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1. General provisions

This Privacy Policy for users of the online service “Uklon” (hereinafter referred to as the “Policy”) has been developed by the Limited Liability Company “UKLON CORPORATE”, Company code 44378710, location: 20B Bandery Avenue, Kyiv, 04073 (hereinafter referred to as the “Company”, “We”, “Our” in the respective cases), which acts as the following:

–  the personal data controller within the meaning of the Law of Ukraine “On Personal Data Protection” dated June 01, 2010 No. 2297-VI (hereinafter referred to as the “Law”), or

– the controller within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation) (“GDPR») where GDPR may apply to certain processing activities involving Personal Data.

The definitions and abbreviations used in this Policy shall have the meanings given in the Law and other applicable personal data protection legislation, where such legislation applies to specific processing activities involving personal data, as well as in:

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

With this 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 processing and protecting personal data.

This Policy applies to all types of personal data of users of the Uklon online service, which we collect and process through the website uklon.com.ua (hereinafter referred to as the “Website”), the Uklon mobile application for iOS and Android (hereinafter referred to as the “Mobile Application”), as well as through other sources specified below in this Policy.

Whenever You use the Online Service in the capacity of a Marketplace User, We process Your personal data in accordance with this Policy and taking into account the provisions of Section 12 of the Marketplace Terms of Use.

By using the Website and/or the Mobile Application, as well as when placing an order without registration, you confirm, warrant and declare that you have read and accepted this Policy and, accordingly, agree to our processing of your personal data in accordance with this Policy and, if You use the Online Service in the capacity of a Marketplace User, subject also to the provisions of Section 12 of the Marketplace Terms of Use.  

If you do not agree to this Policy and the relevant processing of your personal data, do not use the Website and/or Mobile Application, or otherwise use the Uklon online service.

We may amend or otherwise change this Policy from time to time. We may make changes to this Policy without prior notice to you and without your consent, so we recommend that you regularly check this Policy on the Website and/or Mobile Application. If possible, if we have your e-mail address, we may inform you of the relevant changes to this Policy. Your continued use of the Website and/or the Mobile Application after changes to the Policy have been made will mean that you have read and accepted such changes.

This Policy is written in Ukrainian, but may also be provided for review in English. In case of discrepancies between the terms of this document in Ukrainian and its translation into English, the Ukrainian version of the document shall be legally binding.

2. What personal data we collect and process

We process the personal data that you provide to us both when filling out the registration form on the Website or in the Mobile Application and when further filling out your profile in the account(s), namely: name, e-mail address, telephone number, date of birth, gender, country, city and certain addresses that you mark as important, photo images, information about the presence of children, car and pets, information about participating in the loyalty program. 

We may also additionally process data about your Facebook and Google plus account when you register in the Uklon mobile application via Facebook and Google plus. Your account in the Uklon mobile application allows you to save personal settings, view previous orders, plan future orders and manage current orders, which in turn allows Us to process this information.

Please note that for the purpose of registering an account, at the first stage of registration, you provide us with only a contact phone number to be used for registration. At this stage, you have the opportunity to familiarize yourself with this Policy and refuse to create an account, use the Uklon online service and, accordingly, provide us with other personal data. After you provide us with your 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 in order to confirm or clarify certain registration information.

When you place an order via the Website without registering, we process the following information: phone number, name, location and movement data, and automatically collected data as well as other data as disclosed in this Policy.

We also process your personal data when you contact Our customer support service or contact Us through other channels (for example, through social media), or when we contact you based on legitimate interest or other legal grounds, including application of the Uklon online service policies, such as handling complaints, negative feedback, incidents, or inquiries. In particular, We may record communication with You.

By participating in advertising (promotional) campaigns or giveaways, you will also provide Us with your personal data, depending on the official terms and conditions of the respective campaign or giveaways. As a rule, We ask for the following personal data to participate in advertising (promotional) campaigns: first and last name, age, phone number. And to participate in a giveaway and receive a reward (gift), we usually need to collect the following personal data: name and surname, phone number, city, Nova Poshta branch or full address of the location, taxpayer registration number (TIN) and passport data.

