Regarding the Processing and Protection of Personal Data on the website www.evyap.com.ua

This Privacy Policy (hereinafter referred to as the “Policy”) sets out the procedure for the collection, processing, use, storage, and protection of personal data received by EVYAP TRADING UKRAINE LLC (hereinafter referred to as the “Company”, “we”, “us”, or “our”) when users visit and use the website www.evyap.com.ua (hereinafter referred to as the “Website”).

Personal data is processed in accordance with the Law of Ukraine “On Personal Data Protection”, the Constitution of Ukraine, and other applicable laws and regulations of Ukraine. By using Website functionality that involves the provision of personal data and by providing such data, the User confirms that they have read and understood this Policy.

1. Personal Data Controller

The controller of personal data collected through the Website is:

  • Company name: EVYAP TRADING UKRAINE LLC
  • EDRPOU code: 38649420
  • Registered address: 32-V Hlybochytska Street, Kyiv, 04050, Ukraine
  • Person responsible for personal data processing: Vadym Volodymyrovych Zhuravskyi
  • Email for personal data enquiries: vzhuravskyi@evyap.com
  • Phone: +38 (044) 247-57-81

2. Personal Data We Collect

We collect only the data that you voluntarily provide, as well as technical data automatically transmitted by your device. In particular:

2.1. Data You Provide Voluntarily

Through the “Contact Us” form and other forms available on the Website, we may collect:

  • first name (and, optionally, last name);
  • email address;
  • phone number;
  • the content of your enquiry, request, or message;
  • other information that you voluntarily provide in your communication.

2.2. Data Collected Automatically

When you visit the Website, the following data may be processed automatically:

  • IP address and approximate location (at city/country level);
  • browser type and version, operating system, and device type;
  • date and time of visit, pages viewed, and referral source;
  • cookies and similar technologies (see Section 7 for details).

The Website is hosted locally in Ukraine. The provider of hosting and technical services may process technical data solely to the extent necessary to ensure the operation, security, and administration of the Website.

3. Purposes and Legal Grounds for Processing

We process personal data for the following purposes and on the following legal grounds (Article 11 of the Law of Ukraine “On Personal Data Protection”):

  • responding to your enquiries, requests, or messages — on the basis of your consent;
  • reviewing commercial enquiries, product enquiries, cooperation requests, or other business communications — on the basis of your consent and/or for taking steps prior to entering into or performing a transaction;
  • ensuring the proper operation, information security, administration, and technical support of the Website — on the basis of the necessity to pursue the legitimate interests of the personal data controller in ensuring the proper functioning, information security, and administration of the Website, as well as in other cases provided for by Article 11 of the Law of Ukraine “On Personal Data Protection”;
  • complying with applicable Ukrainian legislation, including accounting, tax, contractual, and other record-keeping requirements — on the basis of a legal obligation.

4. Consent to Personal Data Processing

By providing your data through forms on the Website and selecting the relevant checkbox, you consent to the Company processing your personal data within the scope and for the purposes specified in this Policy.

Consent is given voluntarily. You have the right to withdraw your consent at any time by sending a corresponding request to the email address specified in Section 1. Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

5. Disclosure of Personal Data to Third Parties

We do not sell personal data. Personal data may only be disclosed in the following cases:

  • to companies within the Evyap Group, including the parent company EVYAP İNTERNATIONAL DIŞ TİCARET A.Ş. (Republic of Türkiye), where necessary for internal administrative, commercial, accounting, or management purposes;
  • to service providers acting on our behalf, including the local hosting provider in Ukraine and providers of technical support, Website administration, information security, and analytics services, subject to confidentiality obligations and only to the extent necessary to provide the relevant services;
  • to public authorities, law enforcement agencies, courts, or other authorised persons in the cases and in accordance with the procedures provided for by Ukrainian law.

