Privacy Policy

1. DEFINITION OF TERMS

1.1. Personal data base means a named set of organized personal data in electronic form and/or in the form of personal data files. In the context of this provision, the Company is the owner of personal data "Users".

1.2. Company or We means DC LINK EAST LIMITED LIABILITY COMPANY, identification code 44577747

1.3. Marketplace means an Internet service specially created for the Company's activities in the field of commerce, as well as for the Company's intermediary activities between sellers (Partners) and buyers (Users) in the field of commerce. The purpose of the Marketplace is to provide the User with the opportunity to remotely (via the Internet) access information about the Products and/or Partners, remotely (via the Internet) order the Products and receive information in this regard.

1.4. Partners means any individuals or legal entities related to the Company by contractual relations, which are granted the right of limited access to the Website in order to disseminate and provide information about the services and/or Products of the Partners, as well as to receive applications for ordering Products from users with the subsequent purchase of the Products.

1.5. Regulations means this privacy policy.

1.6. User or You means a legal entity or individual registered on the Website or a person who has visited the Website at least once, including without registration. In the process of using the Website, the User acquires the status of a personal data subject.

1.7. Products means any products (goods), works or services that are manufactured, performed or offered by the Company or Partners for the needs of the User using the Website as a Marketplace.

1.8. Website means the website https://dcac.group/ administered by the Company, including its mobile versions and applications.

1.9. Consent means any voluntary, specific, informed and unambiguous expression of the will of the User made by filing an application or taking clear positive actions to confirm consent (permission) to the processing of their personal data by the Company. The consent of the User (subject of personal data) is provided by placing (sending) an order or placing a mark (tick) in the appropriate field on the electronic page of the document on the website https://dcac.group/ or in an electronic file processed in the information system of the website https://dcac.group/ on the basis of documented software and hardware solutions.

1.10. Cookie means a piece of data in the form of one or more files generated by the Website, sent to a web browser, which is stored on the User's device. In the context of these Regulations, Cookies shall also mean any similar technologies, such as pixel tags, web beacons and empty GIFs (added to the Website).

1.11. Capitalized terms used but not defined in these Regulations shall have the meaning assigned to them by the applicable law.

2. GENERAL PROVISIONS

2.1. These Regulations have been developed in accordance with the current legislation of Ukraine and determine how the Company collects, registers, accumulates, stores, adapts, changes, updates, uses, distributes, depersonalizes, transfers and destroys your personal data on the Website. In all cases, personal data is processed in accordance with the Law of Ukraine "On Personal Data Protection".

2.3. These Regulations apply to the Website with its mobile versions, applications and other programs/software. The Website may contain links to other websites (for informational purposes only). If you follow a link to other websites, the Regulations will not apply to such websites.

The use of the Website (ordering, registration) certifies that the User has given the prior written consent of such User, in electronic form, to the distribution of advertising (information, marketing mailings that may be sent in accordance with the terms and purpose of processing personal data) using the User's telephone numbers or other network identifiers.

2.4. The purpose of personal data processing is: 

fulfilment of contractual relations, relations in the field of consumer protection, in the field of advertising and market research, exercise of the functions, powers and duties in accordance with the current legislation of Ukraine;

identification of the User as the User of the Website;

to communicate with the User, including for the provision of services, payment processing, sending, settlement operations, reporting, accounting and management accounting;

providing or offering goods or services to the User by the Company or Partners;

processing of the User's orders;

creating and implementing bonus programs, loyalty programs, promotional offers, etc.;

sending newsletters, commercial offers, informing about loyalty programs, bonus programs, information and marketing mailings (news, company promotions, promotional codes and discounts, personal recommendations, personal discounts and offers, etc.) containing information about goods and/or services, in order to send notifications about the functioning of the Website by mail, analyze the activity of Users, conduct market research, surveys, etc. by means of electronic communications (by e-mail, phone number, sending information messages and alerts in the Mobile Application);

the possibility of contacting the User through (i) sending service, legal, informational, advertising or other letters and newsletters to the User by e-mail by the Company or Partners; (ii) making calls (including automatically dialed and/or pre-recorded) from the Company and/or Partners to the User's phone number; (iii) sending SMS, Viber messages or other text messages by the Company or Partners to the User's phone number;

improving / simplifying the work with the Website;

ensuring the security of the Website;

performing other duties imposed by law on the Personal Data Owner to protect the legitimate interests of the Personal Data Owner or a third party to whom personal data is transferred.

