Privacy and Personal Data Protection Policy

The website https://es-trans.com.ua/ (hereinafter referred to as the “Website”) is managed by LLC “European Transport Systems,” code 4147З292, a legal entity registered and operating in accordance with the requirements of Ukrainian law (hereinafter referred to as the “Company”).

The Company highly values the privacy of all visitors to the Website and those using its services. As a result, the Company strives to protect personal data (information or a set of data about an individual who is identified or can be specifically identified) by creating and ensuring maximum comfort in using the Website services for each user.

This Privacy and Personal Data Protection Policy (hereinafter referred to as the “Policy”) defines the procedure for the Company’s processing of personal data, the types of personal data collected, the purposes of their use, interaction with third parties, security measures to protect personal data, conditions for access to personal data, as well as contact information for users to access, amend, block or delete their personal data or address any questions regarding the Company’s data protection practices.

Collection and Use of Personal Data

The controller and processor of personal data collected through the Website is European Transport Systems LLC.

During the use of the Website services, the Company processes the following types of data:

  • Data provided by the user while filling out registration forms or in the process of using the services;
  • Cookies;
  • IP addresses;
  • Parameters and settings of internet browsers (User-agent).

The Company collects only the personal data that users voluntarily and knowingly provide (such as name, surname, login, password, email address, phone number, date of birth, gender, etc.) for the purpose of using the Website’s services. Such data collection is considered consent to process personal data in accordance with the purposes outlined in this Policy.

The Company records all system accesses when the Website is visited. Other traffic-related information is not processed or stored.

The Company limits its data collection to the minimum amount necessary to fulfill the user’s request. If optional information is requested, the user will be informed during the collection of such data.

The Company does not collect data subject to specific legal requirements, such as information about racial or ethnic origin, political or religious beliefs, membership in political parties or trade unions, criminal convictions, health, sexual activity, or genetic or biometric data.

Processing of Personal Data

The processing and storage of provided personal data are carried out in data centers where the equipment ensuring the operation of the Website’s services is located. The personal data provided is processed and may be stored in the Personal Data Database or in a specific table within the Website’s Database.

Purposes of Personal Data Usage

Your personal data is used for the purposes of providing the Website’s internet services, exchanging information/news and maintaining advertising and communication relations in accordance with and for compliance with Ukrainian laws, including but not limited to:

  • “On the Protection of Personal Data”,
  • “On the Ratification of the Convention for the Protection of Individuals with Regard to Automatic Processing of Personal Data and the Additional Protocol to the Convention for the Protection of Individuals with Regard to Automatic Processing of Personal Data regarding Supervisory Authorities and Transborder Data Flows”,
  • “On Information”,
  • “On Advertising”,
  • “On Telecommunications”,
  • “On the Protection of Information in Information and Telecommunication Systems”,
  • “On State Support of Mass Media and Social Protection of Journalists”,

as well as in compliance with the Website Usage Rules and other acts regulating the Company’s activities.

Data Storage Duration

Personal data is stored no longer than necessary to fulfill the purposes for which it was collected. If the user deletes their account on the Website, their personal data is automatically deleted.

Use of Cookies

Cookies are text files that contain a small amount of information sent to a web browser and stored on the user’s device. Such devices may include a computer, mobile phone or other devices used to access the Website.

Cookies can be either persistent (known as permanent cookies) and remain stored on the user’s computer until manually deleted, or temporary (known as session cookies), which are stored only until the browser is closed.

Additionally, cookies are categorized into primary cookies (set directly by the visited Website) and third-party cookies (set by other websites).

It is important that:

  • Upon revisiting the Website, cookie data is updated.
  • In most cases, web browsers are set by default to allow the automatic storage of cookies on the user’s device.
  • Disabling cookies may limit access to published materials and/or result in the incomplete functionality of the Website’s services.

The Company values its users and strives to make their experience on the Website as comfortable as possible. To achieve this, cookies are used to analyze user behavior, preferences and interests. Such analysis helps the Company enhance the interaction experience, define the most convenient interface and optimize the Website’s navigation.

