The law firm (“Avitar” or “we”) welcomes you.
We care about your personal data, and that’s why we have created this Privacy Notice (“Privacy Notice”). The Privacy Notice informs you how your personal data is collected, stored, and used, and provides a step-by-step description of what happens when you interact with our website accessible via the provided link www.avitar.legal (“Website”).
Privacy Notice Avitar(brief version)
Last updated: 29th of August, 2024
Welcome! We have prepared a brief version of our Privacy Notice for you.
Who we are?
We are law firm "Avitar"
Data controller: Private Entrepreneur Myroslav Khmarskyi
Address: Ukraine, 01103, Kyiv, 47 Volodymyrska street
Data controller: Private Entrepreneur Myroslav Khmarskyi
Address: Ukraine, 01103, Kyiv, 47 Volodymyrska street
Who you are?
Depending on the functions you use, you can be:
- Visitor;
- News subscriber
- Reader
- Listener;
- Potential client
Personal data
We can collect the following personal data:
- Name
- Email address;
- Company name ;
- Industry position;
- Phone number
The lawful bases for processing this data are your consent, legitimate interest, or the necessity for the performance of a contract.
Purpose of data collecting
Depending on the volume of data, the purpose of processing may be:
- Communication;
- Fulfilling your request;
- Marketing;
- Identification;
- Keeping statistics.
Data storage
Depending on the legal basis for data processing, we may retain your data for up to three years.
For more details on data retention, please refer to the full version of our Privacy Policy.
We transfer data
We may disclose your data to the extent necessary to provide you with services:
- To our employees;
- To our subcontractors.
We may also disclose your personal data to relevant third parties to comply with legal requirements.
You have the right to
- Right to information
- Right to access personal data
- Right to object to processing
- Right to rectification of data;
- Right to erasure;
- Right to data protection,
- Right to lodge a complaint with the Data Protection Authority or the court,
- Right to withdraw consent,
To exercise your rights, please contact us via email: privacy@avitar.legal.
Age restriction
We do not knowingly process data of users under the age of 18.
If you become aware that we are processing child data, please contact us: privacy@avitar.legal.
To obtain complete information, please refer to the full version of the Privacy Notice.
Privacy Notice “Avitar” (full version)
Last updated: 29th of August, 2024
Intro
Content
- About us
- About you
- Personal Data
- Data sources
- Lawful basis for processing
- Users’ data
- News subscribers’ data
- Readers’ data
- Listeners’ data
- Potential clients’ data
- Potential partners’ data
- The data we receive from the third parties
- Data transfer to third parties
- Protection of your Data
- Your rights
- Ukraine residents
- European Economic Area and United Kingdom residents
- Data transfer outside the EEA
- Cookie
- Privacy Notice update
About us
We are the controller of your personal data that is processed through the Website. This means we determine the purposes, scope, and methods of personal data processing.
| Data controller | Private Entrepreneur Myroslav Khmarskyi |
|---|---|
| Tax number | 3441709411 |
| Postal address | Ukraine, 01103, Kyiv, 47 Volodymyrska Street |
| privacy@avitar.legal |
About you
By using the Website, you become our user (“User”).
We divide the Users into categories so you can easily find details about the processing of your personal data. Pay attention that you can fall into several categories depending on your actions.
We divide the Users into categories so you can easily find details about the processing of your personal data. Pay attention that you can fall into several categories depending on your actions.
| News subscriber | Users who have subscribed to our newsletters. |
|---|---|
| Reader | Users who submit requests to receive e-books. |
| Listener | Users who register their participation in our webinars. |
| Potential client | Users who submit service inquiries through contact forms or contact details provided on the Website. |
| Potential partners | Users with whom we contact to establish partnerships. |
We do not knowingly process the personal data of Users under the age of 18. If you are such a User or the legal representative of such a User, please contact us.
Please note!
If you communicate with us about vacancies via email or other services, you become a “Candidate,” and your data is subject to our Recruitment Notice.
Personal Data
Data sources
We receive your data when you visit the Website and interact with it, depending on your actions on the Website.
You can change your personal data by exercising your right to rectification or by the Website functionality. Please note that the same lawful basis and storage terms apply to the changed data.
We may also receive data from third parties, depending on your browser settings and the features you use.
You can change your personal data by exercising your right to rectification or by the Website functionality. Please note that the same lawful basis and storage terms apply to the changed data.
