WELLCITY LIMITED LIABILITY COMPANY, registered under the legislation of Ukraine, reg. number: 38698787, legal address: Ukraine, 04073, Kyiv, Vyshgorodska Street, bldg. 4, Office 2 (hereinafter “We”, “Wellcity”), highly respects personal data protection and seeks to process personal data in a lawful, fair and transparent manner.
We ask You to read this Policy carefully, as Your further actions on the Website will mean that You have read and understand the content of this Policy.
1.Information about personal data owner (controller)
1.1.Wellcity determines the purpose of personal data processing, the scope of these data, and procedures for their processing. Therefore, according to the Law of Ukraine “On Protection of Personal Data” Wellcity is the owner of personal data processed during Your use of the Website.
1.2.Wellcity may also carry out unsystematic processing of personal data of individuals within the European Economic Area. In this case, Wellcity acts as a controller in the sense of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the “General Data Protection Regulation” or the “GDPR”)
1.3.If You have any questions regarding the processing of Your personal data, You can always contact us via e-mail email@example.com or send a letter to Ukraine, 02000, Kyiv, Kurenivska Street, 21.
2.Legislation applicable to the processing of personal data
2.1.The Law of Ukraine “On Protection of Personal Data” applies to the processing of personal data in connection with the use of the Website except as provided in this Policy.
2.2.In case of the processing of personal data of individuals within the European Economic Area, the GDPR and local legislation of the host country are applicable.
3.1.In the course of Your use of the Website, we collect and process various categories of personal data. At the same time, we adhere to the principle of data minimization and collect only those personal data that are necessary for the purposes specified in this Policy.
3.2.When You access and use the Website, we automatically collect the following personal data from Your browser (hereinafter “Automatically Collected Data”):
a.IP address, information about Your location, information about Your mobile operator or Internet provider;
b.data related to Your device: its operating system, browser type, and version, screen resolution, set time zone, language settings, device type: its model and manufacturer (if applicable);
c.information about Your browsing session and any interaction with the Website interface (for example, the number of pages You visited, the number of pages You clicked);
d.information about the source from which You visited the Website.
3.3.When You leave a request on the relevant page of the Website, we collect the following personal data (hereinafter “Data provided by You personally”):
b.The name of Your company;
In addition to this information, You may also voluntarily provide us with other personal data. In any case, we promise to handle them properly.
3.4.When You leave a request on the relevant page of the Website and specify the name of Your company, we conduct an independent search and analysis of information about Your company and You from open sources (hereinafter “Search Data”). These data may include:
a.Company name, country of registration, location, company size, structure, etc.;
b.Industry, the sphere of activity, etc.;
c.Information about You, posted by You on the pages of social networks, as well as available by search on the Internet, in particular, regarding Your position, work experience, career, etc.
3.5.To ensure Your rights as a personal data subject in accordance with the Law of Ukraine “On Protection of Personal Data” and the GDPR we can also collect the following personal data (hereinafter “Data to ensure Your legal claim”):
a.Your full name;
c.Place of residence (stay);
d.Details of the document proving Your identity.
3.6.To follow the latest updates and news on the Website, You can sign up for a free subscription and we will send the news and updates to Your email address. To do this, we collect the following personal data (hereinafter “Subscription Data”):
You can opt out of receiving such a newsletter at any time by notifying us at firstname.lastname@example.org.
