Confidentiality and personal data protection policyconfidentiality and personal

This document is intended to inform users of our website, as well as future clients of A/Typical Agency, of the existing Confidentiality Policy during their interaction with the site.

This website https://a-typical.agency/ (hereinafter referred to as the “Site”) is managed by Anna Oleksandrivna Chernenko, an individual entrepreneur, who acts on the basis of the Extract from the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organizations № 2003370000000003871 from 07.06.2021 р.

The confidentiality and protection of personal data policy (hereinafter referred to as the “Сonfidentiality Policy”) applies to all information located at the address on the Internet: https://a-typical.agency/ and receives data about the User during the use of the Site.

Please note that the presented Сonfidentiality Policy has been prepared considering the legislation governing the protection of personal data, namely the General Data Protection Regulation (EU Regulation No. 2016/679 of 04.27.2016 or GDPR — General Data Protection Regulation) and the current legislation of Ukraine

1.DEFINITION OF TERMS

This clause defines the interpretation of the following terms, definitions and expressions used
in this Confidentiality Policy.

1.1. “Site” is a web page located at the domain name: https://a-typical.agency/ and managed by
the Site Administration.

1.2. “Site administration” — employees authorized to manage the site, acting on behalf of the Site and the agency, organize and carry out the processing of personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions or operations carried out with personal data.

1.3.  “User” is any natural person who has access to the Site and uses it via the Internet. 2.

1.4.  “Personal data” means any information directly or indirectly related to a certain natural person (subject of personal data).

1.5. “Processing of personal data” is any action (operation) or set of actions (operations) performed with or without the use of automation tools, with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), blocking, deletion, destruction of personal data.

1.6. “Confidentiality of personal data” is mandatory for compliance by the Site Administration or another person who has gained access to personal data, the requirement not to allow their distribution without the consent of the subject of personal data or the presence of another legal basis.

1.7. “Cookies” is a small piece of data sent by the web server and stored on the user’s computer, which the web client or web browser sends to the web server in an HTTP request every time when trying to open the page of the corresponding site.

1.8. “IP address” is a unique network address of a node in a computer network built according to the
IP protocol. All definitions, determinations and terms not defined by this section shall be interpreted in the meaning determined by the current legislation of Ukraine, and in the absence of such a determination, in their ordinary meaning.

2. GENERAL TERMS

2.1. The User’s use of the Site means the User’s automatic and full agreement with this Сonfidentiality Policy and the terms of processing the User’s personal data.

2.2. If the User does not agree with the terms of the Сonfidentiality Policy, the latter is obliged to stop using the Site and leave it immediately.

2.3. The current Сonfidentiality Policy applies exclusively to the Site. The Administration of the Site does not control and is not responsible for the sites of third parties to which the User can go through the links available on the Site.

3. AGE LIMITS

3.1. By any interaction with the Site, the User confirms that he has reached the appropriate age, which allows him to conclude contracts on his own, as well as to give consent to the processing of personal data.

3.2. The Site Administration may ask the User to provide additional documents or to undergo additional procedures, in order to clarify that he has the right to independently consent to the processing of personal data.

4. SUBJECT OF CONFIDENTIALITY POLICY

4.1. The valid Сonfidentiality Policy establishes the obligations of the Site Administration regarding non-disclosure and ensuring the privacy protection regime of personal data, which the User must provide upon request to the Site Administration when registering or making a payment on the Site.
4.2. Personal data permitted to be processed under this Сonfidentiality Policy is provided by the User by filling out certain forms on the Site and may include the following information:

• full name of the User;
• the User’s contact number;
• e-mail address of the User;
• other confidential data about the User’s identity or the User’s contacts.

4.3. In addition to the data provided in the previous paragraph, the Site Administration reserves the right to automatically collect, in the process of viewing the Site or its individual IP addresses of the electronic computing device (computer, phone, tablet, etc.) of the User;

• information about cookies stored in the User’s browser;
• information about electronic computing devices (computers, phones, tablets, etc.) of the User;
• information about the User’s browser, including the name, version of the browser, etc.;
• access time to the Site;
• addresses of the pages of the Site viewed by the User;
• addresses of previous pages from which the
• Site was accessed.

4.4. Disabling the function of collecting cookies by the User may make it impossible to access certain parts of the Site. 4.5. The Site collects confidential data provided by this Сonfidentiality Policy, including for the purpose of identifying and solving technical problems of the Site, to control the load on the Site
and to conduct statistical calculations of the effectiveness of advertising campaigns.

4.6. Any other personal or confidential information, not specified above, is subject to reliable storage and non-distribution, except for the cases provided for in this Сonfidentiality Policy.