We may also receive data from third parties, depending on your browser settings and the features you use.
Lawful basis for processing
To process your personal data, we rely on the following lawful bases:
- performance of the contract – for the processing of personal data necessary for the negotiating on, conclusion, and performance of a contract with you;
- legitimate interest – for the processing necessary for the development of our services, taking into consideration your interests, rights, and expectations;
- legal obligation – for the processing as required by applicable laws (for example, to comply with tax or KYCandAML regulations) or if requested by a law enforcement agency, court, supervisory authority, or another state-authorized public body;
- consent – for additional specific purposes.
If we collect personal data on the basis of legitimate interest or performance of the contract, we can use it for another purpose after checking that the new purpose is compatible with the original purpose.
When your data processing is based on a legal obligation or performance of the contract, you are obliged to provide your personal data. We need this data to comply with legal requirements or to properly provide you with our services. The failure to provide such data may have negative consequences, such as tax liability, inability to enter into a contract or provide services to you, etc.
Users’ data
When you visit the Website, we collect some data automatically. We collect some technical data about the Users to optimise performance, debug issues, and enhance features while ensuring security and privacy to improve the overall user experience.
Most of the technical data we collect are anonymous, but some data is associated with your IP address and device ID. Please read about personal technical data below.
Most of the technical data we collect are anonymous, but some data is associated with your IP address and device ID. Please read about personal technical data below.
| Type of data | Reasons for processing | Lawful basis |
|---|---|---|
| Information about the сoarse location (IP address, country) | The optimization of the performance, debugging, enhancement of the features’ proper functioning, administering and improvement of your user experience on the Website | Legitimate interest |
| Technical device information and network information (including IP address, HTTP user agent, browser type, referral sources, time, and duration of visits, navigation) | ||
| Data retention period |
|---|
| We store the data for 3 years from its collection |
We also need cookies to operate, maintain, and improve the functionality of the Website.
| Type of data | Description | Reasons for processing | Lawful basis |
|---|---|---|---|
| Necessary cookies | Information necessary for the operation of the Website | Ensuring the proper functioning of the Website and making it easier to use | Performance of the contract |
| Statistical cookie | Statistical data on the usage of the Website | Tracking the effectiveness of the Website for statistical and analytical purposes | Consent |
| Data retention period |
|---|
We store the data during the expiry period, provided in the Cookie Policy |
News subscribers’ data
When you choose to subscribe to our newsletter, you become a news subscriber. Please note that you can change your mind and unsubscribe at any time by clicking the corresponding button in the email.
| Data | Reasons for processing | Lawful basis |
|---|---|---|
| Name | Proper salutations in emails | Legitimate interest |
| Email address | Sending emails with webinar announcements | Consent |
| Data retention period | |
|---|---|
| Data processed based on your consent | Stored until consent is withdrawn |
| Data processed based on legitimate interest | Stored for a period of 2 years from its collection |
Readers’ data
When you send us a request to receive an e-book, you become part of the Readers category.
| Data | Reasons for processing | Lawful basis |
|---|---|---|
| Name | Reader identification and proper addressing | Performance of the contract |
| Email address | Sending the requested book | |
| Position | Maintaining statistics of requests | Legitimate interest |
| Field |
| Data retention period |
|---|
| Stored for a period of 1 year from the date of the last request |
Listeners’ data
When you send us a request to attend a webinar, you become a Listener.
| Data | Reasons for processing | Lawful basis |
|---|---|---|
| Name | Identification of the Listener | Performance of the contract |
| Email address | Providing access and input data for the webinar | |
| Position | Keeping track of request statistics | Legitimate interest |
| Data retention period | |
|---|---|
| Data processed based on the conclusion and performance of a contract | The data is stored during the webinar’s duration and 1 year after |
| Data processed based on legitimate interest | The data is kept as statistical data for 3 years |
Since webinars are conducted outside of our Website, the data that may be collected during the webinar will be governed by the privacy documents of the respective platforms.
Potential clients’ data
When you contact us using the contact forms on our Website, you become a potential client.
Upon receiving your request for our services, we may process additional data to fulfil our obligations. This may include checks for conflicts of interest and actions to prevent fraud.
We may also use your contact information for payment purposes and to inform you about any changes to our agreement terms.
