Privacy Notice (extended version)
Introduction
The company “Golem Agency” (“Golem” or “we”) welcomes you.
We care about your personal data, and that's why we have created this Privacy Notice. The Notice informs you how your personal data is collected, stored, and used, and provides a step-by-step description of what happens when you interact with our website accessible via the provided link https://golem.agency/ (“Website”).
Content
About us as the Controller of your personal data
| Data controller | Private Entrepreneur Volodymyr Golembivs’kyi, tax number 3314019996 |
|---|---|
| Postal address | Ukraine, 03113, Kyiv, 49 Dehtiarivs’ka street |
| Email address | privacy@golem.agency |
| Data location | Ukraine |
About you as a data subject
By using the Website, you become our user ("User"). We categorise all Users separately for the purpose of understanding the stages of your interaction with the Website, adhering to the principle of data minimisation, and facilitating the processing of your requests regarding your own data.
| Visitor | All users who visit our Website. |
|---|---|
| News subscriber | Users who have subscribed to our newsletters. |
| Reader | Users who submit requests to receive e-books. |
| Listener | Users who register their participation in our webinars. |
| Potential client | Users who submit service inquiries through contact forms or contact details provided on the Website. |
If you respond to our job vacancy through job search services or communicate with us regarding vacancies via email, you become a "Candidate" and your data is governed by our Recruitment Notice.
Age restriction
We consciously do not process data of visitors who have not reached the age of 18 without the consent of their legal representatives.
If you are such a visitor or their legal representative, please contact us at the email address provided privacy@golem.agency and we erase it.
Personal Data
Data sources
We receive personal data when you visit and interact with our Website. The extent of personal data collected depends on your actions on the Website. We may also receive data from third parties, depending on your browser settings and the features you use.
Lawful basis for processing
For processing your personal data, we rely on the following legal bases:
- Performance of the contract: to take pre-contractual measures, enter into a contract, and fulfil contractual obligations (e.g., Terms of Use) with you.
- Legitimate interest: to protect our legitimate interests.
- Consent: for additional processing for specific purposes.
Visitor data
When you visit the Website, certain data is collected automatically. These technical and other data are necessary for us to operate, support, and improve the Website's functionality.
| Type of data | Description | Reasons for processing | Lawful basis |
|---|---|---|---|
| Technical data | Information about your visits and usage of the Website, including: referral sources, time, and duration of visits, navigation | Improving your user experience on the Website | Performance of the contract |
| Necessary cookies | Information necessary for the operation of the Website | Ensuring the proper functioning of the Website and making it easier to use | Performance of the contract |
| Marketing cookie | Marketing information | Providing relevant advertising tailored to you | Consent |
| Statistical cookie | Statistical data on the usage of the Website | Tracking the effectiveness of the Website for statistical and analytical purposes | Performance of the contract |
Data retention period
| Data processed based on the conclusion and performance of a contract | Stored for a period of 1 year from the date of the last request |
|---|---|
| Data processed based on legitimate interest | Stored for a period of 1 year from the date of the last request |
Listener data
When you send us a request to receive an e-book, you become categorized as a reader.
| Type of data | Description | Reasons for processing | Lawful basis |
|---|---|---|---|
| Data of request | Name | Identification of the listener | Performance of the contract |
| Email address | Providing access and input data for the webinar | Performance of the contract | |
| Position | Keeping track of request statistics | Legitimate interest |
Data retention period
| Data processed based on the conclusion and performance of a contract | Stored for a period of 1 year from the date of the last request |
|---|---|
| Data processed based on legitimate interest | It is kept as statistical data for 3 years |
Since webinars are conducted outside of our Website, the data that may be collected during the webinar will be governed by the privacy documents of the respective platforms.
Potential client data
When you contact us using the contact forms on our Website, you become a potential client.
Upon receiving your request for our services, we may process additional data to fulfil our obligations. This may include checks for conflicts of interest and actions to prevent fraud.
We may also use your contact information for payment purposes and to inform you about any changes to our agreement terms.
| Type of data | Description | Reasons for processing | Lawful basis |
|---|---|---|---|
| Feedback data | Name | Identification of the representative | Performance of the contract |
| Email address | Communication regarding the inquiry | Performance of the contract | |
| The company name | Identification of the representative | Legitimate interest | |
| Position | Identification of the representative | Legitimate interest | |
| Phone number | Identification of the representative | Legitimate interest |
Data retention period
| Data processed based on the conclusion and performance of a contract | Stored for a period of 3 years from the date of the last communication |
|---|
- If you refuse to provide us with the necessary personal data, we will not be able to provide you with services or interact with you in any other way under the contract.
- The Website may contain links to other resources for which we are not responsible for the content and privacy practices. When you leave our Website, please familiarise yourself with the personal data processing policies of those websites.
