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.
| Data controller | Private Entrepreneur Volodymyr Golembivs’kyi (trading as Golem Agency) |
|---|---|
| Registered address | 49A Dehtiarivska St., Kyiv 03113, Ukraine |
| Postal address | 17 Lvivska St., Kyiv 03115, Ukraine |
| Data requests | [email protected] |
| Where data is stored | Website and email — in the EU (Poland). Enquiries, CRM, tasks and files — on the agency’s own server in Ukraine |
| Visitor | Anyone who browses the website |
|---|---|
| Prospective client | Anyone who sends an enquiry, books a call or writes to us |
| Client | A representative of a company we have a contract with |
If you apply for a vacancy, your data is covered by a separate document — the Recruitment Notice.
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.
| Type of data | What exactly | Why | Legal basis |
|---|---|---|---|
| Technical data | IP address, browser and device type, request time, pages viewed | Running the website and protecting it from attacks and abuse | Legitimate interest |
| Necessary cookies | Session, form protection, your cookie choice | Making the website and forms work properly | Legitimate interest: the website cannot work without them |
| Analytics | Referral source, pages viewed, clicks, scrolling, session recordings without the contents of input fields | Understanding what is useful on the website and measuring advertising performance | Your consent |
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.
| Type of data | What exactly | Why | Legal basis |
|---|---|---|---|
| Enquiry form | Name, phone, email (required), project details | Replying to your enquiry and preparing a proposal | Steps taken at your request before entering into a contract |
| Call booking | Name, email, chosen time | Arranging the meeting | Steps taken at your request before entering into a contract |
| Correspondence | Whatever you send us by email or messenger | Discussing the project | Steps taken at your request before entering into a contract |
| Type of data | What exactly | Why | Legal basis |
|---|---|---|---|
| Representatives’ contact details | Name, position, email, phone | Communication during the project | Performance of a contract |
| Contract and payment data | Company details, invoices, acts, payment history | Payments, accounting and reporting | Performance of a contract; legal obligation |
| Working materials | Tasks, comments and files in our project management system | Delivering the work | Performance of a contract |
| Neo orders | Name, email, domain, form settings, access to hosting and Cloudflare | Deploying the website and subscription support | Performance of a contract |
If you do not provide the required data, we cannot reply to your enquiry or enter into a contract.
| Enquiries and correspondence that did not lead to a contract | 2 years from the last contact |
|---|---|
| Client data | For the term of the contract and 3 years after it ends |
| Accounting and tax records | For the period required by Ukrainian law |
| Analytics | Session recordings — 30 days; other analytics data — up to 14 months |
| Technical logs | A limited period set by our hosting provider and Cloudflare |
When the period ends, we delete or anonymise the data.
| Golem Agency team | Only 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 |
| Cloudflare | Content delivery, attack protection, loading analytics tools |
| Analytics (Google Analytics), calendar for meetings | |
| Microsoft | Website behaviour analytics (Microsoft Clarity) |
| Telegram, Threema | Day-to-day communication — at the client’s choice |
| Monobank, Wise, WayForPay | Receiving payments |
| Public authorities | Only on a lawful request |
We do not sell personal data or share it for other companies’ advertising.
Our server is located in Ukraine, in premises with restricted physical access.
| Encrypted disks on servers and work devices | Encrypted backups stored separately from the server | Two-factor authentication |
| Role-based access to systems | Administrative server access only via one person’s SSH key | An NDA with every team member |
| Backup power | Weekly scheduled updates | Messages to privacy@ are read only by the person responsible |
| Right | What it means |
|---|---|
| Access | Find out what data we hold about you and get a copy |
| Rectification | Correct inaccurate or outdated data |
| Erasure | Ask us to delete data we no longer need to keep |
| Restriction | Temporarily pause processing while we review your request |
| Portability | Receive your data in a machine-readable format or have it sent to another company |
| Objection | Object to processing based on legitimate interest |
| Withdrawing consent | Withdraw consent to analytics at any time; this does not affect processing before the withdrawal |
| Complaint | Contact the Ukrainian Parliament Commissioner for Human Rights ([email protected]) or, if you are in the EU, the data protection authority in your country |
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.
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.
