Privacy policy

We, the Limited Liability Company “Netwave,” hereinafter referred to as “Netwave,” “We,” “Us,” “Our,” value your personal data and make every effort within our capabilities to ensure the integrity and security of your personal data, as well as information about you.

This Privacy Policy, hereinafter referred to as the “Policy,” applies to the processing of personal data that Netwave may obtain from individuals (data subjects) based on the Constitution of Ukraine, the Law of Ukraine “On Personal Data Protection” dated June 1, 2010, No. 2297-VI (hereinafter referred to as the “Law”), as well as the General Data Protection Regulation of the European Union 2016/679 (GDPR) and other applicable European data protection laws, collectively referred to as the “Legislation.” It is an integral part of the agreement between you and Netwave regarding the use of this website.

This Privacy Policy has been developed to inform you about:

• What personal data is;
• What personal data of yours we collect;
• How and why we use it;
• To whom we disclose your personal data;
• How we protect the confidentiality of your personal data;
• How to contact us and whom to contact if you have questions regarding the processing of your personal data.
• We process your personal data only if one of the conditions specified in Article 6 of the GDPR is met, including but not limited to:
• You have given consent to the processing of personal data;
• Processing is necessary for the conclusion or performance of a contract with you;
• Such processing is required by the legislation of the country in which you are located.

1. Terms and Definitions

Personal data – information or a set of information about an identified or identifiable natural person (User);

Limited Liability Company “Netwave” – a company established in accordance with the legislation of Ukraine, with a legal and postal address at: Ukraine, 04112, Kyiv, Aviakonstruktora Ihoria Sikorskoho Street, 8.

“Processing of personal data” refers to any action or combination of actions, such as collection, registration, accumulation, storage, adaptation, alteration, restoration, use, and dissemination (distribution, realization, transmission), anonymization, and destruction of personal data, including using information (automated) systems.

“Disclosure of personal data” encompasses actions involving the transfer of information about a physical person with the consent of the data subject.

“Use of personal data” encompasses any actions by Netwave related to the processing of this data, actions related to their protection, as well as actions related to granting partial or full rights to process personal data to other subjects of relationships related to personal data, carried out with the consent of the data subjects, in accordance with the legislation of Ukraine and the legislation of the European Union.

“Depersonalization of personal data” involves the removal of information that allows for the direct or indirect identification of an individual.

A “User” is a subject of personal data, any capable natural person who has agreed to this Policy in their own interests, has viewed or registered on the website https://netwave.ua using the Internet.

The “Website” is an electronic information resource owned by Netwave, accessible via the domain name (address) https://netwave.ua.

“Registration” refers to actions by the User to fill out and submit the registration form provided by Netwave on the Website, resulting in the provision of consultations in response to User requests, the placement of orders for the supply of products, or the performance of any other actions.

The “Policy” is this privacy policy, developed in accordance with the requirements of the Legislation and located on the Website.

A “Controller of personal data” is a natural or legal person who determines the purposes and means of processing personal data and is responsible for their processing. Netwave is the controller of your personal data when you use the Website, provide feedback, or communicate with Netwave, in accordance with this policy. The controller of personal data is the “owner of personal data” in the terminology of Ukrainian legislation.

A “Processor of personal data” is a natural or legal person who, on the basis of instructions (guidelines, orders) of the data controller, processes personal data for the data controller. By using the Website, you may decide to transfer personal data of your clients to Netwave, in which case you are the data controller, and Netwave is the data processor for the purposes of the Legislation. The processor of personal data is the “manager of personal data” in the terminology of Ukrainian legislation.

2. General Provisions

2.1. This Policy applies to all your personal data that may be obtained by us during your use of the Website.

This Policy applies to personal data obtained both before and after the effective date of this Policy.

2.2. The purpose of this Policy is to provide you with the necessary information that allows you to assess which personal data are processed by us, the methods of their processing, and ensuring their security.

2.3. By using the Website, you acknowledge your consent to the processing of your personal data by Netwave, including through third parties when you provide your personal data, in accordance with this Policy.

