Privacy Policy

General Provisions

1.1. This Privacy and Personal Data Protection Policy of the Online.ua website (hereinafter referred to as the “Policy”) defines the general rules for the collection, receipt, storage, use, disclosure, de-identification, deletion and other processing of personal data and technical information during access to the Online.ua website, all of its pages, subdomains, archives, technical interfaces, APIs, RSS feeds, feedback forms, files, software modules, databases, materials and other functional elements placed on the Website or accessible through it.

1.2. For the purposes of this Policy:

1.2.1. “Website” means a set of digital resources, materials, functions, pages, subdomains, technical interfaces and related informational elements available under the Online.ua designation.

1.2.2. “Website Administration” means a neutral functional designation of the person or persons who, in whole or in part, provide technical, organizational, legal, editorial, informational or other support for the Website.

1.2.3. “Company” means legal entity or another person duly identified on the Website as the controller, owner or administrator of the relevant digital resource, unless otherwise expressly stated on the Website.

1.2.4. “User” means any individual, legal entity, representative of a legal entity, automated system, search engine, AI agent, bot, crawler, scraper, aggregator, archiver or other entity that directly or indirectly accesses the Website.

1.2.5. “Personal Data Subject” means an individual whose personal data is processed during the use of the Website or interaction with the Website Administration.

1.2.6. “Personal Data” means information or a set of information about an individual who is identified or can be specifically identified.

1.2.7. “Technical Data” means data that is automatically generated or transmitted when accessing the Website, including, in particular, IP address, browser data, device data, operating system data, browser language, timestamps, URL requests, referrer, user-agent, approximate location based on technical attributes, cookies, access log data, page interaction data and other similar technical parameters.

1.3. This Policy is an integral part of the Terms of Use of the Online.ua Website. Terms used in this Policy and not defined separately shall have the meanings given to them in the Terms of Use of the Website.

1.4. This Policy applies to personal data and technical information processed in connection with the operation of the Website, ensuring its security, analytics, communication with Users, consideration of requests, and protection of the rights and legitimate interests of the Website Administration, Users and third parties.

1.5. This Policy does not regulate the processing of personal data on external websites, in third-party applications, social networks, messengers, advertising systems, search engines, AI services or other third-party resources, even if links to such resources are placed on the Website.

1.6. By using the Website, the User confirms that they have read this Policy. If the User does not agree with this Policy in whole or in part, the User must stop using the Website.

Personal Data Controller and Contact Channel

2.1. Within the scope of personal data processing related to the operation of the Website, the personal data controller is the Company or another person expressly identified on the Website as the personal data controller in relation to the relevant functional element.

2.2. The Website Administration may engage personal data processors, technical contractors, hosting providers, providers of analytics, security, advertising, CDN, communication, legal and other auxiliary solutions, if this is necessary for the operation of the Website, ensuring its security, fulfilling legal obligations or protecting rights and legitimate interests.

2.3. Contact channel for personal data matters: [email protected].

2.4. The Website Administration may decline to respond on the merits to anonymous, incomplete, technically incorrect, repeated, manifestly unfounded, abusive requests or requests that do not make it possible to identify the applicant or the subject matter of the request, unless otherwise expressly provided by law.

Data That May Be Processed

3.1. When accessing the Website, the Website Administration may process the following categories of data:

3.1.1. technical access data: IP address, date and time of access, URL request, page address, referrer, user-agent, browser type and version, operating system, device type, browser language, error data, technical logs, session data and other similar parameters;

3.1.2. cookies and similar technology data: identifiers of cookies, local storage, pixels, tags, SDKs, analytics scripts, advertising or security tools;

3.1.3. Website usage data: pages viewed, viewing duration, page depth, transitions, interaction with page elements, general statistical indicators and other analytical data;

3.1.4. data voluntarily provided by the User: first name, last name, email address, telephone number, organization name, position, message content, attachments, documents, links or other information that the User independently sends through contact forms, email or other available communication channels;

3.1.5. data related to requests, complaints and notices of rights violations: applicant’s contact details, content of the request, documents, evidence, information about the disputed material, legal basis of the claim, correspondence and other data necessary for considering the request;

3.1.6. data necessary for Website security: data on suspicious activity, attempted unauthorized access, automated requests, spam, phishing, malicious code, violations of technical restrictions, circumvention of robots.txt, rate limits, anti-bot tools or other Website instructions;

3.1.7. data obtained from publicly available sources or from third parties, if necessary for verifying requests, protecting rights, responding to violations, fulfilling legal obligations or ensuring Website security.

