Privacy policy and consent to information processing

By interacting with our website, as well as related resources and individual pages, you agree to this privacy policy and give your consent to the processing of information that may be required for such interaction.

1. General provisions. We respect your personal data and collect, process, and transfer it to the minimum extent necessary, in strict compliance with the legislation of Ukraine, the requirements of the legislation of your country where this does not conflict with the norms of international law, including the GDPR (General Data Protection Regulation; Regulation (EU) 2016/679).

1.1. Purpose. This Policy is intended to help you understand how and why we collect, process, and transfer-or may collect, process, and transfer-your personal data as a result of your interaction with the Company’s website.

1.2. Terms and definitions. In this document, terms are used with the following meanings:

1.2.1. Company - Ukreksimleasing LLC;

1.2.2. Policy - the Company’s privacy policy;

1.2.3. Site - the Company’s website on the Internet at axisleasing.com.ua;

1.2.4. Related resources - resources, including individual pages on the Internet, with which the Company cooperates as partners, contractors, or in any other capacity under the applicable law of Ukraine and the law of the European Union;

1.2.5. Site user - a person who in any form interacts with the website or the Company’s related resources, including for the purpose of further cooperation with the Company;

1.2.6. Personal data - information that the user transmits or may transmit as a result of interaction with the website or the Company’s related resources.

2. Collection of personal data. We collect or may collect your personal data in the course of interaction with the Company’s website.

2.1. By your use of the Company’s website (which may include completing and submitting various forms and subscribing to news digests), including:

2.1.1. the user’s name;

2.1.2. phone number;

2.1.3. email address;

2.1.4. username in Telegram;

2.1.5. username on Facebook;

2.1.6. information from feedback forms on website pages;

2.1.7. cookies (in the manner provided for in Section 6 of this Policy).

2.2. By your interaction with resources related to the website.

2.3. By your contacting us by phone or email, including:

2.3.1. surname and first name;

2.3.2. other personal data where necessary.

3. Retention of personal data. We will retain your personal data for at least three years from the date of your last interaction with the Company’s website, in accordance with obligations provided for by the applicable law of Ukraine and the law of the European Union.

4. Access to personal data. We seek to maintain the confidentiality of the personal data you provide to us and have implemented appropriate policies, rules, and technical information security measures to protect personal data under our control from unauthorized access, improper use or disclosure, unauthorized modification, and unlawful destruction or accidental loss.

4.1. Conditions of access. All our partners, employees, consultants, staff, and processors who have access to your personal data and/or are involved in processing it are required to respect its integrity and confidentiality.

4.2. Where necessary, we may transfer your personal data to our legal and financial advisers, as well as:

4.2.1. to state and/or law enforcement authorities on the basis of an official request and/or a court decision;

4.2.2. to insurance, postal, and courier companies;

4.2.3. to companies in the analytics sector (Google Analytics);

4.2.4. to other third parties in the field of specific outsourcing services.

4.3. Geographic jurisdiction. To provide certain services, we may need to transfer your personal data to locations outside the jurisdiction in which you are located. In particular, if you are in the European Economic Area (EEA), please note that where necessary we transfer or may transfer your personal data to countries outside the EEA.

5. Use of personal data. We collect, process, and transfer your personal data for the purpose of shaping the scope of our services, improving and developing them; complying with laws, court decisions, and requirements of public authorities; and for investigating, settling, and preventing any disputes and disagreements. This may include, but is not limited to, the following purposes:

5.1. Provision of services. We collect and store personal data that you voluntarily provide to us when using the Site and/or our services so that we can provide the services and fulfil our obligations.

5.2. Marketing purposes. We carry out or may carry out the following marketing activities using your personal data:

5.2.1. Marketing communications. We use information we collect about you through your interaction with the Company’s website to establish appropriate marketing communication. In messages sent by email, we give users the option to opt out of further messages from the Company. Each email includes instructions on how to unsubscribe and remove your email address from the mailing list.

