1. GENERAL CLAUSE

1.1. This document: "Personal data processing and protection policy for the Users of https://sef.com.ua" (hereinafter the Policy) was developed in accordance with the Law of Ukraine dated 01.06.2010 No. 2297-VI "On Personal Data Protection" and is the main internal document of the Company Sef Digital LLC (hereinafter referred to as the Operator), which regulates the activities in the field of personal data processing and protection.

1.2. The Policy was developed in order to implement the requirements of the legislation of Ukraine in the field of processing and protecting personal data and is aimed to ensure the security of the rights in the processing of personal data by the Operator, including the protection of the rights to privacy, personal and family secrets.

1.3. The policy determines the composition and the purpose of the received and processed personal data, the procedure for storing and transmitting personal data, as well as measures implemented by the Operator aimed at protecting it.

1.4. This Policy applies to any User information obtained by the Operator, both before and after the approval of the Policy.

1.5. This Policy applies to all information that the Operator can receive about the User, including the usage of sef.com.ua website.

1.6. Visiting and using the Site means the unconditional consent of the User for:

· Processing of his personal data specified in point 3 of this Policy for the purposes specified in point 4 of this Policy;

· Conditions for the processing of their personal data contained in this Policy.

1.7. In case of disagreement with the Policy, the User must stop using the Site.

1.8. This Policy applies only to the sef.com.ua site. The Operator does not control and is not responsible for the collection and processing of personal data by third parties, to the sites of which the User can follow the links available on the website sef.com.ua.

1.9. The Operator is not responsible for the accuracy of personal data provided by the User.

2.1. The Operator - "Sef Digital" Limited Liability Company (65000, Ukraine, Odessa region, Odessa, Mikhailovskaya Square, 1);

2.2. Site - a set of web pages hosted on the Internet united by a single domain sef.com.ua. The start page of the Site, from which all other web pages of the Site can be accessed, is available on the Internet at sef.com.ua.

2.3. Personal data - any information related directly or indirectly to a specific or designated individual (subject of personal data).

2.4. Personal data processing - any action (operation) or set of actions (operations) performed with or without use of automation tools for personal data, including the collection, recording, systematization, accumulation, storage, refinement (update, change), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.5. The User - a person having access to the Site via the Internet and using the Site.

2.6. Cookies are a small piece of data sent by a web server and stored on the User's computer, which the web User or web browser sends to the web server in an HTTP request when trying to open a page on the Site.

3.1. User data received and processed under this Policy is received by the Operator in the following ways:

3.1.1. Provided by the User on the Site when filling out personal entry forms and may include the following information:

Name;

E-mail address;

3.1.2. Automatically transferred to the Operator during the visit and use of the Site using the software installed on the User's device (information from the cookie files), including: location information; User device type and the resolution of its screen; type, version and language of the operating system installed on the User's device; type, version and language of the browser (or any other program by which the Site is accessed); IP address; the address of the page from which User navigated to the Site (referrer), information about which pages are opened and which buttons the User clicks on the Site.

The site uses Yandex.Metrics program for tracking and web analytics from YANDEX LLC (Russian Federation, 119 021, Moscow, Lev Tolstoy St., 16, YANDEX LLC). It helps to collect anonymous (without reference to personal data of the User) data on site visits in order to better understand the behavior. The additional information, can be accessed at: legal.yandex.ru/metrica_termsofuse/.

The site uses Google Analytics, a tracking and web analytics program developed by Google, Inc. (1600 Amphitheater Parkway, Mountain View, CA 94 043, USA). Google Analytics uses cookies. Data on the use of the Site (including the IP address) created by cookies is usually transmitted to Google servers and stored on these servers. Google uses this information to evaluate the use of the Site, to compile reports on actions on the Site for the Operator and to provide other services related to actions on the Site and on the Internet. More information available at: www.google.com/intl/en/analytics/.

3.2. The Operator does not process special categories of personal data relating to race, nationality, political opinion, religious or philosophical beliefs.

4.1. Collection and processing of personal User data specified in clause 3.1.1. of this Policy is carried out by the Operator in order to:

· Conclusion and execution of contracts between the Operator and the User;

· Communication with the User, including sending notifications, requests and information related to the use of the Site, the provision of services if necessary;

· Processing any inquiries and requests from the User.

4.2. Collection and processing of personal User data specified in clause 3.1.2. carried out by the Operator in order to create statistics that helps to understand how the Site is used, which allows to optimize its structure, content, and improve the usability of the Site.

The User can at any time make changes to the cookies settings and block the automatic transfer of specified files. Detailed information on the possibilities and methods of transferring cookies is available in the settings of the web browser. The restrictions on the use of cookies may affect some of the features available on the web pages of the Site.

4.3. It is not allowed to process personal data that does not meet the processing objectives specified in clauses 4.1. and 4.2. of this Policy.

5.1. The time for processing User's personal data is unlimited. The processing procedure can be carried out in any manner provided by the legislation of Ukraine. In particular, with the help of personal data information systems, which can be maintained automatically or manually.

5.2. The processed personal data is destroyed or de-identified by the Operator upon reaching the processing goals or in case of loss of the need to achieve these goals, as well as when the User withdraws consent to the processing of personal data.

5.3. The User may at any time withdraw his consent to the processing of personal data by sending a written notice to the email address: info@sef.com.ua marked "Personal data processing cancellation". This entails the destruction of records containing any personal data in the Operator's processing systems, including the deletion of a User account on the Site.

5.4. The User has the right to require the Operator to clarify his personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take other measures provided by the legislation of Ukraine to protect their rights .

5.5. The right of the User to change, delete, block personal information may be limited by the requirements of the legislation of Ukraine.

5.6. With respect to personal data of the User, their confidentiality is maintained, except for the cases stated in clause 5.7. of this Policy.

5.7. The Operator has the right to transfer personal User data to third parties in the following cases:

5.7.1. The transfer is required by the Ukrainian or other applicable legislation in the framework of the established procedure (by a court decision, a request from law enforcement agencies, etc.);

5.7.2. In order to ensure the possibility of protecting the rights and legitimate interests of the Operator.

5.8. In case of loss or disclosure of personal data, the Operator informs the User about it.

6.1. The Operator takes the necessary organizational and technical measures to protect the User's personal data from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, as well as from other illegal actions of third parties.

6.2. The website sef.com.ua has a SSL security certificate, under which information is transmitted between the User and the Operator in encrypted form, in order to prevent its interception and distortion during transfer.

7.1. In case of non-fulfillment of their obligations, the Operator shall be liable for losses incurred by the User in connection with the unlawful use of personal data, in accordance with the legislation of Ukraine, except as otherwise provided for in 7.2. of this Policy.

7.2. In case of loss or disclosure of personal data of the User, the Operator is not responsible if this information has become public before its loss or disclosure, or was disclosed by the Users themselves or with the consent of the User.

8.1. The Operator has the right to make changes and additions to this Policy. The new version of the Policy is valid from the moment it is posted on the site sef.com.ua, unless otherwise provided in the new version of the Policy.

8.2. The relations in the field of processing and protection of personal data that are not regulated in this Policy are applied under the current legislation of Ukraine.

8.3. All offers or questions related to the processing and protection of personal data by the Operator should be sent to the email address info@sef.com.ua.

8.4. Contact details of the Operator:
Limited Liability Company "Sef Digital"
Address: 65000, Ukraine, Odessa region, Odessa, St. Michael's Square, 1