3.2. The Website Administration does not aim to collect special categories of personal data, including data on racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties or trade unions, criminal convictions, as well as data concerning health, sex life, biometric or genetic data, except where such data has been clearly made public by the Personal Data Subject, voluntarily provided by them in a request, or where its processing is expressly permitted or required by law.

3.3. The User may not transmit personal data of third parties through the Website without a proper legal basis. If the User transmits such data, the User is solely responsible for having a legal basis, for the accuracy of the data and for the lawfulness of such transmission.

3.4. If the Website does not provide for the creation of accounts, personal dashboards or mailboxes, the Website Administration does not collect logins, passwords, mailbox contents or other registration data for such functions, except where the relevant functional element is expressly introduced and accompanied by separate rules.

Purposes of Data Processing

4.1. Personal data and technical data may be processed for the following purposes:

4.1.1. providing access to the Website and its main functional elements;

4.1.2. technical support for the operation of the Website, servers, databases, APIs, RSS feeds, feedback forms, archives and related tools;

4.1.3. ensuring information security, protection against cyberattacks, spam, phishing, malicious code, unauthorized access, automated abuse and excessive load;

4.1.4. detecting, preventing, recording and investigating violations of the Terms of Use of the Website, this Policy, technical instructions or legislation;

4.1.5. Website analytics, measuring traffic, improving structure, performance, navigation, accessibility and the quality of technical solutions;

4.1.6. processing requests, complaints, notices of rights violations, personal data requests and contact messages;

4.1.7. complying with legal requirements, court decisions, requests from competent authorities and other mandatory requirements;

4.1.8. protecting the rights, legitimate interests, security and reputation of the Website Administration, Users, right holders, advertisers, partners and third parties;

4.1.9. storing evidence, maintaining internal logs, preparing a legal position, resolving disputes and responding to claims;

4.1.10. displaying, configuring, limiting, measuring the effectiveness of or auditing advertising, partner, sponsored, promotional or other commercial materials, if such materials are placed on the Website;

4.1.11. fulfilling other lawful purposes directly related to the operation of the Website as an informational resource.

Legal Grounds for Processing

5.1. Personal data is processed on the grounds provided for by the legislation of Ukraine, including:

5.1.1. the consent of the Personal Data Subject, where such consent is required for the relevant processing;

5.1.2. permission to process personal data granted by law exclusively for the exercise of powers or performance of duties by the Website Administration;

5.1.3. the need to process data in order to consider a request, inquiry, complaint or notice submitted by the Personal Data Subject;

5.1.4. the need to process data in order to comply with legal requirements, a court decision or a mandatory request from a competent authority;

5.1.5. the need to process data in order to protect the rights and legitimate interests of the Website Administration, Users or third parties, provided that such processing does not contradict the law;

5.1.6. the need to process data in order to ensure Website security, prevent abuse, record violations and protect the information infrastructure;

5.1.7. other grounds provided for by the current legislation of Ukraine.

5.2. Where processing is carried out on the basis of consent, the Personal Data Subject has the right to withdraw such consent. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal and does not prevent processing that may be carried out on another lawful basis.

Cookies, Pixels and Similar Technologies

6.1. The Website may use cookies, pixels, tags, local storage, access logs, analytics scripts, anti-bot tools and other similar technologies.

6.2. Cookies are small files or data fragments that may be stored on the User’s device or read from it during a visit to the Website.

