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PRIVACY POLICY

Before starting to use the website https://gama-consulting.com (hereinafter - the Site) and the @gamaconsulting Telegram chatbot (hereinafter - the Chatbot), please read the terms of this privacy policy (hereinafter - the Privacy Policy) and the Public Offer Agreement ( Terms of sale). The fact of using the Site/Chatbot in any way (both intentional and unintentional) is recognized as acceptance, i.e. the full and unconditional consent of any user of the Site/Chatbot (hereinafter referred to as the User) to use the Site/Chatbot under the following conditions. If the User does not accept the terms in full, he has no right to use the Site/Chatbot for any purpose.

1. Terms and definitions

The following terms are used in this Privacy Policy:

1.1. "Personal data" - any information relating directly or indirectly to the User of the Site/Chatbot (natural person, subject of personal data) identified or identified.

1.2. "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, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

1.3. "Consent of the subject of personal data" is a voluntary expression of the will of a natural person (provided that he is informed) regarding the granting of permission for the processing of his data by the formulated purpose of their processing, expressed in writing or in a form that makes it possible to conclude that consent has been given. The consent of the subject of personal data can be given when placing an Order on the Site/Chatbot by marking the consent to the processing of their data by the stated purpose of their processing, provided that such a system does not create opportunities for processing personal data until the moment marking.

2. General provisions

2.1 This Privacy Policy is a public offer of the Site/Chatbot rights holder LLC "GAMA CONSULTING", 01014, Kyiv, str. Mykola Solovtsova, bldg. 2, office 38/2, EDRPOU 44881440, (hereinafter - the Operator) and determines the procedure for processing and protecting the information of the Site/Chatbot Users.

2.2. The purpose of this Privacy Policy is to ensure adequate protection of information about Users, including their personal data, from unauthorized access and disclosure.

2.3. Relations related to the collection, storage, distribution and protection of information about Users are regulated by this Privacy Policy, other official documents of the Operator and the current legislation of Ukraine.

2.4. The User has the right to use the Site/Chatbot to study the information contained there without providing the Operator with any information about himself, and the Operator will not process the User's personal data, except for information collected automatically. The operator does not process biometric personal data and special categories of personal data.

2.5. At the same time, the Site/Chatbot presents some functions that the User will be able to use only if the Operator will process the User's personal data. In this case, the Operator will process only the data that the User provides independently, with the exception of information collected automatically.

3. Basic rights and obligations of the Operator

3.1. The operator has the right to:

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

3.1.2. to independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law of Ukraine dated 01.06.2010. No. 2297-VI "On Personal Data Protection".

3.2. The operator is obliged to:

​3.2.1. to provide the subject of Personal Data at his request with information on the processing of his Personal Data;

3.2.2. to organize the processing of Personal data by the procedure established by the legislation of Ukraine;

3.2.3. respond to appeals and requests of Personal Data subjects and their legal representatives by the requirements of the Personal Data Protection Law;

3.2.4. stop the processing of Personal Data or ensure the termination of such processing if the subject of the Personal Data withdraws consent to the processing of the Personal Data;

3.2.5. publish or otherwise provide unrestricted access to this Personal Data Processing Policy;

3.2.6. take legal, organizational, and technical measures to protect Personal Data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of Personal Data, as well as from other illegal actions regarding Personal Data;

3.2.7. stop the transfer (provision, access) of Personal Data, stop processing and destroy Personal Data in the order and cases, provided by the Law;

3.2.8. perform other duties stipulated by the Law "On the Protection of Personal Data".

4. Basic rights and obligations of the Subject of personal data

4.1. The subject of personal data has the right to:

​4.1.1. to receive information related to the processing of his personal data, with the exception of cases provided for by Ukrainian legislation. Information is provided to the subject of Personal Data by the Operator in an accessible form, and it should not contain Personal Data relating to other subjects of Personal Data, except when there are legal grounds for disclosing such Personal Data;

4.1.2. demand from the Operator clarification of his Personal data, their blocking or destruction in case the Personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, as well as take legal measures to protect his rights.

4.2. The subject of personal data is obliged to:

​4.2.1. provide the Operator with reliable data about yourself;

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

5. Terms of use of the Site/Chatbot

5.1. The Operator, acting reasonably and in good faith, believes that when using the Site, the User:

5.1.1. He has all the necessary rights that allow him to complete the survey and use the Site/Chatbot.

5.1.2. Enters reliable information about himself in the amount necessary for using the Site.

5.1.3. Having familiarized himself with this Privacy Policy, he expresses his agreement with its provisions and assumes the rights and obligations specified therein.

5.2. The Operator does not verify the authenticity of the information received (collected) about the Users, except when such verification is necessary for the purpose of the Operator fulfilling its obligations to the User.

6. Composition of information about Users

6.1. If individual services of the Site / Chatbot require the input of personal data, such personal data are stored and processed by the principles and rules of personal data processing provided for by the requirements of the Law of Ukraine dated 01.06.2010. No. 2297-VI "On the protection of personal data", which defines the procedure for processing personal data and measures to ensure the security of personal data.

6.2. Confidentiality of personal data is maintained, except in cases where the Client voluntarily provides information about himself for general access to an unlimited number of persons.

6.3. The Client's data will not be transferred to third parties, except in cases related to the implementation of current legislation or the execution of the Agreement.

6.4. GAMA CONSULTING takes the necessary organizational and technical measures to protect personal data from use not provided for in the Agreement.

6.5. By providing personal data on the Site / in the Chatbot, the Client agrees to the method of collection, use, and other management of personal data specified in the GAMA CONSULTING Privacy Policy published on the Site, which is an integral part of these Terms of Sale and the Agreement.

