Kbusiness

MIN10X

PRIVACY POLICY

1. GENERAL PROVISIONS

1.1. This Privacy Policy (hereinafter referred to as the “Policy”) sets out the procedure for the collection, processing, storage, and protection of the personal data of users of the website min10x.com (hereinafter referred to as the “Website”), carried out by MIN10X Limited Liability Company (hereinafter referred to as the “Company,” “we,” or “us”).

1.2. The Company is the owner of personal data within the meaning of the Law of Ukraine “On Personal Data Protection” No. 2297-VI dated 1 June 2010, and a data controller within the meaning of Regulation (EU) 2016/679 (GDPR).

1.3. By using the Website, submitting any feedback form, or otherwise interacting with the Website in any way, You agree to the terms of this Policy. If You do not agree with the terms of this Policy, please refrain from using the Website.

1.4. This Policy applies to all visitors of the Website regardless of their citizenship, place of residence, or jurisdiction.

2. DEFINITIONS

For the purposes of this Policy, the terms below shall have the following meanings:

  • “Personal data” — any information that directly or indirectly identifies, or may identify, a natural person (a data subject).
  • “Processing of personal data” — any action or set of actions carried out with respect to personal data, including collection, registration, accumulation, storage, adaptation, alteration, updating, use, dissemination, de-identification, destruction, and the like.
  • “Data subject” — a natural person whose personal data is processed.
  • “Cookies” — small text files stored on a user’s device while visiting the Website.
  • “Third parties” — any legal entities or natural persons, other than the data subject and the Company, to whom personal data is or may be transferred.
  • “GDPR” — Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.

3. PERSONAL DATA WE COLLECT

3.1. Data provided voluntarily

When completing the contact form on the Website, You provide us with the following data:

  • First and last name (name).
  • E-mail address.
  • Subject of the inquiry.
  • Message text (at Your discretion).

Provision of the above data is voluntary. However, without it we will not be able to contact You or respond to Your inquiry.

3.2. Data collected automatically

While visiting the Website, the following technical data may be automatically collected:

  • Device IP address.
  • Browser type and version.
  • Operating system.
  • Date and time of the visit.
  • URLs of the pages visited.
  • Referral URL (the source from which You arrived at the Website).
  • Browser language settings.
  • Cookie data (for details, see the Cookie Policy).

3.3. Data we do not collect

We do not collect or process special categories of personal data, including racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data.

We process Your personal data on the following bases and for the following purposes:

4.1. Handling of inquiries (contact form)

  • Purpose: reviewing requests, responding to inquiries, and conducting negotiations regarding the conclusion of service agreements.
  • Legal basis (Law of Ukraine “On Personal Data Protection”): consent of the data subject (Art. 11).
  • Legal basis (GDPR): performance of a contract, or taking steps at the request of the data subject prior to entering into a contract (Art. 6(1)(b) GDPR); legitimate interest of the Company (Art. 6(1)(f) GDPR).

4.2. Technical operation of the Website

  • Purpose: ensuring the functionality and security of the Website, and preventing fraud and abuse.
  • Legal basis: legitimate interest of the Company (ensuring the operation of the Website).

4.3. Analysis and statistics

  • Purpose: analysing use of the Website and improving its functionality and content.
  • Legal basis: consent (for analytics cookies) or legitimate interest of the Company.

4.4. Marketing and communication (where applicable)

  • Purpose: informing You about the Company’s services, promotions, and news (only where separate consent has been obtained).
  • Legal basis: consent of the data subject.

5. PERSONAL DATA RETENTION PERIODS

5.1. Personal data is retained for the period necessary to achieve the purpose of its processing:

  • Contact form data — for 12 months from the date the inquiry is received, or until the end of the business relationship arising from such inquiry, whichever is later.
  • Technical logs and visit data — for 12 months.
  • Data related to the performance of contracts — for the term of the relevant contract and for 3 years thereafter, in accordance with the requirements of applicable law.

5.2. Upon expiry of the applicable retention period, personal data is destroyed or de-identified.

6. TRANSFER OF PERSONAL DATA TO THIRD PARTIES

6.1. The Company does not sell, transfer, or disclose Your personal data to third parties, except as provided for in this Policy or under applicable law.

6.2. Personal data may be transferred to the following categories of recipients:

  • Technical service providers (hosting, e-mail, analytics) — solely to the extent necessary to provide such services, and on the basis of appropriate data processing agreements.
  • State authorities — in the cases provided for by the legislation of Ukraine (in fulfilment of a lawful request of a court, law enforcement authorities, or similar bodies).
  • Consultants and legal advisers — where necessary to protect the rights and legitimate interests of the Company.

6.3. Where personal data is transferred outside Ukraine (including to countries that are not EU member states or have not been recognised as providing an adequate level of data protection), the Company shall take all necessary protective measures in accordance with the requirements of the GDPR (standard contractual clauses, adequacy decisions, and the like).

7. RIGHTS OF DATA SUBJECTS

You have the following rights with respect to Your personal data:

  • Right of access — to obtain confirmation as to whether Your personal data is being processed and to obtain a copy of such data.
  • Right to rectification — to request the correction of inaccurate personal data or the completion of incomplete personal data.
  • Right to erasure (“right to be forgotten”) — to request the deletion of personal data where there is no lawful basis for its further processing.
  • Right to restriction of processing — to request the restriction of the processing of personal data in the cases provided for by the GDPR (Art. 18).
  • Right to data portability — to receive personal data in a structured, commonly used, and machine-readable format.
  • Right to object — to object to the processing of personal data carried out on the basis of legitimate interest.
  • Right to withdraw consent — to withdraw, at any time, consent previously given to the processing of personal data. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
  • Right to lodge a complaint with a regulator — to file a complaint with the Ukrainian Parliament Commissioner for Human Rights or with the supervisory authority for personal data protection in Your country of residence.

7.1. To exercise the rights set out above, please send Your request to: [[email protected]](mailto:[email protected]). We will review Your request within 30 (thirty) calendar days of receipt. If Your request is denied, You will be informed of the grounds for such denial.

8. PROTECTION OF PERSONAL DATA

8.1. The Company takes appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction, including:

  • Encryption of data in transit (SSL/TLS).
  • Restriction of access to personal data to authorised personnel only.
  • Regular review and updating of security measures.
  • Execution of confidentiality agreements with employees and contractors.

8.2. Notwithstanding the security measures taken, no system is completely secure. In the event of a personal data breach, the Company will take all necessary measures and notify You in the manner prescribed by applicable law.

9. COOKIES

9.1. The Website uses cookies and similar technologies. Detailed information on their use is set out in the Cookie Policy, which forms an integral part of this Policy.

9.2. You may configure Your cookie preferences through Your browser settings or through the applicable consent management tool on the Website.

The Website may contain links to third-party websites. This Policy does not apply to such resources. We recommend that You review the privacy policies of the relevant resources before using them.

11. CHANGES TO THIS POLICY

11.1. The Company reserves the right to amend this Policy at any time. The current version of the Policy is always available on the Website.

11.2. In the event of material changes, the Company will notify You by posting a notice on the Website or by sending a notification to Your e-mail address, if You have previously provided one.

11.3. Continued use of the Website after the amendments take effect constitutes Your acceptance of the updated Policy.

12. CONTACT DETAILS

For questions related to this Policy or to the processing of personal data, You may contact us at:

  • MIN10X Limited Liability Company.
  • EDRPOU Code / RNOKPP: 45441416.
  • Registered address: 76019, Ukraine, Ivano-Frankivsk, 6 B. Pivnichnyi St., Apt. 19.
  • E-mail: [email protected]