6.3. Pixels, tags and similar technologies may be used to measure views, conduct technical analytics, verify the effectiveness of materials, ensure security, protect against abuse, and configure or measure advertising.

6.4. The Website may use the following categories of cookies and similar technologies:

6.4.1. necessary technical cookies — to ensure the operation of the Website, store technical settings, route requests, ensure security, balance load and protect against abuse;

6.4.2. analytical cookies — to collect aggregated statistics on Website use, traffic, interaction with pages, technical errors and Website performance quality;

6.4.3. functional cookies — to remember User settings, if such settings are available;

6.4.4. advertising and partner cookies — to display, limit, measure, audit or configure advertising, partner, sponsored or promotional materials, if such tools are used on the Website;

6.4.5. security cookies — to detect automated requests, suspicious activity, spam, malicious code, circumvention of technical restrictions or other abuse.

6.5. Some cookies and similar technologies may belong to third parties, including providers of analytics, advertising, security, CDN, video players, social plugins or other technical solutions. Data collected by such third parties may be processed in accordance with their own privacy policies.

6.6. The Website Administration does not fully control the use of cookies, pixels, tags or other technologies by third parties where such technologies belong to or are managed by the respective third parties.

6.7. The User may manage cookies through the settings of their browser or device. Disabling cookies may result in the incorrect operation of certain pages, restricted access to certain functional elements, reduced performance, incorrect display of materials or inability to use certain technical functions.

6.8. If the Website contains a separate Cookie Policy, cookie banner or cookie settings center, such special rules shall apply in the relevant part with priority over the general provisions of this Policy.

Analytics, Advertising and Third-Party Tools

7.1. The Website may use third-party analytics, advertising, security, statistical, CDN, video, social or other technical tools.

7.2. Such tools may collect technical data, cookies, device data, browser data, page interaction data, views, transitions, approximate location, traffic source and other similar data.

7.3. The Website may contain code, scripts, pixels, widgets or other third-party elements. As a result, the relevant third parties may receive information that the User interacted with a particular page, material or functional element of the Website.

7.4. The Website Administration is not responsible for the privacy policies, terms of use, technical settings or actions of third parties providing such tools, except where such responsibility is expressly and unconditionally established by law.

7.5. The presence of advertising, partner, sponsored, promotional or other commercial material on the Website does not mean that the Website Administration assumes responsibility for the processing of personal data by an advertiser, partner, supplier of goods, works or services, or the owner of an external resource.

Transfer of Data to Third Parties

8.1. The Website Administration may transfer or provide access to personal data and technical data to third parties in the following cases:

8.1.1. to hosting providers, data centers, CDN providers, server infrastructure providers, domain registrars, telecommunications operators and other technical providers — to ensure the operation of the Website;

8.1.2. to providers of analytics, advertising, anti-bot, security, monitoring, communication and other technical solutions — for the purposes defined in this Policy;

8.1.3. to legal advisers, auditors, consultants, insurers or other professional advisers — to protect rights and legitimate interests;

8.1.4. to courts, law enforcement agencies, public authorities, local self-government bodies, regulators or other competent authorities — in cases and to the extent provided by law;

8.1.5. to persons who have submitted, or in respect of whom there has been submitted, a request, complaint, claim or notice of rights violation — to the extent necessary for considering such request, provided that this does not contradict the law;

8.1.6. to legal successors, acquirers of assets, partners or other persons in the event of reorganization, change of control, transfer of rights to the Website, technical migration or another similar organizational change, if such transfer is carried out in accordance with the law;

8.1.7. to other persons — with the consent of the Personal Data Subject or on another lawful basis.

8.2. Personal data processors engaged by the Website Administration may process personal data only for the purpose and to the extent determined by the Website Administration, by contract or by law.

8.3. The Website Administration does not sell Users’ personal data as a separate standalone commodity. At the same time, the use of advertising, analytics or partner technologies may involve the processing of technical and behavioral data by third parties in accordance with their own rules.