In addition, you may send us feedback about the Website and the Mobile Application, share your opinion or ask for help regarding the use of the Website or the Mobile Application and voluntarily provide us with your personal data in such feedback or requests.

In the event of an insured event during transportation in accordance with the terms of insurance of your life and health, including accidents, in order to receive insurance indemnity for you and other injured persons, We may request the following personal data from you, which will be transferred by Us to the insurance company: surname, name and patronymic, telephone number, date of birth, passport details, e-mail address, health data (list of injuries, photo/video record of injuries), place, date and time of the insured event

In the event of an insured event with respect to an insured delivery, if you have ordered a delivery service, we request the following personal data, which will be transferred by us to the insurance company: surname, name and patronymic, phone number, delivery address.

If you order services through the Website and/or the Mobile Application under the Public Offer of the Organizer of Passenger Transportation by Road (Bus) Transport, We may process the following categories of Personal Data for the purpose of fulfilling such orders:

– Data of users ordering services: contact details (telephone number, e-mail address, country, city), age, gender; data contained in requests or complaints and the results of their processing, or other individualized customer support provided in the course of service delivery, including recordings of telephone conversations where you contact the customer support hotline, as well as data contained in messenger communications, e-mail correspondence or other communications;

– Passenger data: surname, first name, telephone number, e-mail address, data relating to the order and its status, including trip details; data contained in requests or complaints and the results of their processing, or other individualized customer support provided in the course of service delivery, including recordings of telephone conversations where you contact the customer support hotline, as well as data contained in messenger communications, e-mail correspondence or other communications.

3. Data that we process automatically

We may automatically process certain data, in particular when you use the Website, including: Your IP address, the date and time you used Our services, information about the hardware, software and Internet browser you are using, information about the operating system of your device. We may also collect information about the clicks and web pages that We have shown You.

If you use the Mobile Application, we may also receive data identifying your mobile device, its settings and characteristics, location data, application malfunctions, other system operations, and your advertising identifiers.

When you place an order through the Website, Our system records the means by which you placed the order, from which websites you came to Our Website.

The Uklon mobile application, with your consent, may access various services and data of your mobile device, including, but not limited to: phone book (contacts), location and external storage devices (memory cards). In any case, access to the services of Your mobile device is possible only if You provide Your separate unambiguous consent in response to Our push notification.

The above types of information may not always contain personal data (i.e. data that identifies or can identify you). Some of this information may be depersonalized data (i.e. data that does not and cannot identify you).

4. Personal data of other persons that You provide to Us

Using the Uklon online service, you can place orders not only for yourself. In particular, you can order a transportation service for any person by providing us with their phone number, name and address.

When ordering a delivery service, you provide us with the personal data of the sender and recipient of the shipment, who may not be you, which will mean that we will receive the following personal data of other persons: address, name and surname, phone number.

In such cases, you are responsible for ensuring that the transfer of the relevant personal data to us is lawful and that the person whose personal data you transfer is aware that you have done so and is familiarized with how we use the personal data received (as set forth in this Policy).

To do so, you must share a link to this Policy with the person whose data you provide to us in advance. By placing an order and providing personal data of another person, You confirm that You have obtained the consent of such person in accordance with the terms of this Policy. In addition, You agree to Our right to require You, under certain circumstances, to confirm the above actions.

We also draw your attention to the fact that, where you order for yourself and/or other persons:

– the services under thePublic Offer of the Organizer of Passenger Transportation by Road (Bus) Transport, information on the processing of personal data related to the provision of such services and the fulfilment of your orders is provided in this Policy;

– the services under the User Agreement “General Terms and Conditions for Access to the Online Service for Searching, Booking, and/or Purchasing Tickets or Other Travel Documents”, the scope and conditions of personal data processing required for booking, purchasing, delivery tickets, and related service communications are determined by the Privacy policy of the Seller (https://fatpayments.net/uklon_private.html) and by privacy policies of respective service providers in accordance with the terms of such Agreement. Any other processing of personal data arising from the operation of the Uklon online service and relating to the own purposes of Uklon is governed by this Policy.