The User may at any time refuse to use his/her data, including the receipt of information and marketing newsletters, free of charge, through the appropriate settings on the Website or by sending a request by e-mail.

2.5. Personal data is stored for as long as necessary for the purposes of personal data processing, unless otherwise provided by applicable law.

2.6. Personal data is processed with your consent. You consent to the processing of your personal data when registering or using the Website. By giving your Consent to the processing of personal data, you confirm that you are fully and completely familiarized with and agree to the terms of the Regulations and the Website Terms of Use. By giving your Consent to the processing of your personal data, you also confirm that you fully understand the purpose of the Website as a Marketplace and the purpose of processing your personal data.

2.7. The Company reserves the right to change the Regulations at any time, update it by publishing changes on the Website. If you continue to use the Website after the changes have been made, you automatically assume a legal obligation to comply with the updated terms of the Regulations. The Company shall not be liable for any damages or losses incurred by you or third parties as a result of misunderstanding or failure to understand the terms of these Regulations.

2.8. The Regulations are binding on employees of the Company and Partners who directly process and/or have access to personal data in connection with the performance of their official duties and/or contractual obligations.

3. COLLECTION AND PROCESSING OF PERSONAL DATA

3.1. You are given the opportunity to register on the Website using the registration form on the Website, and in this case you must enter the following data: name, surname, e-mail address, mobile phone, and optionally gender, date of birth, and create a password. You are also given the opportunity to place an order without registration by entering the following data: name, surname, e-mail address, mobile phone number, address (payment, delivery).

3.2. When leaving a review, the User fills in the following data: name, order number (optional), phone number (optional), e-mail address, review. When leaving feedback, the User fills in the following data: name, e-mail address, message addressed to the relevant department of the Company. For a callback, the User shall provide a mobile phone number.

3.3. When placing an order, the following information may be collected for the purpose of placing, delivering and issuing the order:

order delivery address; IP address; mobile phone number; e-mail address; first name; last name; confirmation of reaching the full age of majority (18+); date of birth; sound/voice recordings (telephone conversations) and information that became known as a result of audio recording.

3.4. When changing the functionality of the website, we may ask you to provide other data required for authorization.

3.5. The company does not collect information about racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, convictions to criminal punishment, as well as data related to health, sexual life, biometric or genetic data.

3.6. The Website is not intended for underage users. The fact of registration on the Website is a confirmation that you have reached the age of 18 and have full legal capacity and legal competence.

3.7. The Company may from time to time monitor or review the feedback/notifications distributed on the Website, however, the Company does not assume any obligation and shall not be liable for (i) the content of any messages/reviews; (ii) any error, slander, omission, falsification, advertising materials, vulgarity, profanity, disclosure of private/confidential/commercial information or (iii) for inaccurate, unreliable or out-of-date information (e.g. regarding information materials distributed by the Partners or in their interests through the Website as a Marketplace) (iv) for violation of the legislation of Ukraine committed in the process of processing and creating Personal Data Databases owned by third parties / Partners.

3.8. The Users shall be personally responsible for any information they post on the Website, communicate to other Users, as well as for any interaction with other Users, such interaction shall be at their own risk.

3.9. The Partners shall be personally responsible for any information materials posted on the Website or posted on the Website in their interests (including information about the Products in the context of paragraph 1 of Article 15 of the Law of Ukraine “On Consumer Protection”).

3.10. The Company collects the Cookies in order to make visiting the Website more convenient, track Website visits and improve the service.

3.11. Personal data is processed by the Company and/or Partners in accordance with the purpose of such processing and in accordance with these Regulations and the applicable laws of Ukraine.

3.12. Processing of personal data is carried out in full or in part in electronic form using the means of an information (automated) system. Personal data is processed in the Company's data centers (servers).

3.13. All Personal Data Databases owned by the Company are located in the data centers or at the Company's address.

4. COLLECTION AND USE OF COOKIES

4.1. The Company collects the following categories of Cookies:

Strictly necessary cookies, which are essential for the proper functioning of the Website. These Cookies include, for example, files that allow you to view secure pages of the Website and use the shopping cart. Due to their importance for the functioning of the Website, you cannot reject such Cookies. The possibility of such data processing is based on paragraph 3 of Part 1 of Article 11 of the Law of Ukraine "On Personal Data Protection" (contractual provision of services).

