UKLON CARE NON-GOVERNMENTAL ORGANIZATION, EDRPOU code: 44710031, location: 20B Bandery Stepana Av., Kyiv, 04073, Ukraine (hereinafter referred to as the “Transportation Organizer” or “UKLON CARE NGO”) offers the Uklon Online Service Users who, due to specific health conditions associated with the musculoskeletal disorder, or who have limited mobility or have limited physical capabilities for other reasons and in connection with this need special conditions of transportation with the option of placing a wheelchair in a vehicle (hereinafter referred to as the “Inclusive Class Users”), who are endowed with a sufficient amount of rights and powers, to receive services for the organization of transportation of passengers in a specially equipped passenger motor vehicle in accordance with the provisions of this Agreement.

UKLON CARE NGO is a non-profit organization that carries out business activities in the organization of transportation for Inclusive Class Users without the purpose of making a profit.

The cost of the Services under this Agreement is set by the Transportation Organizer based on the actual expenses associated with the organization of the transportation of the Inclusive Class Users and may not exceed the cost necessary to cover such expenses.

Income from the economic activity of UKLON CARE NGO or its part is not distributed among the founders (participants within the meaning of the Civil Code of Ukraine), members of the organization, employees (except for the payment of their labor and the accrual of a single social contribution), members of management bodies, and other related persons. The income of the non-profit UKLON CARE NGO is used exclusively for financing expenses for its maintenance, the implementation of the goals (objectives, tasks), and activities defined by the charter of UKLON CARE NGO.

This Agreement is public in accordance with Articles 633 and 641 of the Civil Code of Ukraine, and its conditions are the same for all Inclusive Class Users, unconditional acceptance of the conditions of which is considered acceptance of this offer, for which the Transportation Organizer publishes this Agreement as follows:

1. GENERAL PROVISIONS

1. 1 Each Party warrants to the other Party that it has the necessary legal capacity as well as all the rights and powers necessary and sufficient for the conclusion and execution of the Agreement in accordance with the terms and conditions hereof.

1. 2 The current version of this Agreement is posted on the web page of the Transportation Organizer at https://uklon.com.ua/user-agreement and is mandatory for review by the Inclusive Class User.

1. 3 Services under this Agreement shall be provided within the city of Kyiv, Ukraine.

1. 4 Organization of the transportation of Inclusive Class Users shall be carried out with the technical support of UKLON UKRAINE LLC (20B S. Bandery Av., Kyiv, 04073; EDRPOU code: 44293344) (hereinafter referred to as the “Administrator”) based on the Uklon Online Service, which is a technological platform in the form of an interconnected set of computer programs and electronic data in the form of numbers, letters, symbols, images, and their combinations (including graphic information, video information, etc. ), which will provide automated monitoring, collection, processing, distribution, storage, presentation of data about the order by Inclusive Class Users of services for the organization of passenger transportation (hereinafter referred to as the “Uklon Online Service”).

1. 5 Access of the Inclusive Class Users to the Uklon Online Service shall be carried out through:

the Administrator`s Website — a web page on the Internet at https://uklon.com.ua.

the Mobile Application — a copy of a computer program in the form of a mobile application for iOS, Android mobile devices called “Uklon”, which is provided by the Administrator to the Inclusive Class User for temporary use by the end user for its functional purpose as a tool for obtaining access to the Online Service in accordance with the Inclusive Class User Agreement.

1. 6 By entering into (accepting) this Agreement, the Inclusive Class User confirms that he/she has read and accepted the terms and conditions of the Inclusive Class User Agreement posted on the Administrator`;s Website at https://uklon.com.ua/user-agreement and/or in the Mobile Application.

1. 7 By choosing the Inclusive Class among the functionality of the Uklon Online Service, the User thereby confirms that he/she is a person with a disability who has a musculoskeletal disorder, and/or is a person with limited mobility, and/or has limited physical capabilities for other reasons, and therefore, he/she moves with the help of a wheelchair and needs to receive passenger transportation services by a specially equipped passenger motor vehicle.

1. 8 The Inclusive Class User, by placing an order for transportation in the Inclusive Class, confirms that he/she is placing the order for personal purposes and that such an order is not related to any commercial activity.

2. SUBJECT MATTER OF THE AGREEMENT

2. 1 In accordance with the terms and conditions of this Agreement, the Transportation Organizer undertakes to provide services for the organization of transportation of the Inclusive Class User and his/her luggage (hereinafter referred to as the “Services”), and the Inclusive Class User undertakes to pay for the Services of the Transportation Organizer.

2. 2 Transportation under this Agreement shall be carried out by a carrier/carriers who have a valid license for the transportation of passengers by passenger motor vehicle (hereinafter referred to as the “Carrier”) and provide transportation services for Inclusive Class Users at the request of the Transportation Organizer under an agreement concluded with the Transportation Organizer.

3. AGREEMENT CONCLUSION PROCEDURE

3. 1 The Agreement shall be deemed concluded between the Inclusive Class User and the Transportation Organizer in the form of an accession agreement (Article 634 of the Civil Code of Ukraine).

3. 2 Acceptance of the terms and conditions of the Agreement shall mean full and unconditional acceptance by the Inclusive Class User of all the terms and conditions of the Agreement, without any exceptions and/or limitations, and shall be equivalent to the conclusion of a bilateral written Agreement on the provision of Services to the Inclusive Class User.

3. 3 After reviewing the terms and conditions of this Agreement set out on the website of the Transportation Organizer at https://uklon.com.ua/user-agreement, the Inclusive Class User shall accept the Agreement by taking conclusive actions, namely by placing an order using the technical capabilities and functionality of the Uklon Online Service, including by clicking the “Order” button on the Uklon Website and/or in the Mobile Application when placing an order for transportation in the Inclusive Class.

3. 4 Actions specified in clause 3. 3. of this section that are performed by the Inclusive Class User, indicate that the Inclusive Class User is familiar with this Agreement and agrees with the terms and conditions hereof in full.

3. 5 The term of acceptance shall be unlimited.

3. 6 The Agreement shall be deemed concluded and enters into force once it is accepted, and it shall be valid for the entire period of receiving the Services, or until the moment of its termination, in accordance with the legislation of Ukraine.

3. 7 The conclusion of the Agreement shall mean that the Inclusive Class User:

– to the extent necessary for him/her, has familiarized himself or herself with the rules for the provision of Services;

– before ordering the Service, has received full and comprehensive information about the Service, and agrees to receive it in accordance with the procedure and under the conditions stipulated in this Agreement and the application for the organization of transportation;

– accepts all the terms and conditions of the specified Agreement without comment.

4. SETTLEMENT PROCEDURE

4. 1 Transportation organization services provided to the Inclusive Class User shall be subject to payment in accordance with the cost of the Services, which is posted in the Mobile Application and on the Website, and which is brought to the attention of the Inclusive Class User and confirmed by the last placing of an order for transportation in the Inclusive Class.

4. 2 Payment for the Services, as well as other financial obligations of the Inclusive Class User to the Transportation Organizer that may arise in accordance with the requirements of this Agreement, can be made using a bank card through the Mobile Application or on the Administrator`s Website. At the same time, the Inclusive Class User shall automatically go to the site of the corresponding payment system and enter his/her personal data and bank card data directly on the website of this payment system. The Transportation Organizer shall not store or transfer bank card data of the Inclusive Class Users.

4. 3 Payment for the Services, as well as other financial obligations of the Inclusive Class User to the Transportation Organizer, which may arise in accordance with the requirements of this Agreement, may be made in another way not prohibited by law. In terms of payment for the services, the Carrier performing the transportation may act on behalf of, at the expense of, and in the interest of the Transportation Organizer in order to ensure payment for the Services.

4. 4 The Inclusive Class User hereby confirms that he/she is aware that the amount of payment for the Services shall be determined based on the actual expenses of the Transportation Organizer related to the provision of Services. The Transportation Organizer is a non-profit organization, and therefore the provision of Services hereunder is not aimed at obtaining any profit by the Transportation Organizer. The Transportation Organizer shall provide services under this Agreement within the scope of its statutory activities. The main purpose of the Transportation Organizer hereunder is to ensure the possibility of Inclusive Class Users, who have special needs due to their health, to move with the help of specially equipped passenger motor vehicles.

5. RIGHTS AND OBLIGATIONS OF THE PARTIES

5. 1 Rights of the Transportation Organizer:

– to choose and change the route of movement at its own discretion;

– to change the conditions of the provision of Services by posting information in advance on the website of the Transportation Organizer;

– to postpone or cancel the execution of the order (trip) for technical reasons, in connection with adverse weather conditions, or for other reasons beyond the control of the Transportation Organizer;

– to refuse to provide services to the Inclusive Class User in the event that the Inclusive Class User owes payment for the Services.