5. Information received from third parties and other sources

We may collect certain data about you from our Partners, from a third-party platform (website) if you provide a link to your profile on such platform (website), in particular, when filling out information in your account(s), if you provide your account information in a social network (e.g., Facebook, Google) or your “ONE ID” account information (Unified Remote Access Tool).

In addition, if you visit our pages on social media (Facebook, LinkedIn, X, TikTok, Instagram, etc.) and interact with us in any way, such as posting comments, using “Likes”, etc., the operator of the respective social media platform publishes this information and we have access to it, including information about your profile on such social media.

Information from third-party websites, including when you: leave reviews, ratings, additional information, including in connection with claims or disputes.

Also, in some cases, we may receive information about you from insurance companies (in the event of an insured event), financial service providers (for example, in case of suspected fraud or to clarify payment data) and information from publicly available (open) sources (for example, if it is necessary to conduct an audit in the event of a pre-trial or court proceeding).

6. How we treat personal data of children

We strictly adhere to the protection of children’s personal data. We do not knowingly collect personal data from anyone under the age of 18.

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

If you are under the age of 18, please do not use or access the Website or the Mobile Application at any time or in any manner.

If a parent or legal guardian believes that their child has accessed the Website and/or the Mobile Application and provided personal data, We strongly encourage the parent or legal guardian to contact Us immediately and We will use Our best efforts to delete such personal data immediately.

Where you order services under the User Agreement “General Terms and Conditions for Access to the Online Service for Searching, Booking, and/or Purchasing Tickets or Other Travel Documents”  or under thePublic Offer of the Organizer of Passenger Transportation by Road (Bus) Transport for booking, issuance, and purchase of tickets for children, You are fully responsible for ensuring that such sharing and  processing of their personal data is compliant with applicable laws and meets legal requirements, including the protection of children’s rights as data subjects.  

7. Purposes and legal grounds for processing personal data

We process personal data solely in accordance with applicable law. We process your personal data for the following purposes on the following legal basis (data may be processed on more than one legal basis):

– Placing orders: in order for you to place orders in the Uklon online service and, accordingly, to transfer your personal data to Uklon Partners in order for Uklon Partners to fulfill the relevant orders (taking measures preceding the conclusion of the transaction, execution of the transaction, legitimate interest).

– Use of the Website: to personalize your experience when you visit the Website using cookies and similar technologies, as well as to offer you relevant information on the Website (legitimate interest, consent of the personal data subject);

– Account on the Website or in the Mobile Application: to enable you to register an account on the Website or in the Mobile Application and, accordingly, to access the Uklon online service (conclusion and/or execution of a transaction or taking measures preceding the conclusion of a transaction).

– Using the Mobile Application (via your mobile device): The Mobile Application may access various services and data on Your mobile device, including, but not limited to, Your phone book (contacts), location, and external storage devices (memory cards). Access to the services of Your mobile device is possible only if You provide Your separate unambiguous consent in response to Our push notification. Please note, regarding access to:

● The “Phonebook (Contacts)” section: it is necessary for you to place an order for any other person by providing us with their phone number from your phone book.

● The “Location” section: to ensure the quality of services, in particular, to demonstrate the location of the car that will fulfill your order, as well as if you pressed the SOS button in the Uklon Mobile Application.

● The section “Writing to the memory card”: We may write some technical temporary data (cache) related to your order to your phone’s memory card.

