PRIVACYhow we handle your data

Version of 1 March 2021. The original document is drawn up in Ukrainian; this translation is provided for convenience, and in case of any discrepancy the Ukrainian version prevails.

General provisions

Limited Liability Company «Kompaniya «Wintel», company number 32864300 (the «Agency»), registered and operating under the laws of Ukraine, undertakes to protect the confidentiality of the personal information (personal data) of every person who uses the services of the Winteltour.com.ua website (the «site») and can be identified in any way (the «clients»). The Agency seeks to protect the confidentiality of clients personal data in order to keep them secure and to improve the quality of service.

This privacy policy does not extend to websites reached through hyperlinks placed on the Agency site. By visiting this site and using its services, clients fully and unreservedly agree to this privacy policy. If a client does not agree with the terms of this privacy policy, the client must stop using the site.

The Agency may make changes and additions to this privacy policy from time to time and without prior notice to each client. In such a case the Agency publishes a notice on the site and sets the date on which the new version takes effect. If the client does not refuse the new version in writing within that period, this means unconditional agreement with the terms of the new version.

Categories of personal data

The personal data of clients that may be collected, stored and used include, but are not limited to:

• the surname, first name and patronymic entered by the client, passport details, place of residence, date of birth, sex, identification number, phone number, email address and other information entered by the client;
• information about the client device, including IP address, geographic location, type and version of the browser and the operating system;
• information about the client visit to the site and use of the site, including the duration of the visit, page views and navigation paths;
• information related to the client payment transactions when using the services of the site;
• any information contained in the client messages to the Agency.

Purposes of processing personal data

Personal data of clients are collected, stored and used in order to provide the full scope of the site services, to administer the site and the business, to analyse statistics, for web analytics, marketing purposes, exchange of information, advertising and communication, including:

• identifying the client in order to provide services, send messages and handle the client requests and applications;
• confirming the accuracy and completeness of the information provided by the client;
• receiving and processing the client payments;
• providing customer and technical support;
• keeping the site secure and preventing fraud.

Retention period and methods of processing

The consent of clients to the processing and storage of personal data is valid for an indefinite period, but no longer than is necessary to achieve the purposes set out in this privacy policy.

Personal data are processed by any lawful method, including in personal data information systems, with or without the use of automation.

The client consents to the transfer of personal data to the booking system and to the carrier or service provider and partners, solely for the purpose of providing the client with the services of the site. The client consents to the transfer of personal data to third parties, including but not limited to postal organisations, courier services and telecom operators, solely for the purpose of providing the client with the services of the site.

The client personal data may be passed to the relevant state authorities on the grounds and in the manner prescribed by the laws of Ukraine. The Agency takes all necessary organisational and technical measures to protect the personal data of clients and to prevent their loss, disclosure and unauthorised access.

Cookies

The site may use cookies – a text file, or a file containing a small piece of data, that is sent to the web browser and stored on the client device (computer, mobile phone and so on). Cookies may be persistent, stored until the client deletes them, or temporary, stored until the browser is closed; first-party (set by the site itself) and third-party (set by other websites).

Cookies do no harm to the client devices and are stored to provide technical support and optimised delivery of services.

The site uses Google Analytics to collect information about visits solely in order to improve the services offered. The client may prevent recognition by Google Analytics by disabling Google Analytics cookies in the browser. Google Analytics terms of use — google.com/analytics/terms.

Client rights

The Agency recognises that the personal non-property rights to personal data held by the client are inalienable and inviolable, and guarantees that such rights are observed in accordance with the law, namely:

• the right to receive information about the sources of collection and the location of ones personal data, the purpose of their processing, the location or place of residence of the owner or controller of the personal data, or the right to authorise other persons to obtain this information, except in the cases established by law;
• the right to receive information about the conditions of access to personal data, in particular information about third parties to whom the personal data are transferred;
• the right to access ones personal data;
• the right to receive an answer to a request about the processing of ones personal data and their content within thirty calendar days of the request;
• the right to a reasoned demand objecting to the processing of ones personal data, to their change or destruction, if the data are processed unlawfully or are inaccurate;
• the right to protection of ones personal data against unlawful processing and accidental loss, destruction or damage caused by deliberate concealment, failure to provide or untimely provision, and to protection against the provision of information that is inaccurate or damages the honour, dignity and business reputation of an individual;
• the right to lodge a complaint about ones personal data with the Ukrainian Parliament Commissioner for Human Rights or with a court;
• the right to legal remedies in the event of a breach of personal data protection law;
• the right to make reservations limiting the right to process ones personal data when giving consent;
• the right to withdraw consent to the processing of personal data;
• the right to be informed about the mechanism of automatic processing of personal data;
• the right to protection against an automated decision that has legal consequences for the client.

Contact information

For customer and technical support, to update or delete personal data, to obtain access, to withdraw consent to the processing of personal data, or if there are any comments, suggestions or complaints, the client may contact the Agency.

Feedback is provided by filling in the contact forms placed on the pages of Winteltour.com.ua and by email at info@winteltour.com.ua.

Postal address: 1B Sholudenka St, Kyiv, 01135.

The state authority for personal data protection in Ukraine is the Department for Personal Data Protection of the Secretariat of the Ukrainian Parliament Commissioner for Human Rights.

Postal address: 21/8 Instytutska St, Kyiv, 01008, email: hotline@ombudsman.gov.ua.