5. 2 Obligations of the Transportation Organizer:

– to properly provide the Services;

– in the event of cancellation or significant changes to the conditions of the provision of Services (if, as a result of such changes, the Inclusive Class User waives the order), to return the funds received as an advance payment to the Inclusive Class User;

– to provide advice on issues arising from the Inclusive Class User regarding the provision of Services;

– to keep the information received from the Inclusive Class User confidential;

– to use all means dependent on it for the transportation and delivery of the Inclusive Class User and his/her luggage to the destination in a reasonable time.

5. 3 Rights of the Inclusive Class User:

– to receive advice on issues arising in connection with the provision of Services;

– to demand confidentiality in relation to the information provided when making the payment.

5. 4 Obligations of the Inclusive Class User:

– to comply with the terms and conditions of this Agreement during the entire period of the provision of Services;

– to pay for the Services provided in accordance with the procedure specified herein;

– at the request of the Transportation Organizer, to provide documents and reliable information regarding whether the Inclusive Class User has an objective need for transportation by motor vehicle of the Inclusive Class specially equipped for the transportation of persons with musculoskeletal disorders who move with the help of wheelchairs;

– to provide the Transportation Organizer and the Carrier with other information and documents necessary for the proper provision of Services;

– during the provision of Services, to diligently follow the recommendations of the Transportation Organizer and the Carrier.

6. LIABILITY OF THE PARTIES

6. 1 The Transportation Organizer shall not be liable for:

– the delay, cancellation, transfer, or change of the conditions of provision of Services, if such changes were caused through no fault of the Transportation Organizer;

– expenses incurred by the Inclusive Class User as a result of late arrival at the destination;

– things left or forgotten in the vehicle;

– any damages incurred by the Inclusive Class User as a result of the illegal activity of any private person (including traffic participants);

– late delivery of the vehicle, which occurred as a result of force majeure circumstances (including, but not limited to, weather conditions, traffic jams, actions of state authorities, etc., as well as actions of third parties that affect the proper performance by the Transportation Organizer or the Carrier of their obligations), or other circumstances (technical issues of the vehicles on the way to the place of delivery), which the Transportation Organizer, despite the measures taken, could not have foreseen nor prevented;

6. 2 The Inclusive Class User shall be liable for:

– providing unreliable data when ordering the Services;

– causing material damage to the property of the Transportation Organizer or the Carrier during the execution of the order.

6. 3 The Parties have agreed that any disputed issues that may arise in connection with the implementation of this Agreement will be resolved through negotiations.

6. 4 If the Parties cannot reach an agreement on disputed issues through negotiations, these issues shall be resolved in accordance with the legislation of Ukraine.

7. FINAL PROVISIONS

7. 1 The Inclusive Class User warrants that he/she understands all the terms and conditions of this Agreement and accepts them unconditionally and in full.

7. 2 On issues not regulated by this Agreement, the Parties undertake to be guided by the legislation of Ukraine.

7. 3 All the terms used in this Agreement, but not defined herein, shall have the meaning given in the Inclusive Class User Agreement and in the User Agreement for providing access to the Uklon Online Service that are posted on the Administrator`s Website.

Transportation Organizer’s details

NGO “UKLON CARE”

Ukraine, 04073, Kyiv City, 20B, Bandery Stepana ave.

Registration number: 44710031

IBAN UA253006140000026007500502258

JSC «Credit Agricole Bank»

Bank number: 300614

Version effective date: October 26, 2023

Public Offer

on Making Charitable Donation

 1. This Public Offer on Making Charitable Donation (hereinafter referred to as the «Offer»), in accordance with Art. 641 of the Civil Code of Ukraine, is a proposal of the NONPROFIT ORGANIZATION «UKLON CARE», legal entity identification code 44710031, located at the address: Ukraine, 04073, Kyiv, Bandery Stepana Avenue, building 20B (hereinafter – the “Organization”), represented by the Head of the Organization Serhii Anatoliiovych Smus, who acts on the basis of the Charter, to an indefinite circle of individuals with full legal capacity and private legal entities which/who voluntarily carry out charitable activities (hereinafter, each such person is a “Benefactor”), to enter into an agreement on the provision of a Charitable Donation (hereinafter – the «Agreement») on the terms described in this Offer, with each Benefactor who applies.

2.  This Offer enters into force from the moment it is posted on the webpage of the Organization on the Internet at the link: https://uklon.com.ua/user-agreement (hereinafter – the «Website»). This Offer is open-ended and may be changed or withdrawn by the Organization at any time (prior to its acceptance by the Benefactor) by posting relevant information on the Website.

3.  Benefactor and Public Organization, guided by Art. 207, Part 2 of Art. 639, Art. 641, 642 of the Civil Code of Ukraine, agree that from the moment of Acceptance, the Agreement is considered concluded in writing. At the same time, the Parties agree that the Parties’ failure to comply with the written form of the transaction does not mean its invalidity.

4.  Acceptance – full and unconditional acceptance of the Offer by taking actions to make a money transfer using the payment forms and means placed on the Website, as well as by transferring funds to the current bank account of the Organization. The moment of Acceptance is the date of money transfer and/or crediting of funds to the bank account of the Organization. Acceptance means that the Benefactor agrees with all its provisions, he is fully aware of and agrees with the subject of the Agreement and with the purpose of public collection of donations.

5.  Charitable Donation – voluntary transfer of funds by the Benefactor to the Organization for the achievement of certain, pre-arranged activity purposes, in accordance with the Agreement and the Law of Ukraine “On Public Associations”.

6.  Fondy is a payment service provided by Financial Company Elaiens LLC (identification code: 38905834), created for large and small businesses, intended for making payments between individuals, legal entities and/or individual entrepreneurs on the Internet using personal computers and/or other mobile devices.

7.  Way For Pay is a payment service provided by Financial Company Way For Pay LLC (identification code: 39626179), created for large and small businesses, intended for settlement between individuals, legal entities and/or individuals – by entrepreneurs on the Internet using personal computers and/or other mobile devices.

8.  Subject of the contract

The subject of this Agreement is the free and voluntary transfer of funds by the Benefactor into the ownership of the Organization, by making voluntary donations for the implementation of the statutory activities of the Organization.

The Benefactor independently determines the size of the Charitable Donation.

The Organization independently determines the directions for the use of the Charitable Donation within the framework of its own statutory activity, unless otherwise determined by the Benefactor in accordance with the procedure specified in this Agreement.

The subject of this Agreement is not directly or indirectly receiving profit by any of the Parties to the Agreement.

The Benefactor’s transfer of funds under this Agreement is recognized as a Charitable Donation in accordance with Art. 6 of the Law of Ukraine “On Charitable Activities and Charitable Organizations”.

9.  The Organization has the right to:

• receive Charitable Donations and use them in accordance with the subject and terms of this Agreement;
• to independently determine the directions of use of the Charitable Donation in accordance with its statutory activity and the legislation of Ukraine, except for cases when the Benefactor has determined the specific purpose of his donation under a separate contract with the Organization. Thus, if the Benefactor does not specify the specific purpose of the Charitable Donation, it is considered that the donation was made for the implementation of statutory activities by the Organization;
• without agreement with the Benefactor, to change the direction of the use of the donation within the statutory activity of the Organization;
• without agreement with the Benefactor, to use a part of the Charitable Donation for the administrative expenses of the Organization, in an amount not greater than that provided for by the legislation of Ukraine.

10.  The Organization is obliged to:

• in the case of using the Charitable Donation contrary to the purposes of this Agreement, return the funds to the Benefactor upon his written request.

11.  The Benefactor has the right to:

• monitor the intended use of the Charitable Donation;
• receive information about the use of his Charitable Donation. For this purpose, the Organization may post monthly financial reports on the Website, which include information on (i) the amounts of donations received by the Organization during the reporting period, and (ii) the expenses of the Organization during the reporting period. At the Benefactor’s written request, the Organization may also confirm the intended use of the Charitable Donation with additional documents. Access to reports on the use of Charitable Donation is provided by the Organization in the manner and within the time limits stipulated by the current legislation of Ukraine and this Offer.

