Privacy Policy

1. Introduction

This Privacy Policy explains how UA Consulting LLC, a limited liability company established under the laws of Ukraine ("we", "us", "our", or the "Company"), processes personal data in connection with the website at uaconsulting.eu(the "Website"), enquiries and communications made to us, and any consulting, advisory, or related services that may be separately agreed with us in writing (the "Services").

The Website is provided for informational and introductory purposes. We do not seek to collect personal data beyond what is necessary for operating the Website, responding to enquiries, communicating with you, assessing whether we can work together, performing any separately agreed Engagement, complying with legal obligations, and protecting our rights.

This Privacy Policy is provided for transparency and compliance with applicable data protection law. It does not create any contractual obligation to provide or purchase Services and does not form part of any Engagement. Any terms of cooperation are governed separately by our [Terms and Conditions] and by any written Engagement agreed between you and us.

We process personal data in accordance with the Law of Ukraine "On Personal Data Protection" (No. 2297-VI) and, where applicable, Regulation (EU) 2016/679 (the "GDPR"), including where our processing activities fall within its territorial scope.

2. Definitions

• "Personal Data" means any information relating to an identified or identifiable natural person.

• "Processing" means any operation performed on Personal Data, such as collection, storage, use, disclosure, or deletion.

• "Data Subject" means the natural person to whom Personal Data relates.

• "Processor" means a person or entity that processes Personal Data on our behalf.

• "Applicable Data Protection Law" means the Law of Ukraine "On Personal Data Protection" (No. 2297-VI), the GDPR where applicable, and any other data protection law applicable to us or to you.

• "Engagement" has the meaning given in our Terms and Conditions.

3. Who We Are and How to Contact Us

For the purposes of this Privacy Policy, the data controller is:

UA Consulting LLC Email: info@uaconsulting.eu Website: https://uaconsulting.eu

You may contact us at the email address above regarding this Privacy Policy, our handling of personal data, or the exercise of your rights.

4. Scope of This Policy

This Privacy Policy applies to Personal Data we process about:

• visitors to the Website;

• persons who contact us by email, contact form, telephone, online meeting, social media, or other channels;

• prospective clients, clients, and their representatives, employees, contractors, advisers, or other persons connected with an actual or potential Engagement;

• persons whose data is included in documents, correspondence, or materials provided to us in connection with an actual or potential Engagement.

This Policy does not apply to third-party websites, platforms, tools, or services that we do not own or control (see Section 20).

5. Personal Data We May Process

We process only the categories of Personal Data relevant to the purposes described in this Policy.

(a) Data you provide to us

• name, company, role or position, and professional affiliation;

• email address, telephone number, business address, and other contact details;

• the content of your enquiries, messages, correspondence, instructions, and communications with us;

• information contained in documents, reports, contracts, corporate or business materials, or other files you share with us;

• billing, invoicing, tax, payment, and administrative information where relevant to an Engagement.

(b) Data collected automatically through the Website

• IP address, browser type and version, device type and operating system;

• pages visited and approximate time of access;

• technical logs required for website operation, security, diagnostics, and fraud prevention.

We do not use this technical data to identify you unless necessary for security, legal compliance, protection of rights, or investigation of misuse.

(c) Data from third parties or public sources

• where relevant to an actual or potential Engagement, information lawfully received from third parties, public registers, business databases, professional sources, counterparties, or advisers, provided such processing is permitted by Applicable Data Protection Law.

6. Data We Do Not Seek to Collect

We do not intentionally collect Personal Data that is unnecessary for the operation of the Website, communication with you, assessment of potential cooperation, performance of Services, or compliance with law.

Please do not send us special categories of Personal Data such as data revealing health, racial or ethnic origin, political opinions, religious beliefs, trade union membership, biometric or genetic data, or information concerning sex life or sexual orientation — unless this is strictly necessary for a specific Engagement and we have confirmed an appropriate legal basis.

