1. DEFINITIONS
“Controller” means a person responsible for the processing and protection of Personal Data of Users located within the EU, as understood under the General Data Protection Regulation (GDPR) dated 27th April 2016.
“Site” means an informational unit on the Internet, a resource consisting of web pages (documents) united by a common theme and linked to each other through hyperlinks. It is registered by the Right Holder and is bound to a specific domain, which serves as its address. This Policy is designed for the following website: https://sankor.ee
“Personal Data” means a combination of personal information and/or non-personalized information about the User, provided by the User to the Right Holder and/or automatically collected by the Right Holder and/or third parties.
“Policy” refers to this Privacy Policy for the website (including all existing additions and amendments).
“User” means a legal or natural person who uses the Site and/or has gained access to it from any device.
“User Agreement” means an agreement concluded between the Right Holder and the User regarding the procedures, rules, and features of using the Site. The User adheres to such an agreement and is not entitled to make or demand any changes or additions to it. The User can review the terms of the User Agreement through the following link: https://sankor.ee/privacy-policy/
“Right Holder” means the following individual/entity on whose name the Site is registered: Company SANKOR.
“Cookies” mean small files sent by any website and placed on Users’ computers, smartphones, tablets, watches, and other mobile devices to improve the functionality of the sites and the quality of the content hosted therein.
2. SCOPE OF THE POLICY
General Provisions
This Policy is used and applies exclusively to Personal Data obtained from Users in connection with their use of the Site. The provisions of this Policy aim to:
(1) Determine the types and categories of Personal Data received, the purposes and directions of the use (processing) of Personal Data, as well as the sources of obtaining such Personal Data; and
(2) Determine the rights of Users regarding the protection of the confidentiality of the transmitted Personal Data; and
(3) Identify persons responsible for the processing and storage of Personal Data, as well as third parties to whom such data is disclosed (in full or in part).
The rules of this Policy do not apply to the processing of Personal Data voluntarily provided by Users by third parties.
By using the Site, the User agrees to the terms of this Policy and gives consent to the Right Holder for the collection, processing, retention, and storage of Personal Data in accordance with the provisions of this Policy.
If the User does not agree with the terms of the Policy and/or finds certain conditions of the Policy unclear, the User must immediately cease using the Site.
User Rights Regarding Personal Data Protection
In connection with the provision of Personal Data, the User automatically gains the following rights:
(1) To receive information regarding the processing of their data (the basis and purposes of such processing, methods applied in processing, information about persons who have access to the data, or to whom the data may be disclosed based on a contract or the Law).
(2) To receive information about the location and identification data of individuals processing Personal Data.
(3) To receive information about the retention periods of Personal Data.
(4) To receive information about the conducted or intended cross-border transfer of Personal Data.
(5) To appeal the actions or inactions of the Right Holder to the authorized body for the protection of the rights of personal data subjects or through legal proceedings.
(6) To claim compensation for damages and/or moral harm in legal proceedings resulting from violations of the User’s rights to the protection and defense of their Personal Data committed by the Right Holder and/or third parties.
(7) To exercise other rights related to the protection of personal data provided by the Law or the provisions of this Policy.
3. LIST OF COLLECTED PERSONAL DATA
Non-personalized information about users
In connection with the use of the Site, the Right Holder may automatically collect and process the following non-personalized information about the User:
(1) Information about traffic, possible numbers of clicks, logs, and other data.
(2) Information about the device (device identification number used for login, operating system, platform, browser type, and other browser-related information, IP address).
Personal data about users
The User provides the following personal data about themselves to the Right Holder:
(1) Full name, first name, and patronymic.
(2) Date of birth and age.
(3) Email address.
(4) Mobile phone number.
(5) Data about orders placed by Users and/or received/paid services through the Site.
(6) Data and information obtained through the combination of specific User’s Personal Data and data and information obtained from third parties (partners, marketers, researchers).