12.  Statutory activity of the Organization

The Organization is a non-entrepreneurial entity, the main purpose of which is not to make a profit. The main goal of the Organization is: implementation and protection of rights and freedoms, satisfaction of public, in particular economic, social, cultural, environmental and other interests of citizens of Ukraine. The main areas of activity of the Organization include, but are not limited to:

• promoting the construction of a peaceful and open society for the purpose of its sustainable development;
• implementation of projects in the field of reducing CO2 emissions and other environmental initiatives;
• promoting the implementation of public-private partnership projects in all spheres of public life permitted by law for the purpose of sustainable development of society;
• implementation of projects in the field of ride-hailing development;
• promotion of the harmonious development of the transport infrastructure of cities that is safe for the environment;
• implementation of projects in the field of services for transportation of people with limited mobility by road transport;
• protection and implementation of human rights in Ukraine, in particular, civil and political rights; approval and implementation of all forms of direct democracy in Ukraine;
• protection of citizens from breach of their rights and freedoms guaranteed by the Constitution and laws of Ukraine;
• prevention of attempts to hinder the implementation of direct democracy in Ukraine;
• assistance in the provision of volunteer assistance (assistance in the collection of volunteer assistance) to units of the Armed Forces of Ukraine, the Ministry of Internal Affairs of Ukraine, the Security Service of Ukraine, the State Border Service, other legal paramilitary formations (organizations), as well as to persons who suffered as a result of military operations in Ukraine ;
• assistance in the implementation of recreational, cultural, educational activities for members of the Organization, as well as for persons who suffered as a result of military actions in Ukraine.

13.  Making a donation

13.1  Irregular Charitable Donations

The Benefactor on his/her sole discretion determines the size of the Charitable Donation. The Charitable Donation is voluntary and is not subject to further return to the Benefactor except in the cases stipulated by this Agreement and the legislation of Ukraine.

The Charitable Donation is transferred to the ownership of the Organization to achieve its statutory goals. Periodically, the Organization initiates new charitable and social projects, supports existing ones and independently resolves the issue of their duration and proportionality of funding in relation to other charitable projects of the Organization.

In the case of making a donation for the implementation of a specific charitable project announced by the Organization, it is used for the implementation of such a project. At the same time, the Organization has the right to change the goals and procedure of using the charitable donation, including changing the project.

13.2  Regular Charitable Donations

The Benefactor can choose a fixed amount of the Charitable Donation, which will be debited every time the Benefactor places an order in the Uklon application (Regular Charitable Donation). The size of the Regular Charitable Donation is arbitrary and determined at the discretion of the Benefactor.

Terms of use of the Uklon application are posted on the website https://uklon.com.ua. The Benefactor independently enters into legal relations, accepts rights and acquires obligations in connection with the use of the Uklon application. By agreeing to this Offer, the Benefactor confirms that the Organization is not a party to such legal relations.

Regular Charitable Donations received by the Organization are transferred to the following charitable organizations in the amount and/or proportions determined at the discretion of the Organization to fulfill the statutory goals of such charitable organizations, including to support the projects of these organizations with the aim of helping enterprises, institutions and organizations, including, but not exclusively to legal entities that are part of or subordinate to the Ministry of Defense of Ukraine, the Armed Forces of Ukraine, the National Guard of Ukraine, the Security Service of Ukraine, the Foreign Intelligence Service of Ukraine, the State Border Service of Ukraine, involved in repelling and deterring armed aggression, ensuring national security and defense of Ukraine:

1. CHARITABLE ORGANIZATION “INTERNATIONAL CHARITABLE FOUNDATION “COME BACK ALIVE”, address: Ukraine, 01030, Kyiv, Bohdana Khmelnytskogo Street, building 32, office 41, EDRPOU code 39696398;
2. CHARITABLE ORGANIZATION “CHARITABLE FOUNDATION OF SERHIY PRYTULA”, address: Ukraine, 01135, Kyiv, str. Zolotoustivska, 47-49,152, EDRPOU code 43720363;
3. CHARITABLE ORGANIZATION “CHARITABLE FOUNDATION “DIGNITAS”, address: Ukraine, 03039, Kyiv city, Holosiivska street, building 5, apartment 59, EDRPOU code: 44943914.
4.  CHARITABLE ORGANIZATION “CHARITABLE FOUNDATION “THE SKY OF VICTORY”, address: Ukraine, 01021, Kyiv, Pechersk district, Klovskyi descent, 7, EDRPOU code: 45109890

The Benefactor has the right at any time in the Uklon application to cancel the Regular Charitable Donation, change the amount of the Regular Charitable Donation or change the details of the bank card from which the Regular Charitable Donation is debited.

13.3  All expenses for the payment of sums (commissions) related to the transfer and crediting of the donation are borne by the Benefactor.

14.  Place of collection of Charitable Donations

Public collection of donations is carried out on the territory of any country in the world. The direct activity of the Organization related to the public collection of donations under the Agreement is carried out at the location of the Organization.

 15.  Term of collection of Charitable Donations

The public collection of Charitable Donations continues until the liquidation of the Organization, unless another term is determined by the Organization.

16.  Payment details

When paying a Charitable Donation by bank card, payment processing (including entering the card number) takes place on a secure page of the Fondy and/or Way For Pay processing system. This means that confidential data (card details, registration data, etc.) are not sent to the Website, their processing is completely protected and no one can obtain the Benefactor’s personal and bank data.

When working with card data, the information protection standard developed by the international payment systems Visa and MasterCard – Payment Card Industry Data Security Standard (PCI DSS) is used, which ensures safe processing of details of the Benefactor’s bank card. The applied data transmission technology guarantees the security of transactions with bank cards by using Secure Sockets Layer (SSL), Verified by Visa, SecureCode protocols and closed banking networks with a higher degree of protection.

17.  By making a Charitable Donation, the Benefactor unconditionally affirms (i) his legal capacity, (ii) the voluntary nature of the deed, (iii) that the subject of the Charitable Donation is not subject to a ban, arrest, lien, is not encumbered by any other rights of third parties and was not acquired in violation of the Law of Ukraine “On prevention and countermeasures against the legalization (laundering) of criminal proceeds, the financing of terrorism and the financing of the proliferation of weapons of mass destruction.” In the event that the Organization has reasonable doubts about these statements, the Organization has the right to ask, and the Benefactor undertakes to provide appropriate supporting evidence of these statements.

18.  Final provisions

The provisions of the current legislation of Ukraine apply to the relationship between the Benefactor and the Public Organization.

The Organization’s liability for violation of this Agreement or the procedure for the use of Charitable Donations occurs on the grounds, in the amount and in the manner determined by the requirements of the current legislation of Ukraine.

In the event of disputes between the parties to this Agreement, they must be resolved through negotiations. If it is impossible to resolve disputes through negotiations, disputes are considered by courts in the manner established by the current legislation of Ukraine.

The Organization has the right to unilaterally change or update the terms of this Offer at any time. All changes in this Offer, the new edition of the Offer come into force from the moment they are published on the Website.

19.  Contact details

Name: NONPROFIT ORGANIZATION «UKLON CARE»

Location: Ukraine, 04073, city of Kyiv, Bandery Stepana Avenue, building 20B

Email: care@uklon.com.ua

The edition is effective from 12 March 2024

COOKIE POLICY

INTRODUCTION

This Cookie Policy (hereinafter – the “Policy”) provides detailed information about what cookies and other tracking tools (hereinafter – “Cookies”) are used by websites of Uklon (hereinafter – the “Website”) and the third parties and how to change the cookies preferences or opt-out from their appearance and storage.

In some cases, we may use Cookies to collect Personal Data, or to collect information that becomes Personal Data if we combine it with other information and therefore it results in the processing of Your Personal Data. Please visit our Privacy Policy to get more details about how we process Your Personal Data.

LEGAL AND CONTACT INFORMATION

Any reference in this Policy to “Uklon”, “We”, “Our”, “Us” shall mean Uklon LTD, a legal entity established under the laws of Republic of Cyprus, company number: HE 357185, with its duly registered address at: 12 Dimostheni Severi, 6th floor, flat/office 601, 1080 Nicosia, Cyprus.

Any reference in this Policy to “You”, “Your”, “Yourself” shall mean a natural person, who is visiting the Website/downloading the Mobile Application(s) and registering an account with those Website and Mobile Application(s).

Using of Cookies and processing of Your Personal Data will be carried out in compliance with all applicable laws and regulations on the protection of personal data, with particular reference to: (i) Regulation (EU) 679/2016 (the so-called “General Data Protection Regulation”); (ii) Directive 2002/58/EC (the so-called “E-Privacy Directive”) and (iii) any other act, order, regulation, guideline or provision issued by the relevant data protection authorities at global, European and national level of laws in the countries in which we do business – hereinafter jointly referred to as the “Applicable Data Protection Laws”.

