Privacy and Cookies Policy

www.theukrainian.eu

This Website collects some Personal Data from its Users.

This Privacy and Cookie Policy describes the type of information that we collect from you through the use or
provision of coaching services ("Services”) on our Website, www.theukrainian.eu (the "Website"), how that
information may be used or disclosed by us and the safeguards we use to protect it. A user of coaching services
shall be known as a “user”.

Our Platform and Services may contain links to third party websites that are not covered by this Privacy and
Cookie Policy. We therefore ask you to review the privacy statements of other websites and applications to
understand their information practices.

We have drafted this Privacy and Cookie Policy to be as clear and concise as possible. Please read it carefully to
understand our policies regarding your information and how we will treat it. By using or accessing our Website or
the Services, you agree to the collection, use and disclosure of information in accordance with this Privacy and
Cookie Policy. This Privacy and Cookie Policy may change from time to time and your continued use of the
Website or the Services is deemed to be acceptance of such changes, so please check periodically for updates.

This Privacy and Cookie Policy was last updated in July 2022. Please check back regularly to keep informed
of updates to this Privacy and Cookie Policy. Please read this Privacy and Cookie Policy carefully and ensure
that you understand it. Your acceptance of our Privacy and Cookie Policy is deemed to occur upon your first use
of our Website. If you do not accept and agree with this Privacy and Cookie Policy, you must stop using our
Website immediately.

Owner and Data Controller

Owner contact email: dmilashchuk@gmail.com

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies,
Usage Data, email address, first name, last name, date of birth, phone number, address and country.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy
policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using
this Website.

Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may
make it impossible for this Website to provide its services. In cases where this Website specifically states that
some Data is not mandatory, Users are free not to communicate this Data without consequences to the
availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by
this Website serves the purpose of providing the Service required by the User, in addition to any other purposes
described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Website and
confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or
unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures
and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be
accessible to certain types of persons in charge, involved with the operation of this Website (administration,
sales, marketing, legal) or external parties (such as third-party technical service providers, mail carriers, hosting
providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner.
The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
processing is related to a task that is carried out in the public interest or in the exercise of official
authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in
particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement
necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the
processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than
their own. To find out more about the place of processing of such transferred Data, Users can check the section
containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or
to any international organization governed by public international law or set up by two or more countries, such as
the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or
inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to
such processing, if such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal
Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an
authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to
erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the
retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following
purposes: Access to third-party accounts, Interaction with external social networks and platforms, Analytics,
Handling payments, Content commenting, Registration and authentication, Displaying content from external
platforms, Managing contacts and sending messages and Platform services and hosting.

Users can find further detailed information about such purposes of processing and about the specific Personal
Data used for each purpose in the respective sections of this document.

Facebook permissions asked by this Website

This Website may ask for some Facebook permissions allowing it to perform actions with the User's Facebook
account and to retrieve information, including Personal Data, from it. This service allows this Website to connect
with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to
the Facebook privacy policy.

The permissions asked are the following:

Basic information
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain
connections of the User, such as the Friends, are also available. If the User has made more of their
Data public, more information will be available.
About Me
Provides access to the 'About Me'; section of the profile.
Access Friend Lists
Provides access to any friend lists the User created.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Access to third-party accounts

This type of service allows this Website to access Data from your account on a third-party service and perform
actions with it. These services are not activated automatically but require explicit authorization by the User.

Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to
keep track of User behaviour.

Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected
to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookies and Usage Data. Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Content commenting

Content commenting services allow Users to make and publish their comments on the contents of this Website.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an
email address among the Personal Data provided by the User, it may be used to send notifications of comments
on the same content. Users are responsible for the content of their own comments. If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

Facebook Comments (Facebook, Inc.)
Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User
to leave comments and share them on the Facebook platform.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of
this Website and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Instagram widget (Instagram, Inc.)
Instagram is an image visualization service provided by Instagram, Inc. that allows this Website to
incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.

YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows this Website to
incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the
pages of this Website. The interaction and information obtained through this Website are always subject to the User’s privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook
social network provided by Facebook, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google+ +1 button and social widgets (Google Inc.)
The Google+ +1 button and social widgets are services allowing interaction with the Google+ social
network provided by Google Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

LinkedIn button and social widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social
network provided by LinkedIn Corporation.

Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

YouTube button and social widgets (Google Inc.)
The YouTube button and social widgets are services allowing interaction with the YouTube social
network provided by Google Inc.
Personal Data collected: Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield participant.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Platform services and hosting

These services have the purpose of hosting and running key components of this Website, therefore
allowing the provision of this Website from within a unified platform. Such platforms provide a wide
range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-
commerce, payment processing – that imply the collection and handling of Personal Data. Some of
these services work through geographically distributed servers, making it difficult to determine the
actual location where the Personal Data are stored.

Wix (Wix.com, Ltd.)

Wix is a platform provided by Wix.com, Ltd. that allows the Owner to build, run and host this Website.
Wix is highly customizable and can host websites from simple blogs to complex e-commerce
platforms. Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Israel – Privacy Policy.

Registration and authentication

By registering or authenticating, Users allow this Website to identify them and give them access to
dedicated services. Depending on what is described below, third parties may provide registration and authentication
services. In this case, this Website will be able to access some Data, stored by these third-party
services, for registration or identification purposes.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner
or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by
providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can
object to that processing at any time without providing any justification. To learn, whether the Owner is
processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this
document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this
document. These requests can be exercised free of charge and will be addressed by the Owner as early as
possible and always within one month.

Cookie Policy

This Website uses Cookies. All Cookies used by and on our Platform are used in accordance with current EU
Cookie Law. We use cookies to distinguish users and improve our Platform.

'Session cookies' allow us to track your actions during a single browsing session, but they do not remain on your device afterwards.

'Persistent cookies' remain on your device between sessions. We use them to authenticate you and to remember
your preferences. We can also use them to balance the load on our servers and improve your experience on our
site.

Session and persistent cookies can be either first or third party cookies. A first-party cookie is set by the website
being visited; a third-party cookie is set by a different website. Both types of cookie may be used by us or our
business partners.

Third Party Cookies we use include: Google Analytics, which is a web analytics service provided by Google, Inc.
The cookies used by Google Analytics help us to analyse how users use the site and to count the number of
people who use the site. Google Analytics stores your IP address anonymously and neither us or Google
associate your IP address with any personally identifiable information. We also use cookies from social media
websites and applications to understand how you are finding and accessing the site.

All our cookies are categorised by the role they fulfil on our Platform:

a. Strictly Necessary: these are essential to enable you to move around our Platform and use features such as
secure services. Without these cookies such services could not be provided;

b. Functionality: allow the Platform to remember your choices and to personal certain features. These cookies
may be anonymised and cannot track your browsing activity on other websites;

c. Performance: collect information as to how users use the Platform. These cookies don't collect information that
identifies a visitor. The information collected is aggregated and used to improve our Platform.

d. None of the cookies employed are classified as behavioural targeting.
If at any time you wish to disable our cookies, you may do so through the settings on your browser. However, if
you choose to disable or delete our cookies that will prevent certain important areas and features of our service
from functioning properly. (but if you do so you will not be able to use certain important features of our service).
You can find additional information at AboutCookies.org.

Notwithstanding, the audit undertaken regarding our cookies, it is possible we may have missed one from our list
above. If you happen to find one that is being set on our site, please let us know.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to
possible legal action arising from improper use of this Website or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public
authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional
and contextual information concerning particular Services or the collection and processing of Personal Data upon
request.

System logs and maintenance

For operation and maintenance purposes, this Website and any third-party services may collect files that record
interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any
time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read
their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on
this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to
Users via any contact information available to the Owner. It is strongly recommended to check this page often,
referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall
collect new consent from the User, where required.

Your Consent
By using our Website and by way of acknowledgement, you consent to our Privacy and Cookie Policy.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal
identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which
can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the
URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to
the server, the size of the file received in response, the numerical code indicating the status of the server's
answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating
system utilized by the User, the various time details per visit (e.g., the time spent on each page within the
Application) and the details about the path followed within the Application with special reference to the sequence
of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of
the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines
the purposes and means of the processing of Personal Data, including the security measures concerning the
operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current
member states to the European Union and the European Economic Area.

Small sets of data stored in the User's device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of
Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Website, if not stated otherwise within this document.