Privacy Policy
This document outlines the collection, processing, and protection of personal data for users in the EU/EEA, Ukraine, and the US (including California).
1. Data Controller and Contact Details
Data Controller: Yevhen Samkov, independent Software Architect and Consultant.
Privacy Inquiries Contact: samcheek1989@gmail.com. Location: Cherkasy, Ukraine.
2. Scope of Application
This Policy applies to data processed via this website, contact forms, email correspondence, and during pre-sales communications.
Should a separate Master Services Agreement (MSA) be executed, it may contain supplementary Data Processing Addendums (DPA).
3. Categories of Personal Data
Identity and Contact Data: Name, email address, phone number, company name, and project details.
Technical Data: IP address, browser type, device identifiers, referring URLs, timestamps, and security logs.
4. Purposes and Lawful Basis for Processing (GDPR Art. 6)
Purposes: To process client inquiries, prepare commercial proposals, ensure website security, and conduct performance analytics.
Lawful Basis: User consent (where required), actions necessary prior to entering a contract, legitimate interests (security and service quality), and compliance with legal obligations.
5. Data Recipients and Processors
Data may be shared with trusted third-party providers for hosting, analytics, and infrastructure services under strict data processing agreements.
Personal data is never sold to third parties. As of the effective date of this policy, data is not shared for cross-context behavioral advertising.
6. Cross-Border Data Transfers
If data is transferred outside your jurisdiction, appropriate safeguards are implemented, including Standard Contractual Clauses (SCCs) and organizational measures.
You may request detailed information regarding these safeguards via our contact email.
7. Data Retention Periods
Business correspondence and pre-sales inquiries are retained for up to 24 months, unless a longer period is mandated for tax, legal, or dispute resolution purposes.
Technical and security logs are retained for a limited duration, strictly proportionate to operational and security requirements.
8. Data Subject Rights (EU, Ukraine, US/CA)
EU/EEA & Ukraine: The right to access, rectification, erasure (right to be forgotten), restriction of processing, objection, data portability, and withdrawal of consent.
California (CCPA/CPRA): The right to know, access, delete, correct, and the right to non-discrimination. Requests can be submitted via email.
10. Policy Updates
This Policy may be updated to reflect changes in legislation, technology, or business operations.
Continued use of the website following any updates constitutes acknowledgment of the revised Policy.
Related Legal Documents
Review related legal documents for comprehensive information regarding our privacy practices and terms of engagement.