This Policy applies when You use our Websites and Mobile Applications respectively as required by the Applicable Data Protection Laws. For the purposes of this Policy “Mobile Application” means applications for mobile devices “Uklon” (for users) and “Uklon Driver” (for partners) for iOS and Android and “Website” means any website with the following domains: uklon.eu, uklon.com.ua, az.uklon.eu, uz.uklon.eu, driverambassador.uklon.com.ua, partnerregistration.uklon.com.ua, posterapp.uklon.com.ua, m.uklon.com.ua, fleets.uklon.com.ua, corporate-portal.uklon.com.ua, partner-registration.uklon.com.ua, driverregistration.uklon.com.ua, events.uklon.com.ua, ios.uklon.com.ua, driverregistrationuz.uklon.eu, driverregistrationaz.uklon.eu.

Capitalized terms used herein without definition shall have the meaning given to them in Privacy Policy.

If You have any questions relating to this Policy or if You wish to exercise Your rights granted by the Applicable Data Protection Laws, please check our Privacy Policy or contact Us via e-mail address: privacy@uklon.com.ua (for Ukraine) and  privacy@uklon.eu (for other countries).

DEFINITION OF COOKIES

Cookies are small-size text files with an identifier (a string of letters and numbers) that are:

• saved in the web browser on Your computer or other device each time when You access the Website;
• used to identify Your computer or other device, which You use to visit the Website or Mobile Application; and
• used to store information, including users’ preferences and page views for customization of the Website’s content to each user and subsequent improvement of Your browsing experience and overall the Website and Mobile Application secure functionality etc.

Cookies do not typically contain any information that personally identifies someone, but Personal Data that we store about You may be linked to the information stored in and obtained from Cookies, e.g. IP address, device ID, country or region, click history.

For the purpose of better Cookies understanding and making a well-informed choice, we recommend to visit a respective browser Cookies guide or visit www.aboutcookies.org or www.allaboutcookies.org.

COOKIES APPEARANCE AND DISABLING

When You enter the Website, You will be informed with a respective Cookie Banner at the bottom of the Website. Any user or partner is free to decide whether to accept or reject some or all categories of Cookies with possibility to control 1) through the device browser settings, 2) by writing an e-mail to Uklon or 3) by accessing the “Cookies Declaration” on the Website.

According to Applicable Data Protection Laws, we are allowed to store Cookies on Your device if they are strictly necessary for the operation of the Website: this is the case of essential/technical Cookies. To store other types of Cookies, we need Your consent. Your consent will be applicable to all Websites and Mobile Applications of Uklon mentioned in this Policy.

TYPES OF COOKIES THAT WE USE

Category 1 – Depending on the initiating party:

First-Party Cookies	Third-Party Cookies
Set by Uklon, accessible and readable only by Us.	Set by third-party providers, such as Google Analytics, Facebook, etc.

Category 2 – Depending on a period of lifetime:

Name	Description	Example
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Permanent Cookies	Stored as file on Your computer or other device for a certain period of time.	Password, language of the Website.

Category 3 – Depending on the functionality:

Name	Description	Example
Necessary Cookies	Strictly necessary to enable You to browse around the Website and use its features, as they were developed and intended to work. These are First-Party and Third-Party Cookies.	To protect and keep Your information secure; to authenticate Your and used device details for the Website work and services optimization etc.
Preferences Cookies	Enable the Website to remember information that changes the way the Website behaves or looks. These are First-Party and Third-Party Cookies.	To detect and apply Your preferred language or the region that You are in.
Statistics Cookies	Enabled for the purpose of collection of information as of the user’s activities/use of the Website and the Website overall performance. These are First-Party and Third-Party Cookies.	To obtain information regarding the device, time and preferred pages; the Website performance during user’s stay and use of the Website (Google Analytics); the performance of retargeting, which helps to decide whether to display or not, a relevant advertising to You when the You are visiting certain websites within the retargeting network. For the purpose of better understanding of Google Analytics, we recommend to visit website.
Marketing Cookies	Marketing cookies are used to track visitors across websites.	To display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.

OPT-OUT FROM COOKIES

When You enter the Website, You will be informed with a respective Cookie Banner at the bottom of the Website.

1) Any user or partner is free to decide whether to accept or reject some or all types of Cookies with possibility to control (meaning: to allow; delete; clear or block any, including bot limited to third party Cookies) through the device browser settings.

Browsers usually allow You to refuse to accept and delete cookies. We recommend to visit the following web pages to find information on how to block and delete cookies in respective browser:

• Chrome;
• Mozilla Firefox;
• Internet Explorer;
• Safari.

Please note that if Preferences Cookies are disabled, You may experience some difficulties during the use of certain Website features.

Please, note that Statistics Cookies are used to improve the overall Website performance. Without Statistics Cookies You will still be able to use and enjoy all features of this Website.

Depending on Your device and operating system, You may not be able to delete or block all Cookies. In addition, if You want to reject Cookies across all Your browsers and devices, You will need to do so on each browser on each device You actively use.

2) You may change Your preferences and withdraw Your consent by writing to Us at the contact details indicated in this Policy or in the Privacy Policy. Please remember it is necessary to provide to Us Your consent ID (provided below in the Cookie Declaration).

3) Cookie Declaration

If any Third Party operated services are mentioned in the Cookie Declaration, these may be used to track Your browsing habits in addition to the information specified herein and without Uklon’s or user’s/driver’s knowledge. For the complete information of collected information and its retention period by a respective Third Party, familiarize Yourself with a respective privacy policy of such Third Party listed in the Cookie Declaration above, namely:

• Doubleclick;
• Google AdSense;
• Google Analytics;
• Meta Platforms, Inc.;
• YouTube;
• CookieBot;
• Hotjar;
• Wixstudio;
• Weblium.

REVIEW OF THE POLICY

Uklon reserves the right to change this Policy at any time without prior notification and will not be liable to any party in any way for possible consequences of such changes. In case of any changes, Uklon will post the revised version of this Policy and change their effective date. All changes shall be effective from the date of publication unless otherwise provided in the notification.

If we make material changes to this Policy, we will notify You by prominently posting on our Website or through other appropriate communication channels.

Uklon advises You to periodically review this Policy in order to be informed of any changes whenever You access and/or on the Website.

Your continued use of the Website and Mobile Application shall be considered that You have read, understood, accepted and agreed with these changes.

Effective Date: 26.10.2023

This Privacy Policy was developed by Limited liability company “UKLON UKRAINE”, EDRPOU code 44293344, location: 20b Stepan Bandera Avenue, city of Kyiv, 04073, Ukraine (hereinafter referred to as ” We ” in the appropriate cases), which is the owner of personal data within the meaning of the Law of Ukraine “On the Protection of Personal Data” dated June 1, 2010 No. 2297-VI (hereinafter referred to as the ” Law “) and is regulated by this Law.

Consistent and effective protection of your personal data is one of Our priorities, so We make every effort to keep your personal data safe.

With this Privacy Policy, we would like to inform you about what personal data we process and how we process it, as well as the purposes and means of personal data processing and protection. This Privacy Policy applies to all types of personal data of users of the online service “Uklon” and users of the online service “Uklon Driver”, which We collect and process through the website: uklon.com.ua (hereinafter – “Website”), applications for mobile devices “Uklon” and ” Uklon Driver ” for iOS and Android (hereinafter referred to as ” Mobile Applications “), as well as through other sources specified below in this Privacy Policy. By using and registering on the Website and/or in the Mobile Applications, as well as when placing an order without registration through the Website, You confirm, warrant and declare that You have read and understood this Privacy Policy and give your unequivocal consent to Us processing Your personal data in accordance with this Privacy Policy. If you do not agree to these Terms in their entirety, do not use the Website and/or Mobile Applications.

supplement or otherwise change these Terms from time to time. We may make changes to these Terms without prior notice to you, so we recommend that you regularly check these Terms on the Website and thereby agree to any changes to these Terms. We may notify you of any material additions or changes to this Privacy Policy. If you do not agree to any material or other additions or changes made or may be made in the future, do not use the Website and/or Mobile Applications.

This Privacy Policy is written in the Ukrainian language but is available for viewing in Russian and English. In case of inconsistency between the terms of this document in Ukrainian and its translations in Russian and English, the Ukrainian version of the document shall have legal force.

What personal data do we process?

A) Users of the online service “Uklon”.

