Date of last update: 03.03.2025
This Privacy and Personal Data Protection Policy (hereinafter referred to as the "Policy") defines the procedure for processing and protecting personal data of users of the website https://todo.ltd (hereinafter referred to as the "Site"), owned by TODO LIMITED LIABILITY COMPANY (TODO LLC).
We respect the confidentiality of your personal data and strive to ensure its protection in accordance with the requirements of the current legislation of Ukraine, in particular the Law of Ukraine "On Personal Data Protection".
1. DEFINITION OF TERMS
- Personal data owner (Owner): TUDU LIMITED LIABILITY COMPANY, EDRPOU code 40278741, address: Crystal Business Center, 21A, Centralna St., Kyiv, 02132, Office 53.
- Personal data: information or a set of information about an individual who is identified or can be specifically identified (e.g., name, surname, phone number, e-mail address, IP address, etc.).
- User: any individual who visits the Website and/or interacts with its functionality, in particular by filling out contact forms.
- Processing of personal data: any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, updating, use and dissemination (distribution, sale, transfer), depersonalization, destruction of personal data, including with the use of information (automated) systems.
- Consent of the personal data subject: voluntary expression of will of an individual (subject to his/her awareness) to grant permission to process his/her personal data in accordance with the formulated purpose of their processing, expressed in writing or in a form that allows to conclude that consent has been granted (for example, by marking the form on the Website).
2. WHAT PERSONAL DATA WE COLLECT
We may collect the following categories of personal data:
- Data that you provide to us directly:
- Name, surname, patronymic;
- Contact phone number;
- Email address (E-mail);
- Company name, position;
- Any other information that you voluntarily provide to us through the contact forms on the Site (for example, the name of the company, the content of your request or message).
- Data collected automatically when using the Website:
- IP address;
- Browser type and version;
- The type of device and its operating system;
- Data on visits to the Website (pages you have viewed, time spent on the Website, source of referral, etc;)
- Cookies and similar tracking technologies (for more information, see the section "Use of Cookies").
3. PURPOSES OF COLLECTION AND USE OF PERSONAL DATA
We collect and use your personal data for the following purposes:
- Responding to your inquiries, requests and providing you with information about our services;
- Processing your orders and providing you with the services you order;
- Marketing and advertising activities, informing you about new services, special offers, promotions (subject to your prior consent, if required by law);
- Conducting analytics to improve the operation of the Site, the quality of our services and user experience;
- Ensuring the security of the Website and preventing fraud;
- Compliance with the requirements of the current legislation of Ukraine.
4. LEGAL GROUNDS FOR PROCESSING PERSONAL DATA
We process your personal data on the following legal grounds:
- Your consent to the processing of personal data provided by filling out and submitting forms on the Site or in another explicit way;
- Necessity to fulfill an agreement to which you are a party or to take measures preceding the conclusion of an agreement at your request;
- Our legitimate interest (for example, to analyze the Website, ensure its security, for marketing purposes in cases permitted by law), provided that such interest does not override your rights and freedoms;
- The need to fulfill our legal obligations under Ukrainian law.
5. TRANSFER OF PERSONAL DATA TO THIRD PARTIES
We do not share your personal data with third parties, except in the following cases:
- If it is necessary to achieve the goals set out in Section 3 of this Policy (for example, engaging hosting service providers, analytical services, marketing platforms that act on our instructions and are obliged to maintain confidentiality);
- With your explicit consent;
- At the request of the authorized state bodies of Ukraine in cases stipulated by the applicable law.
We do not sell or rent your personal data. If we engage third parties (data processors) to process your personal data on our behalf, we ensure that they comply with appropriate security and confidentiality measures.
6. THE PERIOD OF STORAGE OF PERSONAL DATA
We store your personal data for the period necessary to achieve the purposes for which it was collected or for the period established by the current legislation of Ukraine. After this period, your personal data will be deleted or anonymized.
7. RIGHTS OF USERS (SUBJECTS OF PERSONAL DATA)
As a personal data subject, you have the following rights:
- The right of access: 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.
- The right to receive information: receive information about the conditions for granting access to personal data, including information about third parties to whom your personal data is transferred.
- The right to access your personal data: to receive a response on whether your personal data is processed no later than thirty calendar days from the date of receipt of the request, except as provided by law, and to receive the content of such personal data.
- The right to rectification: submit a reasoned request to the personal data controller to object to the processing of their personal data or to demand the modification or destruction of their personal data if such data is processed illegally or is unreliable.
- The right to erasure ("right to be forgotten"): request the deletion of your personal data in cases provided for by law. You can exercise this right by contacting us at the following email address: [email protected].
- The right to restrict processing: request restriction of processing of your personal data in certain cases.
- The right to object to processing: object to the processing of your personal data, in particular for direct marketing purposes.
- The right to withdraw consent: withdraw your consent to the processing of personal data at any time. The withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
- The right to defense: to protect 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 protect against the provision of information that is inaccurate or discrediting the honor, dignity and business reputation of an individual.
- The right to file a complaint: file complaints about the processing of their personal data to the Ukrainian Parliament Commissioner for Human Rights or to the court.
To exercise your rights, you can contact us at the contact details specified in Section 11 of this Policy.
8. PROTECTION OF PERSONAL DATA
We take appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, loss or destruction. These measures include, but are not limited to:
- Restricting access to personal data to authorized employees only;
- Use of secure servers and data encryption (where appropriate);
- Regular updates of software and security systems.
9. USE OF COOKIES
Our Site may use cookies and other tracking technologies to improve the user experience, analyze the use of the Site and for marketing purposes. Cookies are small text files that are stored on your device.
You can manage your cookie settings through your browser settings. Disabling certain cookies may affect the functionality of the Site. We recommend that you read our separate Cookie Policy (if any) or get more information about which cookies are used on the Site.
10. CHANGES TO THE PRIVACY POLICY
We may update this Policy from time to time. In case of significant changes, we will notify you by posting an updated version of the Policy on the Website and/or by other available means. We recommend that you regularly review this Policy to be aware of any changes. The date of the last update will be indicated at the beginning of the Policy.
11. CONTACT INFORMATION
If you have any questions about this Policy or the processing of your personal data, please contact us:
TUDU LIMITED LIABILITY COMPANY
EDRPOU code: 40278741
Office address: Crystal Business Center, 21A Tsentralna St., Kyiv, 02132, Office 53
Work schedule: Mon - Fri from 9:00 to 18:00
E-mail (for privacy issues and data deletion): [email protected]
Phone: +38 073 871 53 13