This Policy explains what personal data the Circle studio collects, why, how long it keeps it and what rights you have. It has been drawn up in accordance with the Law of Ukraine “On Personal Data Protection” No. 2297-VI of 1 June 2010. For visitors from the European Union, we also take into account the General Data Protection Regulation (GDPR).
The personal data controller is individual entrepreneur (FOP) Yevhen Hlinkin, taxpayer number (RNOKPP) 3398501850, operating under the name “Circle” through the website https://circle.in.ua (the “Studio”, “we”).
By using the website or contacting us, you confirm that you have read this Policy.
1. What data we collect
1.1. Data you provide yourself. When you fill in the form on the website, email us, call us or write to us on Telegram or WhatsApp, we receive:
- your name;
- your phone number, email address or messenger username;
- the subject and text of your message, your company name and project description, if you provide them;
- the website page from which the form was sent;
- the content of our correspondence.
Requests from the form go to the Studio team’s work Telegram chat.
1.2. Data for the contract. If we start working together, the contract and payment require the client’s details: full name or company name, company registration code (EDRPOU) or taxpayer number (RNOKPP), address and bank details.
1.3. Technical data. When you visit the website, the hosting server automatically records your IP address, browser and device type, and the date and time of the request. These are standard logs needed for the website to work and stay secure.
1.4. Visit statistics. If you have agreed to analytics cookies, Google Analytics collects anonymised data: where you came to the website from, which pages you viewed, from which device, your approximate city and clicks on contacts. We do not pass your name or phone number to Google Analytics.
We do not collect data about health, religious or political views or any other sensitive categories of data.
2. Why we use it
- to reply to your request and prepare a proposal;
- to conclude and perform a contract for developing a website or CRM, issue an invoice and accept payment;
- to stay in touch while working on the project and after launch (warranty, edits);
- to keep the website working and secure;
- to understand how visitors use the website and improve it (only with your consent);
- to comply with the law, in particular tax accounting requirements.
We do not send advertising newsletters. If we ever start, it will only be to those who separately agree to it.
3. Legal grounds
- your consent — when you send the form or contact us yourself, and for analytics cookies;
- conclusion and performance of a contract — for work on the project;
- the Studio’s legitimate interest — for website security;
- legal obligation — for accounting and tax records.
4. Who we share data with
We do not sell your data or share it for commercial purposes. The minimum necessary amount of data may be received by:
- technical service providers: Google Firebase website hosting, Google Analytics (with your consent), email, and the Telegram and WhatsApp messengers through which requests arrive and we communicate with you;
- the bank — to accept payment under the contract;
- government authorities — only in cases expressly provided for by law.
The servers of some of these services are located outside Ukraine (in particular in the EU and the USA). We use only large services that have their own data protection policies.
5. How long we keep data
- form requests and correspondence about a project that did not start — up to 1 year from the last contact;
- Google Analytics statistics — 14 months;
- contract data and payment documents — for the period required by tax law (at least 3 years);
- hosting technical logs — up to 30 days.
After these periods, the data is deleted or anonymised.
6. How we protect data
The website runs over a secure connection (HTTPS). Only the team members working on a project have access to client data. Work accounts are protected with passwords and two-factor authentication.
7. Your rights
You have the right to:
- find out what data of yours we hold and why;
- correct inaccurate data;
- request deletion of data if the law does not oblige us to keep it;
- withdraw your consent to processing;
- object to processing or restrict it;
- file a complaint with the Ukrainian Parliament Commissioner for Human Rights or with a court. Visitors from the EU can contact the supervisory authority of their country.
To exercise a right, email us at the address in section 10. We will reply within 30 days.
8. Data of our clients’ customers
When we develop a website, online store or CRM, it comes to contain the data of the client’s customers. The client is the controller of that data, and the Studio processes it only on the client’s instructions and within the contract. This Policy applies only to the Studio’s website. Our clients’ websites are covered by their own policies.
9. Cookies
How the website uses cookies and browser storage is described in a separate Cookie Policy.
10. Changes and contacts
We may update this Policy. The current version is always on this page, and the date of the update is shown at the top.
For questions about personal data, contact:
Individual entrepreneur (FOP) Yevhen Hlinkin
Email: circle.in.ua@gmail.com
Phone: +38 063 403 30 45
Website: https://circle.in.ua