4.Purposes and lawful bases for personal data processing
|The purpose of processing||The scope of personal data||The lawful basis for processing|
|Providing You with access to the Website functionality||Automatically Collected Data Cookie data||Wellcity’s legitimate interest is that You have access to the Website and are able to use its functionality completely (Article 11 (1)(6) of the Law of Ukraine “On Protection of Personal Data”; Article 6 (1)(f) of the GDPR).|
|Maintaining the correct operation and ensuring the security of the Website||Automatically Collected Data Cookie data||Wellcity’s legitimate interest is in ensuring the proper functioning of the Website, protection against cyberattacks and any other external threats (Article 11 (1)(6) of the Law of Ukraine “On Protection of Personal Data”; Article 6 (1)(f) of the GDPR).|
|Improving the performance of the Website||Automatically Collected Data Cookie data||Wellcity’s legitimate interest is to analyze the effectiveness of Your interaction with the Website and provide it to You in the best possible way (Article 11 (1)(6) of the Law of Ukraine “On Protection of Personal Data”; Article 6 (1)(f) of the GDPR).|
|Communication with You in course of Your use of the Website||Data provided by You personally||Wellcity’s legitimate interest is in communicating with Website Users and the public (Article 11 (1)(6) of the Law of Ukraine “On Protection of Personal Data”; Article 6 (1)(f) of the GDPR).|
|Communicate with You to establish a business relationship with the company You represent||Data provided by You personally||Wellcity has a legitimate interest in communicating with You to establish a business relationship with the company You represent (Article 11 (1)(6) of the Law of Ukraine “On Protection of Personal Data”; Article 6 (1)(f) of the GDPR).|
|Preliminary analysis of information about Your company and its activities||Data provided by You personally Search data||Wellcity’s legitimate interest is to have preliminary information about Your company and to understand the context and prospects of our further communication (Article 11 (1)(6) of the Law of Ukraine “On Protection of Personal Data”; Article 6 (1)(f) of the GDPR).|
|Ensuring Your rights as a personal data subject||Data to ensure Your legal claim||Compliance with the requirements of the legislation on the ensuring of the rights of personal data subjects (Article 11 (1)(5) of the Law of Ukraine “On Protection of Personal Data”; Article 6 (1)(c) of the GDPR).|
|Send You updates and news on the Website based on Your subscription||Subscription data||Consent of the personal data subject (Article 11 (1)(1) of the Law of Ukraine “On Protection of Personal Data”; Article 6 (1)(a) of the GDPR).|
5.1.We undertake to store Your personal data no longer than it is necessary to achieve the purposes stipulated in this Policy.
5.2.We store Automatically Collected Data for 14 (fourteen) months from Your last visit to the Website.
5.3.We store Data provided by You personally and Search Data for as long as we communicate with You. When our communication with You is terminated, we will be sure to delete this data. In the event of any dispute with You, we will store Your personal information for as long as necessary to resolve the dispute.
5.4.We store the Data to ensure Your legal claim for the period necessary to exercise Your rights as a personal data subject.
5.5.We store Your Subscription Data until You unsubscribe.
6.Rights of personal data subjects
6.1.f You are on the territory of Ukraine, we guarantee You the rights of the personal data subject provided for in Article 8 of the Law of Ukraine “On Protection of Personal Data”.
6.2.If You are in the territory European Economic Area, we guarantee You the following rights:
a.The right to be informed (Articles 13, 14 of the GDPR);
b.The right to access data (Article 15 of the GDPR);
c.The right to rectification (Article 16 of the GDPR);
d.The right to erasure (Article 17 of the GDPR);
e.The right to restriction of processing (Article 18 of the GDPR);
f.Right to object (Article 21 of the GDPR);
g.The right to data portability (Article 20 of the GDPR);
h.Automated individual decision-making and profiling rights (Article 22 GDPR);
i.The right to lodge a complaint with the supervisory authority (Article 77 of the GDPR).
6.3.We ask You to carefully read Your rights in accordance with the law applicable to the processing.
6.4.To exercise any of Your rights, contact us via email@example.com or send a letter to Ukraine, 02000, Kyiv, Kurenivska Street, 21.
7.Protection of children’s personal data
7.1.Our Website is not intended for use by children, and therefore we do not collect or process, at least intentionally, the personal data of individuals under 18 (eighteen) years.
8.Transfer of personal data
8.1.To ensure the proper operation of the Website, we may transfer Your personal data to third parties, including:
a.Our contractors, subcontractors, external consultants. We may engage third parties to service the Website and, accordingly, transfer Your personal data to them. We guarantee that these persons have a contractual obligation with us to process Your personal data in accordance with this Policy and the applicable law.
b.Website Hosting Providers. We use the services of hosting providers and host our Website on their server. In this regard, they may have access to Your personal data, but in encrypted form.
c.Analytics service providers. We may also use the services of companies that analyze the operation of the Website, Your interaction with it and help us to monitor and prevent any external threats to the Website. We currently use the services of the following providers:
9.1.Cookies are small files that are created when You are using the website and stored on Your electronic device (computer or smartphone). Cookies do not allow You to identify You as an individual, but only Your device using special tags.
9.2.We use the following cookies:
|Name of Cookie||Type of Cookie||Storage time||Purpose of use|
|Security Cookie||1 month||This Cookie helps to protect the Website from bots and other external threats.|
|_gid||Analytics Cookies||1 day||Google Analytics uses these cookies in order to analyze how Users interact with the Website. With this information, we can improve the Website.|
|cookies_settings||Functionality Cookie||1 month||This Cookie stores Your Cookie settings on the Website.|
|Functionality Cookies||1 month||These Cookies are used to maintain the operation of the subscription window on the Website.|
10.Changes to this Policy
10.1.If necessary, from time to time, we may make changes, corrections, additions to this Policy. The current version of the Policy will be posted on the Website, so please follow all updates.
Edited on April 9, 2021