7. Purposes of personal data processing

7.1. The operator always processes personal data for certain purposes and only those personal data related to the achievement of such purposes. In particular, the Operator, in addition to the above-mentioned purposes, processes the personal data of Users for the following purposes:

7.1.1. performance of the functions, powers, and duties assigned to the Operator by the legislation of Ukraine;

7.1.2. fulfillment of the Operator's obligations to Users regarding the use of the Site/Chatbot;

7.1.3. providing access to the Site/Chatbot, information on the Site/Chatbot;

7.1.4. communicating with the User to send messages, surveys, and information related to the operation of the Site/Chatbot/Operator, execution of agreements, and processing of User surveys;

7.1.5. conclusion, implementation, and termination of civil legal relations;

7.1.6. improving the ease of use of the Site/Chatbot;

7.1.7. protection of the rights of the User and the Operator;

7.1.8. for the rights and legitimate interests of the Operator or third parties, including in cases provided for by the legislation of Ukraine;

7.1.9. other legal grounds provided for by the legislation of Ukraine.

7.2. The Operator processes the User's data only if they are filled in and/or sent by the User independently through special forms located on the Site/Chatbot. By filling out the appropriate forms and/or sending personal data to the Operator, the User expresses his agreement with this Policy.

7.3. 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. Storage and use of personal data

8.1. 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.

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

8.3. The term of personal data processing is unlimited.

8.4. Personal data of users is processed both with the use of automated systems and without them.

8.5. The Operator takes all necessary measures to protect the User's data from unauthorized access, modification, disclosure, or destruction. The Operator provides access to the User's data only to those persons who need this information to fulfill the purpose of the Site/Chatbot and to ensure the functioning of the Site/Chatbot, as well as other actions not prohibited by Ukrainian legislation.

8.6. Disclosure of personal data without the consent of the User or a person authorized by the User is allowed in cases defined by law and only in the interests of national security, economic well-being, and human rights, in particular, but not exclusively:

8.6.1. upon justified requests of government bodies that have the right to request and receive such data;

8.6.2. if, in GAMA CONSULTING's opinion, the User violates the terms of this Agreement and/or other contracts and agreements between GAMA CONSULTING and the User.

8.7. The User is informed and agrees that, for quality control, the Operator has the right to conduct research on the information transmitted and received by the User in a depersonalized, aggregated form, without the possibility of attributing such information directly or indirectly specified or specified User.

8.8. The operator will keep personal data for as long as necessary to achieve the purpose for which it was collected or to comply with the requirements of legislation and regulations.

9. Transfer of personal data

9.1. The terms of sale and the Agreement are regulated by the current legislation of Ukraine. All issues that are not regulated by the Terms of Sale and the Agreement, or are not regulated in full, are regulated in accordance with the legislation of Ukraine. All disputes and disagreements between the Parties must be resolved through negotiations. If the Parties do not reach an agreement, the dispute shall be considered by a competent court of Ukraine.

9.2. Terms of sale come into force from the moment of their publication on the Site.

9.3. GAMA CONSULTING may change the Terms of Sale at any time unilaterally at its sole discretion without special notice. Changes take effect from the moment the updated edition is posted on the Site.

9.4. If any provision of the Terms of Sale and/or the Agreement is held to be invalid or void, the remaining provisions shall not be affected and every other provision of the Terms of Sale and/or the Agreement shall be valid and enforceable to the fullest extent permitted by law. Any invalid or void provision of the Terms of Sale and/or the Agreement may be replaced by GAMA CONSULTING unilaterally with a provision that is valid and enforceable and most closely reflects the original intent of the provision deemed invalid or void.

9.5. The contract is concluded in electronic form. The electronic form of the Agreement is equivalent to the written form.

9.6. The Agreement is valid from the moment of its conclusion in accordance with the procedure established by these Terms of Sale and is valid until the Parties fully fulfill their obligations under the Agreement, except for cases of unilateral termination of the Agreement (cancellation of the Order) provided for by these Terms of Sale.

9.7. The contract can be terminated by agreement of the Parties. GAMA CONSULTING may terminate the Agreement (cancel the Order) unilaterally in the cases provided for in these Terms of Sale.

9.8. The contract is a complete agreement between GAMA CONSULTING and the Client. GAMA CONSULTING does not assume any conditions and obligations not specified in the Terms of Sale.

9.9. The section headings used in the Terms of Sale are provided for convenience only and should not be used in interpreting the Terms of Sale and/or the Agreement.

10. Additional conditions

10.1. The User can get any clarifications on issues related to the processing of his personal data by contacting the Operator using the feedback form on the Site.

10.2. This Privacy Policy may be changed by the Operator without any special notice, the new edition of the Privacy Policy shall enter into force from the moment of its posting on the Internet at the address specified in this paragraph, unless otherwise provided by the new edition of the Privacy Policy. The current version of the Privacy Policy can be found on the page at: https://gamaconsulting.com.ua/privacy, unless otherwise specified in the Privacy Policy.

10.3. If, for any reason, one or more terms of this Privacy Policy are held to be invalid or unenforceable, this will not affect the validity or enforceability of the other terms of the Privacy Policy.

10.4. In the event that the Operator has made any changes to this Privacy Policy, with which the User does not agree, he is obliged to stop using the Site/Chatbot.

10.5. The User grants the Operator the right to send information and advertising messages about the Operator's products, special offers and various events to the User's e-mail or mobile phone number (SMS, Telegram, WhatsApp, Viber, etc.). The User is aware that he has the right to refuse to receive messages at any time by notifying the Operator using the User's email address/mobile phone number in use or by sending to the Operator.

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