Performance Cookies, which collect information about the User's behavior on the Website, for example, which pages you visit most often and whether you encounter any errors. These files do not identify you personally. All collected information is collected in aggregate and, as a result, anonymously, and is also used solely to improve the performance of the Website. If you restrict the use of performance Cookies, we will not be able to use the information based on the results of your use of our Website to improve your experience of using the Website in the future.

Functionality Cookies. They are used to recognize and remember the settings that you have selected during previous visits to the website. As a result, the Website will automatically take into account your personal preferences when you use it in the future. For example, the Website will be able to remember the size of text, fonts, name/login, choice of city or settlement. The processing of such information is carried out on the basis of the User's consent and paragraph 1 of Part 1 of Article 11 of the Law of Ukraine “On Personal Data Protection”. This information may be anonymized. Often, such Cookies are placed with the consent of the Company by third parties, and the data collected by such files may be transferred to third parties for the above purpose. If you limit the use of functional Cookies, we will not be able to take into account your preferences when you visit our Website in the future.

Targeting Cookies, which are used to display advertisements on the Website that are more relevant to your interests. These files also allow you to limit the number of times the User sees an advertisement, and the Company to analyze the effectiveness of marketing activities. Thus, targeting Cookies store data about the User's visit to the Website, the pages that the User has visited, and the links that the User has followed. The processing of such information is carried out on the basis of the User's consent and paragraph 1 of Part 1 of Article 11 of the Law of Ukraine "On Personal Data Protection". This information may be anonymized. Often, such cookies are placed with the consent of the Company by third parties, and the data collected by such cookies may be transferred to third parties for the above purpose. If you restrict the use of targeting cookies, we may not be able to provide you with advertising that is relevant to your interests.

Analytics Cookies. They allow recognizing and counting the total number of visitors to the Website, as well as analyzing their behavior on the Website. This helps the Company to improve the performance of the Website, for example, to ensure that Users can easily find the information they are looking for. This information is not personal.

The Company reserves the right to collect other categories of Cookies.

4.2. The Company uses the following Cookies on the Website, including those of third-party resources:

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The Company reserves the right to collect and use other cookies not listed herein.

4.3. Most of the cookies collected by the Company are session cookies. That is, such files are temporary in nature, which is counted from the moment the browser window is opened until it is closed. After the end of the browser session, they are deleted from your electronic device.

4.4. In addition, our cookies are so-called security cookies, which allow us to protect the contents of such files during the browser session.

4.5. For prompt delivery, better display and detailed analysis of the content on the Website, the Company uses services owned by other third-party companies, such as Facebook, Google and others. The companies listed above may use cookies on your device while using the Website. Please note that the Website cannot affect the operation of cookies used by these services. All the necessary information about their use can be found in the policy on the use of relevant analytics available at the following addresses:

Google Analytics Terms of Use – https://marketingplatform.google.com/about/analytics/terms/ru/;

Facebook data use policy – https://www.facebook.com/privacy/explanation;

4.6. When using the Website, its pages may contain codes of other Internet resources and third parties, which may result in such Internet resources and third parties receiving and processing information that you have visited the Website, as well as other information transmitted by your browser. Such Internet resources may include: banner display systems; social network plug-ins (e.g., Facebook, Google+).

4.7. Some of the data from the Cookies collected by the Company may be provided to third parties who have the right to receive such data in accordance with contractual or other legal grounds (in particular, the Company may provide such data to Partners).

5. DISABLING COOKIES

5.1. By using our Website, you automatically agree to the use of Cookies and the terms of these Regulations.

5.2. You can reject the use of Cookies (this option is available in your browser settings). However, disabling the function of sending cookies may limit the ability to use the Website.

5.3. If for any reason you do not want other Internet resources whose codes are present on the Website (for example, Facebook) to access your data, you can voluntarily log out of your account or profile, clear cookies (through your browser).

6. PERSONAL DATA PROTECTION

6.1. The Company shall use system, software and hardware and communication tools that prevent loss, theft, unauthorized destruction, distortion, forgery, copying of information and meet the requirements of international and national standards.

6.2. The work related to the protection of personal data during their processing in the Company is organized by a responsible person in accordance with the law. The responsible person for the processing of personal data is the responsible employee of the Company.