If you provide us with unsolicited or unnecessary Personal Data, we may delete it, disregard it, or process it only to the extent required to handle your communication, comply with law, or protect our rights.

7. Purposes and Legal Bases for Processing

We process Personal Data only where we have a lawful basis. Our purposes and corresponding legal bases are:

• Responding to enquiries and pre-contractual communications; assessing potential cooperation; preparing proposals or engagement documentation — Legal basis: steps taken at your request prior to entering into a contract, and/or our legitimate interests in responding to enquiries.

• Providing the Services and managing the client relationship, administration, and billing — Legal basis: performance of a contract, and/or our legitimate interests in administering our business.

• Operating, maintaining, securing, and improving the Website; preventing fraud, misuse, and security incidents — Legal basis: our legitimate interests in the proper operation and security of the Website.

• Non-essential cookies, analytics, or optional communications (where used) — Legal basis: your consent.

• Complying with legal, tax, accounting, sanctions, anti-corruption, due diligence, record-keeping, and other compliance obligations, where applicable, and responding to lawful requests — Legal basis: compliance with a legal obligation to which we are subject, and/or our legitimate interests in operating lawfully and protecting our legal position.

• Establishing, exercising, or defending legal claims, and protecting our rights and legal position — Legal basis: our legitimate interests and/or compliance with a legal obligation.

We do not sell Personal Data, and we do not use Personal Data for unrelated marketing or for automated profiling that produces legal or similarly significant effects.

Where processing under Ukrainian law requires consent or another lawful basis, we process Personal Data in accordance with the Law of Ukraine "On Personal Data Protection". Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal.

8. Cookies and Similar Technologies

The Website may use cookies or similar technologies that are necessary for its operation, security, and basic functionality; these are used on the basis of our legitimate interests. The Website is intended to avoid unnecessary tracking.

If we introduce non-essential analytics, marketing, preference, or tracking cookies, we will use them only where permitted by law and, where consent is required, only after you have given consent. You may give or withdraw consent through our cookie settings, where available, or through your browser controls. Disabling certain cookies may affect how the Website functions.

9. How We Share Personal Data

We do not sell Personal Data and do not disclose it publicly. We may share Personal Data only where necessary and where we have a lawful basis, including with:

• service providers and Processors — such as hosting, IT, cybersecurity, email, cloud, communication, and analytics providers, acting on our instructions and under appropriate confidentiality and data protection commitments;

• professional advisers — lawyers, accountants, auditors, tax advisers, insurers, and compliance advisers;

• banks, payment providers, and administrative or accounting service providers, where relevant to an Engagement;

• public authorities, courts, regulators, law enforcement, tax authorities, notaries, or registries, where required or permitted by law, or to establish, exercise, or defend legal claims;

• counterparties or other relevant parties, where necessary for an Engagement and consistent with its purpose;

• a successor entity, in connection with a reorganisation, merger, or transfer of our business, subject to appropriate safeguards.

10. Confidentiality of Communications

We treat communications with us as confidential in the ordinary course of business and do not disclose them except as described in this Policy — for a potential or actual Engagement, for professional advice, for legal compliance, or for the protection of rights.

However, sending us an enquiry, message, or document does not by itself create a client relationship, Engagement, fiduciary duty, or contractual obligation. Formal confidentiality obligations relating to a specific project may be set out separately in an Engagement, non-disclosure agreement, or other written agreement, where applicable.

11. International Data Transfers

We are established in Ukraine, and Personal Data may be processed in Ukraine. Where our Processors operate in other countries, or where you are located in the European Economic Area (EEA), Personal Data may be transferred across borders.

Where the GDPR applies and Personal Data is transferred outside the EEA, we rely on an appropriate transfer mechanism where required — such as an adequacy decision of the European Commission or the EU Standard Contractual Clauses — or, where no such mechanism applies, in limited cases on a derogation permitted under Article 49 of the GDPR (for example, where the transfer is necessary for pre-contractual steps or the performance of a contract with you, for legal claims, or with your explicit consent). Ukraine does not currently benefit from an EU adequacy decision. You may contact us for further information about the safeguards we apply.

