Policy on Personal Data Processing

This personal data processing policy is prepared in accordance with the requirements of art. 6, 8, 10, 11 of the Law of Ukraine “On Protection of Personal Data” and defines the procedure for processing personal data and measures to ensure the security of personal data by Web-agency ProGamma (hereinafter – the Operator).

1. The Operator’s main purpose and condition for its activity is observance of human and citizen’s rights and freedoms when processing his/her personal data, including protection of rights to privacy, personal and family secrets.
2. This Operator’s personal data processing policy (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the http://progamma.com.ua website.

1. Automated processing of personal data – processing of personal data by means of computer technology;
2. Blocking of personal data – temporary termination of processing of personal data (except for cases when processing is necessary to clarify personal data);
3. Website means aggregate of graphic and information materials, as well as computer programs and databases, making them available on the Internet at the network address http://progamma.com.ua;
4. Information system of personal data – a set of personal data contained in databases of personal data, and information technologies and technical means, ensuring its processing;
5. Personal data depersonalization – actions, as a result of which it is impossible to determine without the use of additional information whether the personal data belongs to a particular User or another subject of personal data;
6. Processing of personal data – any action (operation) or a set of actions (operations), performed with or without the use of automation with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, removal, destruction of personal data;
7. Operator – a state body, municipal authority, legal entity or individual, independently or together with other persons organizing and (or) performing processing of personal data, as well as determining the purpose of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data;
8. Personal data – any information related, directly or indirectly, to a particular or definable user of http://progamma.com.ua web site;
9. User – any visitor to the http://progamma.com.ua website;
10. Provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain circle of persons;
11. Dissemination of personal data – any actions aimed at disclosure of personal data to an indefinite range of persons (transfer of personal data) or to familiarize with personal data to an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way;
12. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual or a foreign legal entity;
13. Destruction of personal data – any actions, as a result of which personal data is destroyed irretrievably with impossibility of further restoration of content of personal data in information system of personal data and (or) as a result of which tangible carriers of personal data are destroyed.

1. Surname, first name, patronymic;
2. E-mail address;
3. Telephone numbers;
4. Cookies;
5. The website also collects and processes impersonal visitor data (including cookies) using Internet statistical services (Yandex Metrika and Google Analytics, etc.).
6. The above-mentioned data are referred to hereinafter in the Policy under the general term Personal Data.

1. The purpose of processing the User’s personal data is to inform the User by sending emails; conclude, execute and terminate civil law contracts; provide the User with access to the services, information and/or materials contained on the website.
2. The Operator is also entitled to send the User notifications about new products and services, special offers and different events. The User can always refuse to receive information messages by sending an email to the Operator at info@progamma.com.ua with the note “Unsubscribe from notifications about new products and services and special offers”.
3. The anonymised User data collected through Internet statistics services are used to collect information about the User’s activities on the website and to improve the quality of the website and its content.

1. The Operator processes the User’s personal data only if the User fills in and/or submits them himself through the special forms located on the website http://progamma.com.ua. By completing the relevant forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.
2. The Operator processes anonymised data about the User in case it is permitted in the User’s browser settings (cookie saving and the use of JavaScript technology are enabled).

Security of personal data processed by the Operator shall be ensured by implementing legal, organisational and technical measures necessary to comply fully with the requirements of applicable legislation in the area of personal data protection.

1. The operator ensures safety of personal data and takes all possible measures that exclude access to personal data by unauthorised persons.
2. The user’s personal data will never, under any circumstances, be disclosed to third parties, except in cases related to the execution of current legislation.
3. In case of identification of inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s email address info@progamma.com.ua with a note “Updating of personal data”.
4. The time period for processing personal data is unlimited. The user may withdraw their consent to the processing of personal data at any time by sending the Operator a notification via email to the Operator’s email address info@progamma.com.ua, marked “Withdrawal of consent to the processing of personal data”.

1. Prior to transborder transfer of personal data, the operator shall ensure that the foreign country to whose territory the transfer of personal data is to take place provides reliable protection of personal data subjects’ rights.
2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only be performed if the personal data subject consents in writing to the cross-border transfer of his/her personal data and/or performance of an agreement to which the personal data subject is a party.

1. The user may obtain any clarification on questions of interest relating to the processing of their personal data by contacting the Operator by email at info@progamma.com.ua.

2. This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.

The current version of the Policy is freely available on the Internet at https://progamma.com.ua/en/privacy-policy-2/