– Customer support: to process (consider) your inquiries, requests or complaints, provide a response and further respond to them, as well as to provide you with round-the-clock support of the Uklon online service, in particular, to help you with your order, answer related questions (consent of the personal data subject, execution of a transaction, legitimate interest). Please note that conversations with support staff may be monitored in real time or recorded for the purpose of monitoring the quality of service provision and further training of our team. Call recordings are usually stored for a limited period of time in accordance with the purpose of their processing and are deleted automatically, unless We deem it necessary to retain them for a longer period (for example, to investigate cases related to violation of the law). All telephone call recordings will be used in accordance with this Policy.

– Communication with you via social networks: to establish and maintain communication with you, including to provide advice and answer questions (legitimate interest, conclusion and/or execution of a transaction).

– Insurance of your life and health during transportation: We transfer the personal data we receive from you to the insurance company in the event of an insured event for the purpose of insuring your life and health during transportation, including when you use Uklon Travel Service,  as well as to fulfill the requirements of the law, the life and health insurance contract, other contracts, including reinsurance, to exercise the rights granted to the insurance company by law or contract, and to ensure the implementation of tax relations and relations in the areas of accounting, auditing, financial services and assistance services, advertising, marketing and actuarial services.

– Delivery insurance: We transfer your personal data to the insurance company that provides shipment insurance in the event of an insured event as a result of your ordering of the delivery service (if applicable).

– Protection of your life and health during transportation: In order to save your life or health and/or prevent the threat of harm to your life or health during the trip, in particular if you have pressed the SOS button in the Uklon mobile application (protection of the vital interests of the personal data subject, legitimate interest).

– Marketing: To send you information, emails with news, surveys, advertising (promotional) materials. Some advertising (promotional) campaigns may include the condition that you consent to the Company’s use of the received contact information for advertising (marketing) purposes without violating applicable data protection laws. The online service “Uklon” provides the possibility of placing and displaying advertising materials within the Uklon mobile application, including graphic, text, video and other content (the display of such materials may be carried out taking into account your behavioral characteristics and/or the peculiarities of your interaction with the online service “Uklon”).

– Other promotional activities: We may transfer your personal data to third parties in order to offer/provide you with discounts from the existing (current) prices for goods and/or services of such third parties, and/or gifts and/or prizes and/or other incentives, offered and provided by such third parties, as well as to determine the participants/winners of advertising (promotional) campaigns and to receive the reward provided for by the terms of such campaign (legitimate interest of the Company, consent of the personal data subject, execution of the transaction).

– Legal purposes and compliance with legal requirements: To protect against any malicious acts (such as fraud); to detect and/or investigate a crime, in connection with other security considerations; to meet internal and external audit requirements, including information security measures and regular risk assessments of personal data processing; to respond to requests and other legal requirements of regulatory and law enforcement authorities; to prepare a claim or respond to a claim received; to comply with other requirements of the law applicable to us.

– Analytics and statistics: To conduct internal analytical research, develop, test and improve the characteristics and functions of the Website and/or Mobile Application and other Our possible services, as well as to obtain Your feedback about Us and Our services (legitimate interest).

– Service quality assessment and monitoring compliance with the rules of using the Uklon online service,including requirements for service quality, mutual respect, user safety, and improving the user experience: We collect your feedback, comments, and ratings regarding the level of service provided for each trip or other order. We also take into account trip ratings provided by Partners and related comments regarding their experience in fulfilling your orders, to promote mutual respect, improve the user experience of the online service “Uklon”, and ensure compliance with the rules of use of the online service “Uklon” and the Rider Etiquette (legitimate interest of the Company, consent of the personal data subject, execution of the transaction).

How it works: the rating from 1 to 5 stars is a dynamic indicator calculated based on Partners’ assessments of their experience from trips or other orders with you over your most recent 40 trips. Following a detailed review of all trip-related information, certain ratings may be excluded and may not affect the overall rating. Both the rider and the driver may choose to opt out of being matched with each other for future trips if either party assigns a 1-star rating after a trip. At the same time, the users’ access to the online service “Uklon” and their ability to place orders are not restricted based on the rider rating.