We process the personal data that you provide to Us, namely: name, email address, phone number, and city, both when filling out the registration form on the Website or in the Mobile Application, and when filling out your profile. We can also process your personal data when you register via Facebook, Google plus.

We process your personal data, namely: phone number and username when you place an order through the Website without registration.

We also process your personal data in cases where you need to contact Our customer support service or contact Us through other channels (for example, through social networks).

There are other cases when you provide us with personal data. You can create an account (account), which allows you to save personal settings, view previous orders, plan future orders and manage current ones.

In order to register an account, you will need to provide us with a certain amount of personal data. At the first stage of registration, you provide us with a contact phone number to be used for registration. At this stage, you have the opportunity to familiarize yourself with this Privacy Policy. After sending the phone number, we will have the right to use this number to send you messages (SMS, push notifications) and make calls. In particular, such messages and calls may occur in the event of unsuccessful registration (for example, when you have not completed the registration process) or to confirm or clarify certain registration information.

By participating in promotions or sweepstakes, you will also provide us with your personal data. In addition, you can send Us feedback about the Website and Mobile Application, share your opinion or ask for help with using the Website or Mobile Application.

In case of insuring your life and health during transportation and for the purpose of receiving insurance compensation, you provide us with your personal data: surname, first name and patronymic, phone number, date of birth, passport series and number, registration number taxpayer’s registration card and other information that may be required by the insurance company.

In the case of shipment insurance, if you ordered a delivery service, you provide us with your personal data: address, surname, first and last name, and phone number.

B) Uklon partners (users of the online service “Uklon Driver”).

We process personal data that you provide to Us: name, surname, email address, phone number, vehicle registration certificate data, driver’s license data, registration number of the taxpayer’s account card (ITN) and bank card number, which are transferred to the financial company, your photo (image), the city of concluding a Public Offer with Us to provide access to the online service (supply of software products) by accepting the Public Offer posted on the Website, other information that You voluntarily provide to Us. We also assign you a unique identifier (UID), which includes information about your name, car make and model, vehicle registration plate number, and phone number.

We also process your personal data in cases where you need to contact Our partner support service or contact Us through other channels.

There are other cases when you provide us with personal data. You can create an account (personal account), which allows you to save personal settings, upload photos, view completed orders, etc.

In order to register an account, you will need to provide us with a certain amount of personal data. At the first stage of registration, you provide us with a contact phone number to be used for registration. At this stage, you have the opportunity to familiarize yourself with this Privacy Policy. After sending the phone number, we will have the right to use this number to send you messages (SMS, push notifications) and make calls. In particular, such messages and calls may occur in the event of unsuccessful registration (for example, when you have not completed the registration process) or to confirm or clarify certain registration information.

By participating in promotions or sweepstakes, you will also provide us with personal data. In addition, you can send Us feedback about the Website and Mobile Application, share your opinion or ask for help with using the Website or Mobile Application.

In the case of insurance of your life and health during the transportation of passengers and for the purpose of receiving insurance compensation, you provide us with your personal data: surname, first name and patronymic, phone number, date of birth, passport series and number, registration number taxpayer’s registration card number and other information that may be required by the insurance company. We transfer the aforementioned data to the insurance company immediately after receiving it from you, and after the transfer, we delete it.

In order to strengthen the security measures of the users of the online service ” Uklon ” and the proper additional verification/identification of the identity of the Uklon Partner, We may also process the following personal data of the Uklon Partners, namely: data of identity documents (for example, passport number and series, its validity period, date of issue and name of the body that issued it; data of residence permit; criminal record certificate) and/or their copies, other information voluntarily provided by Uklon Partners.

If you conclude a Public Offer for the provision of access to the Online Service (software supply) or an Adhesion Contract (public offer) for the provision of access to the Online Service with UKLON LTD and create an account (personal account) using the identification process through the service of the SE “Diia”, we will receive from the SE “Diia” copies (in the format of pdf files and metadata fields) of those documents that you allow to be shared with us. In accordance with the rules of the SE “Diia” and our settings, Uklon Partner may share copies of such documents:

• Biometric passports: ID card, international passport;

• Taxpayer card;

• Driver’s licence;

• Vehicle registration certificate.

We may also process personal data as a data controller upon receipt from the data controller – UKLON LTD, in case the Partner enters into the Adhesion Contract (public offer) to provide access to the online service. In this case, we receive the following personal data: name, surname, email address, telephone number, vehicle registration certificate data, driver’s licence data, passport or residence permit data, taxpayer registration number (TIN), photo, location, account (personal account) data, reviews, rating, other information that you voluntarily provide at the time of conclusion or after conclusion of the specified Agreement with UKLON LTD.

Data that We process automatically

We may automatically process certain data, including your IP address, the date and time you used Our Services, information about hardware and software, as well as the Internet browser you use, as well as information about the operating system of your computer or mobile device (for example, application versions and language settings). We may also collect information about clicks and pages that We have shown you.

If you use a mobile device, We may also receive data identifying that device, its settings and characteristics, location data, application crashes, other system operations, and your advertising identifiers. When you place an order through the Website or Mobile Application, Our system records by which means and through which websites it was made or from which websites you went to the Website or Mobile Applications.

Mobile applications can access various services and data of your mobile device, including but not limited to the phone book (contacts), location and external data storage devices (memory cards). In any case, access to the services of your mobile device is possible only in case of providing your separate and unambiguous consent in response to Our push message.

The above types of information may not always contain personal data (that is, data that identifies or can identify you). Some of this information may instead constitute non-personal data (that is, data that does not and cannot identify you).

Personal data of other persons that you provide to Us

Users of the online service “Uklon”.

Of course, you can make an order not only for yourself. You can order a transportation service for any person by providing Us with their phone number and name. In addition, when ordering a delivery service, you provide us with the personal data of the recipient of the shipment: address, surname, first name and phone number. However, in this regard, We must note that You are responsible for ensuring that the person whose personal data You have provided knows that You have done so, understands and agrees to the manner in which You use your personal data (as set out in these Provisions).

To do this, you are obliged to share in advance a link to this Privacy Policy available on the Website with such a person, and hereby you confirm that you have done so, obtained the unequivocal consent of the such person to the processing of his personal data in accordance with the conditions set forth herein Privacy Policy, and will provide such consent to Us upon request.

Information obtained from third parties and other sources

This information may include user feedback such as ratings or compliments, information from users or others who provide information in connection with claims or disputes, information from insurance providers, financial service providers, and information from publicly available sources. We may combine information collected from these sources with other information in Our possession.

Why do we process your personal data?

We process the following personal data for the following purposes. In particular, your personal data may be used as follows:

A) Users of the online service “Uklon”.

– Placement of orders: We use your personal data for the purpose of placing orders for passenger transportation and/or delivery in the online service “Uklon” and for the transfer of your personal data to Partners in order for the Partners to fulfil the respective orders. We may transfer your personal data to Partners in other cases only with your separate consent.

– Customer Support: We provide 24/7 customer support. With your personal data, the support team can help you with orders and answer related questions, as well as any other questions.

– Account (account): users can create an account on the Website or in the Mobile Application. We use the information you provide to us to manage your account.

– Marketing: We also use your personal data (phone number and e-mail address) to send information, newsletters, surveys, advertising and promotional materials. When participating in promotions, the relevant information will be used to manage these promotions. We also post information, newsletters, advertising and promotional materials on the Mobile App and on the Website.

You have the right to refuse to receive (email) information, newsletters, advertising and promotional materials by sending a corresponding message to the e-mail address: privacy@uklon.com.ua.

– Communicating with You: We may also contact You about other matters by e-mail, telephone and electronic messages, depending on the type of contact information You have shared with Us. We also make every effort to process all requests that you send to us.

– Call tracking: when you call the support service, we use an automatic number identification system to identify your phone number with your order – this will help both you and us save time. Conversations with support service employees can be listened to in real-time or recorded for the purpose of monitoring the quality of service provision and further training of Our team. Records are stored for a limited period of time in accordance with the purpose of their processing and are deleted automatically, except when We consider it necessary to keep them for a longer period (if necessary, including for the purpose of investigating cases related to violations of the law). . All recordings of telephone conversations will be used in accordance with this Privacy Policy. Hereby, You give your unequivocal consent to the listening and recording of telephone conversations and the processing of relevant personal data by Us.

– Use of your mobile device services: The mobile application may access various services and data of your mobile device, including but not limited to phone book (contacts), location and external data storage devices (memory cards). Access to the services of your mobile device is possible only if you give your separate and unambiguous consent in response to Our push message.

