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Privacy Notice

Effective date:

Golem Agency is the trading name of Private Entrepreneur Volodymyr Golembivs’kyi. This notice explains what personal data we receive through golem.agency and in our work with clients, why we need it, who else can access it, and how you can control it.

We collect only what we need to answer your enquiry or deliver the work.

Who is responsible for your data

Data controllerPrivate Entrepreneur Volodymyr Golembivs’kyi (trading as Golem Agency)
Registered address49A Dehtiarivska St., Kyiv 03113, Ukraine
Postal address17 Lvivska St., Kyiv 03115, Ukraine
Data requests[email protected]
Where data is storedWebsite and email — in the EU (Poland). Enquiries, CRM, tasks and files — on the agency’s own server in Ukraine

Who this notice applies to

VisitorAnyone who browses the website
Prospective clientAnyone who sends an enquiry, books a call or writes to us
ClientA representative of a company we have a contract with
Job applicants

If you apply for a vacancy, your data is covered by a separate document — the Recruitment Notice.

Our clients’ data

In some projects we work with data that belongs to our clients: CRMs, HR systems, user databases. There we act as a processor on the client’s instructions, and that relationship is governed by our contract and its data processing annex, not by this notice.

Visitor data

Type of dataWhat exactlyWhyLegal basis
Technical dataIP address, browser and device type, request time, pages viewedRunning the website and protecting it from attacks and abuseLegitimate interest
Necessary cookiesSession, form protection, your cookie choiceMaking the website and forms work properlyLegitimate interest: the website cannot work without them
AnalyticsReferral source, pages viewed, clicks, scrolling, session recordings without the contents of input fieldsUnderstanding what is useful on the website and measuring advertising performanceYour consent
Analytics

We turn on analytics (Google Analytics and Microsoft Clarity) only after you consent in the cookie banner. You can change your choice at any time — see the Cookie Policy.

Prospective client data

Type of dataWhat exactlyWhyLegal basis
Enquiry formName, phone, email (required), project detailsReplying to your enquiry and preparing a proposalSteps taken at your request before entering into a contract
Call bookingName, email, chosen timeArranging the meetingSteps taken at your request before entering into a contract
CorrespondenceWhatever you send us by email or messengerDiscussing the projectSteps taken at your request before entering into a contract

Client data

Type of dataWhat exactlyWhyLegal basis
Representatives’ contact detailsName, position, email, phoneCommunication during the projectPerformance of a contract
Contract and payment dataCompany details, invoices, acts, payment historyPayments, accounting and reportingPerformance of a contract; legal obligation
Working materialsTasks, comments and files in our project management systemDelivering the workPerformance of a contract
Neo ordersName, email, domain, form settings, access to hosting and CloudflareDeploying the website and subscription supportPerformance of a contract

If you do not provide the required data, we cannot reply to your enquiry or enter into a contract.

How long we keep data

Enquiries and correspondence that did not lead to a contract2 years from the last contact
Client dataFor the term of the contract and 3 years after it ends
Accounting and tax recordsFor the period required by Ukrainian law
AnalyticsSession recordings — 30 days; other analytics data — up to 14 months
Technical logsA limited period set by our hosting provider and Cloudflare

When the period ends, we delete or anonymise the data.

Who else can access data

Golem Agency teamOnly the data needed for a specific role and project. Every team member signs an NDA
Hosting provider (ukraine.com.ua)Hosting for the website and corporate email
CloudflareContent delivery, attack protection, loading analytics tools
GoogleAnalytics (Google Analytics), calendar for meetings
MicrosoftWebsite behaviour analytics (Microsoft Clarity)
Telegram, ThreemaDay-to-day communication — at the client’s choice
Monobank, Wise, WayForPayReceiving payments
Public authoritiesOnly on a lawful request

We do not sell personal data or share it for other companies’ advertising.

Transfers outside Ukraine

  1. European Union. The website and email are hosted on a server in Poland. Team members in Poland and Germany can access only the data their role requires.
  2. United States. Google, Microsoft and Cloudflare may process data in the US. These companies are certified under the EU-U.S. Data Privacy Framework and use the EU Standard Contractual Clauses.
  3. Other services. Telegram, Threema and Wise process data under their own privacy policies.

How we protect data

Our server is located in Ukraine, in premises with restricted physical access.

Encrypted disks on servers and work devicesEncrypted backups stored separately from the serverTwo-factor authentication
Role-based access to systemsAdministrative server access only via one person’s SSH keyAn NDA with every team member
Backup powerWeekly scheduled updatesMessages to privacy@ are read only by the person responsible

Your rights

RightWhat it means
AccessFind out what data we hold about you and get a copy
RectificationCorrect inaccurate or outdated data
ErasureAsk us to delete data we no longer need to keep
RestrictionTemporarily pause processing while we review your request
PortabilityReceive your data in a machine-readable format or have it sent to another company
ObjectionObject to processing based on legitimate interest
Withdrawing consentWithdraw consent to analytics at any time; this does not affect processing before the withdrawal
ComplaintContact the Ukrainian Parliament Commissioner for Human Rights ([email protected]) or, if you are in the EU, the data protection authority in your country
How to exercise your rights

Write to [email protected]. We may ask you to confirm your identity so that we do not disclose data to someone else, and we will reply within 30 days. If something concerns you, write to us first: most questions are resolved with a single email.

We do not make decisions about you by automated means alone.

Other provisions

Age. Our services are intended for businesses. We do not knowingly process data of people under 18. If you learn that such data has reached us, write to [email protected] and we will delete it.

Links to other websites. The website links to external resources. Their data practices are set by their owners.

Applicable law. We process data under the Law of Ukraine “On Personal Data Protection” and, for people in the EU, also under the EU General Data Protection Regulation (GDPR).

Changes. The effective date is shown at the top of this notice. We will announce material changes on the website and notify clients by email.