The User is solely responsible for the completeness of the provided personal data and must promptly update them (refresh, verify, correct) on a regular basis.
The Right Holder assumes that all personal data provided by the User are accurate and that the User maintains such information up to date.
Use of Cookies
The Site applies certain Cookies to store the User’s IP address, preferences, or the type of device used for the following purposes:
(1) To monitor site visits and traffic.
(2) To personalize the data displayed on the User’s screen.
(3) To store data necessary for User identification, including accessing from different devices.
(4) To display advertising based on the User’s interests and preferences. The Site may use both its own Cookies belonging to the Right Holder and third-party Cookies.
The Site uses the following Cookies:
(1) Technical (functional) Cookies necessary for traffic control and data transmission, User identification, and providing User access to content. Without these Cookies, the use of the Site is functionally limited, and they also prevent providing recommendations not corresponding to the User’s interests.
(2) Statistical Cookies necessary for tracking the frequency of Site visits, the ways of using the Site and/or its content by Users, detecting the type and kind of content that is popular or interesting to the User.
(3) Third-party Cookies set by third parties with the User’s permission, intended for conducting statistical research regarding User behavior on the Internet and/or providing personalized advertising or marketing materials to the User and/or providing goods or services.
The User has the right to disable Cookies at any time by changing certain settings in their browser. Such disabling does not restrict or change the User’s access to the functional capabilities of the Site and/or its content.
4. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA
Definition of processing purposes:
The collection and processing of Personal Data are carried out for the following purposes:
(1) To analyze User behavior and identify User preferences towards specific types of content.
(2) To ensure the smooth and proper functioning of the Website, improve its functionality, and content.
(3) To identify the User.
(4) To comply with legal requirements.
(5) To track orders made by the User through the Website.
(6) For technical support of the Website, identification, and resolution of any issues affecting its operation.
(7) To maintain communication with the User.
(8) To fulfill other obligations of the Data Controller towards the User.
(9) For any other purposes, subject to obtaining separate consent from the User.
Processing of Personal Data is based on the principles of:
(1) Legality of processing purposes and methods.
(2) Fairness.
(3) Consistency of processing purposes with the purposes defined and declared at the time of collecting such Personal Data.
(4) Consistency of the scope and nature of processed Personal Data with the declared purposes of their processing.
Conditions for processing personal data:
Processing of Personal Data is carried out in the following cases:
(1) When obtaining consent from the User.
(2) When the Data Controller achieves the purposes provided by an international treaty or the Law.
(3) When the User provides their Personal Data to an unlimited circle of persons.
(4) To fulfill other obligations of the Data Controller towards the User, including but not limited to providing specific content to the User.
(5) To save the life or health of the User when obtaining consent for processing their Personal Data is not possible in advance.
In case of depersonalization of Personal Data, which does not allow direct or indirect identification of the User, subsequent use and disclosure of such data to third parties are permitted, and the rules of this Policy no longer apply to them.
The Data Controller takes all possible measures to protect the confidentiality of the obtained Personal Data unless the User has made such data publicly available.
Processing of Personal Data is carried out both with the use of automation tools and without such tools.
5. ACCESS OF THIRD PARTIES TO PERSONAL DATA
Disclosure of personal data to third parties:
The Data Controller has the right to disclose Personal Data to:
(1) Its affiliated companies, branches, and representative offices.
(2) Successors of the Data Controller resulting from its liquidation, reorganization, or bankruptcy, who have acquired exclusive rights to own the Website.
(3) Third parties solely for the purpose of providing the User with specific content or access to it.
(4) Third parties when the User has given consent to disclose, transfer, or process their Personal Data, as well as in other cases directly provided by the Law or this Policy.
The Data Controller discloses Personal Data only if:
(1) It is confident that third parties will comply with the conditions of this Policy and take the same measures to protect the confidentiality of Personal Data as the Data Controller does.
(2) Consent to such disclosure has been previously given by the User and/or is allowed based on the Law.
