1. General provisions

This policy of personal data processing is drawn up in accordance with the requirements of Articles 6, 8, 10, 11 of the Law of Ukraine “On personal data protection” and determines the order of personal data processing and measures to ensure the security of personal data of Web-agency ProGamma (hereinafter – the Operator).

1.1 The Operator sets as its most important goal and condition of its activity the observance of human and citizen’s rights and freedoms in the processing of personal data, including the protection of the rights to privacy, personal and family secrecy.

1.2 This Operator’s policy on personal data processing (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website http://progamma.agency.

2 Basic concepts used in the Privacy Policy

2.1 Automated processing of personal data – processing of personal data by means of computer equipment;

2.2 Blocking of personal data – temporary cessation of processing of personal data (except for cases when processing is necessary to clarify personal data);

2.3 Website – a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address http://progamma.agency;

2.4 Personal data information system – a set of personal data contained in databases and information technologies and technical means ensuring their processing;

2.5 Personal data depersonalization – actions as a result of which it is impossible to determine, without using additional information, whether personal data belong to a particular User or other subject of personal data;

2.6 Processing of personal data – any action (operation) or set of actions (operations) performed with the use of automation means or without the use of such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;

2.7 Operator – a state authority, municipal authority, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out processing of personal data, as well as determining the purposes of personal data processing, composition of personal data subject to processing, actions (operations) performed with personal data;

2.8 Personal data – any information relating directly or indirectly to a certain or defined User of the website http://progamma.agency;

2.9 User – any visitor of the website http://progamma.agency;

2.10 Provision of personal data – actions aimed at disclosure of personal data to a certain person or a certain circle of persons;

2.11 Dissemination of personal data – any actions aimed at disclosure of personal data to an indefinite number of persons (transfer of personal data) or at familiarization with personal data of an unlimited number of persons, including disclosure of personal data in mass media, placement in information and telecommunication networks or providing access to personal data in any other way;

2.12 Trans-border transfer of personal data – transfer of personal data to the territory of a foreign country to a foreign government authority, a foreign individual or a foreign legal entity;

2.13 Destruction of personal data – any actions, as a result of which personal data are irretrievably destroyed with the impossibility of further recovery of the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed.

3 The Operator may process the following personal data of the User

  • Surname, first name, patronymic;
  • E-mail address;
  • Telephone numbers;
  • cookies;
  • The site also collects and processes anonymized data about visitors (including cookies) using Internet statistics services (Yandex Metrics and Google Analytics and others).

The aforementioned data is hereinafter referred to as Personal Data.

4. Purposes of personal data processing

4.1 The purpose of processing the User’s personal data is to inform the User by sending e-mails; to conclude, execute and terminate civil law contracts; to provide the User with access to services, information and/or materials contained on the website.

4.2 The Operator is also entitled to send the User notifications about new products and services, special offers and various events. The User can always opt out of receiving informational messages by sending an e-mail to the Operator at info@progamma.agency with the note “Opt-out of notifications about new products and services and special offers”.

4.3 The anonymized data of Users collected by means of Internet statistics services are used to collect information about Users’ actions on the website, to improve the quality of the website and its content.

5. Legal basis for processing personal data

5.1 The Operator processes the User’s personal data only if it is filled in and/or sent by the User through special forms located on the website http://progamma.agency. By filling in the relevant forms and/or sending his/her personal data to the Operator, the User expresses his/her consent to this Policy.

5.2 The Operator processes anonymized data about the User if it is allowed in the User’s browser settings (cookies and JavaScript technology enabled).

6. Procedure for collection, storage, transfer and other types of personal data processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary for full compliance with the requirements of the current legislation in the field of personal data protection.

6.1 The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

6.2 The User’s personal data will never, under no circumstances, be transferred to third parties, except for cases related to the execution of the current legislation.

6.3 In case of identification of inaccuracies in personal data, the User may update them independently by sending a notice to the Operator to the Operator’s e-mail address info@progamma.agency with the remark “Personal Data Update”.

6.4 The period of personal data processing is unlimited. The User may withdraw his/her consent to the processing of personal data at any time by sending a notice to the Operator by e-mail to the Operator’s e-mail address info@progamma.agency with the note “Withdrawal of consent to the processing of personal data”.

7. Trans-border transfer of personal data

7.1 Prior to the commencement of trans-border transfer of personal data, the Operator is obliged to ensure that the foreign state, to the territory of which the transfer of personal data is supposed to be carried out, provides reliable protection of the rights of personal data subjects.

7.2 Transborder transfer of personal data to the territory of foreign states that do not meet the above requirements may be carried out only in case of written consent of the personal data subject to transborder transfer of his/her personal data and/or fulfillment of the agreement to which the personal data subject is a party.

8. Final provisions

8.1 The User may obtain any clarifications on matters of interest regarding the processing of his/her personal data by contacting the Operator via e-mail at info@progamma.agency.

8.2 This document will reflect any changes to the Operator’s personal data processing policy. The Policy is valid indefinitely until it is replaced by a new version.

The current version of the Policy is freely available on the Internet at https://progamma.agency/privacy-policy/.