• Phone Book (Contacts) Section: Access to this section is required for You to place an order for any other person by providing Us with their phone number from Your Phone Book. We do not transfer phone book data to third parties, except for the transfer to the Partner of the phone number of the person for whom transportation is ordered, for the purpose of fulfilling the order for this person, and we do not use it in any other way than in connection with the use of the Mobile Application as provided for in this Privacy Policy.

• “Location” section: We get access to your location in order to ensure the quality of service provision, in particular, to demonstrate the location of the car that will fulfil your order. We do not transfer this data to third parties, except in cases where there is a possibility of a threat to your life or health during the trip and only after you have pressed the SOS button in the “Uklon” Mobile Application.

• Memory card recording section: We may record some technical temporary data (cache) related to your order on your phone’s memory card. We do not transfer this data to third parties and do not use it in any other way than to ensure the smooth functioning of the Mobile Application.

– In case of insuring your life and health during transportation: We transfer the personal data received from you to the insurance company for the purpose of insuring your life and health during transportation , including for the transfer of personal data to foreign subjects of relations related to personal data, for the purpose of fulfilling the requirements of legislation, life and health insurance contracts, other contracts, including reinsurance, implementation of the rights granted to the insurance company by law or contract, and ensuring the implementation of tax relations and relations in the areas of accounting, auditing, financial services and assistance services , advertising, marketing and actuarial research, assessment of the quality of the insurance company’s service. In the case of insuring shipments, We also transfer your personal data to the insurance company that insures shipments, in the event of an insured event as a result of your ordering a delivery service (if applicable). In case of transfer of your personal data to foreign subjects of relations related to personal data, if it is necessary for the purposes outlined above, you hereby give your unequivocal consent to the transfer (as well as further processing) of your personal data outside of Ukraine, including jurisdictions that are not recognized as providing adequate data protection.

– Protection of your life and health during transportation: We may transfer your personal data (name, surname, phone number, travel route and location) to emergency services in order to save your life or health and/or prevent the threat of accident harm to your life or health during the trip if you pressed the SOS button in the ” Uklon ” Mobile application.

– Legal purposes: We can use your personal data to process and transfer them to competent authorities only in cases provided for by the current legislation of Ukraine.

– Marketing activities and other promotional activities: We may transfer your personal data (surname, name, phone number) to third parties in order to offer/provide you with discounts from actual (current) prices for goods and/or services of such third parties, and/or gifts, and/or prizes, and/or other promotions, offered and provided by such third parties.

B) Uklon partners ( users of the online service “Uklon Driver”)

– Fulfillment of orders: We process your personal data, if you have accepted an order for transportation and/or delivery, to transfer them to the user of the online service ” Uklon “.

– Partner support service: We provide support for Partners. With your personal data, the support team can help you with orders and answer related questions, as well as any other questions.

– Account (personal account): Partners can create a personal account on the Website. We use the information you provide to us to manage your personal account. We securely store and do not transfer to third parties data related to settings and statistical information contained in the Mobile Application (settings of filters and order selection algorithms, statistics of completed orders, etc.).

– Marketing: We also use your personal data to send information, newsletters and advertising materials. When participating in promotions, the relevant information will be used to manage these promotions.

You have the right to refuse to receive (email) information, newsletters, advertising and promotional materials by sending a corresponding message to the e-mail address: privacy@uklon.com.ua.

– Communicating with You: We may also contact You about other matters by e-mail, telephone and via electronic messages, depending on the type of contact information You have shared with Us. We also make every effort to process all requests that you send to us.

– Call tracking: when you call the Partner support service, or when the Partner support service contacts you, we use an automatic caller ID system to identify your phone number with your order – this will help both you and us to save time. Conversations with support service employees can be listened to in real-time or recorded for the purpose of monitoring the quality of services and further training of Our team. Records are stored for a limited period of time and are deleted automatically, except when We consider it necessary to keep them for a longer period (if necessary, including for the purpose of investigating cases related to violations of the law). All recordings of telephone conversations will be used in accordance with this Privacy Policy. Hereby, You give your unequivocal consent to the listening and recording of telephone conversations and the processing of relevant personal data by Us.

– Use of your mobile device services: Mobile applications can access various services and data of your mobile device, including but not limited to: location and external data storage devices (memory cards). Access to the services of your mobile device is possible only in case of providing your separate and unambiguous consent in response to Our push message.

• “Location” section: We get access to your location in order to ensure the quality of service provision, in particular, to provide up-to-date information about orders that are placed near your location, as well as ensuring security, prevention and detection of fraud cases. Data regarding your location is processed when the Mobile application “Uklon Driver » works in priority (opened and displayed on the screen) or background (opened but not displayed on the screen) mode. In order to stop processing your location data, you must close the “Uklon Driver “. In any case, we do not transfer data about your location to third parties.

• Section “Recording to the memory card”: We may record some technical temporary data (cache) related to your use of the Mobile Application on the memory card of your phone. We do not transfer this data to third parties and do not use it in any other way than to ensure the smooth functioning of the Mobile Application.

– In case of insuring your life and health during the transportation of passengers: We transfer the personal data received from you to the insurance company for the purpose of insuring your life and health during transportation, including for the transfer of personal data to foreign subjects of relations, related to personal data, in order to fulfil the requirements of legislation, life and health insurance contracts, other contracts, including reinsurance, exercise the rights granted to the insurance company by law or contract and ensure the implementation of tax relations and relations in the areas of accounting, audit, financial services and assistance services, advertising, marketing and actuarial research, evaluation of the quality of the insurance company’s service. In case of implementation shipment insurance, We also transfer your phone number to the insurance company in the event of an insured event as a result of your delivery service. In case of transfer of your personal data to foreign subjects of relations related to personal data, if it is necessary for the purposes outlined above, you hereby give your unequivocal consent to the transfer (as well as further processing) of your personal data outside of Ukraine, including jurisdictions that are not recognized as providing adequate data protection. We transfer the aforementioned data to the insurance company immediately after receiving it from you, and after transferring it, we delete it.

– Search for things left in the car: We transfer your name and phone number to users of the online service “Uklon” in order to help them return personal things left in the car during transportation.

We can transfer your phone number to users of the online service “Uklon” in other cases only if we receive your separate consent.

– Legal purposes: We can use your personal data to process and transfer them to competent authorities only in cases provided for by the current legislation of Ukraine.

– Marketing activities and other promotional activities: We may transfer your personal data (name, phone number) to third parties in order to offer/provide you with discounts from actual (current) prices for goods and/or services of such third parties, and/or gifts, and/or prizes, and/or other promotions, offered and provided by such third parties.

How do we transfer your personal data to third parties?

Under certain circumstances, We may transfer your personal data to third parties.

Any transfer of your personal data, which is carried out on the basis of your consent to the processing of personal data in accordance with this Privacy Policy, will not require your separate consent or provide you with a separate notice.

A) Users of the online service “Uklon”.

– Placement of orders: We transfer your personal data to the Partners for the purpose of the Partners fulfilling your orders. In other cases, at the written or verbal request of the Partner, We can transfer your phone number to the Partner only in case of receiving your separate consent.

– Third parties providing services to Us: We may use the services of third parties, including electronic communications operators to which you are a subscriber, to process your personal data on Our behalf, which will be considered either personal data processors or third parties within the meaning of the Law. This processing is carried out for various, but always legitimate, purposes. For example, we may engage electronic communication operators to send you information and promotional materials on our behalf and in our interests, which will send you SMS messages and push notifications on our behalf. The electronic communication operators to which You are a subscriber may transfer to Us data on the electronic communication services provided to You solely for the purposes specified in this Regulation. Such service providers agree to the mandatory observance of confidentiality, conclude relevant agreements with Us and have no right to use your personal data for their own or other purposes. We do not transfer your personal data to third parties to send information and promotional materials on behalf of and in the interests of persons other than Us.

– Competent state authorities: We transfer personal data to law enforcement, tax, fiscal and other competent authorities to the extent and in those cases required by the current legislation of Ukraine, in particular, if it is necessary to prevent, detect or stop criminal acts and fraud, in addition, personal data in the appropriate amount may be transferred to competent authorities to protect Our rights or property, as well as the rights and property of Uklon Partners.

– Insurance companies: by signing the relevant annexes to the contract with the insurance company, We transfer your personal data to the extent necessary for insuring your life and health during transportation, as well as by notifying the insurance company of your personal data in writing in case the occurrence of an insurance event as a result of your ordering a delivery service.

– Protection of your life and health during transportation: We may transfer your personal data (name, surname, phone number, travel route and location) to emergency services in order to save your life or health and/or prevent the threat of harm to your life or health during the trip if you pressed the SOS button in the “Uklon” Mobile application. 