8. Disclosure and transfer of your personal data

Under certain circumstances, we may transfer personal data to personal data processors (an individual or legal entity to whom we, as the personal data controller grant the right to process such data on behalf of the controller) and/or, provided that sufficient legal grounds exist, to other categories of recipients, including foreign recipients, or may likewise obtain the necessary personal data from them for the following purposes:

– Placing orders: We transfer your personal data to Uklon Partners for the purpose of Uklon Partners fulfilling your orders. In other cases, at the written or verbal request of a Partner Uklon, we may transfer your phone number to a Partner Uklon only if we receive your express consent.

– Service quality assessment and monitoring compliance with the rules of using the Uklon online service,including requirements for service quality, mutual respect, and user safety: We collect, analyse, and share your personal data with Partners, and receive necessary data from them, to assess service quality and support a positive user experience as well as to handle inquiries and complaints, including  your scores, calculated rating, service-related comments, and data from reviews and complaints.

– Partners who provide electronic communications services to Us: We may use the services of electronic communications operators to which you are a subscriber to process your personal data on Our behalf. This processing takes place for various, but always legitimate, purposes. For example, to send you information and promotional materials on Our behalf and in Our interests, we may engage electronic communication operators to send you SMS messages and push notifications. Such service providers agree to maintain confidentiality, enter into appropriate agreements with Us and are authorized to use your personal data only for the purposes specified by Us or applicable law.

– External consultants, professional service providers: We may provide access to your personal data to service providers and/or consultants who provide professional assistance to Us and need access to such data to perform their work, for example, technical support and maintenance of the Website, invoice processing, accounting, auditing and legal services.

– Competent public authorities: We may disclose personal data to law enforcement, tax and other competent authorities only to the extent and in the cases when they have the right to receive the relevant data, in particular, if required by applicable law, as well as on Our initiative when it is necessary to prevent, detect or stop criminal acts (e.g. fraud). In addition, in certain cases, personal data may be transferred to the competent authorities to the extent necessary to protect Our rights or property, as well as the rights and property of Uklon Partners.

– Insurance companies: We transfer your personal data to the extent necessary for the insurance of your life and health during transportation, as well as by written notification of your personal data to the insurance company in the event of an insured event as a result of your ordering of transportation or delivery services or other services.

– Protection of your life and health during transportation: We may disclose your personal data to emergency services (police, rescue service, ambulance) in order to save your life or health and/or prevent a threat to your life or health during the trip.

– Banks, payment systems and other financial institutions: We may transfer your travel history, order information, as well as data confirming the fact of communication with you regarding the order and trips made (for example, screenshots of e-mail and other means of communication), which may contain personal data provided by you during registration in the online service “Uklon” or when ordering a service without registration, at the request of financial institutions (financial service providers) in order to confirm the services you have ordered through the online service “Uklon”. Such transfer will not constitute a violation of the confidentiality of correspondence. Sometimes we may ask you to provide a written request for a refund, which may contain your personal data, for transmission to the financial institution.

– Our partners who offer/provide you with discounts and/or gifts and/or prizes and/or other incentives: We may transfer your personal data in the manner and to the extent sufficient to provide you with the relevant discounts, gifts, prizes, etc. offered and provided by such partners.

– Cloud and other service providers: We may grant access to your personal data to providers of cloud and other services, for example, for obtaining software supply services and other cloud services, to the extent necessary for receiving the relevant service.

– The group of companies operating under the Uklon brand, as well as the parent company Kyivstar PrJSC: to ensure intra-group coordination, accounting, audit and other reporting, optimization of business processes, as well as within joint B2C and B2B initiatives, in particular, to improve the customer experience and the quality of Our services.

In the event of a merger, reorganization or similar corporate event or the sale of the Company or part of the Company’s assets, the information We collect, including personal data, may be transferred to the other company (subject to merger or acquisition). All such transfers will, of course, be made in accordance with applicable law and our obligations as set forth in this Policy.

Please note that to the extent permitted by applicable data protection legislation, no transfer of your personal data that is based on your consent to the processing of personal data or in accordance with this Policy will require your separate consent or provision of separate notice to you.

