PRIVACY POLICY

General Provisions

LLC “KYIVSTAR.TECH”, EDRPOU code 39958803, address: 53 Dehtiarivska St., Kyiv, Ukraine, 03113 (hereinafter referred to as “Kyivstar.Tech”, “we”, “us”, “our”) respects your privacy and is committed to protecting it by complying with this Privacy Policy and all applicable laws and regulations, including the Law of Ukraine “On Personal Data Protection”.

We have developed this Privacy Policy to inform you about our actions regarding the collection, use, transfer, and disclosure of personal information (hereinafter referred to as “personal data”), as well as your rights that may arise in connection with the processing of such information.

For any requests or questions regarding this Privacy Policy, please use the email address response@kyivstar.tech.

Application Limits

This Privacy Policy applies to access to and use of the Internet resource https://kyivstar.tech/ (hereinafter referred to as the “Site”).

Kyivstar.Tech owns and operates the Site. The Site may contain links to digital resources owned and operated by other companies. This Privacy Policy does not apply to websites or services that are owned and operated by third parties not affiliated with us.

By using the Site, you consent to the processing of your personal data by Kyivstar.Tech. If you do not agree with this Privacy Policy, please immediately discontinue using the Site.

This Privacy Policy also applies to the processing of personal data of our business partners, (potential) customers, and (potential) suppliers, including individuals who provide services to us through third parties, such as outsourcing or recruitment companies.

This Policy explains who we are, why and how we process personal data, and, if you are the subject of any relevant personal data, what rights you have and how you can contact us. It also explains the rules applicable to the processing of personal data in business, commercial, and marketing relationships.

Definition of Terms

Personal data / personal information – all information related to you that we process. For example: name, last name, email address, phone number, etc.

Processing – all actions performed on your personal data. For example: collection, storage, updating, sending you messages, or deletion of data.

GDPR – 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 (General Data Protection Regulation).

Who We Are

We, Kyivstar.Tech, are the Controller of your personal data processed through the Site. This means that we determine the purposes, scope, and means of processing personal data.

Whose Personal Data We Process

We may process your personal data if:

• you are our current or potential customer, supplier, or an individual providing services to us through a third party;
• you are a person (or you work for such a person) to whom we would like to present or offer our services or products;
• you work for our customer or supplier, or for someone who uses our services or products that we have developed (you act on behalf of the above-mentioned person, for example, as an employee or authorized representative);
• you are interested in our activities (for example, as a member of the media); you are our employee, contractor, or are interested in cooperating with us.

Whose Personal Information We Do Not Collect – Children

• We do not knowingly request or collect personal information online from children under the age of 18, nor do we offer services to them. If we become aware that a child under 18 has provided us with personal information without parental consent, we will take steps to delete such information.

What Data We Collect?

We may process personal data obtained directly from you or from other sources. Accordingly, your personal data may be processed in the following cases:

• if you have provided us with personal data through any communication channels (for example, by sending a request or proposal by email, by phone, or via messaging on social networks);
• when entering into or performing a transaction, including where your personal data has been provided to us as a contact for the purposes of its execution;
• if we receive your personal data from other sources (for example, from a company that is our contractor or client, during events, or if someone recommends you as a potential candidate).

Information You Knowingly Provide to Us

The amount of personal data we process depends on the information necessary for a particular relationship. The personal data we process may include:

• your name;
• information about the entity you work for, your department, job responsibilities, and qualifications, as well as information regarding the services you provide to us or order from us (products you purchase);
• your address, phone number, email address, or other contact details (personal or business, depending on the nature of our relationship with you or with the entity you work for);
• personal data obtained in the course of communicating with you by phone, email, through the Site, social networks, or by other means. This also includes data we receive or that you provide to us when using the Site, providing us with goods or services, inquiring about our services or products, participating in events or surveys, contacting us to report a problem, or performing any of the above actions on behalf of the entity you work for;
• information relating to activities involving both us and you or the entity you work for (for example, details about products we have developed, or services we have provided to you or received from you or the entity you represent).

Providing information is usually voluntary, but may sometimes be necessary, for example, to enter into or perform a transaction, respond to your request, or allow us to contact you.

Information We Collect Automatically

The personal data we automatically collect from you when you use the Site includes:

• technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform;
• information about your visit, including full Uniform Resource Locators (URLs), your browsing history and navigation through the Site, your exit history from the Site (including date and time), the services you viewed or searched for, page response times, download errors, length of time spent on certain pages, information about page interaction (such as scrolling, clicks, and mouse movements), methods used to leave the page, and the phone number or social media account you used to contact us.