Cookie Categories According to the International Chamber of Commerce Classification:

  1. Strictly Necessary Cookies:
    These are essential for navigating the Website and using certain services, such as accessing secure pages, registration and authorization, or conducting searches on the Website. They also remember the user’s previous actions when returning to a previous page during the same session.
  2. Performance Cookies:
    These collect aggregated data on how the Website is used. This information is stored on the user’s device between browser sessions. Examples include:
    • Time spent on the Website.
    • Most frequently visited pages.
    • Understanding which sections and services were most interesting to users.
    • Evaluating the effectiveness of advertising or marketing campaigns.

All information collected via performance cookies is intended for statistical and analytical purposes. Some data from these cookies may be shared with third parties authorized by the Website for the aforementioned purposes.

  1. Functional Cookies:
    These are used to save parameters or configurations on the user’s device between browser sessions. Examples include:
    • User’s name.
    • Profile picture.
    • Information about comments left.
    • Language version of the Website.
    • Location.
    • Other Website settings.

These cookies also allow users to watch videos, participate in polls, interact with social networks and remember preferences for a more personalized experience. Some functional cookie data may be shared with authorized third parties for the purposes mentioned above.

  1. Targeting Cookies:
    These cookies are used to deliver content that may interest the user. Examples include:
    • Tracking recommended text, graphic, audio, or video materials to avoid repeated display.
    • Managing targeted advertising.
    • Assessing the effectiveness of advertising campaigns.
    • Recording visits to other resources during transitions.

The Website may share this information with other parties, including media clients, advertisers, agencies and business partners, to provide high-quality targeted advertising.

Third-Party Services and Analytical Cookies:

The Company uses services provided by third parties, such as Facebook, Twitter, Instagram, Alphabet Inc., Gemius, and others, for efficient content delivery, improved display quality, and detailed content analysis. These services may use cookies on the user’s device during Website interaction.

The Company cannot influence the operation of these third-party cookies. Users are encouraged to visit the relevant resources to learn about their use.

Cookie Management:

Most web browsers are set to automatically accept cookies. To disable cookies, use the help function in your browser (usually accessible via the menu or the F1 key).

Browsers include: Microsoft Edge, Mozilla Firefox, Google Chrome, Opera and Safari for macOS.

Important:

  • Cookie settings for mobile browsers may differ.
  • Full functionality of the Website is only available with cookies enabled.
  • Disabling cookies may limit access to content and services.

To contact the Company regarding cookie usage, send an email to the designated mailbox. If a user disables cookies or deletes all cookies from their browser, they will be prompted to enable cookies again upon returning to the Website.

The information collected via cookies is not sold, shared publicly or distributed, and remains the property of the Company that owns the Website.

Interaction of the Website with Other Resources

When using the Website’s services, pages may contain codes from other internet resources or third parties. As a result, these resources and third parties may access your data. These resources may collect and process information about your visits to these pages, as well as other information transmitted by your browser.

Such internet resources may include:

  • Banner ad systems (e.g., DoubleClick for Publishers, Admixer, AdRiver, etc.);
  • Social network plugins (e.g., Facebook, Twitter, Google+).

The Company uses these services to analyze Website visits, evaluate internal and external traffic, assess page views and monitor user activity. The data collected by these services is not stored or processed by the Company.

If, for any reason, the user does not wish these services to access their personal data, they may log out of their account or profile and clear cookies (via their browser settings).

Safety for Minors

The Website is not intended for use by minors. The Company takes safety concerns very seriously, especially regarding individuals who have not reached the age of majority. Therefore, the Company urges parents to explain to their children the importance of internet safety, as well as the specific purposes and necessity of using the Website’s services.

Interaction of the Company with Third Parties Regarding Personal Data

The Company does not transfer personal data to third parties, except in cases where such transfer is required by law, at the request of the subject of personal data, or in other instances outlined in this Policy.

The Company understands that personal information is a valuable and integral part of the personal non-property rights of any individual. Therefore, the Company takes all possible measures to protect the personal information voluntarily and consciously provided by users.