6. Cross-Border Data Transfers

The primary storage of data related to the operation of the Website is carried out on local hosting in Ukraine. The Company is part of the international Evyap Group, and therefore certain personal data may be transferred to Group companies outside Ukraine, including to Türkiye. Pursuant to Part 3 of Article 29 of the Law of Ukraine “On Personal Data Protection”, the Republic of Türkiye, as a party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, is considered to provide an adequate level of personal data protection. Transfers of personal data are governed by a controller-to-controller Personal Data Transfer Agreement between Evyap companies, which establishes organisational safeguards for data protection. Where consent of the personal data subject is required by law as the legal basis for such transfer, such consent is obtained before the transfer takes place.

7. Cookies

The Website uses cookies — small text files stored on your device. We use:

  • essential (technical) cookies — required for the basic operation of the Website, its security, and correct display of pages;
  • functional cookies — may be used to remember certain user preferences where such functionality is implemented on the Website;
  • analytics cookies — may be used for aggregated analysis of Website traffic only where the relevant analytics tools are enabled.

Essential cookies may be used without separate consent because they are necessary for the operation of the Website. Optional cookies, including analytics or marketing cookies, where used, are applied only after obtaining your consent through the relevant banner or another consent management mechanism. You may change your settings or delete cookies in your browser at any time. Disabling certain cookies may affect the functionality of the Website. Detailed terms governing the use of cookies, their categories, and retention periods are set out in a separate Cookie Policy available on the Website, which forms an integral part of this Policy.

8. Data Retention Periods

Personal data is retained for no longer than necessary to achieve the purposes for which it is processed, including:

  • enquiry data — for the period necessary to review and respond to the request, as well as for 1 year after communication has ended, unless another period is established by law or retention is necessary to protect the rights and interests of the Company;
  • data related to contractual, tax, accounting, or other record-keeping relationships — for the periods established by Ukrainian law;
  • data processed on the basis of consent — until consent is withdrawn, unless another retention period is required by law or follows from the purpose of the processing.

9. Your Rights

In accordance with Article 8 of the Law of Ukraine “On Personal Data Protection”, you have the right to:

  • know the sources from which your personal data is collected, the location of your personal data, the purpose of its processing, and the location of the controller;
  • receive information about the conditions for granting access to your personal data;
  • access your personal data;
  • request correction or updating of inaccurate or outdated data;
  • request deletion or destruction of your personal data where it is processed unlawfully or is inaccurate;
  • protect your personal data against unlawful processing, accidental loss or destruction, as well as against the dissemination of inaccurate information or information that damages honour, dignity, or business reputation;
  • withdraw your consent to personal data processing;
  • make reservations regarding restrictions on the processing of your personal data when providing consent;
  • object to the processing of your personal data;
  • know the mechanism of automatic processing of your personal data;
  • be protected from automated decisions that have legal consequences for you;
  • use legal remedies in the event of violations of personal data protection legislation;
  • submit complaints regarding the processing of your personal data to the Ukrainian Parliament Commissioner for Human Rights or to a court.

To exercise your rights, please send a request to the email address specified in Section 1 of this Policy.

In your request, please provide your name, contact details for receiving a response, the nature of your request, and information that enables us to identify the personal data processed by the Company. A response will be provided within the time limits established by Ukrainian law, including no later than 30 calendar days from the date the request is received, unless otherwise provided by law.

10. Personal Data Protection

The Company implements organisational and technical measures to protect personal data against unauthorised access, loss, destruction, alteration, or disclosure, including restricted access to data, the use of secure connections (HTTPS/SSL), backups, access controls for Website administration panels, the use of local hosting in Ukraine, and confidentiality obligations for employees and engaged service providers.

11. Protection of Children’s Data

The Website is not intended to collect data from persons under the age of 18. We do not knowingly collect personal data from children. If you become aware that a child has provided us with personal data without the consent of a legal representative, please notify us so that the data can be deleted.

12. Changes to this Policy

We may update this Policy from time to time. The current version will always be available on this page of the Website together with its effective date. We recommend reviewing it periodically. Continued use of the Website after changes are made constitutes acceptance of the updated version.

13. Contact Details

For any questions regarding the processing of personal data or this Policy, please contact the responsible person:

  • Responsible person: Vadym Volodymyrovych Zhuravskyi
  • Email: vzhuravskyi@evyap.com
  • Phone: +38 (044) 247-57-81

Address: 32-V Hlybochytska Street, Kyiv, 04050, Ukraine