Privacy Policy

Personal data processing policy

1. 1. Terms

   This personal data processing policy has been compiled in accordance with the requirements of the Law of Ukraine "On the Protection of Personal Data" dated 01.06.2010 No. 2297-VI (hereinafter - the Law), as well as the General Data Protection Regulation (EU) 2016/679 dated 27.04. 2016 (hereinafter - the Law on Personal Data) and determines the procedure for processing personal data and measures to ensure the security of personal data used by Yuliya Shayenko (hereinafter - the Operator).

   1.1. The operator sets as its most important goal and condition for the implementation of its activity the observance of the rights and freedoms of a person and a citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.

   1.2. This policy of the Operator on the processing of personal data (hereinafter - the Policy) applies to all information that the Operator can obtain about visitors to the website https://be-better.today.

2. 2. Basic concepts used in the Policy

   2.1. Automated processing of personal data – processing of personal data using computer technology.

   2.2. Blocking of personal data – temporary suspension of processing of personal data (except when processing is necessary to clarify personal data).

   2.3. A website is a collection of graphic and informational materials, as well as computer programs and databases, which ensure their availability on the Internet at the address https://be-better.today.

   2.4. The information system of personal data is a set of personal data contained in databases, and their processing is ensured by information technologies and technical means.

   2.5. Depersonalization of personal data — actions in which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other subject of personal data.

   2.6. Processing of personal data – any action (operation) or set of actions (operations) carried out with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing) , extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

   2.7.Operator – a state body, municipal body, legal entity or natural person, which independently or jointly with other persons organizes and (or) carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, actions (operations) , which are carried out with personal data.

   2.8. Personal data – any information relating directly or indirectly to a specific or identified User of the website https://be-better.today.

   2.9.Personal data authorized by the subject of personal data for distribution - personal data, access to an unlimited range of persons to whom the subject of personal data has been granted by giving consent to the processing of personal data, authorized by the subject of personal data for distribution in the manner prescribed by the Law on personal data (hereinafter referred to as personal data, data authorized for distribution).

   2.10. A user is any visitor to the site https://be-better.today.

   2.11. Provision of personal data – actions created to disclose personal data to a certain person or a certain circle of persons.

   2.12.Dissemination of personal data – any actions aimed at disclosing personal data to an unspecified number of persons (transfer of personal data) or to familiarization with personal data of an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way.

   2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign natural person or a foreign legal entity.

   2.14. Destruction of personal data - any actions, as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) material carriers of personal data are destroyed.

3. 3. Basic rights and obligations of the Operator

   3.1.The operator has the right to:

– to receive reliable information from the subject of personal data and/or documents containing personal data;

– in case of withdrawal of consent to processing of personal data by the subject personal data The Operator has the right to continue processing personal data data without the consent of the subject of personal data if there are grounds, specified in the Personal Data Act;

• independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the prescribed duties The Law on Personal Data and adopted in accordance with it regulatory legal acts, unless otherwise provided by the Law on personal data or other federal laws.

  3.2.The operator is obliged to: – to provide the subject of personal data at his request with information regarding the processing of his personal data;

• Organize the processing of personal data in accordance with the procedure established by the current legislation of the RU;

• respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;

• to notify the authorized body for the protection of the rights of personal data subjects at the request of this body, the necessary information within 30 days from the date of receipt of such a request;

• publish or otherwise provide unrestricted access to this Policy on the processing of personal data; – take legal, organizational and technical measures to protect personal data from illegal or accidental access to them, destruction, changes, blocking, copying, provision, distribution of personal data, as well as from other illegal actions regarding personal data;

• stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;

• Perform other duties stipulated by the Law on Personal Data.