2.4. In case of disagreement with the terms of this Policy, you are obliged to cease using the Website.

2.5. Consent to the processing of personal data can be revoked by the data subject. In the event of the data subject’s withdrawal of consent to the processing of personal data, Netwave has the right to continue processing personal data without the data subject’s consent, provided there are grounds specified in the Legislation.

2.6. Netwave does not verify the accuracy of personal data provided by the User and cannot assess their legal capacity. However, Netwave assumes that the User acts conscientiously, carefully, provides accurate and sufficient personal data, and makes all necessary efforts to maintain such data up to date, without violating the rights of third parties.

2.7. By agreeing to the terms of this Policy, you confirm that at the time of collecting personal data, you have informed the individuals whose personal data are being transferred, of the content and purposes of collecting personal data. You confirm (guarantee) that the personal data transferred to us for processing have been provided with the consent of the owners of personal data and within the framework of the Legislation.

2.8. Netwave, upon receiving personal data from the User, does not undertake the obligation to inform the data subjects (their representatives) whose personal data have been transferred to it about the commencement of personal data processing. This obligation lies with the User who provided the personal data when entering into an agreement with the data subject and/or obtaining consent for such transfer.

2.9. The processing of your personal data is carried out in accordance with the requirements of the Law. The processing of personal data of individuals located within the EU or who are EU citizens is regulated, in particular, by the General Data Protection Regulation (GDPR). Additionally, the legislation of other countries may establish additional requirements.

2.10. This Policy applies to all information that Netwave may obtain about the User when the User uses the Website, as well as during the performance of any agreements and contracts between Netwave and the User.

2.11. This Policy is an internal document of Netwave.

3. Composition of Personal Data

3.1. Netwave processes the User’s personal data provided by the User when using the Website https://netwave.ua/, to carry out its activities and fulfill its obligations.

3.2. The User’s personal data include: last name, first name, patronymic, email address, mobile/landline phone number, country of residence, workplace, position, date of birth, as well as any other data obtained from the data subject during the use of the Website’s functionality.

We ask you to provide only the personal data that are necessary for placing an order, providing the selected service, receiving informational newsletters, or responding to your specific request/complaint. However, if you decide to provide us with additional personal data, we will also be able to process them with the necessary level of protection.

3.3. Netwave may establish requirements for the composition of personal data that must be provided when using the Website. If certain information is not indicated by Netwave as mandatory, its provision or disclosure is at the discretion of the User.

3.4. Data that are automatically transmitted to Netwave when the User uses the Website through software installed on the device include: IP address, information about the browser and type of operating system of the device, technical characteristics of hardware and software, date and time of access to the Website, and cookies.

3.5. We do not intentionally request personal data from children under 16 years of age, nor do we offer them goods and/or services. If we learn that a child under the age of 16 has provided their personal data without parental consent, we will take all necessary actions to delete such information.

4. Grounds and Purpose of Personal Data Processing

4.1. The grounds for processing personal data are:

• The User’s consent to Netwave processing their personal data.
• Conclusion and execution of a contract, with the User being one of the parties as the data subject, or for taking pre-contractual measures at the request of the data subject.
• The necessity of Netwave’s compliance with the requirements stipulated by the Legislation.

4.2. The purpose of processing personal data is:

• Carrying out functions assigned to Netwave in accordance with Ukrainian law and GDPR.
• Collecting, storing, and processing personal data received from the Website in accordance with the Law and GDPR.
• Providing the User with information about services, current promotions, and special offers related to the services provided by Netwave through the Website.
• Identifying the data subject when using the Website.
• Communication with the data subject when necessary, including the direction of offers, informational materials, messages, information, and inquiries, as well as processing the data subject’s requests.
• Improvement of the quality of the Website, its usability, development of new features, and improvement of service quality.
• Enhancement of the data subject’s professional skills and qualifications.
• Conducting statistical and other research based on anonymized data.
• Fulfillment of contractual and other obligations by Netwave to the User under agreements concluded between Netwave and the User or third parties in the User’s interest.
• To fulfill Netwave’s legal obligations, such as crime prevention, detection, or investigation, and preventing losses or fraud.

