PRIVACY POLICY

1. Introduction

1. Kreston Ukraine, LLC operates under the Kreston brand and is a member of the Kreston Global Network, whose members are separate and independent legal entities.
2. The confidentiality of our website users is essential to us, and we make every effort to ensure its protection. This Policy explains how we use your personal information.
3. By agreeing to use cookies on your first visit to our website, by the provisions of this Policy, you permit us to use cookies on each subsequent visit.
4. Before using our website, carefully study your rights and obligations regarding processing personal data, specified in the Law of Ukraine On the Protection of Personal Data, this Policy, and express your entire agreement with its terms.

B. Collection of personal data

The following types of personal data are subject to collection, storage and use:

1. Information about your computer, including your IP address, geographic location, browser type and version, and operating system;
2. Information about your visits to and use of this website, including referral sources, duration of visits, pages viewed and site navigation paths;
3. Information about your email address that you used to register on our website;
4. Information you entered when you created a profile on our website – such as your name, your profile picture, gender, date of birth, marital status, hobbies and interests, education and place of employment;
5. Information, such as your name and email address, that you provide when you subscribe to our mailings and/or newsletters;
6. Information you entered when using our website services;
7. Information generated when you use our website, including information about the time, frequency and conditions of its use;
8. Information regarding any purchases you make, services you use, or transactions you make through our website, including your name, address, telephone number, email address, and credit card information;
9. Information you post on our site for the purpose of posting it online, including your username, profile picture and the content of your post;
10. Information contained in any communications you send to us by email or through our website, including message content and metadata;
11. Any other personal information you have submitted to us.
    Before disclosing a third party’s personal information to us, you must obtain this person’s consent to disclose and process that information per this Policy.

Before disclosing a third party’s personal information to us, you must obtain this person’s consent to disclose and process that information per this Policy.

C. Use of your personal information

The personal information you provide us through our website will be used for the purposes set out in these policies or on the website’s relevant pages. We may use your personal information for the following purposes:

1. administering our website and business;
2. personalising our website for you;
3. enabling you to use the services available on our website
4. sending you goods purchased through our website;
5. providing you services purchased through our website;
6. sending you messages, invoices, and reminders to pay and receive payments from you;
7. sending you non-marketing commercial messages;
8. sending you the email that you specifically requested;
9. sending you the email newsletters if you have ordered them (you can tell us at any time that you wish not to receive email newsletters from us anymore);
10. sending you marketing communications regarding our business or the business activities of carefully selected third-party companies that we think might be interesting to you by publication or, if you have expressly agreed to it, by email or similar technologies (you can tell us at any time that you wish not to receive marketing communications anymore);
11. providing third-party companies with statistical information about our users (but these third-party companies will not be able to identify any individual user from this data);
12. handling inquiries and complaints made by or about you regarding our website;
13. for ensuring the security of our website and preventing fraud;
14. to verify compliance with the terms and conditions governing your use of our website (including monitoring private messages sent through our website’s personal messaging service); and
15. for other purposes.

If you provide personal information for publication on our website, we will publish it. Otherwise, we will use this information in accordance with the license you provide us.

Your privacy settings may be used to restrict the publication of your personal data on our website and may be adjusted through the website’s privacy controls.

Without your express consent, we will not share your personal information with any third-party company for direct marketing use by this or any other third-party company.

D. Disclosure of personal information

We reserve the right to disclose your personal information to any of our employees, managers, policyholders, professional advisors, agents, suppliers or subcontractors to the extent and for the purposes outlined in this Policy.

We reserve the right to disclose your personal information to any member of our group of companies (this includes our subsidiaries, our ultimate holding company and all of its subsidiaries) to the extent and for the purposes set out in this Policy.

We reserve the right to disclose your personal information:

1. in those cases in which the current laws of Ukraine require us to do so;
2. in connection with any current or future legal proceedings;
3. to establish, exercise or protect our legal rights (including providing information to other parties, including law enforcement, to prevent fraud or any illegal/unsafe activity);
4. to a buyer (or potential buyer) of any business or assets that we sell (or intend to sell); and
5. in response to a court order or other legal request.

We will not disclose your personal information to third parties except for the cases specified in this Policy.

E. International transfers of personal information

1. The information we collect may be stored, processed and transferred between any countries we operate to enable us to use the information per this Policy.
2. The information we collect may be transferred to the following countries that do not have data protection laws similar to those in force in the European Economic Area: USA, Japan, China and India.
3. By agreeing to this Policy, you consent to transferring your personal information.

