PriPRIVACY POLICY
PRIVACY POLICY AND PROCEDURE FOR THE PROCESSING OF PERSONAL DATA
OF ENTAI LIMITED LIABILITY COMPANY (hereinafter – the Policy)
This Privacy Policy and Procedure for the Processing of Personal Data of LIMITED LIABILITY COMPANY “ENTAI” (hereinafter referred to as the “Company”), has been developed in accordance with the Law of Ukraine “On the Protection of Personal Data” (hereinafter – the Law) and other applicable Ukrainian legislation in the field of personal data processing and ensuring the confidentiality of information.
This Policy takes effect on December 26, 2025, is posted on the Website, and remains in effect until a new version of the Policy takes effect.
The Policy contains information on the procedure for processing personal data, the types of personal data processed, the purposes and legal grounds for processing personal data, categories of data subjects, the Company’s interactions with third parties, conditions for accessing personal data, contact information for the Company’s customers regarding accessing, modifying, or deleting their personal data, and addressing any questions that may arise for data subjects regarding the protection of their personal data, as well as requirements for ensuring the confidentiality of information regarding the Company’s pre-contractual/contractual relationships with customers and any third parties.
The Company’s processing of personal data is carried out exclusively to fulfill the purposes specified in the Policy and with the Buyer’s Consent.
Definition of Terms
Personal Data Database — a named collection of organized personal data in electronic form and/or in the form of personal data files;
Personal Data Database Controller — a natural or legal person who, by law or with the consent of the data subject, has been granted the right to process such data, who determines the purpose of processing personal data in this database, establishes the composition of such data, and sets the procedures for its processing;
Consent — a natural person’s voluntary expression of will (provided they are informed) to grant permission for the processing of their personal data in accordance with the stated purpose of such processing, expressed in writing or in a form that allows for the conclusion that consent has been granted;
Processing of personal data — any action (operation) or set of actions, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (dissemination, provision of access), anonymization, blocking, deletion, destruction, etc., of personal data;
Personal data — information or a set of information about a natural person who is identified or can be specifically identified;
Personal Data Controller — a natural or legal person who has been granted the right to process such data by the owner of the personal data database or by law. A person who has been entrusted by the owner and/or controller of the personal data database to perform technical work on the personal data database without access to the content of the personal data is not considered a personal data controller;
Website – the Company’s software or a set of software tools used by the Company that enable the Company to receive, process, and fulfill orders for the remote purchase of goods/services, provide Buyers with information about goods/services, etc.
Data Subject — a natural person whose personal data is being processed;
Third Party — any person, other than the data subject, the controller or processor of personal data, and the Ukrainian Parliament Commissioner for Human Rights, to whom the controller or processor of personal data transfers personal data;
Personal data posing a particular risk — personal data regarding racial, ethnic, and national origin; political, religious, or philosophical beliefs; membership in political parties and/or organizations, trade unions, religious organizations, or public organizations of a philosophical nature; health status; Sexual life; biometric data; genetic data; administrative or criminal liability; measures taken against a person as part of a pre-trial investigation; measures taken against a person as provided by the Law of Ukraine “On Operational-Investigative Activities”; acts of violence of any kind committed against a person; a person’s location and/or routes of movement.
Categories of Data Subjects
The Company is the Data Controller and Data Processor. The location of personal data processing is at the Company’s registered office, at the following address: Kyiv, LUTERANSKA STREET, Building 10-A. A personal data processor may also be a natural or legal person authorized by the Company or by law to process personal data on behalf of the Company.
The data subject is a natural person who is in a pre-contractual/contractual relationship with the Company regarding the purchase of the Company’s goods/services (hereinafter referred to as the “Buyer”).
The Buyer consents to the Company’s right to transfer their Personal Data to Third Parties during the processing if necessary to achieve the purposes of processing, provided that such Third Parties comply with the confidentiality and security of the Buyer’s Personal Data
Purpose and Legal Basis for Processing Personal Data
The purpose of processing Buyers’ Personal Data is to ensure civil, tax, and accounting relations, in particular to facilitate business relations, to provide/receive and process payments for purchased goods/services, and to send informational and marketing communications (news, promotions, information about promotions, promo codes, and discounts, personalized recommendations, personalized discounts, and offers), which contain information regarding goods and/or services, advertising and commercial offers regarding such goods and/or services, etc. In the event that the specified purpose of processing Personal Data is changed to a new purpose that is incompatible with the previous one, for the further processing of Personal Data, the Company, as the Data Controller and Data Processor, must obtain the Buyer’s consent to the processing of their data in accordance with the changed purpose.
The basis for processing the Buyer’s personal data is the Buyer’s unconditional, indefinite, and irrevocable Consent, which is provided by checking the box to grant permission for the processing of their personal data in accordance with the purpose of their processing / use of the Website as set forth in the Policy.