International Data Transfer

9.1. In connection with the use of hosting providers, CDN, analytics, advertising, security, communication or other technological solutions, personal data and technical data may be transferred or made accessible outside Ukraine.

9.2. Such transfer is carried out only where there are legal grounds and within the limits permitted by the legislation of Ukraine, international treaties of Ukraine or other applicable rules.

9.3. If foreign law, including European Union law, applies to certain processing, such processing may additionally be governed by relevant special notices, cookie settings, agreements with providers or other documents.

Data Retention Periods

10.1. Personal data shall be stored no longer than necessary for the lawful purposes for which it was collected or further processed, unless another period is established by law, a decision of a competent authority, contract or a justified need to protect rights and legitimate interests.

10.2. Approximate retention periods may be as follows:

10.2.1. technical access logs, security logs, IP addresses, user-agent and similar technical data — up to 24 months, unless a longer period is required for security, incident investigation, protection of rights or compliance with legal requirements;

10.2.2. data sent through contact forms or email — for the period necessary to consider the request, maintain further communication, protect rights and legitimate interests, but, as a rule, no longer than 3 years after the completion of the relevant interaction, unless otherwise follows from the nature of the request or legal requirements;

10.2.3. data related to complaints, claims, notices of rights violations, legal demands, evidence or disputes — for the period necessary for their consideration, resolution, proof or protection of rights, including limitation periods and retention periods provided by law;

10.2.4. cookies — for the period determined by the settings of the relevant cookie, browser, device, third-party service or separate Cookie Policy;

10.2.5. de-identified, aggregated or statistical data that does not allow direct or indirect identification of an individual may be stored indefinitely.

10.3. After the purpose of processing has been achieved or the retention period has expired, personal data may be deleted, destroyed, de-identified, archived or restricted in processing in accordance with the law and the technical capabilities of the Website.

Protection of Personal Data

11.1. The Website Administration applies reasonable technical, organizational and legal measures to protect personal data against accidental loss, unlawful destruction, unauthorized access, alteration, disclosure, dissemination or other unlawful processing.

11.2. Such measures may include, in particular, access control, logging, traffic filtering, anti-bot tools, backups, restriction of access to technical systems, threat monitoring, network and application protection, organizational policies, contractual restrictions for contractors and other similar mechanisms.

11.3. Access to personal data may be granted only to those persons who need such access to perform the relevant functions, ensure the operation of the Website, comply with legal obligations or protect rights and legitimate interests.

11.4. No method of transmitting data over the Internet or method of electronic storage is absolutely secure. Therefore, the Website Administration does not guarantee absolute security, uninterrupted availability, absence of technical risks or impossibility of unauthorized interference.

11.5. In the event of a security incident, the Website Administration has the right to take necessary measures to localize, investigate and remedy the consequences, record evidence, notify competent authorities or Personal Data Subjects in cases where such notification is expressly required by law.

Rights of the Personal Data Subject

12.1. The Personal Data Subject has the rights provided for by the legislation of Ukraine on personal data protection.

12.2. Requests concerning personal data may be sent to: [email protected]. Such a request must contain sufficient data to identify the applicant, the substance of the request, a contact channel for response and, where necessary, confirmation of the representative’s authority.

12.3. The Website Administration has the right to request additional information or documents if, without them, it is impossible to properly identify the applicant, verify the representative’s authority or determine which personal data the request concerns.

12.4. The Website Administration considers requests and responds to them in the manner, scope and time limits provided for by the legislation of Ukraine. The Website Administration has the right to refuse to satisfy a request or to limit its fulfillment in cases provided for by law, including where the request is unfounded, abusive, does not allow identification of the applicant or the relevant personal data, violates the rights of other persons, contradicts security requirements or concerns data that the Website Administration has the right or obligation to retain in accordance with the law.

Children’s Data

13.1. The Website is not specifically intended for children and does not aim to knowingly collect children’s personal data.

