Real estate in Ukraine of the comfort class: Quality and availability

**Privacy Policy**

This Privacy Policy (hereinafter referred to as the Privacy Policy) applies to all information that the website (hereinafter referred to as the Website), located at the domain name (as well as its subdomains), may receive about the User during their use of the website (as well as its subdomains), its programs, and its products.

1. **Definition of Terms**

1.1. The following terms are used in this Privacy Policy:

1.1.1. “Website Administration” (hereinafter referred to as the Administration) — authorized employees responsible for managing the website, who organize and (or) carry out the processing of personal data, as well as define the purposes of processing personal data, the composition of personal data to be processed, and actions (operations) performed with personal data.

1.1.2. “Personal Data” — any information that directly or indirectly relates to an identified or identifiable individual (subject of personal data).

1.1.3. “Processing of Personal Data” — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

1.1.4. “Confidentiality of Personal Data” — a mandatory requirement for the Operator or other persons who have gained access to personal data to prevent their dissemination without the consent of the subject of personal data or the presence of another legal basis.

1.1.5. “Website” — a set of interrelated web pages hosted on the Internet under a unique address (URL): https://www.vipok.com.ua/ and its subdomains.

1.1.6. “Subdomains” — pages or a set of pages located on third-level domains that belong to the website, as well as other temporary pages, which contain the Administration’s contact information at the bottom.

1.1.7. “Website User” (hereinafter referred to as User) — a person who has access to the website via the Internet and uses the information, materials, and products of the website.

1.1.8. “Cookies” — a small piece of data sent by a web server and stored on the User’s computer, which the web client or web browser sends to the web server each time it tries to open the corresponding page of the website.

1.1.9. “IP Address” — a unique network address of a node in a computer network, through which the User gains access to the website.

2. **General Provisions**

2.1. The use of the website by the User means consent to this Privacy Policy and the terms of processing the User’s personal data.

2.2. If the User does not agree with the terms of the Privacy Policy, the User must stop using the website.

2.3. This Privacy Policy applies only to the website. It does not control and is not responsible for third-party websites, which the User may visit by following links available on the website.

2.4. The Administration does not verify the accuracy of the personal data provided by the User.

3. **Subject of the Privacy Policy**

3.1. This Privacy Policy establishes the obligations of the Administration to ensure the non-disclosure and protection of the confidentiality of personal data that the User provides at the request of the Administration when registering on the website or when subscribing to email newsletters.

3.2. Personal data allowed for processing under this Privacy Policy are provided by the User by filling out forms on the website and include the following information:

3.2.1. The User’s last name, first name, patronymic;

3.2.2. The User’s contact phone number;

3.2.3. The User’s email address;

3.2.4. The User’s place of residence (if necessary);

3.2.5. The User’s photo (if necessary).

3.3. The website protects data that is automatically transmitted during page visits:

– IP address;
– Information from cookies;
– Browser information;
– Access time;
– Referrer (address of the previous page).

3.3.1. Disabling cookies may result in the inability to access parts of the website that require authorization.

3.3.2. The website collects statistics on the IP addresses of its visitors. This information is used to prevent, detect, and solve technical problems.

3.4. Any other personal information not specified above (browsing history, used browsers, operating systems, etc.) is subject to secure storage and non-disclosure, except as provided in clause 5.2 of this Privacy Policy.

4. **Purpose of Collecting the User’s Personal Information**

4.1. The Administration may use the User’s personal data for the following purposes:

4.1.1. Identifying the User registered on the website for their further authorization.

4.1.2. Providing the User with access to personalized data on the website.

4.1.3. Establishing feedback with the User, including sending notifications, inquiries, and information regarding the use of the website, and processing requests from the User.

4.1.4. Determining the User’s location to ensure security and prevent fraud.

4.1.5. Confirming the accuracy and completeness of personal data provided by the User.

4.1.6. Creating an account for the User if they have consented to the account creation.

4.1.7. Sending email notifications to the User.

4.1.8. Providing the User with effective technical support in case of problems related to using the website.

4.1.9. Offering the User special offers, newsletters, and other information on behalf of the website, with the User’s consent.

5. **Methods and Time of Processing Personal Information**

5.1. The User’s personal data is processed without time limitation, using any legal methods, including in personal data information systems with or without the use of automation tools.

5.2. The User’s personal data may be transferred to authorized state authorities of Ukraine only on the grounds and in the manner established by the legislation of Ukraine.

5.3. In case of loss or disclosure of personal data, the Administration has the right not to inform the User about the loss or disclosure of personal data.

5.4. The Administration takes necessary organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, modification, blocking, copying, dissemination, as well as from other unlawful actions of third parties.

5.5. The Administration, together with the User, takes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User’s personal data.

6. Rights and obligations of the parties

6.1. The User has the right to:

6.1.1. Make a free decision regarding the provision of their personal data necessary for using the website and consent to its processing.

6.1.2. Update or supplement the provided information about personal data in case of changes to this information.

6.1.3. The User has the right to receive from the Administration information regarding the processing of their personal data if such right is not restricted according to federal laws. The User has the right to demand that the Administration clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or unnecessary for the stated purpose of processing, as well as to take legal measures to protect their rights. To do this, it is sufficient to notify the Administration at the specified email address.

6.2. The Administration is obliged to:

6.2.1. Use the received information exclusively for the purposes specified in clause 4 of this Privacy Policy.

6.2.2. Ensure the confidentiality of confidential information, not disclose it without the User’s prior written consent, and not sell, exchange, publish, or disclose the provided personal data of the User in any other possible way, except for clause 5.2 of this Privacy Policy.

6.2.3. Take precautions to protect the confidentiality of the User’s personal data in accordance with the procedures typically used to protect such information in existing business practices.

6.2.4. Ensure the blocking of personal data relating to the relevant User from the moment of the User’s request or demand from their legal representative or an authorized body for the protection of personal data subjects’ rights during the verification period, in case of detection of inaccurate personal data or unlawful actions.

7. Responsibility of the parties

7.1. The Administration that has not fulfilled its obligations is not liable for damages incurred by the User in connection with the unlawful use of personal data.

7.2. In case of loss or disclosure of Confidential Information, the Administration is not liable for damages incurred by the User.