Privacy Policy

1. Who is the data controller

Data controller: Halveroth, LLC ("we", "us"). Registered in Ukraine. Address: 8 Khreshchatyk St, Office 12, Kyiv, 01001, Ukraine. Email: contact@halveroth.com. Phone: +380 981 248 9836.

Legal representative: Laura Dubois, Managing Director.

2. What personal data we collect

• Contact details you provide in forms (e.g., name, email address, phone number) for booking inquiries and contact/lead submissions.
• Information you include in your message (e.g., inquiry content).
• Transaction-related information if you place an order or request contract services.

We do not require special categories of personal data to use the website.

3. How we use personal data

We use personal data to: (a) respond to your inquiries and contact you; (b) provide requested services; (c) manage orders and contracts; (d) communicate about updates, including contractual matters when relevant; and (e) ensure compliance with legal obligations.

4. Legal basis for processing

Our processing is based on a lawful basis under Ukrainian law, including consent where applicable, and other lawful grounds permitted by law. Personal data processing is governed by the Law of Ukraine "On Personal Data Protection" (Закон України "Про захист персональних даних") dated 01.06.2010 № 2297-VI.

For e-commerce and distance-contract scenarios, where applicable, we provide customer-facing information and make contract terms available in an easy-to-access place before ordering in accordance with the Law of Ukraine "On E-commerce" (Закон України "Про електронну комерцію") dated 03.09.2015 № 675-VIII, and distance-contract information requirements set out in the Law of Ukraine "On Consumer Protection" (Закон України "Про захист прав споживачів") dated 10.06.2023 № 3153-IX, Article 17 and Article 19, as well as (where relevant) the Law of Ukraine "On Consumer Protection" dated 12.05.1991 № 1023-XII.

5. Distance contracts: your termination right

If, in distance-contract situations, required confirmation or information is not provided properly, you may terminate the distance contract within the statutory period. This right is referenced under the Law of Ukraine "On Consumer Protection" dated 12.05.1991 № 1023-XII, Article 13, Article 14, and Article 15.

6. Contract terms and ordering

Where the website enables ordering for e-commerce, we ensure that contract terms are accessible in an easy-to-access place before you place an order, in accordance with the Law of Ukraine "On E-commerce" (Закон України "Про електронну комерцію") dated 03.09.2015 № 675-VIII.

7. Data retention

We retain personal data only for as long as needed for the purposes described in this Policy, including to fulfill contractual obligations, handle inquiries, and comply with applicable legal requirements.

8. Your rights

• You may exercise rights related to your personal data under Ukrainian law, including rights connected with access to and correction of personal data, and other rights as provided by the Law of Ukraine "On Personal Data Protection" dated 01.06.2010 № 2297-VI.
• If you have complaints, you can submit them to the business and receive information about possible dispute resolution paths, including out-of-court routes, when a complaint is not resolved. These requirements are referenced under the Law of Ukraine "On Consumer Protection" dated 10.06.2023 № 3153-IX, Article 39 and Article 40.

9. Security

We implement appropriate technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, or destruction.