Upon receiving your request for our services, we may process additional data to fulfil our obligations. This may include checks for conflicts of interest and actions to prevent fraud.
We may also use your contact information for payment purposes and to inform you about any changes to our agreement terms.
| Description | Reasons for processing | Lawful basis |
|---|---|---|
| Name | Identification of the representative | Performance of the contract |
| Email address | Communication regarding the inquiry | |
| The company name | Identification of the representative | |
| Position | Identification of the representative | |
| Phone number | Communication regarding the inquiry |
| Data retention period |
|---|
| Stored for a period of 3 years from the date of the last communication |
Please note!
- If you refuse to provide us with the necessary personal data, we will not be able to provide you with services or interact with you in any other way under the contract.
- The Website may contain links to other resources for which we are not responsible for the content and privacy practices. When you leave our Website, please familiarise yourself with the personal data processing policies of those websites.
Potential partners’ data
We may communicate with you with offers of cooperation. Under applicable law, this may be considered direct marketing.
Please note!
We intend to use only business email addresses; however, we may occasionally receive personal data. Additionally, we collect data exclusively from public sources, such as your website, public registers, etc.
The details of processing may vary depending on the jurisdiction in which you or your company resides.
| Residence | Data | Reasons for processing | Lawful basis |
|---|---|---|---|
| Australia |
| To communicate with you and propose cooperation between our companies | Consent |
| Canada | Implied consent | ||
| EU and UK | Legitimate interest | ||
| Ukraine | Consent | ||
| USA | Opt-out consent |
| Data retention period |
|---|
Stored for a period of 2 years from the date of the last communication or until consent is withdrawn |
The data we receive from the third parties
We may receive some data from third parties, but we do not necessarily receive it. This depends on the features you use and your settings.
The scope of the data collected, the purposes and the lawful basis for processing are determined by the relevant personal data documents of these third parties.
The scope of the data collected, the purposes and the lawful basis for processing are determined by the relevant personal data documents of these third parties.
The moment of collection | Category of data | Third party | Privacy documents |
|---|---|---|---|
When you visit the Website | Analytics (in particular, statistics on country, city, age, gender, language, browser, OS, type of device of the User) | Google Analytics |
Please note!
Analytical data about users is anonymous, and we do not have the technical ability to identify any User.
Data transfer to third parties
We can share your personal data with third parties without any harm to you and in full compliance with applicable law. In addition, we have implemented organisational and technical measures to ensure the security of personal data during data transfer to third-party.
| Categories of third parties | Reasons for processing |
|---|---|
| Marketing and analytics tools | We use analytics tools to understand and improve our business. |
| Social networks | We use various social networks to spread information about our activities. |
| Services for finding interns, and candidates | We use various services to search for candidates. |
| CRM systems | We use CRM systems to develop our business. |
| Messengers | We use messengers to communicate with you in ways that are convenient for you. |
| Payment services | We use the services of payment services to make payments. |
Please note!
To obtain a detailed list of such third parties, please contact us.
To share your data, we rely on the following lawful bases, depending on the case: consent, compliance with the law, and performance of a contract.
Protection of your Data
We protect the information on our computer servers in a controlled and secure environment, safeguarded against unauthorized access, use, or disclosure.
We also implement intelligent organisational security measures to ensure protection, including:
We also implement intelligent organisational security measures to ensure protection, including:
Organisational security measures
Staff training
Regular inventory of assets
Internal policies and instructions
Protection during data transfer
Careful use of Internet resources
Non-disclosure agreements (NDA)
Physical security measures
Closed-circuit television (CCTV)
Physical perimeter security
Security
Restricted access to premises
Alternative power supply
Alarm system
Technical security measures
Encryption technologies
Backup and recovery
Two-factor authentication
Licensed software
Keeping registers of consent
Password controls
Your rights
You, as a data subject (individual), have the right to interact with your data directly or through a request to us. This section describes these rights and how you can exercise them depending on your residency.
To exercise your rights, contact us.
To exercise your rights, contact us.