– Financial companies: We transfer your travel history, order information, as well as data confirming the fact of communication with you regarding the trips made, including, but not limited to, screenshots of e-mail correspondence and other means of communication with a list of personal data, specified by you during registration in the online service “Uklon”, the date of your registration to the relevant requests of financial companies – providers of financial services in order to confirm the trips you have made. You hereby consent to the transfer of the specified screenshots of correspondence by Us to financial companies and confirm that such transfer will not constitute a violation of the confidentiality of correspondence.

– Third parties that offer/provide you with discounts, and/or gifts, and/or prizes, and/or other promotions: We may transfer your personal data (surname, name, phone number) in the manner and to the extent sufficient to provide you with discounts from the actual (current) prices for goods and/or services of such third parties, and/or gifts, and/or prizes, and/or other promotions, offered and provided by such third parties.

B) Uklon partners (users of the online service «Uklon Driver »).

– Fulfillment of orders: We transfer your personal data to users of the online service “Uklon” whose orders you fulfil.

– Third-party service providers: We may use third-party services to process your personal data on Our behalf. This processing takes place for various purposes, for example, for sending informational materials on Our behalf and in Our interests. Independent service providers agree to mandatory confidentiality and may not use your personal data for other purposes.

– Competent state authorities: We transfer personal data to law enforcement, tax, fiscal and other competent authorities to the extent and in those cases required by the current legislation of Ukraine, in particular, if it is necessary to prevent, detect or stop criminal acts and fraud, In addition, personal data to the extent appropriate may be transferred to competent authorities to protect Our rights or property, as well as the rights and property of users of the Website and Mobile Applications.

– Insurance companies: by signing the relevant annexes to the contract with the insurance company We transfer your personal data to the extent necessary for insuring your life and health during transportation, as well as by notifying the insurance company of your personal data in writing in case the occurrence of an insured event as a result of your delivery service. We delete the aforementioned data immediately after it is transferred to the insurance company.

– Search for things left in the car: at the written or verbal request of the users of the online service “Uklon”, we give them your name and phone number in order to help them return personal things left in the car during transportation. In other cases, at the written or verbal request of users of the online service “Uklon”, we can transfer your phone number to them only if we receive your separate consent.

– Financial companies: We transfer the history of completed orders, personal data specified by you during registration in the online service “Uklon”, data contained in your personal account, as well as data confirming the fact of communication with you regarding the trips made, to include, but not limited to, screenshots of e-mail correspondence and other means of communication at the relevant requests of financial companies – providers of financial services. You hereby consent to the transfer of screenshots of the correspondence specified by Us to financial companies and confirm that such transfer will not constitute a violation of the confidentiality of the correspondence.

– Third parties that offer/provide you with discounts, and/or gifts, and/or prizes, and/or other promotions: We may transfer your personal data (surname, name, phone number) in the manner and to the extent sufficient to provide you with discounts from the actual (current) prices for goods and/or services of such third parties, and/or gifts, and/or prizes, and/or other promotions, offered and provided by such third parties.

Why do we get your consent and how can it be withdrawn?

   In cases determined by law, you provide your unequivocal consent to the collection and processing of your personal data by us in accordance with this Regulation. Consent to the processing of personal data is provided by you to perform any actions in relation to personal data that are necessary to achieve the goals that require the consent of the data subject, including, but not limited to: collection, systematisation, accumulation, storage, adaptation, clarification (updating, change), use, distribution (including through sale or transfer), cross-border transfer, depersonalisation, blocking, destruction, as well as any other actions with personal data in accordance with the current legislation of Ukraine.

When processing personal data, we are not limited in the use of methods of processing. Personal data is processed using automation tools.

   The following types of personal data may be processed only on the basis of your separate unambiguous consent in response to Our push notification: location, phone book (contacts), recording on a memory card. You may withdraw such separate consent at any time. If you withdraw your consent, you will not be able to use any services or features that require the processing of personal data that We have collected on the basis of separate consent.

You may withdraw your consent to the processing of any personal data that we have received on the basis of your consent by sending a notification to the following email address: privacy@uklon.com.ua.  Please indicate “Withdrawal of consent” in the subject line of your message to expedite our response.

In this case, the withdrawal of consent to the processing of personal data is possible only in relation to the future processing of personal data. Withdrawal of consent does not affect the lawfulness of processing personal data based on your consent prior to its withdrawal or on other legal grounds, except for consent provided for by the current legislation of Ukraine.

In particular, We have the right not to delete personal data if We receive a notice from You of withdrawal of consent to the processing of personal data or a request to delete personal data, if the processing of such personal data is necessary to fulfil obligations under the laws of Ukraine or to protect Our legitimate interests or the legitimate interests of persons to whom the data is transferred, in particular, for accounting and fraud prevention purposes.

Please note that since your personal data is necessary, among other things, to provide access to the Uklon online service and/or the Uklon Driver online service, your account may be blocked or deleted after withdrawing your consent to the processing of such personal data.

Personal data of the users of the online service “Uklon”, without which it is impossible to provide access to the online service “Uklon”:

● phone number – in case of placing an order through the Mobile Application or the Website.

● phone number and username – in case of placing an order through the Website without registering the user in the online service “Uklon”.

Personal data of Uklon Partners (users of the online service “Uklon Driver”), without which it is impossible to provide access to the online service “Uklon Driver”:

● first name, car make and model, vehicle registration plate number, date of driver registration, phone number, number of trips with the date of the start of using the Uklon Driver online service and the data of the vehicle registration certificate, your photo (image), the city of concluding a Public Offer with Us to provide access to the online service (supply of software products) by accepting the Public Offer posted on the Website.

If you withdraw your consent to the processing of other personal data other than the above, which is necessary for the use of the relevant service, your account will remain active. We will always attempt to identify the request to ensure that it comes from the account holder. If We are unable to successfully identify the request, We will not be able to revoke consent.

You may also contact Customer Support at +380931771511 or email privacy@uklon.com.ua to request that We delete your account. After processing your request and conducting identification, we will delete your account, except as provided for in this Regulation.

If you are a Uklon Partner (user of the online service “Uklon Driver”) and withdraw your consent to processing or ask us to delete personal data, a certain part of the data received from you will remain in processing for some time, even after deleting your account and terminating cooperation, namely: phone number; name; the date you started using our service. This is due to the fact that the relevant Agreement is concluded between Uklon Partners and Us or UKLON LTD by accepting the public offer. In accordance with Article 11 of the Law, the primary legal basis for the processing of personal data, in this case, is the conclusion and execution of a transaction to which the personal data subject is a party or which is concluded in favour of the personal data subject or for the implementation of measures preceding the conclusion of a transaction at the request of the personal data subject. And this is not the only legal basis for processing your data. In particular, we are obliged to comply with certain requirements of the tax legislation regarding the payment and accrual of relevant taxes and fees in respect of the funds received (legal basis for processing – the need to fulfil the obligation of the personal data controller provided for by law). In addition, in certain cases, in particular, when we detect signs of fraud or other questionable actions on the part of the Partner or third parties that violate the applicable law or the Agreement, or when there are unresolved claims or disputes between Us and the Partner, We have a need to protect the legitimate interests of the personal data owner or a third party to whom personal data is transferred (except when the needs to protect the fundamental rights and freedoms of the personal data subject in connection with the processing of his/her data outweigh such interests).

What are your rights to your personal data?

According to Article 8 of the Law, you have the right to:

• to know about the sources of collection, the location of their personal data, the purpose of their processing, the location or place of residence (residence) of the owner or manager of personal data or to give an appropriate order to obtain this information to persons authorized by him, except for cases established by law;

• receive information about the conditions for providing access to personal data, in particular, information about third parties to whom your personal data is transferred;

• to access your personal data;

• to receive no later than thirty calendar days from the date of receipt of the request, except in cases provided by law, an answer about whether your personal data is being processed, as well as to receive the content of such personal data;

• present a reasoned demand to the owner of personal data with an objection to the processing of his personal data;

• make a reasoned demand for the change or destruction of your personal data by any owner and manager of personal data, if these data are processed illegally or are unreliable;

• to protect your personal data from illegal processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of them, as well as protection from providing information that is unreliable or disgraces the honour, dignity and business reputation of a natural person;

• file complaints about the processing of your personal data with the Commissioner or the court;

• apply legal remedies in case of violation of the legislation on the protection of personal data;

• enter a reservation regarding the limitation of the right to process your personal data when giving consent;

• withdraw consent to the processing of personal data;

• know the mechanism of automatic processing of personal data;

• to protect against an automated decision that has legal consequences for you.