13.2. Open viewing of publicly available informational materials is permitted to the extent and in a manner that do not contradict the legislation of Ukraine, the Terms of Use of the Website and other special access conditions.

13.3. If the Website Administration becomes aware that a child’s personal data has been provided through the Website without a proper legal basis, the Website Administration has the right to delete, de-identify or restrict the processing of such data, unless otherwise provided by law.

13.4. Parents, adoptive parents, guardians, custodians or other legal representatives may contact the Website Administration regarding children’s personal data at: [email protected].

External Resources

14.1. The Website may contain links to external resources, pages, services, social networks, messengers, platforms, advertising materials, video players or other third-party resources.

14.2. Following external links is done by the User at their own risk.

14.3. The Website Administration does not control and is not responsible for privacy policies, cookie rules, terms of use, content, security or personal data processing practices on external resources, except where such responsibility is expressly and unconditionally established by law.

14.4. Before transferring personal data on external resources, the User is advised to independently review the privacy policy and terms of use of the relevant resource.

Automated Access, AI Agents and Search Engines

15.1. Search engines, AI agents, aggregators, archivers, crawlers, scrapers and other automated systems may process information available on the Website within the limits determined by law, the Terms of Use of the Website, this Policy, robots.txt, X-Robots-Tag, meta robots, rate limits and other technical instructions of the Website.

15.2. The Website Administration is not responsible for how search engines, AI agents, social networks, aggregators, archivers or other third parties index, cache, shorten, translate, paraphrase, combine, interpret, rank, store or otherwise use Website materials or technical information in their own systems.

15.3. If the User or a third party believes that certain information indexed or stored by a third-party service violates their rights, such person must also contact the relevant third-party service, search engine, social network, archive or other controller of such processing directly.

Limitation of Liability

16.1. To the maximum extent permitted by law, the Website Administration shall not be liable for any direct, indirect, incidental, special, consequential, reputational, informational, non-material, material or other losses, damages or consequences related to the processing of technical data, cookies, actions of third parties, external resources, search engines, AI agents, advertising systems, analytics services or other third-party technologies, except where such liability is expressly and unconditionally established by law.

16.2. The Website Administration does not guarantee that the Website, cookies, technical logs, analytics systems or third-party tools will always operate continuously, error-free, securely or without technical vulnerabilities.

16.3. If the liability of the Website Administration cannot be fully excluded, it shall in any case be limited to the minimum amount directly mandatory under the law and, unless otherwise follows from such law, only to actually proven direct damages.

Changes to the Policy

17.1. The Website Administration has the right to amend, update or supplement this Policy at any time.

17.2. A new version of the Policy shall take effect from the moment it is published on the Website, unless otherwise expressly stated in the new version itself.

17.3. The User is advised to periodically review this Policy in order to stay informed about its current version.

17.4. Continued use of the Website after publication of a new version of the Policy means that the User has read the updated Policy, except where the law requires obtaining separate consent.

Final Provisions

18.1. This Policy is governed by the laws of Ukraine.

18.2. If any provision of this Policy is found to be invalid, unlawful or unenforceable, this shall not affect the validity of the remaining provisions.

18.3. Such provision shall be interpreted or replaced to the extent closest to its original purpose, but only within the limits permitted by law.

18.4. In the event of a conflict between this Policy and the Terms of Use of the Website regarding personal data processing matters, this Policy shall prevail. With respect to the general rules for using the Website, limitation of liability, access to materials, automated access, external resources and other general matters, the Terms of Use of the Website shall prevail.

18.5. Contact channel for matters concerning this Policy and personal data: [email protected].

18.6. This Policy was updated on 10 July 2026 and enters into force from the moment of its publication on this page of the Website. From this date, all previous versions of the Privacy and Personal Data Protection Policy of the Website cease to be valid, shall not apply, may not be used to interpret the rights, obligations or liability of the Website Administration, Users or third parties, and shall not create any legal consequences in relation to further use of the Website. The only valid and binding version of the Policy is the version published on this page of the Website.

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