6.3. Employees of the Company or Partners who directly process and/or have access to personal data in connection with the performance of their official (labor) duties or contractual obligations are obliged to comply with the requirements of the Law of Ukraine "On Personal Data Protection", these Regulations and other internal documents in the field of personal data protection.

6.4. Persons who have access to personal data, in particular, those who process it, in case of violation of the requirements of the Law of Ukraine "On Personal Data Protection" shall be liable in accordance with the legislation of Ukraine.

6.5. Employees of the Company or Partners who have access to personal data, including those who process it, are obliged to prevent disclosure in any way of personal data entrusted to them or which became known in connection with the performance of professional, official or labor duties.

6.6. The Company constantly monitors the measures taken to ensure the security of personal data. However, the Company cannot guarantee absolute protection against any threats arising outside the Company's regulation. On the Internet, electronic messages may be distorted, not always delivered promptly (or not at all). In addition, there is a possibility of infection of electronic information with viruses that exist on the Internet. By using the Website, you agree to assume the risks associated with downloading files and using information.

7. TERMS OF PERSONAL DATA TRANSFER TO THIRD PARTIES

7.1. The Company transfers your personal data (provides access to them) to third parties subject to the purposes of their processing. By giving your consent to the processing of personal data, you simultaneously consent to such transfer of your personal data. Such transfer” shall always take place in accordance with these Regulations and the Law of Ukraine "On Personal Data Protection".

7.2. Below we indicate the cases in which your personal data is transferred, but the Company reserves the right to transfer it in other cases subject to the processing purposes.

7.3. The Company transfers personal data to the Partners and delivery services related to the Company by contractual relations. Such transfer of personal data is required and carried out for the purposes of their processing specified in these Regulations, as well as for the implementation of the main functions of the Website as a Marketplace and is carried out without any additional notice.

7.4. The Company may transfer personal data to affiliates of the Company without any additional notice.

7.5. Personal data received from you may also be transferred to a third party, without additional notice of such transfer, as far as permitted by the applicable laws of Ukraine, if the Website or part of it is disposed of, transferred in any way to third parties in accordance with the procedure established by the applicable laws of Ukraine. In this case, from the moment of such disposal / transfer / granting of access, the rights and obligations defined by these Regulations shall be transferred to the successors on the basis of the relevant agreement.

7.6. Your personal data may be transferred to a third party without additional notice of such transfer in accordance with the requirements of the applicable legislation of Ukraine, a court decision or an act of a public authority. The requirements for disclosure of personal data may be challenged if the Company believes that there are legal grounds for this, but the Company does not assume such an obligation.

7.7. We may engage service providers to process your personal data for the purposes described in these Regulations. These service providers process data only on our behalf, subject to our instructions and under our control in accordance with these Regulations.

7.8. Access to personal data is not provided to a third party if the said person refuses to undertake obligations to ensure compliance with the requirements of the legislation on personal data protection or cannot ensure them. However, the Company cannot bear any responsibility for the actions of employees of the Partners, delivery services, affiliates, other third parties who directly process and/or have access to personal data in connection with the performance of their official (labor) or contractual duties. Such third parties remain responsible for the actions of their employees and bear all related risks on their own.

7.9. The Company shall not be responsible for the processing and disclosure of personal data and any other information to third parties that are not owned or controlled by the Company, by individuals who are not employees of the Company.

7.10. The Company reserves the right, subject to the requirements of the applicable legislation of Ukraine, to exchange data with public authorities in order to: prevent fraud on the Website; resolve disputes and clarify circumstances that are/may cause a violation of applicable law, as well as in case the Company detects illegal actions of Users and/or receives claims, complaints, appeals from third parties.

8. YOUR RIGHTS AS A PERSONAL DATA SUBJECT

8.1. The user as a personal data subject has the right to:

know about the sources of collection, location of their personal data, the purpose of their processing, location or place of residence (stay) of the owner or manager of personal data or give a corresponding order to obtain this information to persons authorized by him/her, except in cases established by law;

receive information about the conditions for granting access to personal data, including information about third parties to whom his/her personal data is transferred;

have access to his/her personal data;

no later than thirty calendar days from the date of receipt of the request, except as provided by law, receive a response on whether his or her personal data is processed, as well as receive the content of such personal data;

submit a reasoned request to the personal data controller with an objection to the processing of their personal data;

make a reasoned request to change or destroy their personal data by any owner and manager of personal data if this data is processed illegally or is unreliable;

protect his/her personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as protection from providing information that is inaccurate or discrediting the honor, dignity and business reputation of an individual;

file a complaint against the processing of his/her personal data to the Commissioner or to the court;

apply legal remedies in case of violation of the legislation on personal data protection;

make reservations about the restriction of the right to process their personal data when providing consent;

withdraw consent to the processing of personal data;

know the mechanism of automatic processing of personal data;

to be protected from an automated decision that has legal consequences for him/her.