Cookies and Similar Technologies

We may use various technologies to collect information about your device and your use of our Site. These technologies include our own and third-party cookies, as well as web beacons. We use these technologies to ensure that you can fully experience and use our Site.

By continuing to use the Site, you consent to Kyivstar.Tech’s use of cookies. Most web browsers can be configured to accept or reject some or all of these technologies, but you may need to take additional steps to do so.

If you would like to learn how to change your browser settings, please use the “Help” menu in your browser or refer to the instructions provided by the following browsers: Internet Explorer, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile and Android browser.

Your Image

From time to time, Kyivstar.Tech may organize or participate in promotional events such as conferences, fairs, or lectures (“Events”), which you may attend as a guest, speaker, presenter, or in another capacity (“Participant”). Events are typically recorded by video or photography (sometimes by a third party acting on our behalf). As a result, your image, as well as your voice and statements (“Image”), may be recorded and used without geographical or temporal limitation, and without restriction as to the medium or number of copies, for the purpose of disseminating information about the Event and for Kyivstar.Tech’s promotional purposes.

To the extent permitted by law, participation in an Event constitutes each Participant’s consent to the free use and repeated distribution of their Image recorded during the Event. Such consent may be withdrawn at any time.

Please note that if you choose to participate in an Event, your personal data, including your Image, may be published online for an indefinite period of time in a manner that allows it to be viewed by an unlimited number of people.

What We Do with Your Personal Data: Purpose of Processing

We process your personal data for the following purposes:

• to enter into and perform a contract with you or the entity you work for;
• to provide services to customers and sell our products to clients;
• to obtain goods and services from suppliers;
• to manage our relationships with customers, clients, and suppliers;
• to advertise, promote, and provide information about our services or products;
• to administer the Site and carry out internal processes, including error correction, data analysis, testing, research, statistics collection, and surveys;
• to improve the Site to ensure that content is presented in the most effective way for you and your device;
• to ensure the security of the Site and other systems;
• to evaluate and determine the effectiveness of advertising displayed to you and others, and to deliver relevant advertising (tailored to your preferences);
• to provide advice and recommendations regarding services or products that may be of interest to you or the entity you work for, and that align with your preferences, where possible;
• to comply with applicable laws and regulatory obligations, including maintaining appropriate records and responding to legitimate requests from public authorities;
• we may also process certain personal data to fulfill other business or marketing purposes.

How We Share Your Personal Data

We may share your personal data as permitted by law:

(a) When we work together. We may share information with our parent company and affiliated companies for management, analysis, decision-making, and other business purposes. For example, we may share your information with our parent, subsidiaries, and affiliates to process orders and inquiries, and to expand and promote our products and services.

(b) When we work with service providers. We may share your information with service providers that support our operations, such as website hosting, email and postal delivery, supply of goods and services, analytics, or research. We prohibit these service providers from storing, using, or disclosing your personal data for any purpose other than performing the agreed-upon services.

© When sharing helps us ensure security and protect legitimate interests. We may disclose your information if we are required to disclose or share your personal data in order to comply with any legal obligation, or to enforce or apply our terms and other agreements with you, or to protect the rights, property, or safety of Kyivstar.Tech, our customers, employees, or others. This includes sharing information with other companies and organizations (including law enforcement authorities) to protect against fraud and prevent other risks.

(d) When you provide consent. We may share information about you with other companies if you give us permission or instruct us to share such information.

(e) When the information does not identify you. We may share your information in a way that does not identify you, including by combining it with similar information about other individuals, and sharing aggregated data for statistical analysis and other business purposes. For example, we may share information about your use of our Site.

Who We Share Your Personal Data With

Access to your personal data is limited to those who need it for the purposes described above and, as a rule, they will only have access to the portion of your data that is relevant to that specific purpose.

We may share your personal data with duly authorized employees of Kyivstar.Tech, as well as with individuals or entities that assist us in conducting our business and are bound by security and confidentiality obligations. Whenever personal data is disclosed to a third party in this manner, it will be only to the extent necessary for the performance of their duties, the execution of a contract, or for the purposes of our legitimate interests.

