Information Security Policy

1. General Provisions

This Personal Data Processing Policy has been created in accordance with the requirements of Ukraine’s Law No. 2297-VI, “On Personal Data Protection,” dated June 1, 2010. It outlines the procedures for processing personal data and the measures taken to ensure its confidentiality by Zabula Tetiana Mykolayivna (hereafter referred to as the “Operator”).

1.1. The Operator is committed to protecting the rights and freedoms of individuals when processing their personal data, with a particular focus on safeguarding privacy, personal and family secrets.

1.2. This Policy applies to all information that the Operator may collect from the website https://digital-marketer.com.ua visitors.

2. Basic Concepts Used in the Policy

2.1 Automated Processing of Personal Data – the processing of personal data using computer technology.

2.2 Blocking of Personal Data – the temporary suspension of personal data processing (except when processing is necessary to clarify personal data).

2.3 Website – a collection of graphic and informational materials, along with computer programs and databases that make them accessible on the internet at https://digital-marketer.com.ua.

2.4 Personal Data Information System – a collection of personal data contained in databases, as well as information technologies and technical tools that enable their processing.

2.5 Depersonalization of Personal Data – actions that make it impossible to identify, without additional information, the ownership of personal data to a specific User or another subject of personal data.

2.6 Cookies – small text files stored on the User’s device when visiting the website. These allow the website to remember the User’s actions and settings over time.

2.7 Processing of Personal Data – any action or set of actions performed with or without automation tools on personal data, including collection, recording, systematization, storage, clarification (updating or changing), retrieval, transfer (distribution, provision, access), depersonalization, blocking, deletion, or destruction of personal data.

2.8 Operator – a state or municipal body, legal entity, or individual who, independently or jointly with others, organizes and processes personal data, and determines the purposes and scope of personal data processing.

2.9 Personal Data – any information related directly or indirectly to a specific User of the website https://digital-marketer.com.ua.

2.10 User – any visitor to the website https://digital-marketer.com.ua.

2.11 Provision of Personal Data – actions aimed at disclosing personal data to a specific individual or group of individuals.

2.12 Dissemination of Personal Data – any actions aimed at disclosing personal data to an indefinite number of people, including sharing data in media, placing it in information networks, or providing access to personal data through other means.

2.13 Destruction of Personal Data – any actions that result in the irreversible destruction of personal data, making it impossible to restore the content of the data in the personal data information system or physical data carriers.

3. The Operator May Process the Following Personal Data of the User

3.1. Full name (last name, first name, patronymic)

3.2. Email address

3.3. Phone number(s)

3.4. Anonymized data about visitors (including cookies) is also collected and processed.

3.5. All of the above-mentioned data is collectively referred to as Personal Data within this Policy.

4. Purposes of Personal Data Processing

4.1. The primary purpose of processing the User’s personal data is to communicate with the User through phone calls, instant messengers, and emails, as well as to provide access to services, information, or materials available on the website.

4.2. The Operator may also send notifications about new products, services, special offers, or events. Users can opt out by emailing zabula.digital@gmail.com with the subject “Refusal to receive notifications about new products, services, and special offers.”

4.3. Anonymized data collected via internet statistics tools is used to analyze user behavior, improve the website’s quality, and enhance its content.

5. User’s Rights Regarding Personal Data

5.1. Users are entitled to request information about how their personal data is processed. The Operator will provide this information upon request.

5.2. Users can correct or update their personal data if inaccuracies are found by contacting the Operator at zabula.digital@gmail.com with the subject “Updating personal data.”

5.3. Users may request the deletion of their personal data (right to be forgotten) if the data is no longer necessary for its original purpose or if consent for processing is withdrawn. Requests should be sent to zabula.digital@gmail.com with the subject “Deletion of personal data.”

5.4. Users can restrict the processing of their personal data in accordance with applicable laws, for instance, when disputing the accuracy of the data or requesting limited usage.

5.5. Users have the right to object to the processing of their personal data for direct marketing or other communication purposes. Requests should be sent to zabula.digital@gmail.com.