9. What are your rights to your personal data

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

● to know about the sources of collection, location of their personal data, the purpose of their processing, location or place of residence (stay) of the controller or processor of personal data or give a corresponding order to obtain this information to persons authorized by them, except in cases established by law;

● to receive information about the conditions for granting access to personal data, including information about third parties to whom your personal data is transferred;

● to access their personal data;

● to receive a response on whether your personal data is processed no later than thirty calendar days from the date of receipt of the request, except as provided by law, and receive the content of such personal data;

● to submit a reasoned request to the personal data controller with an objection to the processing of their personal data;

● make a reasoned request to change or erase their personal data by any controller and processor of personal data if such data is processed illegally or is unreliable;

● to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or discrediting to the honor, dignity and business reputation of an individual;

● to file a complaint against the processing of your personal data with the Commissioner or a court;

● to apply legal remedies in case of violation of personal data protection legislation;

● to make reservations regarding the restriction of the right to process their personal data when giving consent;

● to withdraw consent to the processing of personal data;

● to know the mechanism of automatic processing of personal data;

● to protect yourself from an automated decision that has legal consequences for you.

You have the right to refuse to receive marketing, newsletters, promotional materials by sending a request to the following email address: privacy@uklon.com.ua.

10. Rights of Data Subjects under the GDPR (Where Applicable)

At present, the Company does not carry out the processing of personal pata of the users of the online service “Uklon” that would be carried out in the context of the activities of the Company’s establishment in the European Union. Nevertheless, in certain cases, the processing of personal data may fall within the scope of the GDPR on other grounds.

Where the GDPR applies to the processing of your personal data, you are entitled to the following rights.

Right to Be Informed

You have the right to receive clear, transparent and easily accessible information on how the Company collects, uses, stores, transfers and otherwise processes your personal data.

This Policy provides general information regarding such processing. Should you wish to obtain additional information regarding the processing of your personal data, you may contact us using the contact details provided below.

Right of Access

You have the right to obtain confirmation as to whether or not your personal data is being processed and, where that is the case, to obtain access to your personal data and the information relating to such processing as required under applicable personal data protection law. General information regarding the processing of personal data of users of the online service “Uklon” is set out in this Policy.

Right to Rectification

You have the right to obtain, without undue delay, the rectification of inaccurate personal data concerning you and to have incomplete personal data completed.

Right to Erasure (“Right to Be Forgotten”)

Subject to the conditions established by applicable personal data protection law, you have the right to request the erasure of your personal data.

Where the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

The Company may nevertheless continue processing your personal data where such processing is necessary for compliance with a legal obligation or is based on another lawful basis provided for by applicable law.

Right to Data Portability

In certain cases, you have the right to receive the personal data that you have provided to the Company in a structured, commonly used and machine-readable format, and you have the right to transmit those data to another controller, where this is technically feasible.

Right to Restriction of Processing

You have the right to request the restriction of the processing of your personal data where the relevant grounds exist. This means that, under certain circumstances, you may require Us to cease processing your personal data, other than storing it.

Where the processing of your personal data has been restricted, We may, with the exception of storage, process such personal data only with your consent, or for the establishment, exercise or defence of legal claims, or for the protection of the rights of another natural or legal person.

Right to Object

You have the right to object, on grounds relating to your particular situation, to the processing of your personal data where, in particular, such processing is based on the legitimate interests of the Company or the legitimate interests of a third party.

However, in such circumstances, the right to object is not absolute, and you must provide grounds relating to your particular situation for objecting to the processing of your personal data. We may continue processing such personal data only where We demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or where such processing is necessary for the establishment, exercise or defence of legal claims.

Where your personal data is processed for direct marketing purposes, you have the right to object to such processing at any time. You may opt out of receiving marketing communications by sending a corresponding request to the following e-mail address: privacy@uklon.com.ua.

