Privacy Policy

What documents will we work with?

The current Privacy Policy of the website https://finance.done.partners (hereinafter — the "Policy") is for informational purposes only, which means it is not a source of obligations for the Clients of the website (it is not a contract or rules). The purpose of the Policy is to clearly present the principles of operation of the website, as well as the rules for processing personal data.

Who is the administrator of your personal data?

The administrator of personal data collected through:

• the website https://finance.done.partners (including through the use of "cookies" or similar technologies) or other communication channels with the Client;
• as a result of the Client's online activity, is the Limited Liability Company "Dann.", with its head office located at: 11 Solomianska Street, Kyiv, Ukraine, 03110 (this address is also used for sending correspondence), Identification code 40929000 (hereinafter — the "Administrator", who is also the Seller).

Our personal data protection inspector can be contacted electronically at e-mail: info@dann.com.ua. Your personal data may also be processed for marketing, analytical, and statistical purposes.

How do we take care of your personal data?

The Administrator pays great attention to the security and legality of the process of processing Clients' personal data. The Client's personal data is processed in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) of 27 April 2016 (hereinafter — "GDPR"), as well as other regulatory acts throughout the entire period of personal data processing. "Personal data" means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to identifiers such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

As mentioned at the beginning, the Administrator protects the data not only of persons who visit the website but also of Clients who have provided the Administrator with Personal Data through other communication channels, namely:

a) Websites https://www.facebook.com, https://www.instagram.com/, and all other websites that cooperate with Meta (including domains, international versions, widgets, and mobile phone versions), which operate based on the rules posted at https://www.facebook.com/legal/terms by Facebook Inc. or Meta Platforms, Inc. and Meta Platforms Ireland Limited (hereinafter — the "Facebook Service"), also through the Facebook Lead Ads functions, which usually engage in marketing the Administrator's own products or services. The rules for the protection and use of Personal Data through the Facebook Service are posted on the website: https://www.facebook.com/policy.php. The Administrator has no influence on the content of regulations and rules regarding Personal Data of the Facebook Service.

b) Websites https://www.tiktok.com and all other websites that cooperate with Beijing.

For what purpose and on what basis do we process your data?

Your Personal Data may be processed for various purposes and on various legal grounds, depending on which functionalities of the website you use, in particular for concluding and executing contracts entered into with you, for conducting marketing activities, market and statistical analysis, improving service quality, fulfilling relevant legal obligations imposed on the Administrator, or detecting ad fraud abuse. Details below.

1. Account on the website

The Administrator of your personal data is the entity specified in point II of this Policy.

Your personal data provided by you when registering an Account, as well as collected in connection with your activity on the website and use of our services (in particular, first and last name; email address; contact phone number) are or may be processed for the purpose of:

a) maintaining your account so that you can use the offered benefits (for example, placing orders without having to fill out a form each time, managing your consents in the system, etc.) as well as providing you with the opportunity to use other services available on our website — legal basis: Art. 6(1)(b) GDPR, i.e., the necessity of performing the contract that you conclude when creating an Account and accepting the Rules of the website;

b) marketing, analytical, and statistical activities of the Administrator or its partners or other so-called third parties with whom we cooperate, for example, presenting you with advertisements and offers (discounts) tailored to your interests based on profiling (in a simplified way, we analyze your activities (for example, behavior on our website), thanks to which we can better adapt not only to specific, general groups of our clients but also to your preferences). Our actions do not affect your decisions, for example when placing an order — legal basis: Art. 6(1)(f) GDPR, i.e., the legitimate interest of the administrator or a third party;

c) determining, defending, and considering claims that may arise between you and the Administrator and for other purposes necessary for the realization of the legitimate interests of the Administrator or a third party — legal basis: Art. 6(1)(f) GDPR, i.e., the legitimate interest of the administrator or a third party;

The provision of Personal Data is voluntary but necessary for registration on the website.

We will generally process your personal data during the period of your use of the account (and, for greater protection, they may be deleted 3 years after your last activity on the website), and in the case of marketing activities — until you object, unless the law requires us to process this data for a longer period, or we will store them longer in case of possible claims during the limitation period determined by legislation, in particular the Civil Code, or in case of other purposes resulting from the realization of our legitimate interests. In any case, the longer period of storage of Personal Data is decisive.

Information about recipients of Personal Data is described in detail in point VIII of this Policy.