5.6. Users have the right to data portability, allowing them to receive their personal data in a structured, commonly used format for transfer to another data controller.

5.7. If a User believes their rights have been violated during the processing of their personal data, they are entitled to file a complaint with the appropriate supervisory authority or seek redress in court.

5.8. Users can withdraw their consent to the processing of personal data at any time by notifying the Operator at zabula.digital@gmail.com with the subject “Revocation of consent to the processing of personal data.”

6. Operator’s Obligations Regarding Personal Data

6.1. The Operator commits to processing personal data in compliance with Ukrainian law, including the Law of Ukraine “On Personal Data Protection.”

6.2. Necessary legal, organizational, and technical measures will be implemented to safeguard User data from unauthorized access, disclosure, modification, or destruction.

6.3. Personal data will only be processed for the purposes outlined in this Policy and not used otherwise without User consent or legal justification.

6.4. The Operator ensures confidentiality and will not share data with third parties without prior User consent, except as required by law.

6.5. Upon request, the Operator will provide access to, clarify, block, or delete personal data when inaccuracies arise or as legally mandated.

6.6. The Operator will notify the User of any personal data security breach that could result in unauthorized access, disclosure, or other violations.

6.7. Regular assessments of personal data protection systems will be conducted, with continuous improvements implemented to enhance security.

6.8. Users will be informed of changes to the Personal Data Processing Policy via the publication of the updated Policy on the website.

7. Legal Grounds for Processing Personal Data

7.1. The Operator processes the User’s personal data only when provided directly by the User through forms on the website https://digital-marketer.com.ua. By submitting their data, the User consents to this Policy.

7.2. Anonymized data, such as cookies, is processed if enabled in the User’s browser settings, including technologies like JavaScript.

8. Procedure for Collecting, Storing, Transferring, and Processing Personal Data

The Operator ensures the security of personal data through legal, organizational, and technical measures, complying with personal data protection laws.

8.1. Personal data is safeguarded to prevent unauthorized access.

8.2. Personal data will not be shared with third parties unless required by law.

8.3. Users can update inaccuracies in their data by emailing zabula.digital@gmail.com with “Updating personal data.”

8.4. Data processing is indefinite, but users may withdraw consent anytime by emailing zabula.digital@gmail.com with “Revocation of consent to the processing of personal data.”

9. Use of Cookies

9.1. The Operator uses cookies to enhance the website performance, analyze traffic, and offer personalized user experiences.

9.2. The following cookie types are used:

• Technical cookies: Required for proper site functionality (e.g., navigation, secure access).
• Analytical cookies: Gather anonymous data on site usage (e.g., most visited pages).
• Functional cookies: Save user preferences (e.g., language, region).
• Marketing cookies: Track user actions for relevant advertising.

9.3. Users can adjust cookie settings in their browser.

9.4. Disabling cookies may affect the website performance.

9.5. Cookies are stored as long as needed and automatically deleted after their purpose is fulfilled.

10. Transfer of Personal Data to Third Parties

10.1. The Operator does not transfer personal data to third parties without the User’s prior consent, except as required by applicable law.

10.2. Personal data may be transferred to third parties in the following cases:

• To fulfill a contract or provide services to the User (e.g., sharing data with partners for processing requests or making payments).
• When required by law, such as by government authorities.
• To protect the Operator’s rights and legitimate interests (e.g., in legal disputes).

10.3. When transferring personal data, the Operator ensures that third parties provide an adequate level of protection and comply with data protection laws.

10.4. The Operator may engage external service providers (processors) for specific tasks (e.g., hosting or analytics), to whom personal data may be transferred for limited periods and purposes.

10.5. The User has the right to be informed about the transfer of their personal data and may request such information from the Operator.

11. Final Provisions

11.1. For any clarifications regarding the processing of personal data, the User can contact the Operator at zabula.digital@gmail.com.

11.2. This document will be updated to reflect any changes in the personal data processing policy. The Policy remains valid until a new version is published.

11.3. The latest version of the Policy is available on the website https://digital-marketer.com.ua/user-agreement.