5.2.2. Analysis of the Company’s customers. We analyse your contact personal data that we collect about you through your interaction with the Site, telephone communication, and email. We also use cookies, log files, and other technologies to collect personal data from the computer hardware and software you use to access the Site.

5.3. Compliance with legislation. We use your personal data for business administration and compliance with legal norms, fulfilment of legal obligations, protection of our lawful rights and interests, and protection of the rights of third parties.

6. Use of cookies. A cookie file is a file containing a set of letters and numbers stored in your browser or on your computer’s hard drive. When you visit the Company’s website, certain cookie files will be placed on your device.

6.1. Cookie settings. You can change the cookie settings that will be placed when you visit our website by changing the settings in your browser.

6.2. Main types of cookies.

6.2.1. First-party cookies are cookies set by the Site the user is currently visiting;

6.2.2. Third-party cookies are cookies set by a domain other than the one the user visits on the Site. If the user visits the Site and another domain sets a cookie through this Site, it is a third-party cookie;

6.2.3. Persistent cookies remain on the user’s device for the period specified in the cookies; they are activated each time the user visits the website that created that specific cookie file;

6.2.4. Session cookies allow site operators to link the user’s actions during a browser session; the session starts when the user opens a browser window and ends when they close it. Session cookies are temporary. Once you close the browser, all session cookies are deleted.

6.3. Cookies used by the Company’s website.

6.3.1. Strictly necessary cookies. These allow you to navigate the site and use important functions such as security. Without these cookies we cannot provide the services you need. We use strictly necessary cookies to identify you as logged in on the site, determine which service you are connecting to, and for other security purposes.

6.3.2. Performance cookies. These collect information about how you use the Company’s website, which pages you visit, and inform us of any errors on your side. These cookies do not collect information that identifies you and are used only so that we can improve the Company’s website and understand what interests site users most. Some of our cookies are managed by third parties, but we do not allow third parties to use cookies for any purposes other than those listed above.

6.3.3. Functional cookies. We use them to provide you with extended functionality and personalization of the Company’s website. These files may be set by third-party providers whose services we have added or may add to the Company’s website pages.

6.3.4. Targeting cookies. With their help we give users the ability to share our stories on social networks such as Facebook and Instagram. To provide this service we reference a third-party website called AddThis. We have disabled AddThis from automatically setting cookies when navigating to our website.

6.3.5. Social media cookies. These are set alongside social media services we have added to our Site and allow site users to share content on the relevant networks. They can track the user’s browser on other sites and build a profile of interests.

6.4. By continuing to use the Company’s website, you confirm your consent to the use of cookies.

6.4.1. Strictly necessary cookies do not require your consent to their use, as they are a mandatory condition of the user’s interaction with the Company’s website.

6.4.2. If you do not wish to give consent or wish to withdraw your consent to any cookies related to performance, functionality, or targeting at any time, you need to delete, block, or disable cookies through your browser settings, in accordance with Section 7.6 of the Policy.

6.4.3. Disabling cookies affects website functionality and may or will prevent access to certain features of the Company’s website.

6.5. Deletion and blocking of cookies. You can block cookies by activating settings in your browser that allow you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you will not be able to access all or parts of our website. These settings are usually found in the “Options” or “Settings” menu of your browser.

7. Your rights regarding personal data we process.

7.1. Right of access. Where necessary, you may obtain from us confirmation of the use and processing of your personal data and, where necessary, we will provide you with a copy.

7.2. Right to rectification. If the personal data we store and process are, in your view, inaccurate or incomplete, you have the right to request their correction, provided you do so in person and your identity as the data subject can be verified in a reasonable manner.

7.2.1. If your identity is not verified or cannot be verified by us independently, we may request additional information from you or refuse to change the data.

7.2.2. In the case of a request for change, we are obliged to inform you of the measures taken or the reasons for refusal within 30 business days of such request.