The data we receive from the third parties
We may receive some data from third parties, but we do not necessarily receive it. This depends on the features you use and your settings.
The scope of the data collected, the purposes and the basis for processing are determined by the relevant personal data documents of these third parties.
| Categories of third parties | Reasons for processing |
|---|---|
| Marketing and analytics tools | We use analytics tools to understand and improve our business |
| Social networks | We use various social networks to spread information about our activities |
| Podcast services | We may publish our podcasts on various services through which you may reach our Website |
| Services for finding interns, job candidates | We use various services to search for job candidates |
| CRM systems | We use CRM systems to develop our business |
| Messengers | We use messengers to communicate with you in ways that are convenient for you |
| Payment services | We use the services of payment services to make payments |
To obtain a detailed list of such third parties, please contact us.
Data transfer to third parties
We may transfer your personal data to our subcontractors to the extent necessary for the provision of services and user support. We may also need to transfer data to other parties as indicated below.
Details
We transfer your data on the following grounds:
- Contractual performance: We may transfer your data to our subcontractors and partners for the purpose of entering into and fulfilling contractual obligations. These agreements are primarily required to provide you with quality services.
- Consent: We may transfer your personal data based on your consent.
- Legal compliance: We may disclose your personal data to third parties if necessary for:
- Complying with requests from governmental authorities, court orders, or other legal requirements;
- Preventing unauthorised use of the Website or violations of our policies;
- Protecting against third-party claims;
- Assisting in the prevention or investigation of fraud.
Protection of your Data
We protect the information on our computer servers in a controlled and secure environment, safeguarded against unauthorized access, use, or disclosure.
We also implement intelligent organisational security measures to ensure protection, including:
Organizational security measures
| Staff training | Description | Internal policies and instructions |
| Protection during data transfer | Careful use of Internet resources | Non-disclosure agreements (NDA) |
Physical security measures
| Closed-circuit television (CCTV) | Physical perimeter security | Security |
| Restricted access to premises | Alternative power supply | Alarm system |
Technical security measures
| Encryption technologies | Backup and recovery | Two-factor authentication |
| Licensed software | Keeping registers of consent | Password controls |
Your rights
You as a subject of personal data in relation to your data have the rights described below. Contact us to exercise them.
| The Rights | Description |
|---|---|
| Right to information | You have the right to know and be informed about the sources of collection, the location of your personal data, the purposes of their processing, and the location of the data controller |
| Right to access your personal data | You have the right to request access to and receive all of your data that we store |
| Right to object to the processing of your personal data | You have the right to submit a request with a valid reason to object to the processing of your personal data |
| Right to erasure your personal data | You have the right to submit a request with a valid reason to erasure your personal data if such data is processed unlawfully or is inaccurate |
| Right to rectify your personal data | You have the right to submit a request with valid reason to rectify your personal data if such data is processed unlawfully or is inaccurate |
| Right to personal data protection | You have the right to protect your personal data from unlawful processing and accidental loss, destruction, damage due to deliberate concealment, non-provision, or untimely provision, as well as protection against the disclosure of information that is inaccurate or harms your honor, dignity, and business reputation |
| Right to file complaints regarding the processing of your personal data with the Commissioner or Court | You have the right to file complaints regarding the processing of your personal data with the Commissioner for Human rights of the Verkhovna Rada of Ukraine by email hotline@ombudsman.gov.ua. Please note! If you are dissatisfied with our processing practices, please contact us. |
| Right to withdraw consent | You may withdraw consent to processing at any time. You also have the right to place restrictions on the processing of your personal data when giving consent |
| Right to use legal remedies in case of violation of the personal data protection legislation | You have the right to protect your personal data through legal remedies as established by the laws |
| Right to know the mechanism of automated processing of personal data | You have the right to request information from us about the use of automated processing mechanisms for personal data. Please note! We do not use any automated decision-making processes. |
We may ask you to verify your identity before responding to a request. We will process your request and provide you with an answer within 30 days of receiving it.
Cookie
We use necessary cookies for the functioning of the Website. By using cookies, we collect automatically gathered data. You can read more about this in our Cookie Policy.
If you wish to disable cookies, you can find instructions on managing your browser settings through the following links:
Privacy Notice update
This Message and the relationships falling under its scope are governed by the Law of Ukraine "On Personal Data Protection." As a best practice, we also adhere to the General Data Protection Regulation.
The current legislation and requirements regarding the processing of personal data, as well as the functionality of the Website, may change. In such a case, we will publish a new version of this Message on the Website.
If significant changes are made to the Website that affects your privacy, we will notify you by displaying the information on the main page of the Website and, if necessary, seek your consent.
You have read a full version of our Privacy Policy. Back to the brief version.