Information about the possible transfer of your personal data to third countries (outside the European Economic Area and Ukraine) is described in detail in point IX of this Policy.

Your rights regarding the processing of your personal data are described in detail in point X of this Policy.

2. Placing an order

The Administrator of your personal data is the entity specified in point II of this Policy.

Your personal data provided by you when placing an order, as well as collected in connection with your activity on the website and use of our services (in particular, first and last name; email address; contact phone number) are or may be processed for the purpose of:

a) fulfilling your order and executing the concluded contract — in particular, confirming its placement or reservation (if such an option is available and you have selected it) or sending the selected product to you or to a pickup point, as well as if necessary, contacting you on this matter — legal basis: Art. 6(1)(b) GDPR, i.e., during the placement of the order (if such an option is available and you have selected it);

b) marketing, analytical, and statistical activities of the Administrator or its partners (third parties listed in point 11 of the Cookies Policy) or other so-called third parties with whom we cooperate, for example, presenting you with advertisements and offers (discounts) tailored to your interests based on profiling (in a simplified way, we analyze your activities (for example, your purchase history and behavior on our website), thanks to which we can better adapt not only to specific, general groups of our clients but also to your preferences). Our actions do not affect your decisions, for example when making a purchase — legal basis: Art. 6(1)(f) GDPR, i.e., the legitimate interest of the administrator or a third party;

c) determining, defending, and considering claims that may arise between you and the Administrator and for other purposes necessary for the realization of the legitimate interests of the Administrator or a third party — legal basis: Art. 6(1)(f) GDPR, i.e., the legitimate interest of the administrator or a third party;

The provision of Personal Data is voluntary but necessary for placing an order.

To fulfill your order, we will process your personal data during the period of contract performance, as well as during the time provided for by legislation, in the case of marketing activities — until you object, unless the law requires us to process this data for a longer period, or we will store them longer in case of possible claims during the limitation period determined by legislation, in particular the Civil Code, or in case of other purposes resulting from the realization of our legitimate interests. In any case, the longer period of storage of Personal Data is decisive.

Information about recipients of Personal Data is described in detail in point VIII of this Policy.

Information about the possible transfer of your personal data to third countries (outside the European Economic Area) is described in detail in point IX of this Policy.

Your rights regarding the processing of your personal data are described in detail in point X of this Policy.

3. Complaint form

The Administrator of your personal data is the entity specified in point II of this Policy.

Your personal data provided by you in connection with the submission of a complaint (Complaint Form) and collected during further communication are or may be processed for the following purposes:

a) consideration of your complaint and resolution of complaints — legal basis: Art. 6(1)(c) GDPR, i.e., the necessity of fulfilling a legal obligation imposed on the Administrator;

b) determining, defending, and considering claims that may arise between you and the Administrator and for other purposes necessary for the realization of the legitimate interests of the Administrator or a third party — legal basis: Art. 6(1)(f) GDPR, i.e., the legitimate interest of the administrator or a third party.

The provision of Personal Data is voluntary but necessary for submitting a complaint.

We will process your personal data during the period of handling your complaint, unless the law requires us to process this data for a longer period, or we will store them longer in case of possible claims during the limitation period determined by legislation, in particular the Civil Code, or in case of other purposes resulting from the realization of our legitimate interests. In any case, the longer period of storage of Personal Data is decisive.

Information about recipients of Personal Data is described in detail in point VIII of this Policy.

Information about the possible transfer of your personal data to third countries (outside the European Economic Area and Ukraine) is described in detail in point IX of this Policy.

Your rights regarding the processing of your personal data are described in detail in point X of this Policy.

4. Contact form

The Administrator of your personal data is the entity specified in point II of this Policy.

Your personal data provided by you in the Contact Form and collected during further communication are or may be processed for the following purposes:

a) communicating with you and providing a response to your message — legal basis: Art. 6(1)(f) GDPR, i.e., the legally legitimate interest pursued by the Administrator;

b) depending on the content of the message, taking measures at your request prior to concluding the relevant contract — Art. 6(1)(b) GDPR, i.e., the necessity of taking measures to conclude a contract;

c) depending on the content of the message, marketing, analytical, and statistical activities of the Administrator, or partners (third parties listed in point 11 of the Cookies Policy) or other so-called third parties with whom we cooperate — legal basis: Art. 6(1)(f) GDPR, i.e., the legitimate interest of the administrator or a third party;

d) determining, defending, and considering claims that may arise between you and the Administrator and for other purposes necessary for the realization of the legitimate interests of the Administrator or a third party — legal basis: Art. 6(1)(f) GDPR, i.e., the legitimate interest of the administrator or a third party.