6. PLACEMENT OF ADVERTISEMENTS
Advertisement on the Website:
The Data Controller does not place advertisements on the Website.
7. COMPLAINTS AND REQUESTS TO THE DATA CONTROLLER
Request to cease the processing of personal data:
Each User has the right to express their objection to the Data Controller against the processing and/or storage of their Personal Data. Such an objection can be expressed by contacting the Data Controller at the following email address: sankor053@gmail.com.
Request for information about personal data:
If the User has any questions related to the application or use of this Policy, the procedure and/or method of processing Personal Data, the User may ask such questions by contacting the Data Controller at the following email address: sankor053@gmail.com.
Amendment (update, supplementation, correction), or deletion of personal data:
The User has the right to change or delete Personal Data at any time by sending a special request to the Data Controller at the following email address: sankor053@gmail.com.
The Data Controller has the right to refuse to change or delete Personal Data if such actions would lead to:
(1) Violation of the rules of this Policy.
(2) Violation of the Law.
(3) The nature of Personal Data is evidence in any legal proceeding between the Data Controller and the User.
8. TERMS AND PROCEDURE OF PERSONAL DATA STORAGE
Storage is carried out independently by the Data Controller.
Storage is conducted for the entire period necessary to achieve the declared purposes of processing Personal Data.
The Data Controller undertakes to immediately destroy or depersonalize the Personal Data after the purposes of processing them have been achieved.
9. ACCESS OF MINORS TO THE WEBSITE
Users within the territory of the European Union
The use of the Website is intended for individuals aged 16 and older who can access it only upon providing prior consent for the processing of their Personal Data.
If the Data Controller becomes aware that a User’s age does not correspond to the permissible age for using the Website, the Data Controller shall promptly block access to the Website for such User.
10. PROCEDURE FOR PROTECTING PERSONAL DATA
Protecting the confidentiality of Personal Data is a primary and important task for the Data Controller. The Data Controller adheres to all required international standards, rules, and recommendations for protecting Personal Data.
The Data Controller has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access by third parties.
11. USERS WITHIN THE EUROPEAN UNION
General Provisions
Since the Website is accessible to users from the European Union, the Data Controller undertakes to additionally comply with the provisions of GDPR.
For the purposes of this Policy, the Data Controller is considered the Controller.
The Data Controller stores Personal Data for a reasonable period necessary to achieve the processing purposes but not less than the period prescribed by the local legislation of the European Union member state where the Website is accessible for storing certain types of Personal Data. After the storage period expires, the Data Controller undertakes to immediately destroy or depersonalize such data.
Rights of users regarding the protection of personal data
According to Chapter 3 of GDPR, Users located within the territory of the European Union have the following rights regarding the protection of Personal Data:
(1) The right to be informed about their Personal Data.
(2) The right to access their Personal Data.
(3) The right to rectify Personal Data.
(4) The right to erasure of Personal Data.
(5) The right to restrict the processing of Personal Data.
(6) The right to data portability to third parties.
(7) The right to object.
12. CONCLUDING PROVISIONS
Accessibility of the policy text for review
Users can review the terms of this Policy by following this link: https://sankor.ee/en/privacy-policy/.
This edition of the Policy is effective from August 1, 2023.
Amendment and supplementation of the policy
This Policy may be amended from time to time. The Data Controller is not liable to the User for changing the terms of this Policy without the User’s permission and/or consent.
The User agrees to regularly check the provisions of this Policy for possible changes or additions.
Applicable legislation
This Policy is developed in accordance with the current legislation on the protection of personal data of Ukraine, as well as the provisions of the General Data Protection Regulation (GDPR) dated April 27, 2022.
Disclosure risk
Regardless of the measures taken by the Data Controller to protect the confidentiality of received personal data, the User hereby acknowledges that any transmission of Personal Data over the Internet cannot be guaranteed to be completely secure, and therefore, the User performs such transmission at their own risk.