5. Main Principles of Personal Data Processing

5.1. Processing of personal data by Netwave is based on the following principles:

5.1.1. Lawfulness of the purposes and methods of personal data processing.

5.1.2. Good faith of Netwave, as the data controller, achieved through compliance with the legal requirements for personal data processing.

5.1.3. Achieving specific, predefined purposes of personal data processing.

5.1.4. Alignment of the purposes of personal data processing with the purposes specified and declared during the collection of personal data.

5.1.5. Compliance of the list and volume of processed personal data, as well as methods of personal data processing, with the stated purposes of data processing.

5.1.6. Accuracy of personal data, their sufficiency for the purposes of processing, and the inadmissibility of processing excessive personal data relative to the purposes of processing.

5.1.7. Ensuring the accuracy, sufficiency, and, where necessary, the relevance of personal data in relation to the purposes of personal data processing.

5.1.8. The prohibition of combining databases containing personal data, the processing of which is carried out for incompatible purposes.

5.1.9. Storage of personal data in a form that allows identifying the data subject no longer than required by the purposes of their processing.

5.2. Processed personal data shall be destroyed or anonymized upon achieving the purposes of processing or when the necessity to achieve these purposes ceases, unless otherwise provided by the legislation of Ukraine and GDPR.

5.3. Processing of personal data is carried out by Netwave for statistical or other research purposes, subject to mandatory anonymization of personal data.

5.4. Netwave does not process personal data related to racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties and professional unions, criminal convictions, as well as data related to health, sexual life, biometric, and genetic data.

5.5. Processing of personal data is carried out in accordance with the conditions established by the legislation of Ukraine and GDPR.

6.Terms of Personal Data Processing

6.1. The terms of personal data processing are determined taking into account the purposes of processing but not longer than prescribed by the Law and GDPR.

6.2. Personal data, the processing (storage) term of which has expired, shall be destroyed or anonymized, unless otherwise provided by the legislation. The storage of personal data is carried out in a form that allows identifying the data subject no longer than required by the purposes of personal data processing unless the storage period of personal data is established by the legislation. Processed personal data shall be destroyed or anonymized upon achieving the purposes of processing or when the necessity to achieve these purposes ceases, unless otherwise provided by the legislation. Netwave will delete your personal data within 30 calendar days from the moment of receiving a request from you for their deletion.

6.3. At the same time, Netwave reserves the right to retain some of the personal data necessary for compliance with the legislation and for the period required to meet the requirements of the legislation (for example, applicable legal norms may require data retention for tax reporting, or some data may be necessary for billing purposes for outstanding amounts).

6.4. Over time, we may minimize your personal data that we use, or even make your data anonymous so that they can no longer be associated with you personally. In this case, we may use this information without further notifying you.

7. Persons Authorized to Process Personal Data on Behalf of Netwave

7.1. To achieve the objectives of this Policy regarding the processing of personal data, only those employees of Netwave who are entrusted with such responsibilities in accordance with their job duties shall be authorized. Access by other employees may be granted exclusively in cases provided for by the legislation. Netwave guarantees from its employees the observance of confidentiality and ensuring the security of personal data during their processing.

7.2. Netwave has the right to transfer personal data to third parties in the following cases:

• The data subject has expressed their written consent to such actions;
• Service providers: Sometimes we may transfer your data to service providers who assist us in providing and maintaining our services. For example, when it is necessary to provide a feature you have requested (e.g., a social media profile feature). Like all third parties we work with, service providers enter into agreements with us obligating them to use your data exclusively to provide a particular service for the service and to use them in accordance with this Privacy Policy;
• Advertising partners: We may collaborate with third parties that provide advertising services and organize display ad management on our or their websites. To cooperate with these organizations, we may transfer personal data to them. All third parties with whom we share this information are required to use your personal data in accordance with this Privacy Policy. We and our partners may use cookies and other tracking technologies, such as pixels and web beacons, to collect information about your activity on our and other websites for the purpose of developing personalized advertising campaigns based on your preferences and actions. Please review our Cookie Policy for more information.
• Social media platforms: We may transfer your data to social media platforms in accordance with the provisions described above;
• CMS, CRM systems, and other websites: We may transfer your data to systems and websites integrated with our service upon your request, in accordance with the provisions described above.
• Transfer provided by legislation within the framework of the procedure established by it. In this case, access to personal data shall not be granted to a third party if the said party refuses to assume obligations to ensure compliance with the requirements of the law or cannot fulfill them.