Right Not to Be Subject to a Decision Based Solely on Automated Processing

You have the right not to be subject to a decision based solely on the automated processing of your personal data, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where otherwise permitted under applicable personal data protection law.

At present, the Company does not carry out fully automated decision-making, without human involvement, that produces legal effects concerning users of the online service “Uklon” or similarly significantly affects them.

Right to Lodge a Complaint

Where the GDPR applies to the processing of your personal data and you consider that your rights under the GDPR have been infringed, you have the right to lodge a complaint with the competent supervisory authority, in particular in the Member State of your habitual residence, place of work or the place of the alleged infringement.

The exercise of this right shall be without prejudice to your right to any other administrative or judicial remedy.

Exercising Your Rights

To exercise any of the above rights, you may contact the Company using the contact details provided below.

Before responding to your request, the Company may ask you to provide additional information necessary to verify your identity. Any information obtained for this purpose will be used solely for the purpose of verifying your identity and processing the relevant request.

The Company shall process requests without undue delay and, in any event, no later than one month from the date of receipt thereof, unless a different period is provided for by applicable law. Where an extension of the period for responding to a request is necessary, the Company will inform you accordingly and explain the reasons for such extension.

How to Contact Us

If you have any questions regarding this Policy, wish to exercise your rights as a data subject, or have any comments or complaints regarding the processing of your personal data, you may contact Us by e-mail by sending the relevant request in electronic form to the following e-mail address: privacy@uklon.com.ua, or send a written request to the following address:

Limited Liability Company “UKLON CORPORATE”, 20B Bandery Avenue, Kyiv, 04073.

11. How you can control your personal data

Users who have created an account(s) on the Website and/or Mobile Application may access their personal data, correct personal data or delete it. In doing so, you are responsible for the accuracy and relevance of the personal data provided to us.

Uninstalling the Mobile Application on Your device does not delete Your personal data in Our databases.

We would like to inform you that personal data shall be deleted or destroyed in the event of:

You may withdraw your consent to the processing of any personal data that we have received on the basis of your consent. This can be done by sending a notification to the following e-mail address: privacy@uklon.com.ua.  Please indicate “Withdrawal of consent” in the subject line of your message to expedite our response. If an option is available, you may opt-out by following the instructions in each marketing communication.

If you withdraw your consent, you will not be able to use any programmes or additional benefits that require the processing of personal data that we have collected on the basis of a separate consent.

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 legality of processing personal data based on your consent prior to its withdrawal or on other legal grounds, except for the consent provided for by the current legislation of Ukraine or by other applicable personal data protection law, to the extent applicable to certain processing operations.

Please also note that provided that legal grounds exist, we have the right not to delete personal data if we receive from you a notice of withdrawal of consent to the processing of personal data or a request to delete personal data, particularly, if the processing of such personal data is necessary for us to fulfill our obligations under the applicable laws or to protect our legitimate interests, where such interests are overriding, in particular, for accounting and fraud prevention purposes.

Since certain of your personal data is necessary for us, including to provide you with access to the Uklon online service, your account(s) may be blocked or deleted upon receipt of a request from you to delete all personal data. In particular, the personal data without which it is impossible to provide access to the Uklon online service include:

● phone number – if you place 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”.

When you contact Us with any request to exercise your rights as a personal data subject, you need to go through the identification process and provide your specific requirements so that we can process the request in a timely and correct manner and provide a response on a lawful basis. If we are unable to identify you from the communications we receive or have reasonable suspicions about your identity, we may ask you to provide proof of identity. Only in this way can we avoid disclosing your data to a person who may impersonate you, i.e. the identification process is carried out in your best interests. Any additional information collected for verification purposes will only be used to confirm your identity.

We process requests as quickly as possible, but please note that providing a complete and legitimate response is a complex process that can take up to a month or more. We will notify you if we need more time to prepare a response.

12. Personal data storage periods

Your personal data is stored for the period necessary to achieve the processing purposes or for the established information retention period, if required by applicable law, except for IP address data, which is stored for three weeks from the date of the order.

