And Personal Data Processing

Version of August 11, 2026

1. GENERAL PROVISIONS

1.1. This Privacy and Personal Data Processing Policy (hereinafter — the “Policy”) defines the procedure for collecting, processing, using, storing, protecting, and transferring personal data of users of this website (hereinafter — the “Website”).

1.2. The Policy applies to personal data of individuals who visit the Website, submit inquiries via the Website, place Orders, purchase Goods, or otherwise interact with the Website.

1.3. Personal data is processed in accordance with the Constitution of Ukraine, the Law of Ukraine “On Personal Data Protection”, the Law of Ukraine “On Electronic Commerce”, other regulatory legal acts of Ukraine, and this Policy.

1.4. The Website is an official information resource of the brand and may be used for receiving and transferring Orders to the distributor and/or official dealers of the brand.

1.5. The specific Seller for an Order is determined after processing the Order and is indicated in the Invoice in accordance with the Public Offer of the Website.

1.6. Due to the specifics of the Website's operation, the user's personal data may be processed by the Website operator, the distributor, and/or the relevant official dealer to the extent necessary to achieve the purposes defined by this Policy and subject to a statutory legal basis.

2. KEY DEFINITIONS

2.1. Personal data — information or a set of information about an individual who is identified or can be specifically identified.

2.2. User — an individual who visits the Website or otherwise uses its functionality.

2.3. Buyer — a person who places an Order and/or enters into a purchase and sale agreement in accordance with the Public Offer of the Website.

2.4. Processing of personal data — any action or set of actions related to the collection, registration, accumulation, storage, adaptation, modification, updating, use, dissemination, transfer, depersonalization, destruction, or other processing of personal data.

2.5. Other terms are used within the meanings defined by the legislation of Ukraine and the Public Offer of the Website.

3. PERSONAL DATA SUBJECT TO PROCESSING

3.1. Depending on the method of using the Website and the nature of interaction with the User, the following personal data may be processed:

  • first name, last name, and patronymic (if provided);
  • phone number;
  • email address;
  • city / settlement;
  • address or other details necessary for delivery;
  • information about the selected branch or pick-up point of the carrier;
  • information regarding the Order and purchased Goods;
  • information required for issuing an Invoice;
  • payment details required for refunds;
  • payment information to the extent available to the relevant Seller;
  • information regarding inquiries, warranty or service maintenance, return or exchange of Goods;
  • content of messages and inquiries submitted by the User;
  • other data voluntarily provided by the User during interaction with the Website.

3.2. If an Order is placed on behalf of an individual entrepreneur or a legal entity, information regarding the contact or authorized individual required to process and fulfill the Order may additionally be processed.

3.3. The Website is not intended for the intentional collection of special categories of personal data that are not necessary for placing and fulfilling an Order.

3.4. The User should not provide personal data through the Website that is not necessary for the relevant inquiry or Order.

4. TECHNICAL INFORMATION

4.1. When using the Website, certain technical information may be automatically processed, including:

  • IP address;
  • device type;
  • browser type and version;
  • operating system;
  • date and time of visit;
  • pages of the Website visited by the User;
  • referral source;
  • technical identifiers;
  • cookies and similar technologies.

4.2. Such information may be used to ensure the proper operation and security of the Website, analyze its performance, diagnose technical issues, prevent abuse, and, where a proper legal basis exists, for analytical and marketing purposes.

4.3. The specific terms of using cookies and third-party analytical or advertising technologies may be additionally set out in a separate Cookie Policy.

5. PURPOSES OF PERSONAL DATA PROCESSING

5.1. Personal data may be processed for the purposes of:

  • ensuring the operation of the Website;
  • receiving and processing Orders;
  • identifying the User or Buyer to the extent necessary for the corresponding operation;
  • contacting the Buyer;
  • clarifying information regarding the Order;
  • checking the availability of Goods;
  • determining the distributor or official dealer capable of fulfilling the Order;
  • transferring the Order to the relevant official dealer;
  • determining the specific Seller;
  • preparing and issuing an Invoice;
  • concluding and performing a purchase and sale agreement;
  • organizing packaging, dispatch, and delivery of Goods;
  • maintaining accounting, tax, and other mandatory records;
  • fulfilling warranty obligations;
  • contacting the Buyer after purchasing Goods to obtain feedback on the purchased Goods and/or quality of service, as well as processing received feedback to evaluate and improve the quality of Goods and customer service;
  • processing inquiries regarding the exchange and return of Goods;
  • issuing refunds;
  • handling inquiries, claims, and requests;
  • protecting the rights and legitimate interests of the Buyer, Seller, Website operator, and third parties;
  • ensuring information and technical security of the Website;
  • complying with the requirements of Ukrainian legislation.