12. Data Retention

We retain Personal Data only for as long as reasonably necessary for the purposes for which it was collected, including communication, assessment of potential cooperation, performance of an Engagement, administration, accounting, tax, legal compliance, dispute prevention, and protection of rights.

The specific retention period depends on the nature of the data, the purpose of processing, the relevant Engagement, applicable limitation periods, and legal, tax, accounting, or reporting obligations. Enquiry and correspondence data may be retained for a reasonable period after our last communication, unless a longer period is required for legal, tax, accounting, compliance, or claims-related purposes. When Personal Data is no longer required, we delete it, anonymise it, or securely archive it where continued retention is necessary for legal, compliance, or legitimate business purposes.

13. Data Security

We use appropriate technical and organisational measures intended to protect Personal Data against unauthorised access, disclosure, alteration, loss, misuse, or destruction. These may include access controls, secure communication practices, confidentiality arrangements, and limiting access to persons who need the data for legitimate purposes.

No method of transmission, hosting, or electronic storage is completely secure, and we cannot guarantee absolute security of any data transmitted to or from the Website or sent to us electronically. You are responsible for ensuring that any information you send to us is transmitted through appropriate channels, and for keeping confidential any credentials you use in connection with the Services.

14. Your Rights

Subject to Applicable Data Protection Law, you may have the right to:

• request access to your Personal Data;

• request rectification of inaccurate or incomplete data;

• request erasure of your data in certain circumstances;

• request restriction of, or object to, certain processing;

• request data portability, where applicable;

• withdraw consent at any time where processing is based on consent;

• lodge a complaint with a competent supervisory authority.

To exercise your rights, contact us at info@uaconsulting.eu. We may need to verify your identity before responding, and we will respond within the time limits required by Applicable Data Protection Law.

If you are in Ukraine, the competent supervisory authority is the Ukrainian Parliament Commissioner for Human Rights (Ombudsperson). If you are in the European Economic Area, you may lodge a complaint with the supervisory authority in your country of residence, place of work, or place of the alleged infringement.

15. Data Relating to Other Individuals

If you provide us with Personal Data relating to other individuals — such as colleagues, employees, representatives, counterparties, clients, advisers, beneficial owners, directors, or officers — you confirm that you have a lawful basis to do so and, where required, that you have informed those individuals about the processing described in this Policy.

You are responsible for ensuring that any Personal Data you provide to us is accurate, relevant, lawful, and not excessive in relation to the purpose for which it is provided.

16. Business and Professional Data

The Website and Services are primarily intended for business and professional users. Much of the Personal Data we process is business contact data, professional correspondence, or role-related information processed in the context of a business relationship. Even where such data relates to a professional role, we treat it as Personal Data where required by Applicable Data Protection Law.

17. Children

The Website and Services are not directed to children, and we do not knowingly collect Personal Data from children. If you believe a child has provided us with Personal Data, please contact us so that we can take appropriate steps.

18. Automated Decision-Making and Profiling

We do not make decisions that produce legal or similarly significant effects concerning you based solely on automated processing, including profiling. If this changes, we will update this Policy and comply with Applicable Data Protection Law.

19. Third-Party Websites and Services

The Website may contain links to third-party websites, platforms, tools, or resources. We do not control those third parties and are not responsible for their content, security, privacy notices, or data practices. If you access them, their own privacy policies and terms apply.

20. Changes to This Policy

We may update this Policy from time to time. The updated version will be posted on the Website with a revised "Last updated" date and takes effect upon publication, unless otherwise required by law. Where required by Applicable Data Protection Law, we will provide additional notice or seek your consent. We encourage you to review this Policy periodically.

21. Contact

For questions about this Policy or your Personal Data:

UA Consulting LLC Email: info@uaconsulting.eu Website: https://uaconsulting.eu