How can you control the personal data provided to Us?

You always have the right to access your personal data that We process. You can send a request regarding personal data by sending us a letter by e-mail at the following address: uklon1@uklon.com.ua. Indicate in the subject of the letter “Request for receiving personal data” to speed up the process.

You can also contact us at the address: 20b Stepana Bandery Avenue, city of Kyiv, 04073, Ukraine, if you believe that we have inaccurate or unreliable information about you and request that we change or destroy such personal data, or if you object to our processing of your personal data, or if you have other questions about the use of your personal data or questions about of this Privacy Policy.

Personal data storage periods:

A) Users online service “Uklon”.

Your personal data is stored for the period necessary to achieve the purposes of processing or for the established period of information storage, if this is provided for by the current legislation, with the exception of data about IP address, which are stored for three weeks from the moment of placing the order. If your account is deleted, your personal data will also be deleted from our database 3 (three) years after that, unless there are legal grounds for continuing to process them, for example, to fulfil our obligations under applicable law.

After achieving the purposes of processing or after the above three-year period or the statutory period of storage of personal data, We anonymize (depersonalize) your personal data so that they can no longer be associated with you personally. In this case, We will be able to use this information for the targeting of advertising and/or informational materials, for statistical, analytical or research purposes, without further informing You, since such information will cease to constitute personal data.

Deleting the Mobile application on your device does not lead to the deletion of your personal data.

If you exercise your right to delete your personal data, we will delete your personal data that we have processed for the purpose to which you have objected, without delay, in the absence of another legal basis for the storage and processing of this data or the requirement to store this data provided by the applicable legislation

B) Uklon partners (users of the online service “Uklon Driver”).

Your personal data is stored during the period necessary to achieve the purposes of processing or during the established period of information storage, if this is provided for by current legislation, with the exception of IP address data, which is stored for three weeks from the moment the order is placed. If your personal account is deleted, personal data will also be deleted from our database 3 (three) years after that, unless there are legal grounds for continuing their processing, for example, to fulfil Our obligations under current legislation.

Upon completion of the verification and registration process, We undertake to delete all collected information from our database, except for such data as name, brand and model of the car, vehicle registration plate number, date of registration of the Partner, phone number, number of trips with the date of the start of using our service and data of the vehicle registration certificate, the city of concluding a Public Offer with Us to provide access to the online service (supply of software products) by accepting the Public Offer posted on the Website. This data is stored to ensure the functioning of the service and the fulfillment of the User Agreement.

After achieving the purposes of processing or after the above three-year period or the statutory period of storage of personal data, We anonymize (depersonalize) your personal data so that they can no longer be associated with you personally. In this case, We will be able to use this information for the targeting of advertising and/or informational materials, for statistical, analytical or research purposes without further informing You, as such information will cease to constitute personal data.

Deleting the Mobile application on your device does not lead to the deletion of your personal data.

If you exercise your right to delete your personal data, we will delete your personal data that we have processed for the purpose to which you have objected, without delay, in the absence of another legal basis for the storage and processing of this data or the requirement to store this data provided by the applicable legislation.

Location of your personal data:

We care about the security of your personal data and therefore we store your personal data on servers located in the countries of the European Union.

We can too transfer yours personal given to others countries, but only for purposes of processing data provided hereby Provisions or valid legislation. You hereby give your unequivocal consent to the transfer (as well as processing and storage) of your personal data outside of Ukraine, including jurisdictions that are not recognized as providing adequate data protection. However, we always take measures to properly protect your data.

How do we protect your personal data?

We know that security is important to Our users, and We care about the security of Your personal data. We use technical, physical and administrative security measures to protect your personal data from loss, misuse, unauthorized access, disclosure or alteration. Some of the measures We employ include cross-network security measures, data encryption, physical access controls to Our data centres, and personal data access controls.

Access to personal data is provided to structural units and/or individual employees for the performance of their functional duties related to the fulfilment of Our contractual and legal obligations. Each employee/authorized person who has access to personal data signs an obligation not to disclose information to which he has access during the performance of functional duties.

We also need your help – it is your responsibility to ensure that your personal information is accurate and that your password and account registration information is secure and not shared with third parties.

If, when placing an order for transportation through the online service “Uklon”, you pay with a Uklon Partner by bank card, you automatically go to the website of the relevant financial service provider and provide your personal data and bank card data directly on the website of this financial service provider.

The Website or Mobile Applications do not collect any data about your bank cards. Uklon partners participating in the bonus program may, under certain conditions, provide us with their bank card details.

If you have any questions regarding the protection and security of your personal data, please contact us

– at: 20B Stepan Bandera Avenue, Kyiv, 04073;

– by sending an email to: privacy@uklon.com.ua 

How do we treat children’s personal data?

We strictly adhere to the protection of children’s personal data. We do not knowingly collect, process or store the personal data of persons under the age of 18.

The Website and Mobile Applications are not intended for use by persons under the age of 18.

If you are under 18 years of age, please do not use or access the Websites or Mobile Applications at any time and in any manner.

If a parent or legal guardian believes that their child has accessed the Website and/or Mobile Applications and provided their personal information, We strongly encourage the parent or legal guardian to contact Us immediately and We will make every effort to promptly remove such personal data.

Cookies

We may use cookies, web beacons, tags, scripts, local shared objects such as HTML5, and advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technologies (hereinafter referred to as “Cookie”) in connection with the use of the Website or Mobile Applications for certain purposes: Your authentication, remembering your settings and other purposes specified below.

A cookie is a small piece of data that is sent to the browser on your computer or mobile device. Cookies belonging to the Website or Mobile Applications are primary. Cookies that We allow other organizations to send through the Website are called “additional cookies”.

In addition, session and persistent cookies are distinguished. Session cookies remain valid until you close your browser or Mobile Application. Persistent cookies have a longer duration: they are not automatically deleted when you close the browser.

“Software Development Kits” (SDKs) function like pixels and cookies, but operate in mobile application environments where pixels and cookies may not always function. The developer of the underlying application may install code snippets (SDK) from partners in the application and thereby allow the partner to collect certain information about the user’s interaction with the application and information about the user’s devices and network information.

Cookies are used for various purposes. They help to recognize you as the same user on different pages of the Website or when using Mobile Applications.

The Website and Mobile Applications use cookies for various purposes:

• Technical cookies: We want Our users to be able to use modern, convenient sites and applications that automatically adapt to their needs. We use technical cookies to ensure that the Website and Mobile Applications are displayed correctly and work without errors and that you can create an account, log in and manage your orders. Technical cookies are necessary to ensure error-free operation of the Website and Mobile Applications.

• Functional cookies: they are necessary to remember your preferences and help you use the Website and Mobile Applications effectively. We can use them to remember your personal data and save you from having to enter your username and password every time. At the same time, your password will always be encrypted. Functional cookies are not required for access to the online service “Uklon” and/or the online service “Uklon Driver”, but they make the Website and Mobile Applications more functional and user-friendly.

• Analytical Cookies: These are necessary to learn how visitors use the Website or Mobile Applications. We can understand how well various functions work, optimize the Website and Mobile Applications, analyze advertising and communications. Analytical cookies help Us make sure that the Website and Mobile Applications are interesting and useful for users.

• Marketing Cookies: We use these files to transmit information, newsletters, advertising and promotional materials or to run advertising campaigns. For example, We may rely on information obtained through these cookies to provide you with information, newsletters, advertising and promotional materials that may be of interest to you.

This also means that We may use data about how You interact with the Website, including the number of page clicks, mouse movements and scrolling, search terms and other text that You enter into various fields.

For users of the Mobile application “Uklon”, as well as for Users of the Mobile application “Uklon Driver”, through the operating system of the mobile device, you can choose whether to allow the use of cookies or to share your advertising identifier with Us or Our advertising service providers.

If you do not want your personal data to be collected through cookies on the Website, you can disable cookies by configuring your internet browser to disable, block or disable cookies, deleting your browsing history and clearing your cache internet browser. You can also restrict the sharing of some of this data through your mobile device settings.

How to contact us?

Questions, comments and requests regarding this Policy are welcome and should be directed to our Customer Support Service at +380931771511 or to the email address of the person responsible for the processing and protection of personal data: privacy@uklon.com.ua. 

If you believe that We have violated the terms of this Privacy Policy, contact Us and let us know which terms of this Privacy Policy have been violated. We will promptly consider your complaint.

This version is effective from 13.05.2024.