrect, inaccurate or incomplete personal data.

In accordance with Article 16 of the GDPR, Users have the right to have inaccurate personal data corrected. Also, the User may be able to obtain incomplete personal data – although this will depend on the purposes of processing.

7.2.3. Request the deletion of personal data if they are no longer needed or if their processing is unlawful.

In accordance with Article 17 of the GDPR, Users have the right to delete personal data. This right is also known as the “right to be forgotten”. This right is not absolute and only applies under certain circumstances.

7.2.4. In certain cases, request restrictions on the processing of your personal data.

Article 18 of the GDPR gives Users the right to restrict the processing of their personal data (under certain circumstances). This means that the User can restrict the way in which the company processes his data. This is an alternative to a request to delete their data.

7.2.5. Withdraw your consent at any time.

The GDPR gives a specific right to withdraw consent. Where possible, individuals should be able to withdraw their consent using the same method as at the time they gave it.

 

  1. Implementation of personal data protection

8.1. The activities of the Administration for the processing of personal data in information systems are inextricably linked with the protection by the Administration of the confidentiality of the information received, if this does not contradict the current legislation.

8.2. The personal data protection system includes organizational and (or) technical measures determined taking into account current threats to the security of personal data and information technologies used in information systems. The Administration updates these activities with the advent of new technologies, if necessary.

8.3. The exchange of personal data during their processing in information systems is carried out through communication channels protected by technical means of information protection.

8.4. When processing personal data in information systems, the Administration provides:

– taking measures aimed at preventing unauthorized access to personal data and (or) their transfer to persons who do not have the right to access such information;

– timely detection of facts of unauthorized access to personal data;

– preventing the impact on technical means of automated processing of personal data, as a result of which their functioning may be disrupted;

– the possibility of immediate recovery of personal data modified and destroyed due to unauthorized access to them;

– constant monitoring of the level of protection of personal data.

8.5. With regard to personal information, confidentiality is maintained, except when the technology of the online service or the settings of the software used by the User provide for an open exchange of information with other Users of the online service or with any Internet users.

8.6. The administration implements the following requirements of Ukrainian legislation in the field of personal data:

– requirements for confidentiality of personal data;

– requirements to ensure the implementation by the subject of personal data of their rights;

– requirements to ensure the accuracy of personal data, and, if necessary, relevance in relation to the purposes of processing personal data (with the adoption (ensuring the adoption) of measures to delete or clarify incomplete or inaccurate data);

– requirements for the protection of personal data from unauthorized or accidental access to them, destruction, distortion, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;

– other requirements of the Law.

8.7. In accordance with the Law, the Administration independently determines the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the legislation in the field of personal data from unauthorized or illegal processing and from unintentional loss, destruction or damage.

The administration adheres to the principle of minimizing personal data. We process only the information about you that we need, or the information that you consent to provide more than the limits of necessary processing. In addition, we have configured all interfaces of the Online Service and application to provide services so that the highest possible confidentiality is respected, the settings of which can be adjusted at your discretion. When transferring personal data to government authorities, we always use the most secure and proven methods for transferring such data.

 

  1. Cookies and other tracking technologies.

9.1. We use cookies on our Site, which may involve the processing of your personal data.

9.2. Cookies are text files that are stored in the Internet browser or by the Internet browser when visiting the Site. The cookie file contains a characteristic set of characters that allows the browser to be uniquely identified when the Site is accessed again. Our cookies by themselves do not identify an individual User, but only the computer or mobile device you are using.

9.3. Cookies and other tracking technologies on the Site may be used in a variety of ways, such as for the purpose of operating the Site, analyzing traffic, or for advertising purposes. We use cookies and other tracking technologies, among other things, to improve the quality and efficiency of our services.

9.4. We would like to inform you that you can disable cookies and other tracking technologies in the settings of your Internet browsers. However, you should understand that if you disable some cookies, the functionality of the Site may be limited and you may not be able to use all its benefits, and incorrect operation may also occur.

9.5. By staying on the Site, you agree to the placement of cookies for the purpose of analyzing the use of the Site. If you do not wish to accept cookies, you must stop using the Site.

 

  1. Changing the privacy policy

10.1. This Policy may be changed or terminated by the Administration unilaterally without prior notice to Users, including if required by applicable law. The new version of the Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new version of the Policy. Therefore, we ask you to visit the Site: https://redlux.agency/ to make sure that you have up-to-date information.

 

  1. Who can you contact to protect your personal data

11.1. If you have any questions, comments, complaints or suggestions regarding the protection and processing of personal data, you can contact us info@redlux.agency

Be sure to include in all correspondence your name, surname, e-mail address, as well as detailed questions, comments, complaints or requirements.

11.2. The administrative authority for the protection of personal data in Ukraine is the Office for the Protection of Personal Data of the Secretariat of the Commissioner of the Verkhovna Rada of Ukraine for Human Rights. You can contact him with complaints or suggestions if you think that your rights have been violated in connection with the processing of personal data.

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