The Website may contain links to other websites (for informational purposes only). When following these links, this Policy does not apply to such websites. Therefore, the Company recommends reviewing the privacy and personal data policies of each website before providing any personal data that may identify you.

Confidentiality of User Activity on the Website

Information about user activity (traffic) on the Website, transmitted through the network or via email, is protected under applicable laws. The Company does not, in any way, breach the confidentiality of a user’s activity when using the Website’s services.

Protection of Personal Data

The Company applies generally accepted standards of technological and operational protection to safeguard information and personal data from loss, misuse, alteration or destruction. However, despite all efforts, the Company cannot guarantee absolute protection against any threats that arise outside its regulation.

The Company ensures the application of all appropriate obligations regarding confidentiality, as well as technical and organizational security measures to prevent unauthorized or illegal disclosure, processing, accidental loss, destruction or damage of such information and data.

Access to information and personal data is granted only to authorized employees who have agreed to maintain the confidentiality of such information and data in accordance with the Company’s requirements.

The dissemination of personal data without the consent of the data subject or their authorized representative is allowed only in cases specified by law and only when necessary for national security, economic welfare or the protection of human rights.

Conditions for Access to Personal Data

The procedure for granting access to personal data to third parties is determined by the terms of the user’s consent provided to the data controller for processing such data or in accordance with legal requirements.

Users have the right to obtain any information about themselves from any subject involved in personal data relations, provided they specify their surname, first name, patronymic, place of residence (or stay), and the details of the document confirming their identity. Exceptions apply only in cases established by law.

Access to a user’s personal data is provided free of charge. Delays in granting a user access to their personal data are not allowed.

Delays in granting access to personal data to third parties are permissible only if the requested data cannot be provided within thirty calendar days from the date of the request. In such cases, the total period for addressing the issues raised in the request must not exceed forty-five calendar days.

Notification of the delay must be communicated to the third party who submitted the request in written form, with an explanation of the procedure for appealing the decision.

Decisions regarding delays or refusals to grant access to personal data can be appealed to the Authorized Representative of the Verkhovna Rada of Ukraine for Human Rights or to a court.

Rights of the Subject of Personal Data

The Company informs you about your rights as a subject of personal data, regulated by the Law of Ukraine “On Personal Data Protection,” including:

  • The right to know the sources of collection, the location of your personal data, the purpose of its processing, the location or residence of the controller or processor of personal data, or to delegate obtaining this information to authorized persons, except as provided by law.
  • 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.
  • The right to access your personal data.
  • The right to receive, no later than thirty calendar days from the date of the request (unless otherwise provided by law), information about whether your personal data is being processed, as well as to receive the content of such personal data.
  • The right to make a reasoned request to the personal data controller to object to the processing of your personal data.
  • The right to make a reasoned request to amend or delete your personal data by any controller or processor if the data is processed unlawfully or is inaccurate.
  • The right to protect your personal data from unlawful processing and accidental loss, destruction, damage due to deliberate concealment, failure to provide or untimely provision, as well as to protect against providing information that is inaccurate or defames your honor, dignity, and business reputation.
  • The right to file complaints about the processing of your personal data with the Authorized Representative of the Verkhovna Rada of Ukraine for Human Rights or the court.
  • The right to apply legal remedies in case of violation of personal data protection laws.
  • The right to make reservations regarding restrictions on the right to process your personal data when giving consent.
  • The right to withdraw consent to the processing of personal data.
  • The right to know the mechanism of automatic processing of personal data.
  • The right to protection against automated decision-making that has legal consequences for you.

For updates, access, amendments, blocking or deletion of your personal data or to withdraw consent for processing provided to the Company under this Policy, or if you have any comments, suggestions, or claims regarding your personal data processed by the Company, please contact the Company.

Changes to the Policy

This Policy may be periodically updated and amended without prior notice to the user, including in response to changes in legal requirements.

In the event of significant changes to this Policy, the Company will post a notice on the Website and specify the effective date of such changes. If you do not decline the changes in writing within the specified time frame, it will signify your acceptance of the changes to the Policy.

We recommend reviewing this Policy periodically to stay informed about any updates or amendments.