7.2.3. If you require the Company to correct personal data that we have already shared with third parties, we will notify them of the correction where possible.

7.3. Right to erasure. At any time you may ask us to delete your personal data, provided you do so in person and your identity as the data subject can be verified in a reasonable manner.

7.3.1. If your identity is not verified or cannot be verified by us independently, we may request additional information or refuse to delete the data.

7.3.2. In the case of a request for erasure, we are obliged to inform you of the measures taken or the reasons for refusal within 30 business days of such request.

7.3.3. If you require the Company to delete personal data that we have already shared with third parties, we will notify them of the deletion where possible.

7.4. Right to restriction of processing. You may ask us to stop or suspend the processing of your personal data in certain circumstances, provided you do so in person and your identity as the data subject can be verified in a reasonable manner.

7.4.1. If your identity is not verified or cannot be verified by us independently, we may request additional information or refuse to restrict such processing.

7.4.2. In the case of a request for restriction of processing, we are obliged to inform you of the measures taken or the reasons for refusal within 30 business days of such request.

7.4.3. If you require the Company to restrict such processing of personal data after we have already shared it with third parties, we will notify them of such restriction where possible.

7.5. Right to data portability. In certain circumstances you have the right to receive your personal data (in a structured, commonly used, and machine-readable format) and use it elsewhere or ask us to transfer it to a third party of your choice, provided you do so in person and your identity as the data subject can be verified in a reasonable manner.

7.5.1. If your identity is not verified or cannot be verified by us independently, we may request additional information or refuse to provide you with the ability to export this personal information.

7.5.2. In the case of a request to export personal information, we are obliged to inform you of the measures taken or the reasons for refusal within 30 business days of such request.

7.5.3. Export of personal information that we have already shared with third parties is carried out by those parties upon your separate request.

7.6. Right to withdraw consent. We rely on your consent (or explicit consent) as the legal basis for processing your personal data. You have the right to withdraw that consent at any time.

7.6.1. Right to withdraw consent to the use of cookies. If you wish to withdraw consent to the use of cookies, you may do so at any time. To do so, you must delete cookies using your browser settings in accordance with Section 6 of the Policy.

7.7. Right to lodge a complaint with a supervisory authority. If you have concerns about any aspect of the Company’s privacy policy, including the manner of processing your personal data, you may notify the relevant supervisory authority.

7.7.1. Some of these rights may be limited where we have an overriding interest or legal obligation to continue processing personal data or where such data may be exempt from disclosure for reasons of professional secrecy obligations.

8. Legal bases for collection, processing, use, and transfer of your personal data.

8.1. The legislation of your country, where this does not conflict with the norms of international law.

8.2. The legislation of Ukraine, including: the Constitution of Ukraine, the Law of Ukraine “On Personal Data Protection”, the Law of Ukraine “On Information”, the Criminal Code of Ukraine, the Civil Code of Ukraine.

8.3. The law of the European Union, including: the General Data Protection Regulation (GDPR - EU General Data Protection Regulation).

9. Disclaimer. The content of the Company’s website is compiled and updated by More Tours LLC with the utmost care. Any liability for damage arising directly or indirectly from use of this website is excluded to the extent permitted by law.

9.1. The Company is not liable for violations of your rights or the rights of third parties if such violation resulted from sending any information through contact forms or enquiries by email or telephone.

9.2. This limitation of liability does not apply to life- and/or health-threatening situations arising from intentional or negligent breaches by the Company.

10. Changes to this Policy. We may from time to time amend this Policy to reflect any changes in the use of personal data. We may also make changes in accordance with applicable law or regulatory requirements.

10.1. Where possible, we will notify you by email of any material changes, but we also recommend that you review this Policy periodically for information on how we use your personal data.

10.2. Any changes to the current Policy take effect 30 days after publication of the amended new version of the Policy.

10.3. By continuing to interact with the Company’s website you confirm your agreement to the changes made to this Policy.