4. 4. Basic rights and obligations of subjects of personal data

   4.1.Subjects of personal data have the right to:

• To receive information related to the processing of his personal data, with the exception of cases provided for by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data belonging to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;

• to demand from the operator clarification of his personal data, their blocking or destruction in the event that personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as to take legal measures to protect his rights;

• to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;

• to withdraw consent to the processing of personal data;

• appeal to the authorized body for the protection of the rights of personal data subjects or in a court of law against the illegal actions or inaction of the Operator during the processing of his personal data;

• To exercise other rights provided for by the legislation of the RU.

  4.2. Subjects of personal data are obliged to:

• provide the Operator with reliable data about yourself;

• notify the Operator about clarification (update, change) of their personal data.

  4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another subject of personal data without the latter's consent are responsible in accordance with the legislation of the RU.

5. 5. The Operator may process such personal data of the User

   5.1. Full Name.

   5.2.E-mail address.

   5.3. Phone numbers.

   5.4. The website also collects and processes depersonalized data about visitors (including cookie files) using Internet statistics services (Yandex Metrics, Google Analytics, and others).

   5.5. Further, according to the text of the Policy, the general term Personal data is combined.

   5.6. Processing of special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.

   5.7. Processing of personal data authorized for distribution from among the special categories of personal data specified in Articles 13 and 14 GDPR of the Law on Personal Data is allowed if the prohibitions and conditions provided for in Art. 10.1 of the Personal Data Act.

   5.8. The User's consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of his personal data. At the same time, the conditions stipulated, in particular, in Art. 13 and 14 GDPR of the Personal Data Act. The requirements for the content of such consent are established by the authorized body for the protection of the rights of the subjects of personal data.

   5.8.1 Consent to the processing of personal data permitted for distribution is given by the User directly to the Operator.

   5.8.2 The operator is obliged to publish information about the conditions of processing, the presence of prohibitions and conditions for the processing of personal data permitted for distribution by an unlimited number of persons, no later than three working days from the moment of receiving the specified consent of the User.

   5.8.3 Transfer (distribution, provision, access) of personal data authorized by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This requirement should include the surname, first name, patronymic (if available), contact information (phone number, email address or postal address) of the subject of personal data, as well as a list of personal data whose processing is subject to termination. The personal data indicated in this request can be processed only by the Operator to whom it is sent.

   5.8.4 Consent to the processing of personal data permitted for distribution ceases to be effective from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.

6. 6 .Principles of personal data processing

   6.1. Processing of personal data is carried out on a legal and fair basis.

   6.2. The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data incompatible with the purpose of collecting personal data is not allowed.

   6.3.It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other.

   6.4. Only personal data that meet the purposes of their processing shall be processed.

   6.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the declared purposes of their processing is not allowed.

   6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, in necessary cases, relevance in relation to the purposes of personal data processing is ensured. The operator takes the necessary measures and/or ensures their adoption regarding the deletion or clarification of incomplete or inaccurate data

   6.7. Storage of personal data is carried out in a form that allows identification of the subject of personal data, no longer than the purpose of processing personal data requires, if the term of storage of personal data is not established by federal law, a contract to which the beneficiary is a party or a guarantor for which the subject is personal data. The processed personal data is destroyed or depersonalized after the goals of the processing have been achieved or in the event of the loss of the need to achieve these goals, if otherwise provided by federal law.

7. 7. Purposes of personal data processing

   7.1. The purpose of processing the User's personal data:

• informing the User by sending e-mails.

  7.2. The Operator also has the right to send messages to the User about new products and services, special offers and various events. The User can always refuse to receive information messages by sending a letter to the Operator at the e-mail address yshayenko@gmail.com marked "Rejection of notifications about new products and services and special offers".

  7.3. Depersonalized data of Users, which are collected with the help of Internet statistics services, are used to collect information about the actions of Users on the site, to improve the quality of the site and its content.

8. 8. Legal bases of personal data processing

   8.1. The legal grounds for processing personal data by the Operator are:

• the Law of Ukraine "On the Protection of Personal Data" dated 01.06.2010 No. 2297-VI (hereinafter - the Law), as well as the General Regulation on Data Protection (EU) 2016/679 dated 27.04.2016;

• Federal laws, other legal acts in the field of personal data protection; – consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution.