Ukraine residents
| The Rights | Description |
|---|---|
| Right to be informed | You have the right to know about the sources of collection, the location of your personal data, the purpose of their processing, the location of the owner or the place of residence of the owner or manager of personal data, or to give an appropriate order to receive this information. |
| Right to request information about the terms of disclosure | Upon request, you have the right to receive information about the conditions for granting access to personal data, including information about third parties to whom your personal data is transferred. |
| Right of access | You can request access to and receive all of your personal data that we store. |
| Right to reply | You have the right to receive a response about whether your personal data is being processed and the content of such data. |
| Right to object to processing | You can send us a request with a reasoned request to object to the processing of your personal data. |
| Right to rectification or erasure | You may send us a request with a reasoned request to rectify or erase your personal data if the data is processed unlawfully or is inaccurate. |
| Right to data protection | You have the right to protect your personal data from unlawful processing and accidental loss, destruction, or damage due to intentional concealment, failure to provide, or untimely provision, as well as to protect against the provision of information that is inaccurate or defamatory of your honor, dignity, and business reputation. |
| Right to complain | You may file a complaint regarding the processing of your personal data with the Ukrainian Parliament Commissioner for Human Rights by emailing hotline@ombudsman.gov.ua or in court. |
| Right to apply for legal remedies | You may protect your personal data by means of remedies provided by law. |
| Right to make reservations | You may make reservations regarding the restriction of the right to process your personal data when providing consent. |
| Right to withdraw consent | You can withdraw your consent to the processing of personal data at any time. You can also make reservations regarding the restriction of the right to process your personal data when you give your consent. |
| Right to know the mechanism of automatic processing | You can send us a request to find out whether we are using automatic processing of personal data. |
| Right to be protected against an automated decision that has legal consequences for you | You can send us a request to challenge the results of an automated decision that has legal consequences for you. |
Please note!
We may ask you to verify your identity before responding to your request. We will process your request and respond to you within 30 days of receiving it.
European Economic Area and United Kingdom residents
| The Rights | Description |
|---|---|
| Right to access | You can request information on whether personal data are being processed, and, where that is the case, access to this personal data and the information required by law. |
| Right to rectification | You can change the data if it is inaccurate or incomplete. |
| Right to erasure | You can send us a request to delete your personal data from our systems. We will remove them unless otherwise provided by law. |
| Right to restrict the processing | You may partially or completely prohibit us from processing your personal data in cases provided by law. |
| Right to data portability | You can request all the data you provided to us and request to transfer data to another controller. |
| Right to object | You may object to the processing of your personal data that is collected on the basis of legitimate interest. |
| Right to withdraw consent | You can withdraw your consent at any time. |
| Right to file a complaint | If your request was not satisfied, you could file a complaint to the regulatory body. |
We will answer your request within one month. If your request is not satisfied, you can submit a complaint to your local Data Protection Authority. You may find it here.
Data transfer outside the EEA
We may share personal data with the recipients of other countries, including non-EEA ones, ensuring that your data is protected and processed in accordance with the General Data Protection Regulation.
To share the data outside the EEA, we rely on the adequacy decision by the European Commission or the Data Privacy Framework participation of the recipient.
If the recipient does not participate in the Data Privacy Framework and its country is not deemed to provide an adequate level of protection for your personal data, we adopt Standard Contractual Clauses based on legislation assessments for data protection during transfer and storage.
You can read more detailed measures to protect your personal data here.
To share the data outside the EEA, we rely on the adequacy decision by the European Commission or the Data Privacy Framework participation of the recipient.
If the recipient does not participate in the Data Privacy Framework and its country is not deemed to provide an adequate level of protection for your personal data, we adopt Standard Contractual Clauses based on legislation assessments for data protection during transfer and storage.
You can read more detailed measures to protect your personal data here.
Cookie
We use necessary cookies for the functioning of the Website. By using cookies, we collect automatically gathered data. You can read more about this in the Cookie Policy.
If you wish to disable cookies, you can find instructions on managing your browser settings through the following links:
If you wish to disable cookies, you can find instructions on managing your browser settings through the following links:
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Privacy Notice updates
The Privacy Notice and the relationships falling under its scope are governed by the Law of Ukraine “On Personal Data Protection”, General Data Protection Regulation and best practices.
Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on the Website.
If there are material changes to the Privacy Notice or the Website that affect your data privacy rights, we will notify you by displaying information on the Website and, if necessary, ask for your consent.
Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice on the Website.
If there are material changes to the Privacy Notice or the Website that affect your data privacy rights, we will notify you by displaying information on the Website and, if necessary, ask for your consent.
You have read a full version of our Privacy Policy. Back to the short version
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contact@avitar.legalPhone
+380 (50) 356 74 94
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