as of August 15, 2019

(after this – Policy)

This Policy describes how the site  LLC “VANGAR MEDIA” collects, uses and discloses information and what options the site visitor has concerning such information.

This Policy includes services offered by the website LLC “VANGARD MEDIA” (after this, the Site).

This Policy is developed under the requirements of the legislation of Ukraine, as well as the needs of European directives and regulations regarding the protection of personal data since the services of the websites of “VANGARD MEDIA” LLC (after this – the Company) are publicly accessible both to citizens of Ukraine and to citizens of the European Union.

This Policy was created with the aim of its accessibility, comprehensibility and transparency, for which the Policy was divided into the sections indicated below. The definitions marked with capital letters were introduced into the text of the Policy.

Policy content:

1 Application of the Policy.

2 Information collected and received from visitors.

3 How information is used, distributed and disclosed.

4 Protection of information.

5 Protection of personal data of minors.

6 Changes to the Policy.

7 Rights possessed by visitors.

8 How a visitor to the Site can contact the Company.

1. Policy application

This Policy applies to visitors of the Site, who can receive information, get acquainted with information on the Site, register on the Site using social networks, and distribute information from the Site on social networks, thereby providing the Company with access to its IP address.

It should be noted that the services of the Site may sometimes direct the visitor to the services of other companies, such as the “like”, “share”, and “Twitter” services of social networks Facebook, Instagram, Twitter, and so on, and anonymous data may also be collected (after this – third parties). Such third parties have their privacy and personal data protection policies, so it should be remembered that the mode of use of information that the Site visitor shares with such Third Parties is subject to the policies of such Third Parties.

The company is the owner and administrator of the personal data of the Site visitors.

2. Information collected and received from visitors

Visitors to the Site can familiarise themselves with the Site’s content by viewing the Site’s pages. Visitors can communicate with each other and directly with the Company’s representatives, leaving their comments on the Site and spreading information from it on social networks. Such actions of the respondent give access to the Company: 

  • to the IP address of the viewer;
  • to the data specified by the visitor when registering on the Site (in the case of registration on the Site using already existing accounts in social networks – to the data in these accounts, such as first name, last name, e-mail address, etc);
  • to cookie files

The Company also receives information about visits by visitors to the Site – date, time of visit, browser of the visitor, etc.

In any case, the Company does not collect or receive sensitive information about visitors. Sensitive information means information about racial, ethnic, national origin, political, religious or worldview beliefs, information about sex life, genetic data, and other things.

3. How the information is used, disseminated and disclosed

Like most sites, the company has agreements with Google Analytics, Gemius, Facebook Pixel, Google AdSense, Admixer, Disqus, Bigmir, TNS, Google DFP, Twitter API, Instagram API, etc. These services are researched and analysed for website visitors’ preferences to distinguish the relevant advertising. The company distributes only anonymised information about visitors to the Site.

When you access the Site, the Company stores browsing session cookies (small files) on your hard drive, which are temporary and stored for your stay (session) on the Site. “Cookie” is a small data file saved on your computer for using the Site. These files are used only to record the frequency of visits and the time spent on the Site.

Because of the process, your IP address is used, which is processed anonymously. Personal data analysis does not take place. You can choose to automatically delete all or some cookies through your browser’s settings after closing the browser. You can opt out of the unique cookie tied to the browser that identifies you in the Site’s analytics system, thereby opting out of any collection of information about you and their analysis on the Site. For this, it is necessary to prohibit the storage of cookies in your browser’s settings or to visit the site anonymously.

4. Information protection.

The company considers the issue of personal data protection as one of the most critical issues in the modern world. The Company protects the information visitors share with us using appropriate technical, organisational and administrative measures to avoid risks of loss, illegal access, distribution or disclosure. The company provides access to information only to those employees who need it to perform their official duties.

However, despite all efforts, the Company cannot guarantee absolute protection against any threats that may arise outside of the Company’s influence. 

5. Protection of minors’ data

Children need particular protection for personal data, as they may need to be made aware of the relevant risks, consequences and safeguards, and their rights regarding processing personal data. Since the information posted by the Company on the Site may have specific restrictions regarding its viewing by minors and the Site is not intended exclusively for persons who have not reached the age of majority, the Company appeals to parents to explain to their children the issue of safety on the Internet, the necessity of use by such persons certain services of the Site.

6. Amendments to the Policy

The Company may make changes to this Policy from time to time. Legislation, regulation, and industry standards are evolving. In case of changes, the updated version of the Policy will be uploaded to the Site with a note about the latest version. If the visitor to the Site disagrees with the Policy, the visitor has the right not to visit the Site (in addition to other rights specified in the next section).

7. The rights of visitors

Taking into account the unlimited territorial access to the Site and the obligation to comply with the provisions of the General Regulation on the Protection of Personal Data if personal data of citizens of the European Union is processed and collected, the Company lists the rights of visitors to the Site – residents of Ukraine and residents of the European Union:

The rights of website visitors under the Law of Ukraine “On the Protection of Personal Data”:

– to know about the sources of collection, the location of their personal data, the purpose of their processing, the location or place of residence (residence) of the owner or controller of personal data or to give the appropriate instructions for obtaining this information to  authorised persons, except for cases established by law;

– to receive information about the conditions for providing access to personal data, in particular, information about third parties to whom his data is transferred;

–  access to your personal data;

– to receive no later than thirty calendar days from the date of receipt of the request, except for cases provided by law, an answer on whether his personal data is being processed, as well as to receive the content of such personal data;

– present a reasoned demand to the owner of personal data with an objection to the processing of his personal data;

– make a reasoned demand for the change or destruction of your personal data by any owner and administrator of personal data if these data are processed illegally or are unreliable;

– to protect your personal data from illegal processing and accidental loss, destruction, or damage due to intentional concealment, failure to provide or untimely provision of data, as well as protection from providing information that is unreliable or disgraces the honour, dignity and business reputation of a physical person individuals;

– file complaints about the processing of your personal data with the Commissioner or the court;

– apply legal remedies in case of violation of the legislation on the protection of personal data;

– enter a reservation regarding the limitation of the right to process one’s personal data when giving consent;

– withdraw consent to the processing of personal data;

– know the mechanism of automatic processing of personal data;

– to protect against an automated decision that has legal consequences for him.

The rights of visitors to the Site under the General Regulation on the Protection of Personal Data:

– The right to access (the visitor has the right to receive confirmation of the fact of processing their personal data);

– Right to correction (the visitor has the right to correct their inaccurate personal data);

– The right to erasure (the right to be forgotten) (the visitor has the right to erasure his personal data);

– Right to restriction of processing;

– The right to data portability (the visitor has the right to receive their personal data, which they have provided to a controller or owner of personal data, in a structured, generally accepted, machine-readable format, and to have the right to transfer such data to another controller or owner of personal data without interference from the administrator or owner of personal data to whom personal data was provided);

– The right to object and automated individual processing and decision-making (the visitor has the right to object, on grounds relating to their specific situation, at any time, to the processing of their personal data;

– The visitor has the right not to be subject to a decision based exclusively on automated processing, including profiling, which gives rise to legal consequences for or similarly significantly affects them).

8. How the Site visitor can contact the Company.

The company carries out its activities under the requirements of the legislation of Ukraine, registered in the Unified State Register of Legal Entities, Entrepreneurs and Public Organizations under number 44777494.

Legal address: 04060, Kyiv, str. Riga, building 73-G, office 7/2.

Address for correspondence: [email protected]

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