5.2. Personal data is not used for purposes incompatible with the purpose of its collection without another proper legal basis.

6. LEGAL BASES FOR PROCESSING AND GRANTING CONSENT

6.1. Personal data is processed solely on the grounds provided for by the legislation of Ukraine.

6.2. Depending on the specific situation, such grounds may include:

  • consent of the personal data subject;
  • necessity of taking pre-contractual steps at the request of the User or Buyer;
  • conclusion and performance of a transaction to which the personal data subject is a party;
  • necessity of fulfilling an obligation under Ukrainian legislation;
  • protection of the legitimate interests of the personal data controller or a third party, subject to compliance with statutory requirements;
  • other grounds provided for by the legislation of Ukraine.

6.3. By entering personal data into the Order form on the Website and submitting the Order by clicking “Buy”, “Place Order”, or another similar button, the User confirms that they had the opportunity to review this Policy prior to submitting the Order.

6.4. The actions performed by the User as specified in clause 6.3 of this Policy constitute a voluntary and informed expression of will and signify consent to the processing and storage of the provided personal data within the purposes and under the conditions defined by this Policy.

6.5. Consent encompasses collection, registration, accumulation, storage, adaptation, modification, updating, use, transfer in cases stipulated by this Policy, depersonalization, and destruction of personal data.

6.6. Consent is granted upon the initial self-directed placement of an Order and applies to personal data provided by the User during Order placement, as well as data generated subsequently in connection with Order processing, potential conclusion and performance of the Agreement, delivery, collection of feedback regarding purchased Goods and service quality, warranty service, exchange, and return of Goods or funds.

6.7. The Website may record the fact of consent, including the date and time of Order placement, the version of this Policy in force at that moment, the Order identifier, and other technical information necessary to verify consent.

6.8. The granted consent includes the right to transfer personal data to the extent necessary to the distributor, official dealer, or other business entity to whom the Order is assigned and who may be designated as the Seller, as well as to persons involved in Order fulfillment, in the manner provided for by this Policy.

6.9. Granting consent to personal data processing does not automatically constitute consent to receive advertising or marketing communications. Such consent, if necessary, is obtained separately.

6.10. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal and does not terminate personal data processing if another legal basis exists under applicable law, including the necessity to perform the Agreement, fulfill a statutory duty, or retain documents for the period required by law.

7. TRANSFER OF ORDERS TO OFFICIAL DEALERS

7.1. The Website operates, inter alia, as an official brand information resource through which Orders may be transferred to the distributor and/or members of the official dealer network.

7.2. To determine the feasibility of Order fulfillment, the Buyer's personal data may be transferred to the respective distributor or official dealer to the extent necessary.

7.3. Such transfer may take into account product availability, the Buyer's location, the dealer's territory of operation, lead times and feasibility of fulfillment, logistics terms, or other objective commercial circumstances.

7.4. Only the personal data strictly necessary to process and fulfill the respective Order is transferred to the dealer.

7.5. The specific business entity designated as the Seller is indicated in the Invoice prior to payment by the Buyer.

7.6. Following Order transfer, the respective Seller may independently process the received personal data to the extent necessary for entering into and executing the contract, accounting and tax reporting, warranty service, exchange, return of Goods, refunds, and fulfilling other obligations provided by law.

8. DATA TRANSFERS TO THIRD PARTIES

8.1. Personal data may be transferred to third parties only where a valid legal basis exists and strictly to the extent necessary for the relevant purpose.

8.2. Such persons may include:

  • the brand distributor;
  • official dealers;
  • the designated Seller;
  • postal operators;
  • freight carriers;
  • freight forwarders and delivery services;
  • banks and other payment service providers where necessary to execute or verify payments or issue refunds;
  • hosting and technical support service providers;
  • vendors of software and information systems used for Order processing;
  • professional advisors, auditors, accountants, or legal counsels where necessary;

state bodies, courts, law enforcement, and other authorized authorities in cases and in accordance with procedures established by law.

8.3. Transfer of personal data to carriers is carried out solely to the extent necessary to arrange and execute delivery.

8.4. Transfer of data to public authorities is conducted exclusively when statutory grounds apply.

9. MARKETING COMMUNICATIONS

9.1. Placing an Order does not in itself imply unconditional consent of the Buyer to receive promotional or marketing messages unrelated to Order fulfillment.

9.2. Informational notifications necessary for processing and fulfilling an Order may be sent without separate marketing consent within the applicable legal basis.

9.3. Advertising and marketing messages are sent in cases and on grounds provided for by the legislation of Ukraine.

9.4. If marketing messages are sent based on User consent, the User has the right to withdraw such consent via accessible methods.

10. COOKIES

10.1. The Website may use cookies and similar technologies.

10.2. Strictly necessary cookies may be used to ensure the core operation, security, and primary capabilities of the Website.