8. Implementation of Personal Data Protection

8.1. Netwave’s activities related to the processing of personal data in information systems are closely linked to the protection of the confidentiality of the information received by Netwave, provided it does not contradict the current legislation.

8.2. The personal data protection system includes organizational and/or technical measures determined taking into account current threats to the security of personal data and information technologies used in information systems. Netwave updates these measures when new technologies emerge, as needed.

8.3. The exchange of personal data during their processing in information systems at Netwave is carried out through communication channels protected by technical means of information security.

8.4. When processing personal data in Netwave’s information systems, the following are ensured:

• Measures to prevent unauthorized access to personal data and/or their transfer to persons who are not authorized to access such information;
• Timely detection of facts of unauthorized access to personal data;
• Prevention of any impact on automated personal data processing means that may disrupt their operation;
• The ability to promptly restore personal data modified or destroyed due to unauthorized access to them;
• Continuous monitoring of the security level of personal data.

8.5. Confidentiality is maintained regarding personal information, except in cases where the website’s technology or user settings of the software used by the user allow open information exchange with other website users or any internet users.

8.6. Netwave implements the following requirements of the legislation on personal data:

• Requirements for the confidentiality of personal data;
• Requirements to ensure the data subject’s exercise of their rights;
• Requirements to ensure the accuracy of personal data and, if necessary, their relevance to the purposes of personal data processing (including taking measures to delete or clarify incomplete or inaccurate data);
• Requirements for the protection of personal data from unauthorized or accidental access to them, destruction, distortion, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions with personal data;
• Other requirements of the legislation.

8.7. According to the legislation, Netwave independently determines the composition and list of measures necessary and sufficient to ensure compliance with the obligations set forth in the legislation on personal data regarding protection against unauthorized access or illegal processing and against accidental loss, destruction, or damage.

Netwave adheres to the principle of minimizing personal data. We process only the information about you that is necessary or the information you provide beyond what is required for processing, with your consent. Additionally, we have configured all website interfaces to ensure maximum confidentiality. These settings can be adjusted at your discretion. When transmitting personal data to government authorities, we always use the most secure and proven methods of data transmission.

9. Cookies and Other Tracking Technologies

Cookies are small text files that websites store on your computer or mobile device when you start using them. Thus, the website will remember your preferences and actions for a certain period, so you don’t have to enter this information again. Our cookie files do not identify an individual user but rather identify the computer or mobile device you use.

Cookies and other tracking technologies on our website can be used in various ways, such as for website operation, traffic analysis, or advertising purposes. We use cookies and other tracking technologies to improve the quality and efficiency of our services.

We also use third-party cookies through analytical and other services:

• Google Analytics, Google Optimize, and Google AdWords (Google Privacy Policy – https://policies.google.com/privacy?hl)
• Facebook (Facebook Privacy Policy – https://www.facebook.com/policy.php)
• Twitter (Twitter Privacy Policy – https://twitter.com/en/privacy)
• LinkedIn (LinkedIn Privacy Policy – https://www.linkedin.com/legal/privacy-policy)
• Other involved services.

For additional information on what cookies are, how they work, how to manage them, or how to delete them, you can visit www.allaboutcookies.org.

Please note that in the settings of some internet browsers, you can configure the prohibition of cookies and other tracking technologies. However, you should understand that disabling some cookies may limit the functionality of the website, and you may not be able to use all its features. Additionally, some pages may not work correctly.

10. Rights of the Data Subject

10.1. To know about the sources of collection, the location of their personal data, the purpose of their processing, the location of the personal data controller, or to provide an appropriate authorization to obtain this information by authorized persons, except as provided by the legislation.

10.2. To receive information about the conditions for providing access to personal data, including information about third parties to whom their personal data is transferred.

10.3. To have access to their personal data.

10.4. To receive a response regarding whether their personal data is being processed or stored, no later than thirty calendar days from the date of the request, except as provided by law, and to know the specifics of such processing.