We may share your personal data with:

• our parent company and its affiliates;
• certain third parties, including:
  • our business partners, customers, suppliers, and contractors to perform any contract we enter into, or other transactions that arise in the ordinary course of business with you or the entity you work for;
  • our auditors, legal advisors, and other professional consultants or service providers (for example, those who assist us in communicating with contractors and clients, including sending emails on our behalf);
• with respect to data collected through our website, our advertisers and advertising networks that require such data to select and display relevant advertisements to you and other users. We do not disclose personal data that can identify you to our advertisers, but we may provide them with aggregated information about our users;
• analytics and search engine providers who assist us in improving and optimizing our Site.

Legal Grounds for Processing Your Personal Data

The grounds on which we process your personal data are as follows:

Where it is necessary to obtain your prior consent for the relevant processing in order for us to be permitted to do so (for example, certain direct marketing activities), we will obtain your consent and carry out the processing in accordance with that consent (see below for information on how to withdraw your consent to processing).

Otherwise, we will only process your personal data where such processing is necessary:

• for the performance of a contract to which you are a party, or to take steps at your request prior to entering into such a contract;
• for compliance with a legal obligation to which we are subject.

Data processing deadlines

We process personal data only for as long as is necessary for the purpose(s) for which it was collected, after which the data will be deleted or archived, unless further processing is required to comply with a legal obligation to which we are subject or for other legitimate and lawful purposes.

If necessary, the above retention periods may be extended in the event of any complaints, claims, or legal proceedings — for the duration of such proceedings and until their resolution.

International Transfer of Personal Data

Kyivstar.Tech operates in multiple countries, and therefore personal data may be processed in jurisdictions that may not provide the same level of data protection as your home country. We will transfer information to other countries in accordance with applicable privacy laws, including the GDPR, namely to countries where Kyivstar.Tech conducts business or engages service providers for the purposes set out in this Policy.

Kyivstar.Tech implements all necessary safeguards, including standard contractual clauses on data protection. We may also transfer your data to countries that are deemed to provide an adequate level of protection in accordance with the GDPR.

Security

We follow generally accepted industry standards to protect the personal information provided to us, both during data transmission and after its receipt. All personal data is stored on secure servers.

We also take reasonable security measures to protect, including, but not limited to, personnel training, internal policies and instructions, non-disclosure agreements (NDAs), limited access to premises, alternative power, encryption technologies, backups, licensed software, password controls.

You should be aware that other Internet sites to which links from our Site or from Kyivstar.Tech emails lead may have a different privacy policy that differs from this Privacy Policy. To ensure that your privacy is protected, we advise you to familiarize yourself with the privacy statements of these websites, applications, or other digital resources.

Your rights in the field of personal data

To exercise your rights, please contact us at response@kyivstar.tech.

Kyivstar.Tech respects all applicable privacy laws and your rights under current legislation. In particular, you may:

• know the sources, location, and purpose of processing your personal data, as well as the location or place of residence (or stay) of the data controller or processor, or authorize another person to obtain this information on your behalf, except as provided by law;
• obtain information about the conditions under which access to personal data is provided, including information about third parties to whom your personal data has been transferred;
• exercise your right of access to your personal data;
• receive, within thirty (30) calendar days from the date of your request (unless otherwise provided by law), a response indicating whether your personal data is being processed, and obtain the content of such personal data;
• submit a reasoned request to the data controller objecting to the processing of your personal data;
• submit a reasoned request to amend or delete your personal data to any controller or processor if such data is processed unlawfully or is inaccurate;
• exercise your right to protect your personal data from unlawful processing, accidental loss, destruction, or damage, including as a result of intentional concealment, failure to provide, or delayed provision of such data, as well as protection against the dissemination of inaccurate information or information that harms your honor, dignity, or business reputation;
• file a complaint regarding the processing of your personal data with the Commissioner of the Verkhovna Rada of Ukraine for Human Rights (for residents of Ukraine) or with the court;
• seek legal remedies in case of a violation of personal data protection laws;
• include reservations limiting the right to process your personal data when providing consent;
• withdraw your consent to the processing of personal data at any time;
• be informed of the mechanisms of automated processing of your personal data;
• exercise your right to protection against automated decision-making that has legal or similarly significant effects on you.

Changes to this Policy

We reserve the right to amend or update this Privacy Policy at any time and for any reason.

You may contact us by email at response@kyivstar.tech or by mail at 53 Dehtiarivska St., Kyiv, Ukraine, 03113.