If Your account(s) are deleted, Your personal data will also be deleted from our database three (3) years thereafter, unless there are legal grounds for continuing to process them, for example, to fulfill Our obligations under applicable law.

Upon achievement of the processing purposes or expiration of the above three-year period or the statutory retention period for personal data, we anonymize (depersonalize) your personal data so that it can no longer be associated with you personally, or delete it completely. In case of anonymization of data, we may use this information, including for statistical, analytical or research purposes, as well as for targeting, without further informing you, as such information will no longer constitute personal data.

13. Location of personal data and transfers to third countries

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

We may also transfer your personal data to other countries, but only for the purposes of data processing provided for in this Policy or applicable law. By doing so, you give your unequivocal consent to the transfer (as well as processing and storage) of your personal data outside of Ukraine, including to jurisdictions that are not recognized as providing adequate data protection. At the same time, we always take measures to ensure that your data is properly protected.

For data subjects in the EU, the Company may transfer Personal Data to countries outside the European Economic Area based on an adequacy decision adopted by the European Commission or, in the absence of such a decision, based on the Standard Contractual Clauses adopted by the European Commission for transfers of personal data to third countries, or otherwise based on appropriate safeguards and supplementary measures, where required and available.

If, however, a transfer cannot be based on an adequacy decision or appropriate safeguards, the Company may rely on one of the derogations for specific situations provided under applicable data protection laws, including where:

You hereby give your unequivocal consent to the transfer (and further processing) of your personal data to third countries (particularly, Ukraine and the United States) for the purposes described in this Policy, where neither an adequacy decision nor appropriate safeguards are available and no other derogation applies.

14. How 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 use include firewalls, data encryption, physical access controls to Our data centers and access controls to personal data.

Access to personal data is provided to structural units and/or individual employees to perform their functional duties related to the fulfillment 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/she has access in the course of performing his/her functional duties.

We also need your help – it is your responsibility to make sure that your personal information is accurate and that your password and account registration information is secure and not shared with unauthorized persons.

If you pay with a bank card when placing an order through the online service “Uklon”, you are automatically redirected to the website of the relevant financial service provider and provide your personal data and bank card details directly on the website of that financial service provider.

The Website and the Mobile Application do not collect any information about your bank cards.

15. 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 (collectively, “Cookies”) in connection with your use of the Website or Mobile App for certain purposes: Your authentication, remembering your preferences, and other purposes as described below.

A cookie is a small piece of data that is sent to the browser on your computer or mobile device. Cookies that belong to the Website or Mobile App are essential. Cookies that We allow other organizations to send through the Website are called “first party cookies”.

In addition, a distinction is made between session cookies and persistent cookies. Session Cookies are valid until you close the browser or the Mobile Application. Persistent cookies have a longer lifespan: they are not automatically deleted when you close the browser.

“Software Development Kits” (SDKs) function like pixels and cookies, but work in a mobile application environment where pixels and cookies may not always function. The developer of the underlying application may install code snippets (SDKs) 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 the Mobile Apps.

For users of the Uklon Mobile Application, using the operating system of your mobile device, you can choose whether to allow the use of cookies or share your advertising ID 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 deactivate cookies by setting your Internet browser to disable, block or deactivate cookies, deleting your browsing history and clearing your Internet browser cache. You can also limit the sharing of some of this data through your mobile device settings.

16. How to contact us

Questions, comments and requests regarding this Policy may be addressed to Our Customer Support Service at +380771100710 or to the e-mail address of the Data Protection Officer: privacy@uklon.com.ua.

You may make a request regarding your personal data by sending a letter to Us at: 20B S. Bandera Avenue, Kyiv, 04073 or by sending an e-mail to the following e-mail address:  privacy@uklon.com.ua

If You believe that We have violated the terms of this Policy, please contact Us and inform Us which terms of this Policy have been violated. We will promptly review Your complaint.

The version of the Policy is valid from 13.07.2026.