Privacy Policy

support@ozhibko.com

Welcome to Ozhibko and our website at www.ozhibko.com. We are committed to protecting your Personal Data and to providing clear and transparent disclosures about the types of information we collect and how we use it.


In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular Ukraine`s Law No. 8153 (“Law No. 8153”) and the EU’s General Data Protection Regulation (“GDPR”), and only as described in this Privacy Policy.

Welcome to Ozhibko and our website at www.ozhibko.com. We are committed to protecting your Personal Data and to providing clear and transparent disclosures about the types of information we collect and how we use it.


In principle, we will only use your Personal Data in accordance with the applicable data protection laws, in particular Ukraine`s Law No. 8153 (“Law No. 8153”) and the EU’s General Data Protection Regulation (“GDPR”), and only as described in this Privacy Policy.

General Information

a) What is Personal Data?

Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not Personal Data. This includes, for example, the number of users of a website.

b) What is Special Category Data?

Special category data is Personal Data that needs more protection because it is sensitive. This includes Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data. As well as, data concerning health, a person’s sex life; and a person’s sexual orientation. In order to lawfully process Special Category Data, it is necessary to consent to the processing.

c) What is processing?

"Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data.

d) Responsible for data processing

Responsible for data processing is Ozhibko, Serhiy Ozhibko of Knyahyni Olʹhy, L’viv, L’vivs’ka oblast, 79000, Ukraine (“Ozhibko”, “we”, “us” or “our”). We act as the data controller and ask you to direct all questions about your Personal Data directly to us using support@ozhibko.com.

e) The Legal Bases for processing Personal Data

In accordance with the above-mentioned laws, we have to have at least one of the following legal bases to process your Personal Data:

  • you have given your consent,

  • the data is necessary for the fulfillment of a contract / pre-contractual measures,

  • the data is necessary for the fulfillment of a legal obligation, or

  • the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

General Principles

a) Security

Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us.

You can recognise an encrypted connection if the address line of your browser contains a "https://" instead of a "http://" and also has a lock symbol. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

We have also implemented numerous security measures (“technical and organizational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through this website.

Nevertheless, internet-based data transmissions can always have security gaps, so that absolute protection cannot be guaranteed. And databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion.

Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised as expeditiously as possible after which the breach was discovered.

b) Minors

We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties.

c) Automated decision-making

Automated decision-making is the process of making a decision by automated means without any human involvement. Automated decision-making including profiling does not take place.

d) Do Not Sell

We do not sell your Personal Data.

e) Special Category Data

Unless specifically required when using our services and consent is obtained for that particular service, we do not process special category data.

f) International Transfer

We may transfer your Personal Data to other companies and/or business partners as necessary for the purposes described in this Privacy Policy. In doing so, your Personal Data may be transferred to so called third countries. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organizational measures to protect the Personal Data we transfer.

g) How long is your data stored?

We process and store your Personal Data only to achieve the respective processing purpose or for as long as a legal retention period exists (in particular Ireland`s commercial and tax law for up to 10 years). Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.

h) Sharing and Disclosure

We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services for example with our web host or with our logistic partners to deliver your order, b) you have consented to the disclosure, c) or if we are legally obliged to do so e.g., by court order or if this is necessary to support criminal or legal investigations or other legal investigations or other legal proceedings; as required by law or regulation; if Ozhibko (or a part of Ozhibko) is sold to or merged with another company; or proceedings at home or abroad or to fulfill our legitimate interests.

Data we collect automatically

a) Collection of access data and log files

We also collect data on every access to our website. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider.

Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a maximum of 7 days and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified. The legal basis for the data processing is our legitimate interest.

b) Content Delivery Network

We use a Content Delivery Network (CDN) to distribute our online content. Our CDN is a network of regionally distributed servers of our technical service providers connected via the Internet. When our website is visited, your device`s browser transmits information to these service providers, which is collected in corresponding server log files. Server log files are generally anonymized and then transmitted without any personal reference. Server log files include, in particular, i) details of the browser and operating system used, ii) the previously visited pages (so-called referral URL), iii) the IP address of the device used, iv) the name of the Internet provider, as well as v) the date, time of all page views including the amount of data transmitted. The legal basis for processing is our legitimate interest.

c) Use of cookiess

We use so-called cookies on our web site. Cookies are small text files that are stored on your respective device (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.

d) Hosting

To provide our website, we use the services of Vercel Inc who process all data to be processed in connection with the operation of our website on our behalf. The legal basis for the data processing is our legitimate interest in providing our website.

Data from third party sources

We may obtain data about you from third-party sources, such as our marketing partners, social networks, and other third parties. We may use this data to better analyses your user behavior to improve our ability to provide you with relevant marketing information and services, and to prevent and combat fraud.

Insofar as you have also given us your consent to process your Personal Data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

Data we collect directly

a) General

We may ask you for Personal Data when you:

  • use our website,

  • request support, or information,

  • participate online or otherwise in marketing activities,

  • interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties), or

  • contact us.

