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.