The provision of Personal Data is voluntary but necessary for effective communication with us.

We will process your personal data until we cease communication with you, and in the case of marketing activities — until you object, unless the law requires us to process this data for a longer period, or we will store them longer in case of possible claims during the limitation period determined by legislation, in particular the Civil Code, or in case of other purposes resulting from the realization of our legitimate interests. In any case, the longer period of storage of Personal Data is decisive.

Information about recipients of Personal Data is described in detail in point VIII of this Policy.

Information about the possible transfer of your personal data to third countries (outside the European Economic Area and Ukraine) is described in detail in point IX of this Policy.

Your rights regarding the processing of your personal data are described in detail in point X of this Policy.

5. Newsletter subscription

The Administrator of your personal data is the entity specified in point II of this Policy.

Your personal data, including those provided in connection with the newsletter subscription, may be processed for the following purposes:

a) execution of the contract for the provision of the Newsletter: Art. 6(1)(b) GDPR, i.e., the necessity for the performance of the concluded contract (terms of providing the newsletter service) — to send you, for example, by email, sms, mms, push, or messengers that have an analogous application for you intended directly for your phone number (for example, Messenger, WhatsApp), attractive announcements and offers (discounts). Of course, you can unsubscribe from the newsletter.

b) marketing, analytical, and statistical activities of the Administrator or its partners (third parties listed in point 11 of the Cookies Policy) or other so-called third parties with whom we cooperate, for example, displaying advertisements and offers (discounts), also customized according to your interests based on profiling (in a simplified form, we analyze your activity (for example, behavior on our website) so that we can better adapt not only to specific, general groups of our clients but also to your preferences). However, our actions do not have a significant impact on your decisions: Art. 6(1)(f) GDPR, i.e., the legitimate interest of the Administrator or third parties;

c) determining, defending, and considering claims that may arise between you and the Administrator and for other purposes necessary for the realization of the legitimate interests of the Administrator or a third party — legal basis: Art. 6(1)(f) GDPR, i.e., the legitimate interest pursued by the Administrator or a third party.

The provision of personal data is voluntary but necessary for subscribing to the newsletter.

We will process your data during the period necessary for the performance of the contract (unsubscribing from the newsletter), your filing a complaint, as well as during the time determined by legislation, unless the law obliges us to longer processing of this data, or we will store them longer in case of possible claims, during the limitation period determined by legislation, in particular the Civil Code, or in case of other purposes resulting from the realization of our legitimate interests. In any case, a longer period of storage of personal data is determined.

Information about recipients of Personal Data is described in detail in point VIII of this Policy.

Information about the possible transfer of your personal data to third countries (outside the European Economic Area and Ukraine) is described in detail in point IX of this Policy.

Your rights regarding the processing of your personal data are described in detail in point X of this Policy.

6. Social media accounts

The Administrator of your personal data is the entity specified in point II of this Policy.

Your personal data, including those you leave when visiting our profiles on social media (such as comments, likes, online identifiers), are or may be processed for the following purposes:

a) marketing, analytical, and statistical activities, in the form of providing you with activity on the profile, effectively maintaining our profile, by providing you with information about our initiatives and other activity, as well as in connection with promoting through us various types of events, services, and products (including those of partners (third parties listed in point 11 of the Policy) or other so-called third parties with whom we cooperate): Art. 6(1)(f) GDPR, i.e., the legally legitimate interest of the Administrator;

b) determining, defending, and considering claims that may arise between you and the Administrator and for other purposes necessary for the realization of the legitimate interests of the Administrator or a third party — legal basis: Art. 6(1)(f) GDPR, i.e., the legitimate interest pursued by the Administrator or a third party.

The provision of personal data is voluntary but necessary to fully use the functionality of our profiles on social media.

Your personal data will be processed during the period necessary to achieve the above purposes or your filing a complaint, as well as during the time determined by legislation (for example, tax, accounting procedures), unless the law obliges us to longer processing of this data, or we will store them longer in case of possible claims, during the limitation period determined by legislation, in particular the Civil Code, or in case of other purposes resulting from the realization of our legitimate interests. In any case, a longer period of storage of personal data is determined.