  8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://be-better.today or sent to the Operator by e-mail. By filling out the appropriate forms and/or sending personal data to the Operator, the User expresses his agreement with this Policy.

  8.3.The Operator processes depersonalized data about the User if this is allowed in the User's browser settings (including the saving of cookies and the use of JavaScript technology).

  8.4. The subject of personal data independently decides on the provision of his personal data and gives consent freely, of his own free will and in his own interest.

9. 9. Terms of personal data processing

   9.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.

   9.2. Processing of personal data is necessary to achieve the goals stipulated by the international treaty of Ukraine or the law, to perform the functions, powers and duties assigned to the operator by the legislation of Ukraine.

   9.3. The processing of personal data is necessary for the administration of justice, the execution of a court act, an act of another body or official, which are subject to execution in accordance with the legislation of the Republic of Ukraine on executive proceedings.

   9.4. The processing of personal data is necessary for the performance of a contract to which the beneficiary or guarantor is a party, to which the subject of personal data is a party, as well as for the conclusion of a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.

   9.5. The processing of personal data is necessary to realize the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the legal rights and freedoms of the subject of personal data are not violated.

   9.6. Processing of personal data is carried out, access of an unlimited number of persons to whom the subject of personal data has been provided or at his request (hereinafter - publicly available personal data).

   9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law.

10. 10. The procedure for collecting, storing, transferring and other types of personal data processing The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary for the full implementation of the requirements of current legislation in the field of personal data protection.

    10.1. The operator ensures the preservation of personal data and takes all possible measures that exclude access to personal data by unauthorized persons.

    10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of applicable legislation or in the case that the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill civil obligations - a legal contract.

    10.3. If inaccuracies are detected in personal data, the User can update them independently by sending a message to the Operator at the Operator's e-mail address yshayenko@gmail.com marked "Update personal data".

    10.4.The term of personal data processing is determined by the achievement of the purposes for which personal data were collected, unless another term is provided by the contract or current legislation. The User may at any time withdraw his consent to the processing of personal data by sending a message to the Operator via e-mail to the Operator's e-mail address yshayenko@gmail.com with the mark "Revocation of consent to the processing of personal data".

    10.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize himself with the specified documents. The operator is not responsible for the actions of third parties, including the service providers specified in this clause.

    10.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing of personal data in the state, public and other public interests, defined by the legislation of the RU.

    10.7. During the processing of personal data, the operator ensures the confidentiality of personal data.

    10.8. The operator stores personal data in a form that allows identification of the subject of personal data, no longer than the purpose of personal data processing requires, if the term of personal data storage is not established by federal law, a contract to which the beneficiary is a party or a guarantor for which the subject is object of personal data.

    10.9. The condition for the termination of personal data processing may be the achievement of the goals of personal data processing, the expiration of the consent period of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the detection of improper processing of personal data.

11. 11. List of actions carried out by the Operator with the received personal data

    11.1. The operator collects, records, systematizes, accumulates, stores, specifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.

    11.2. The operator carries out automated processing of personal data with or without receiving and/or transmitting the received information via information and telecommunication networks.

12. 12. Cross-border transfer of personal data

    12.1. At the beginning of the cross-border transfer of personal data, the operator is obliged to make sure that the foreign state, whose territory is intended to transfer personal data, ensures reliable protection of the rights of the subjects of personal data.

    12.2. Cross-border transfer of personal data on the territory of foreign countries that do not meet the above requirements can be carried out only in the case of the consent in writing of the subject of personal data to the cross-border transfer of his personal data and/or the performance of a contract to which the subject of personal data is a party .

13. 13. Confidentiality of personal data The operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.

13.1. The User can get any clarifications on issues related to the processing of his personal data by contacting the Operator via PayPa - yshayenko@gmail.com

13.2. For any document, it will be possible to change the policy of processing personal data by the Operator. Replace the policy without a line with a new version.