Categories of Personal Data we collect may include your contact details (name, email address), and IP addresses. In order to provide you with a more consistent and personalized user experience in your interactions with Ozhibko, data collected through one source may also be linked to other data collected by Ozhibko through other sources. This may include data that helps us identify you when you access our website through several different devices.

In addition to your name, and e-mail address, IP address or telephone number, if provided, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and Contract.

b) Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving. In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.

c) When you are using our Apps

We process Personal Data only to the extent authorized by you personally. In doing so, we only collect and process the data that is absolutely necessary to maintain and use the App. Personal data may be collected in two ways, that is directly when you for example volunteer it to us or automatically for example when you install and use our App.

In addition to the above and unless specifically described in our Apps or supplemental policies and statements, we may collect and process the following data which may contain Personal Data:

  • information that you provide by filling in forms in our Apps, including information provided at the time of registering for, subscribing to any services provided by us, posting material, reporting a problem, or requesting further services;

  • information, data, documents or images that you upload;

  • details of transactions you carry out;

  • details of, resources that you access and actions you are working on;

  • if you contact us, a record of that correspondence.

We use information held, including Personal Data, in the following manner:

  • to ensure that content from our Apps is presented in the most effective manner for you and for your device;

  • to provide you with information or services that you request from us, and to otherwise carry out our obligations arising from any contracts entered into between you and us;

  • to provide you with information or services which we feel may interest you, where you have consented to be contacted for such purposes;

  • to allow you to participate in interactive features of our service, when you choose to do so;

  • to notify you about changes to our services;

  • to investigate any complaints relating to the use of our Apps or any suspected unlawful activities;

  • complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

  • any other purposes for which you have provided the information; and

  • carrying out whatever else is reasonable or related to or in connection with the above and our Apps.

In addition to the above and unless specifically described, we may also collect and process information relating to your device. As such this may include including hardware and software information, device ID and type, version and language, operating system, time sones, identifiers associated with cookies or other technologies that may uniquely identify your device, information on your wireless and mobile network connection, like your service provider and signal strength to maintain a record of how many devices you use to connect to our service. And we may also request access or permission to certain functions from your device. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures.

Our Apps can be downloaded and installed from the "Google Playstore" and "Apple App Store". Downloading the App may require prior registration with the respective App store and/or installation of the respective App store software.

As far as we are aware, Google collects and processes the following data: License check, network access, network connection, WLAN connections, and location information. And Apple collects and processes the following data: device identifiers, IP addresses, and location information.

It cannot be ruled out that Google and Apple also transmit the information collected to a server in a third country. We cannot influence which Personal Data Google and Apple processes with your registration and the provision of downloads in the respective App store and App store software. The responsible parties in this respect are solely Google and Apple.

Google and Apple may collect information from and about the device(s) you use to access our App, including hardware and software information such as IP address, device ID and type, device-specific and app settings and properties, App crashes, advertising IDs information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass.

Some of our Apps are using the Freemium Model. As such, our Apps my use third-party advertising networks service to display ads. In order to provide personalized advertisements to our users, Google uses device information that include personal and non-Personal Data, such as advertising (or ad) identifiers, IP address regarding the delivery of advertisements and your interaction with them and/or other tracking technologies to enable and optimize its advertising procedure. Advertisers and third parties also may collect information about your activity on our Apps, on devices associated with you, and on third-party sites and applications using tracking technologies. Tracking data collected by these advertisers and third parties is used to decide which ads you see both on our Apps and on third-party sites and applications. You can also opt out on the Digital Advertising Alliance (DAA) if you wish not to receive targeted advertising. In addition, you may also choose to control targeted advertising you receive within applications by using the settings and controls on your device(s).

When you make In-app purchases, we (Google and Apple on our behalf) may collect the following data from you to process the purchase:

  • Android or Apple user ID

  • Email address

  • Payment confirmation from the payment data collected by Apple or Google; and

  • Device IP and device serial number to link the story history to the device.

Your Rights and Privileges

a) Privacy rights

Under Law No. 8153 and GDPR, you can exercise the following rights:

  • Right to information

  • Right to rectification

  • Right to object to processing

  • Right to deletion

  • Right to data portability

  • Right of objection

  • Right to withdraw consent

  • Right to complain to a supervisory authority

  • Right not to be subject to a decision based solely on automated processing.

If you have any questions, please contact us.

b) Updating your information

If you believe that the information, we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.

c) Withdrawing your consent

You can withdraw consents you have given at any time by contacting us.

d) Access Request

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

e) Complaint to a supervisory authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. The supervisory authority in Ukraine is: The Authorised Human Rights Representative of the Verkhovna Rada of Ukraine (the “Ombudsman Office”), 21/8 Instytutska Str.,01008, Kyiv, Ukraine www.ombudsman.gov.ua

Validity and questions

This Privacy Policy was last updated on Wednesday, 05 April 2023 and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary. If you have any data protection questions, please feel free to contact us.