10.3. Analytics, advertising, and other non-essential cookies are used in accordance with legal requirements and settings available to the User, provided such settings are supported by the Website.

10.4. The User may also manage cookies through their browser settings.

10.5. Disabling certain cookies may affect the availability or performance of specific Website features.

11. DATA RETENTION PERIOD

11.1. Personal data is retained for no longer than necessary to achieve the purposes of its processing, unless a different period is prescribed by Ukrainian law.

11.2. Data related to completed Orders and commercial transactions may be retained for the statutory durations required to comply with accounting, tax, warranty, and other legal obligations.

11.3. Data regarding claims, warranty cases, or disputes may be retained for the period necessary to resolve the matter and protect the legitimate rights and interests of the parties.

11.4. Upon termination of the legal grounds for further processing, personal data is deleted, destroyed, or depersonalized in accordance with established procedures, unless statutory retention is required.

12. PERSONAL DATA PROTECTION

12.1. Organizational and technical measures are taken to protect personal data from unlawful or accidental loss, destruction, alteration, unauthorized access, copying, dissemination, and other forms of unlawful processing.

12.2. Access to personal data is granted only to individuals who require it to perform their respective duties.

12.3. Individuals granted access to personal data must comply with statutory requirements regarding its protection and confidentiality.

12.4. At the same time, no method of electronic transmission or storage can guarantee absolute security; therefore, reasonable and appropriate safeguards are implemented taking into account the nature of the data and the methods of its processing.

13. RIGHTS OF THE DATA SUBJECT

13.1. An individual has the rights provided for by the Law of Ukraine “On Personal Data Protection”, in particular the right to:
know about the sources of collection, location of their personal data, purpose of their processing, and location

  • of the personal data controller;
  • receive information on the conditions for granting access to personal data;
  • receive information regarding third parties to whom personal data is transferred in cases provided by law;
  • access their personal data;
  • receive confirmation as to whether their personal data is being processed;
  • submit a reasoned objection against the processing of personal data in cases provided by law;
  • submit a reasoned request for modification or destruction of personal data if it is processed unlawfully or is inaccurate;
  • withdraw consent to personal data processing if processing is carried out on the basis of consent;
  • file complaints regarding personal data processing with the Ukrainian Parliament Commissioner for Human Rights or with the courts;
  • exercise other rights provided for by Ukrainian legislation.

13.2. Withdrawal of consent is exercised by contacting the Data Controller and applies subject to other legal grounds for further processing and storage of personal data.

13.3. In particular, a request for data deletion does not imply mandatory destruction of documents and information that must be retained for the statutory period under applicable law.

14. THIRD-PARTY DATA

14.1. If the User provides personal data of another individual (for instance, a recipient of Goods), they must have a lawful basis for providing such data.

14.2. Such data is used strictly to the extent necessary for the corresponding purpose, including arranging delivery of Goods.

15. LINKS AND THIRD-PARTY SERVICES

15.1. The Website may contain links to third-party websites and services.

15.2. This Policy does not govern the processing of personal data by such independent third-party resources.

15.3. Prior to using a third-party resource, the User is advised to review its privacy policy.

16. AMENDMENTS TO THE POLICY

16.1. This Policy may be amended due to changes in legislation, Website functionality, methods of personal data processing, or other justified reasons.

16.2. The new version of the Policy takes effect from the moment of its publication on the Website, unless expressly stated otherwise.

16.3. The current version of the Policy is permanently available on the Website.

17. DATA CONTROLLER DETAILS AND CONTACT INFORMATION

17.1. Information about the Personal Data Controller and up-to-date contact details are published in the Website footer and/or in the relevant information section of the Website.

17.2. Requests regarding access, modification, clarification, deletion of personal data, withdrawal of consent, or exercise of other rights provided for by Ukrainian legislation may be submitted to the Data Controller using the contact details provided on the Website.

17.3. In order to protect personal data from unlawful access or disclosure, reasonable identity verification of the applicant may be conducted prior to fulfilling a request.

17.4. Requests are reviewed according to the procedure and within the timelines established by the legislation of Ukraine.

18. FINAL PROVISIONS

18.1. This Policy constitutes an integral part of the Website Terms of Use with respect to personal data processing.

18.2. By placing an Order, the User confirms that they had the opportunity to review this Policy prior to providing personal data.

18.3. The provision of personal data by the User when placing an Order and submitting such Order constitutes the provision of this data for processing and storage in accordance with the purposes, legal grounds, and terms defined by this Policy.

18.4. If specific processing requires separate consent from the User, such consent is requested separately.

18.5. If any provision of this Policy contradicts a mandatory provision of Ukrainian legislation, the relevant statutory provision shall apply.