5. PURPOSES OF COLLECTION OF PERSONAL USER DATA

5.1. The Site Administration may use the User’s personal data, in particular, for purposes:

• identification of the User for placing an order and (or) joining the public offer agreement remotely;
• providing the User with access to personalized resources of the Site;
• establishing feedback with the User, including the direction of messages, requests related to the use of the Site,
• provision of services, processing of requests and applications from the User;
• determination of the User’s location to ensure security, prevent fraud;
• confirmation of authenticity and completeness of Personal data provided by the User;
• providing the User with effective customer and technical support in the event of problems related to the use of the Site;
• providing the User with his consent, service updates, special offers, price information, news and other information on behalf of the Site;
• implementation of advertising activities with the consent of the User.

5.2. The User’s personal data may be used for other purposes not provided for in the Сonfidentiality Policy, which are included in the scope of activities of the Site.

6. DATA STORAGE

6.1. The Site Administration stores the User’s Personal Data only as long as it is needed for the Site or the Site Administration, for the purpose specified in this Сonfidentiality Policy. The latter also applies to any other third party performing certain actions on behalf of the Site Administration.

6.2. If the Site Administration does not need certain data about the User and it does not need to be stored in accordance with the requirements of the law, the data will be deleted or stored in a way that makes it impossible to identify the User.

7. METHODS, PROCEDURE AND TERMS OF PERSONAL INFORMATION PROCESSING

7.1. The processing of the User’s personal data is carried out without a time limit, in any legal way, including in personal data information systems with the use of automation tools or without the use
of such tools.

7.2. By staying on the Site, the User automatically agrees that the Site Administration has the right to transfer personal data to third parties, solely for the purpose of properly providing services to the User
or for the purpose of the User to pay for agency services.

7.3. The User’s personal data may be transferred to authorized state and judicial bodies only if there
are legal grounds and a corresponding requirement.

7.4. In case of loss or disclosure of personal data, the Site Administration informs the User about the
loss or disclosure of personal data by any means available to it.

7.5. The Site Administration takes the necessary organizational and technical measures to protect personal information from illegal or accidental access, destruction, distortion, blocking, copying,
distribution, as well as from other illegal actions of third parties.

7.6. The Site 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.

8. OBLIGATIONS OF THE SITE ADMINISTRATION FOR THE PROTECTION OF PERSONAL DATA

8.1. The Site Administration undertakes and guarantees the following:

• use any received information solely for the purposes specified in this СonfidentialityPolicy;
• to ensure the confidentiality and preservation of the User’s Personal Information;
• not to disclose without the prior written consent of the User, as well as not to sell, exchange, publish or disclose in other possible ways the transferred personal data of the User, except for the cases provided for in this Сonfidentiality Policy;
• take precautions to protect the confidentiality of the User’s personal data in accordance with the procedure that is usually used to protect this kind of information in the existing business turnover;
• to block personal data related to the relevant User from the moment of the User’s application or request, or his legal representative, or the authorized body regarding the protection of the rights of the subjects of personal data for the period of verification, in case of detection of unreliable personal data or illegal actions.

9. RESPONSIBILITIES OF THE PARTIES

9.1. The Site Administration, in case of violation of its obligations, is responsible for the losses
incurred by the User in connection with the improper use of personal data in accordance with
the current legislation, except for the cases provided for in this Сonfidentiality Policy.

9.2. In case of loss or disclosure of Personal Information, the Site Administration is not responsible if this information:

• became or was public at the time of loss or disclosure;
• was received from a third party before it was received by the Site Administration;
• was disclosed with the consent of the User.

9.3. The Site Administration is not responsible for the loss or disclosure of data, if the loss or disclosure occurred as a result of the actions of third parties or circumstances over which the Site Administration had no influence.

9.4. The User is responsible for complying with the requirements of the current legislation of Ukraine on the protection of intellectual property rights.

9.5. The distribution of materials posted on the Site is allowed only with the prior consent of the Site Administration and with a mandatory reference to the original source, i.e., the Site.

10. PROCEDURE OF SETTLEMENT OF DISPUTES

10.1. The User and the Site Administration resolve all disputes and disagreements arising from the relationship covered by this Сonfidentiality Policy through negotiations.

10.2. In case of failure to reach an agreement, the dispute will be referred to judicial authorities in accordance with the current procedural legislation of Ukraine.

11. ADDITIONAL TERMS

11.1. The Site Administration has the right to make changes to the current Сonfidentiality Policy without the consent and notification of the User.

11.2. The new Сonfidentiality Policy enters into force from the moment it is posted on the Site, unless otherwise provided by the new version of the Сonfidentiality Policy.

11.3. All suggestions or questions regarding this Сonfidentiality Policy should be submitted to the “Contacts” section on the Site’s web page. With respect and concern for your personal data, Anna Oleksandrivna Chernenko, an individual entrepreneur