Information about recipients of Personal Data is described in detail in point VIII of this Policy.

Information about the possible transfer of your personal data to third countries (outside the European Economic Area and Ukraine) is described in detail in point IX of this Policy.

Your rights regarding the processing of your personal data are described in detail in point X of this Policy.

7. Product availability notification

The Administrator of your personal data is the entity specified in point II of this Policy.

Your personal data provided in connection with the desire to use the product availability notification service may be processed for the following purposes:

a) sending notification of product availability: Art. 6(1)(b) GDPR, i.e., the necessity to perform the service contract in the form of product availability notification;

b) marketing, analytical, and statistical efforts of the Administrator or partners (third parties listed in point 11 of the Policy) or other so-called third parties with whom we cooperate: Art. 6(1)(f) GDPR, i.e., the legitimate interest of the Administrator or a third party;

c) determining, defending, and considering claims that may arise between you and the Administrator and for other purposes necessary for the realization of the legitimate interests of the Administrator or a third party — legal basis: Art. 6(1)(f) GDPR, i.e., the legitimate interest pursued by the Administrator or a third party.

The provision of personal data is voluntary but necessary for you to receive a product availability notification.

We will process your data during the period necessary to notify you of product availability (this period may vary depending on the product you have chosen), and in the case of marketing purposes — until you submit objections, unless the law obliges us to longer processing of this data, or we will store them longer in case of possible claims, during the limitation period determined by legislation, in particular the Civil Code, or in case of other purposes resulting from the realization of our legitimate interests. In any case, a longer period of storage of personal data is determined.

Information about recipients of Personal Data is described in detail in point VIII of this Policy.

Information about the possible transfer of your personal data to third countries (outside the European Economic Area and Ukraine) is described in detail in point IX of this Policy.

Your rights regarding the processing of your personal data are described in detail in point X of this Policy.

8. Customer satisfaction survey

The Administrator of your personal data is the entity specified in point II of this Policy.

Your personal information provided to us in connection with the study of your satisfaction with the services we provide may be processed by us for the following purposes:

a) customer satisfaction research (for example, by using various types of surveys), improving the website and the quality of services offered by the Administrator: Art. 6(1)(f) GDPR, i.e., the legally legitimate interest pursued by the Administrator or a third party;

b) determining, defending, and considering claims that may arise between you and the Administrator and for other purposes necessary for the realization of the legitimate interests of the Administrator or a third party — legal basis: Art. 6(1)(f) GDPR, i.e., the legitimate interest pursued by the Administrator or a third party.

The provision of personal data is voluntary; however, without them, this may prevent you from participating in the satisfaction survey. Their provision will allow us to learn your opinion about the services we provide and will allow us to improve the website.

We will process your data during the period necessary to conduct the satisfaction survey and develop and implement solutions aimed at improving the website and the quality of services provided, unless the law obliges us to longer processing of this data, or we will store them longer in case of possible claims, during the limitation period determined by legislation, in particular the Civil Code, or in case of other purposes resulting from the realization of our legitimate interests. In any case, a longer period of storage of personal data is determined.

Information about recipients of Personal Data is described in detail in point VII of this Policy.

Information about the possible transfer of your personal data to third countries (outside the European Economic Area and Ukraine) is described in detail in point IX of this Policy.

Your rights regarding the processing of your personal data are described in detail in point VIII of this Policy.

Are you obliged to provide us with your personal data, and what may be the consequences of failing to do so?

The provision of Personal Data by the Client on the website is voluntary but necessary for using certain functions of our website, for example, for placing an Order, registering an Account, subscribing to the newsletter, or using our forms.

Each time, the scope of data necessary for concluding the relevant contract is indicated in advance on the website (we mark the data, the provision of which is necessary for concluding a contract/using certain functions), through other communication channels with the Client, or in the Rules. Failure to provide Personal Data may result in the inability to effectively perform the actions indicated above.

Are your data subject to profiling, and what does this mean for you?

The Administrator, for the purpose of presenting general advertisements, offers, or promotions (discounts) intended for all Clients in a manner adapted to the interests of a specific Client, may familiarize themselves with their preferences, for example, by analyzing how often they visit the website. This allows for a better understanding of the Client's expectations and adapting to their needs but does not affect their decisions.

The analysis of visits to our website and the information collected about how you use it may also help us detect ad fraud abuse.