8.2. You can update, correct your registration information at any time through the account management function available on the Website. You can also address this request to the Company in a letter to the Company's e-mail or address (indicated below). In the letter, you must specify what information you want to correct or update, and the Company will provide such update or correction.

8.3. If you want your data to be deleted, you can delete your user account, withdraw your Consent or object to the processing of your personal data. In order to withdraw your Consent or object to the processing of your personal data, you need to contact the Company with a letter to the Company's e-mail or address (indicated below) and the Company will delete the collected personal data in a timely manner.

8.4. In some cases, the Company is obliged to store data to comply with legal obligations established by law. In this case, we guarantee that your data will be used only to comply with legal obligations and not for other purposes.

9. PROCEDURE FOR DEALING WITH REQUESTS

9.1. As a subject of personal data, you have the right to receive any information about yourself from any subject of relations related to personal data, without specifying the purpose of the request, except in cases established by law.

9.2. The personal data subject's access to data about himself/herself is free of charge.

9.3. The personal data subject submits a request for access (hereinafter referred to as the request) to personal data to the Company.

9.4. The request shall include:

Surname, name and patronymic, place of residence (location) and details of the identity document of the personal data subject;

other information allowing to verify the identity of the personal data subject;

information about the Personal Data Base in relation to which the request is made, information about the owner or manager of this database;

a list of requested personal data.

9.5. The period for studying the request in order to satisfy it may not exceed ten business days from the date of its receipt.

9.6. During this period, the Company shall inform the personal data subject whether the request will be satisfied or the relevant personal data will not be provided, indicating the grounds under the relevant regulatory legal act.

9.7. The request shall be satisfied within thirty calendar days from the date of its receipt, unless otherwise provided by law.

10. CONTACT INFORMATION

10.1. If you have any questions or complaints, recommendations or comments regarding the protection of personal data, these Regulations, you can send a letter to the Company's e-mail or postal address.

10.2. Contact details of the Company: 

DC LINK EAST LIMITED LIABILITY COMPANY, identification code 44577747

Tel.: +38 (098) 219-81-20

E-mail: dclink.east@gmail.com

Location (correspondence address): 43, Saltivske Shosse, Kharkiv, Kharkiv region, 61038

Consent to the processing of personal data

I confirm that I have read and understood the Privacy Policy posted on the Website, confirm my agreement with all provisions of the Privacy Policy and the Website Terms of Use, and also confirm that I have been duly notified of the owner of my personal data, the composition and content of the collected personal data, my rights as a personal data subject as defined by the Law of Ukraine "On Personal Data Protection", the purpose of collecting data about me and the persons to whom my personal data may be transferred; I understand my rights under the Law of Ukraine "On Personal Data Protection".

The list of rights of the personal data subject defined in Part 2 of Article 8 of the Law of Ukraine "On Personal Data Protection"

The subject of personal data is entitled to:

To know about the sources of collection, location of their personal data, the purpose of their processing, location or place of residence (stay) of the owner or manager of personal data or give a corresponding order to obtain this information to persons authorized by him/her, except in cases established by law;

To receive information about the conditions for granting access to personal data, including information about third parties to whom his/her personal data is transferred;

To have access to their personal data;

To receive, no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, a response on whether his or her personal data is processed, as well as to receive the content of such personal data;

To submit a reasoned request to the personal data controller with an objection to the processing of their personal data;

To submit a reasoned request to change or destroy their personal data by any owner and manager of personal data, if this data is processed illegally or is unreliable;

To protection of their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protection from providing information that is inaccurate or discrediting the honor, dignity and business reputation of an individual;

To file complaints against the processing of their personal data to the Commissioner or to the court;

To apply legal remedies in case of violation of the legislation on personal data protection;

To make reservations about the restriction of the right to process their personal data when giving consent;

To withdraw consent to the processing of personal data;

To know the mechanism of automatic processing of personal data;

To be protected from an automated decision that has legal consequences for him/her.