1. General Provisions

This Personal Data Processing Policy (hereinafter, the “Policy”) sets out the procedure for processing personal data and the measures taken to ensure its security by Individual Entrepreneur Kostiantyn Skliarenko (hereinafter, the “Operator”) in the course of providing services to visitors and customers of the website https://skliarenko.pro.
1.1. The Operator considers the observance of human rights and freedoms in the processing of personal data, including the protection of the rights to privacy and to personal and family confidentiality, to be its paramount objective and a condition of carrying out its activities.
1.2. This Policy applies to all information that the Operator may obtain about visitors to the website https://skliarenko.pro.
1.3. The Operator processes personal data in accordance with applicable personal data protection legislation, including, where applicable, the principles of the General Data Protection Regulation (GDPR) with respect to data subjects from the European Union.

2. Key Definitions Used in the Policy

2.1.Automated processing of personal data means the processing of personal data by means of computer technology.
2.2. Blocking of personal data means the temporary suspension of the processing of personal data (except where processing is necessary to rectify the personal data).
2.3. Website means a set of graphic and informational materials, as well as computer programs and databases, ensuring their availability on the internet at https://skliarenko.pro.
2.4. Anonymization of personal data means actions as a result of which it becomes impossible, without the use of additional information, to determine whether the personal data belongs to a specific User.
2.5. Processing of personal data means any action (operation) or set of actions (operations) performed on personal data, including collection, recording, systematization, accumulation, storage, rectification, use, transfer, anonymization, blocking, deletion, and destruction of personal data.
2.6. Operator means Individual Entrepreneur Kostiantyn Skliarenko, who independently organizes and carries out the processing of personal data and determines the purposes and scope of the personal data to be processed.
2.7. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website https://skliarenko.pro.
2.8. User means any visitor to the website https://skliarenko.pro.
2.9. Provision of personal data means actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.10. Destruction of personal data means any actions as a result of which personal data is irretrievably destroyed, making it impossible to restore its content.

3. Key Rights and Obligations of the Operator

3.1. The Operator has the right to:

• receive accurate information and/or documents containing personal data from the data subject;
• independently determine the scope and list of measures necessary and sufficient to ensure the protection of personal data.

3.2. The Operator has the right to send the User notifications about new products and services, special offers, and various events. The User may opt out of receiving such messages by sending an email to privacy@skliarenko.pro with the subject “Unsubscribe from notifications.”

3.3. The Operator is obliged to:

• provide the data subject, upon request, with information concerning the processing of their personal data;
• organize the processing of personal data in accordance with the procedure established by applicable law;
• respond to inquiries and requests from data subjects within a reasonable time;
• publish this Policy and ensure unrestricted access to it;
• take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, and other unlawful actions;
• cease processing and destroy personal data upon a justified request from the data subject.

4. Key Rights and Obligations of Data Subjects

4.1.Data subjects have the right to:

• receive information concerning the processing of their personal data in an accessible form;
• require the Operator to rectify their personal data, or to block or destroy it, if the data is incomplete, outdated, inaccurate, or not necessary for the stated purpose of processing;
• withdraw consent to the processing of personal data at any time;
• appeal against the actions or omissions of the Operator in the processing of their personal data.

4.2. Data subjects from the European Union (under the GDPR) additionally have the following rights: the right of access to their data, the right to rectification, the right to erasure (“right to be forgotten”), the right to restriction of processing, the right to data portability, and the right to object to processing. The Operator undertakes to consider such a request and respond within a reasonable time not exceeding 30 days.
4.3. Data subjects are obliged to:

• provide the Operator with accurate information about themselves;
• notify the Operator of any rectification (update, change) of their personal data.

4.4. Persons who have provided the Operator with false information about themselves, or with information about another data subject without that person’s consent, shall bear liability in accordance with applicable law.

5. Principles of Personal Data Processing

5.1. Personal data shall be processed lawfully and fairly.
5.2. Personal data processing shall be limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purposes for which it was collected is not permitted.
5.3. Merging databases containing personal data that is processed for purposes incompatible with one another is not permitted.
5.4. Only personal data that is relevant to the purposes of its processing shall be processed; excessive data is not permitted.
5.5. In processing personal data, its accuracy and adequacy shall be ensured. The Operator takes the necessary measures to delete or rectify incomplete or inaccurate data.
5.6. Personal data shall be stored for no longer than the purposes of processing require, unless the storage period is established by contract. Processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or if the need to achieve them is lost.

6. Purposes of Personal Data Processing

6.1 Purpose of processing: contacting the customer for the purpose of selling CRM implementation services.


6.2 Purpose of processing: informing the User about new products and services, special offers, and various events.

7. Conditions of Personal Data Processing

7.1. Personal data is processed with the consent of the data subject.
7.2. Processing of personal data is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, as well as for entering into a contract at the initiative of the data subject.
7.3. Processing of personal data is necessary for the purposes of the legitimate interests of the Operator or third parties, provided that the rights and freedoms of the data subject are not infringed.
7.4. Processing is carried out of personal data to which access by an unlimited number of persons has been granted by the data subject or at the data subject’s request.

8. Procedure for Collection, Storage, Transfer, and Other Types of Processing of Personal Data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to comply with the requirements of applicable personal data protection legislation.
8.1. The Operator ensures the safekeeping of personal data and takes all possible measures to prevent unauthorized persons from accessing it.
8.2. The User’s personal data is not transferred to third parties, except in cases related to the performance of contractual obligations (for example, the use of CRM systems and related services necessary for the provision of the service), or where the data subject has consented to the transfer of data to a third party for the performance of obligations under a contract.
8.3. If inaccuracies are found in personal data, the User may update it independently by sending a notice to the Operator at privacy@skliarenko.pro with the subject “Update of personal data.”
8.4. The period of personal data processing is determined by the achievement of the purposes for which the data was collected, unless a different period is provided for by contract.
8.5. The User may withdraw consent to the processing of personal data at any time by sending a notice to the Operator at privacy@skliarenko.pro with the subject “Withdrawal of consent to personal data processing.”
8.6. Information collected by third-party services (including payment systems, CRM platforms, and other service providers used by the Operator to provide services) is stored and processed by those parties in accordance with their own privacy policies. The Operator is not responsible for the actions of such third parties.
8.7. The Operator ensures the confidentiality of personal data during its processing.
8.8. Grounds for terminating the processing of personal data may include the achievement of the purposes of processing, the expiry of the data subject’s consent, the data subject’s withdrawal of consent, or the discovery of unlawful processing.

9. List of Actions Performed by the Operator with Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, rectification (updating, modification), retrieval, use, transfer (in the cases provided for by this Policy), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator processes personal data with and/or without the use of automation tools (in particular, CRM systems).

10. Cross-Border Transfer of Personal Data

10.1. Where it is necessary to transfer personal data outside the User’s country of residence, the Operator ensures an adequate level of protection of such data in accordance with applicable law and this Policy.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose or disseminate personal data to third parties without the consent of the data subject, unless otherwise provided by applicable law.

12. Final Provisions

12.1. The User may obtain any clarification regarding the processing of their personal data by contacting the Operator at privacy@skliarenko.pro.
12.2. Any changes to the personal data processing policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely accessible at https://skliarenko.pro/privacy.

Operator details: Individual Entrepreneur Kostiantyn Skliarenko
Email for personal data inquiries: privacy@skliarenko.pro