Privacy Policy
DRAFT. This document is a draft and has not been reviewed by a lawyer. All “[ВКАЗАТИ: …]” fields must be completed and the text approved by the business owner and a lawyer/accountant before real payments are accepted. In case of discrepancy, the Ukrainian version prevails [ВКАЗАТИ: confirm with lawyer].
1. Who processes your data
The data controller is the Seller:
- Individual entrepreneur (ФОП, Ukraine): [ВКАЗАТИ: full name as in the Unified State Register]
- Taxpayer number (РНОКПП): [ВКАЗАТИ: РНОКПП]
- Registered address: [ВКАЗАТИ: registered address]
- Correspondence address (if different): [ВКАЗАТИ or remove]
- Email: [ВКАЗАТИ: customer email]
- Phone: [ВКАЗАТИ: phone or remove]
- Single tax payer, group [ВКАЗАТИ: group]; activity codes (КВЕД): [ВКАЗАТИ]
- Licence: not required / [ВКАЗАТИ if the activity is licensed — confirm with lawyer]
2. What data we process
| Data | Purpose | Legal basis |
|---|---|---|
| Email address | Concluding and performing the contract, communication about the order | Performance of contract |
| Order data: program, amount, currency, payment status, date, monobank invoice ID | Order records, payment confirmation, accounting and tax records | Performance of contract; legal obligation |
| Pseudonymised (hashed) IP identifier | Abuse protection (rate limiting), kept up to 24 hours | Legitimate interest (security) |
| Hosting technical logs (Cloudflare) | Security and reliable operation | Legitimate interest |
We never receive or store card details — they are entered only on the monobank page. We do not use advertising or analytics cookies. The checkout only stores your interface language choice in your browser.
The website dana-korn.com counts page views and clicks on its buttons (for example “Book a session” or Telegram) to understand which pages work. These statistics contain no cookies, IP addresses, names, emails or message texts: only the page, the button, the referring site, campaign tags (utm) and the country. They cannot be linked to a person.
3. Who receives data
- JSC Universal Bank (monobank, “plata by mono”) — to process the payment; the bank processes payment data as an independent controller under its own policy.
- Cloudflare, Inc. — hosting of the checkout and order database (servers may be located outside Ukraine, including the EU and the US).
- [ВКАЗАТИ: email provider used by the Seller, and any other processors].
- Public authorities — only where required by law.
4. Retention
Order data is kept for [ВКАЗАТИ: period agreed with accountant, considering retention periods for accounting records], then deleted or anonymised. Data of unpaid orders is kept no longer than [ВКАЗАТИ: e.g. 90 days]. Pseudonymised IP identifiers — up to 24 hours.
5. Your rights
Under the Law of Ukraine “On Personal Data Protection” you may learn about the processing of your data, access it, request correction or deletion, object to processing and withdraw consent (where processing is based on consent). If you are in the EU/EEA, you also have rights under the General Data Protection Regulation (GDPR), including data portability and the right to lodge a complaint with your local supervisory authority. [Lawyer: verify GDPR applicability (Art. 3(2)) and whether an EU representative is required (Art. 27).]
In Ukraine, complaints may be filed with the Ukrainian Parliament Commissioner for Human Rights.
To exercise your rights, write to [ВКАЗАТИ: email].
6. Security
Data is transmitted only over secure connections (HTTPS). Only the Seller has access to order data.
7. Changes
We may update this policy; the current version is published on this page.