10.5. To express a reasoned demand to Netwave to object to the processing of their personal data.

10.6. To express a reasoned demand for the change or destruction of their personal data if the data is processed illegally or is inaccurate.

10.7. To protect their personal data from unlawful processing and accidental loss, destruction, damage due to willful concealment, non-disclosure, or untimely provision, as well as to protect against the provision of information that is inaccurate or discredits the honor, dignity, and business reputation of an individual.

10.8. To file complaints about the processing of their personal data with Netwave or with a court.

10.9. To apply legal remedies in case of violation of legislation on personal data protection.

10.10. To make reservations regarding the restriction of the right to process their personal data when giving consent.

10.11. To withdraw consent to the processing of personal data.

10.12. To familiarize themselves with the mechanism of automatic processing of personal data.

10.13. To protect against automated decision-making that has legal consequences for them.

10.14. You can exercise your rights regarding your personal data by contacting us through any of the communication channels specified in this Policy. We will respond to your request as soon as possible, but in any case, no later than 30 calendar days from the date of receiving the request.

10.15. Netwave may entrust the processing of personal data to a third party with the consent of the data subject unless otherwise provided by the legislation of Ukraine and GDPR. This is done based on an agreement with the third party, the condition of which is the obligation to maintain confidentiality and not disclose personal data.

10.16. Representatives of State Authorities (including supervisory, regulatory, law enforcement, and other authorities) have access to personal data processed by Netwave to the extent and in the manner determined by the legislation of Ukraine.

Other rights of data subjects in accordance with the GDPR:

11. Right to Information

We are ready to provide data subjects with information about what personal data of theirs we process. If you wish to know what personal data we process about you, you can make a request for this information at any time, including by contacting Netwave. The list of data that we must provide to you can be found in Articles 13 and 14 of the GDPR. In this case, when contacting us, you must specify your specific requirements so that we can consider your request on legal grounds and provide a response.

Please note that in cases where we cannot verify your identity through electronic communication or during your phone call, or in case of justified doubts about your identity, we may ask you to provide a document proving your identity, including by personally coming to the location of Netwave’s administration. Only in this way can we avoid disclosing your personal data to a person who may impersonate you.

We will process requests as quickly as possible, but please be aware that providing a complete and lawful response regarding personal data is a complex process that may take up to one month.

Right to Rectification of Your Data

If you find that some of the personal data we process about you is incorrect or outdated, please inform us. In this case, we may ask you to provide a document proving your identity, including by personally coming to the location of Netwave’s administration.

If you want to correct personal data processed by us, you can make corrections yourself by logging into your account on the website or by contacting us.

In some cases, we may NOT be able to change your personal data. For example, this may be the case when your personal data has already been used in the performance of a contract and/or is contained in a tax document issued in accordance with tax legislation.

Withdrawal of Consent for Personal Data Processing and Right to Be Forgotten

If Netwave processes your personal data based on your consent (in particular, for marketing/advertising communications), you can terminate further processing at any time by withdrawing your consent. Simply revoke your consent for such processing.

You can also exercise your right to be forgotten. In cases provided for in Article 17 of the GDPR, Netwave will erase your personal data that it processes, except for personal data that we are obliged to retain in accordance with legal requirements.

In this case as well, for security reasons, we may ask you to provide a document proving your identity, including by coming in person to the location of Netwave’s administration.

12. Storage of Personal Data

To ensure the security of personal data, we use resources for data storage and processing that are controlled by us.

13. Changes to the Privacy Policy

This Privacy Policy may be amended or terminated by Netwave unilaterally without prior notice to users, including if required by applicable laws. The new version of the Policy becomes effective upon its publication on the website unless otherwise provided by the new version of the Policy. Therefore, we ask you to visit the website https://netwave.ua to ensure that you have the most up-to-date information. The date of the last update of the Policy will be indicated on the last page of the Policy under “Last Updated.”

14. Contact Information

For questions regarding the protection of personal data, compliance with confidentiality, or if you have any questions, comments, or suggestions regarding this Policy, please contact us at teams@netwave.ua

Contact phone: +380 44 359 05 50