F. Storage of personal information.

1. This section sets forth the company’s policies and procedures regarding storing personal information. This Policy and these procedures are intended to ensure that we comply with our legal obligations to store and delete personal information.
2. Personal information that we process for a specific purpose or purposes must not be stored for longer than is necessary to achieve that purpose or those purposes.
3. Notwithstanding the other provisions of this Section, we will store documents (including electronic documents) that contain personal information:

• in those cases where the law requires us to do so;
• if we believe that these documents may be relevant to any current or future legal proceedings; and
• to establish, exercise or protect our legal rights (including providing information to other parties to prevent fraud or reduce credit risks).

G. Protection of your personal information

1. We will take adequate technical and organisational measures to prevent the loss, unlawful use or falsification of your personal information.
2. We will store all personal information provided by you on our servers, protected by both passwords and firewalls.
3. Data encryption technology will protect All electronic financial transactions using our site.
4. You acknowledge that the transmission of information over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the World Wide Web.
5. You are responsible for keeping your password to access our website confidential. We will never ask for your password (except when you try to log in to your account on our site).

H. Your rights

You can instruct us to provide you with any personal information we hold about you;

We reserve the right to refuse to provide information at your request within the limits of current laws.

By accepting this Policy, you agree in advance that we use your personal information for marketing purposes.

I. Third-party websites

Our website contains hyperlinks to and details about the websites of third-party companies and individuals. We have no control tools and are not responsible for the privacy policies and practices of third parties and companies in this industry.

J. Security

Generally accepted technical and operational security standards have been implemented to protect personal information from loss, misuse, alteration and destruction. However, no data transmission over the Internet can be completely secure. Although we will always use reasonable efforts to protect your personal information, we cannot guarantee that any information you provide to us can be protected from unauthorised third-party use or access.

Please be careful when sending personal information to us via email. E-mail is generally not considered a secure means of communication.

K. Updating data

We cannot ensure that your personal information is current and accurate without your help. If your personal data is outdated, please contact us so we can correct the information.

L. Cookies

Our website uses cookies. A cookie is a file containing an identifier (a line of letters and numbers) sent by a web server to a web browser and stored by the browser. Subsequently, the identifier is sent back to the server each time the browser requests a web page from the server. Cookies can be either persistent or session: persistent cookies will be stored by the browser and will be valid until the expiration date unless deleted by the user in advance; session ones, on the contrary, will be deleted after the end of the session with the site or after closing the browser. Cookies usually do not contain any information that identifies the user. However, your personal information that we have may be linked to information stored and obtained from cookies.  We use both persistent and session cookies on our website.

1. The names of the cookies we use on our website and the purposes for which they are used are listed below:
   1. On our website, we use Google Analytics and Adwords to recognise a computer when a user visits the website / track user navigation on the website / allow the use of the user’s shopping cart on the site / improve the usability of the site / analysing the use of the website/site administration / preventing fraud and enhancing the security of the site / personalising the site for each user / targeted advertising which may be of interest to individual users;
2. Most browsers give you the option to refuse the use of cookies, for example:
   1. in Internet Explorer (version 10), you can block cookies using the cookie management settings available in the menu Tools – Internet Options – Privacy – Advanced (Tools, Internet Options, Privacy, Advanced);
   2. in Firefox (version 24), you can block all cookies by clicking Tools – Options – Privacy: in the drop-down menu, select the item Use custom log settings and deselect the item Accept cookies from sites; and finally
   3. in Chrome (version 29), you can block all cookies by going to Settings and Controls and selecting Settings – Show advanced settings and Content settings and then selecting Prevent sites from sending any data under the heading Cookies.

Blocking all cookies will have a negative impact on the usability of many websites. If you block cookies, you will not be able to use many features of our website.

1. You can delete cookies that are already stored on your computer, for example:

• in Internet Explorer (version 10), you have to delete cookies manually (instructions on how to do this can be found at http://support.microsoft.com/kb/278835 );
• in Firefox (version 24), cookies can be deleted by going to the menu Tools – Options – Privacy: in the drop-down menu, select the item Use custom log settings, click Show cookies, and then – Delete all cookies;
• in Chrome (version 29), you can delete all cookies by entering the Settings and Controls menu and selecting Settings – Show advanced settings and Clear browsing data before deciding to Delete cookies and other site data and plugins.

1. Deleting cookies will have a negative impact on the usability of many websites.

M. Jurisdiction

By accessing our website, you agree that the laws of Ukraine will apply to all matters relating to using our website. Despite this, if necessary, we reserve the right to bring claims/lawsuits in any court or courts of any country of residence of one of the parties.

N. Support service

You can report any suspected security incident, ask a question or complain about a privacy compromise by writing to us at our email address: audit@kreston.ua

O. Changes to the Privacy Policy

If any changes are made to this Privacy Policy, we will notify you and post those changes here: https://kreston.ua/ . Changes and additions to the Privacy Policy take effect after they are posted. Please visit this page periodically to know what changes have been made to our Privacy Policy.