By granting Consent to the processing of their personal data, the Buyer consents to the inclusion of their personal data in the Personal Data Database, which is owned by the Company. The Buyer confirms that they have read and agree to the terms of this Policy, as well as the rights granted to them as a data subject under Article 8 of the Law of Ukraine “On the Protection of Personal Data,” namely:
1. to know the sources of collection, the location of their personal data, the purpose of its processing, the location or place of residence (stay) of the controller or processor of personal data, or to issue a corresponding instruction to authorized persons to obtain this information, except in cases established by law;
2. to receive information regarding the conditions for granting access to personal data, including information about third parties to whom his personal data is transferred;
3. to access his personal data;
4. to receive, no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, a response as to whether their personal data is being processed, as well as to receive the content of such personal data;
5. to submit a reasoned request to the personal data controller objecting to the processing of their personal data;
6. to submit a reasoned request to any controller or processor of personal data to amend or delete their personal data if such data is processed unlawfully or is inaccurate;
7. to protect their personal data from unlawful processing and accidental loss, destruction, or damage resulting from intentional concealment, failure to provide, or untimely provision of such data, as well as to protect against the disclosure of information that is inaccurate or defames the honor, dignity, and business reputation of a natural person;
8. to file complaints regarding the processing of their personal data with the Commissioner or in court;
9. to seek legal remedies in the event of a violation of personal data protection laws;
10. to include reservations regarding restrictions on the right to process their personal data when providing consent;
11. to withdraw consent for the processing of personal data;
12. to be informed of the mechanism for the automated processing of personal data;
13. to be protected against automated decisions that have legal consequences for them.
The Buyer grants the Company consent for the cross-border transfer of their personal data and confirms that during the cross-border transfer of Personal Data, the recipients of such personal data may be located in other countries.
The Company does not process Personal Data that poses a particular risk.
Composition of Personal Data
The composition of the Buyer’s Personal Data includes: The primary sources of information about the Buyer are: documents issued in their name; documents signed by them; information that the Buyer provides about themselves, including on the Website.
The Buyer undertakes to provide the Company with complete, accurate, reliable, and up-to-date information, details, and data, including personal data, and to bear full responsibility for this. The Buyer is liable (including criminally) for the use of information, details, and data belonging to third parties.
Procedure for Processing Personal Data
The Company processes personal data using automated means as well as without such means. For the processing of personal data, the Company has the right to engage third parties, for whose actions the Company bears responsibility as if they were its own.
The retention period for personal data covers the entire duration of the contractual relationship between the Buyer and the Company, as well as 1 year following the termination of the contractual relationship with the Buyer.
The Company ensures the secure storage of Personal Data using various methods and levels of protection designed to prevent unauthorized access to Personal Data. The Company’s information security system includes: the installation of technical security measures and personal data protection tools; the setting of passwords for all technical and software tools; the selection and installation of antivirus software; and other means of personal data protection.
The deletion/destruction of Buyers’ Personal Data is carried out upon receipt of a reasoned written request from the Buyer and upon expiration of the Personal Data retention period, as well as in other cases specified by the current legislation of Ukraine. Changes to Personal Data are made immediately upon discovery of information about the Buyer that does not correspond to reality.
The Buyer agrees that, during the processing, the Company has the right to transfer their Personal Data to Third Parties if this is necessary to achieve the purposes of processing and provided that such Third Parties comply with the confidentiality and security of Personal Data. The transfer of Personal Data in accordance with this paragraph does not require separate consent or notification from the Buyer and occurs without the Buyer’s notification or consent regarding such transfer.
Access to Personal Data is granted to persons who process the data only if such person has undertaken to ensure compliance with the requirements of the Law and is capable of ensuring them. Access to the Buyer’s Personal Data is granted in response to a request for access to personal data, which must specify: The response period for the request is thirty calendar days from the date of its receipt, unless otherwise provided by the current legislation of Ukraine.
Privacy Policy
The Buyer and the Company have agreed that any information, whether in written, oral, electronic, visual, graphic, or any other form, provided before, during, or after the pre-contractual/contractual relationship between the Buyer and the Company is confidential, except for information that is common knowledge and/or publicly available or obtained lawfully from a third party without violating the terms of this Policy.
Unauthorized use of confidential information includes, but is not limited to, the use of confidential information for personal purposes unrelated to the parties’ cooperation, and the direct or indirect provision or disclosure of confidential information to third parties without the permission of the owner of such information.
The Buyer and the Company are obligated to keep each other’s confidential information confidential, not to disclose or divulge it (orally and/or in writing, including in electronic form), to take all necessary measures to ensure the protection of confidential information, and not to use it for improper purposes.
By using the Website, the Buyer consents to the use of cookies (hereinafter “Cookies”). Cookies are small text files stored on the Buyer’s device used to access the Website. Cookies are stored in a designated folder. Cookies allow data entered once into the Site’s form fields to be saved, so that it does not need to be re-entered during the next visit to the Site or when navigating between the Site’s individual features. The Buyer may refuse the use of Cookies by enabling the corresponding restriction in their device’s settings. In doing so, the Buyer understands that rejecting and/or prohibiting the use of cookies on the Buyer’s device may result in restrictions on the use of certain Site features.
By using the Site, the Buyer consents to the Company’s use of web analytics tools. These tools are used for general analysis of the Website’s usage and to obtain data to improve the Website’s functionality. Information obtained by the Company through the use of web analytics (e.g., IP address and browser type) may be transmitted in an anonymous form to the web analytics service’s server, where it is stored and processed. By adjusting the settings on their device, the Customer may prevent the relevant web analytics service from collecting data and storing cookies from such services on their computer.
If you have any comments, suggestions, or complaints regarding the processing of personal data owned by the Company or the confidentiality of information, please contact the Company via email at royal.spa.kiev@gmail.com, or at the following address: Ukraine, Kyiv, LUTERANSKA STREET, Building 10-A