To whom can we transfer your personal data?

Each time, the catalog of recipients of Personal Data processed by the Administrator depends primarily on the scope of services used by the client.

The catalog of data recipients is also determined by the consent of the Client or by legislation, and is also clarified as a result of actions taken by them on the website.

In the processing of Personal Data to a limited extent, partners of the Administrator may take part, in particular, entities that technically allow for effective management of the website, including communication with our clients (for example, supporting us in sending email messages, and in the case of advertising activities in marketing campaigns), the hosting or data transmission service provider, companies that repair software, support the Administrator in marketing campaigns, as well as providers of legal and consulting services.

In accordance with the above rules, the client's personal data may also be transferred to companies related to the Administrator.

First of all, as part of marketing (advertising) activities, the administrator uses the services of third parties who use cookies or similar technologies in the online store.

Are your personal data transferred to other countries (outside the European Union and Ukraine)?

As part of the Administrator's use of tools that support its current activities, for example, Google, the Client's Personal Data may be transferred to countries outside the European Economic Area, in which the entity cooperating with it will receive tools intended for the processing of Personal Data when cooperating with the Administrator.

The necessary protection of transferred personal data has been ensured by the Administrator through the application of standard data protection clauses adopted by decision of the European Commission and data processing agreements that comply with GDPR requirements. In the case of data transfer to states outside the European Economic Area, we make every effort to ensure that our partners provide an appropriate level of protection by taking additional personal data security measures.

The Client has the right to obtain a copy of the guarantees applied by the Administrator regarding the transfer of personal data to a third country by contacting us (contact details in point II of the Policy).

What rights and obligations do you have?

Each client has the right to:

a) file a complaint with the head of the personal data protection authority (Stawki Street 2, 00-193 Warsaw);

b) transfer the Personal Data that they have provided to the Administrator and which is processed in an automated manner and the processing is carried out on the basis of consent or under a contract, for example, to another administrator;

c) access to Personal Data (including, for example, obtaining information about which personal data is being processed or copies thereof);

d) demand correction and restriction of processing (for example, if the personal data is incorrect) or deletion of personal data (for example, if it has been processed unlawfully);

e) cancellation of any consent expressed to the Administrator at any time, while withdrawal of consent does not affect the processing carried out by the Administrator in accordance with the laws prior to its cancellation;

f) refuse the processing of personal data carried out for the purpose of realizing the legitimate interests of the Administrator or a third party (if there are no other valid legally justified grounds for processing in relation to the client's interests). If personal data is processed for direct marketing purposes, the client has the right at any time to refuse the processing concerning their personal data for the needs of such marketing, including profiling, to the extent that the processing is associated with such direct marketing — in this case, personal data cannot be processed for such purposes.

Will commercial information be sent to you (e.g. to your email address)?

The Administrator has the technical capability to communicate with the client at a distance (for example, email, sms).

Commercial information related to the commercial activity carried out by the Administrator or organizations cooperating with it may be sent after the client has given consent to receive commercial information, including after accepting the terms of the newsletter.

How are your personal data protected?

The Administrator, taking into account the state of technical knowledge, the cost of implementation, as well as the nature, scope, conditions, and purposes of processing, as well as the risk of violating the rights and freedoms of natural persons with varying probability and weight of threat, uses the necessary organizational and technical measures to protect the processed Personal Data, appropriate to the threats, as well as the categories of data being protected, and, in particular, protects data from unauthorized access, processing in violation of applicable law, as well as from change, loss, damage, or destruction.

Providing external information about the technical and organizational means that ensure the protection of processing may undermine their effectiveness, which jeopardizes the proper protection of personal data.

The Administrator duly provides, for example, the following technical measures that prevent unauthorized persons from obtaining and modifying personal data transmitted electronically:

a) protection of the dataset from unauthorized access;

b) SSL certificate on the pages of the website where personal data is hosted;

c) data encryption for the authorization of the person using the functionality of the online store;

d) access to the Account only after entering an individual login and password.

Links to other websites

The website may contain links to other websites. The Administrator suggests reviewing the terms and privacy policies applicable to other websites.

This Policy applies only to the specified actions of the Administrator.

Can this policy be subject to changes, and how will you learn about them?

The Administrator may change the policy in the future. Each time, they will post information about such changes on the website. With each change, a new version of the Policy will appear with a new date.