Eng
Kyiv

Privacy

Privacy policy and personal data processing

1. General Provisions and Scope of Application

Individual entrepreneur «Losinskyi Serhii Oleksandrovych», location: 10005, Ukraine, Zhytomyr region, Zhytomyr city, 106, Chudnivska Street, apartment 46, and/or ZHRAIA Limited Liability Company, location: 73g, Rizka Street, Kyiv, 04060, Ukraine, Office 7/1 (hereinafter referred to together as the «Company») processes personal data of individuals who purchase and/or order goods and/or services for themselves, order recipients, as well as visitors of the Pawwer Online Platform (hereinafter referred to as the «Buyers, Users») on the Pawwer Online Platform (hereinafter referred to as the «Pawwer Online Platform»), which includes the website: pawwer.com (hereinafter referred to as the «Site») and/or the Pawwer Mobile Application (hereinafter referred to as the «Mobile Application») and/or related services, in accordance with these Regulations on the Pawwer Online Platform Users (Buyers) Personal Data Processing and Protection (hereinafter referred to as the «Regulations»).
The Company is the owner of the Buyers’ personal data.
«Personal Data» in these Regulations means information or a set of information about an individual who is identified or can be specifically identified.
The Company’s processing of the Buyers’ personal data includes, but is not limited to, the following actions: personal data collection, registration, accumulation, storage, adaptation, modification, updating, use and dissemination (distribution, sale, transfer), depersonalisation, destruction, including with the use of information (automated) systems.
Other terms in these Regulations are used in the meanings given in the Law of Ukraine «On Personal Data Protection» dated 1 June 2010, No. 2297-VI.
By registering on the Site or in the Mobile Application (downloaded via the Play Market or App Store) and starting to use the Pawwer Online Platform, or placing an order without prior registration, the Buyer grants permission and voluntary unambiguous consent to the processing of his or her personal data under the conditions and in the manner outlined in these Regulations, and confirms that he or she has carefully read and fully understood these Regulations.
The Site may contain links to other websites (for informational purposes only). If you follow the links to other websites, these Regulations will not apply to such websites. In this regard, the Company recommends that you read the privacy and personal data policy of each such website before submitting personal data by which the Buyer can be identified.
Separate user accounts may be created on the Online Platform, including for the convenience of authorisation, ordering, speed of ordering, and payment for goods.

2. Personal Data Collection Composition, Content, and Sources

The Company may process the following personal data of the Buyers and recipients of the order:
Name, surname, patronymic, telephone number, e-mail address, date of birth, presence of children, gender, hobbies, pets, presence of a car and its VIN number, language of communication, delivery address, availability of an account in social networks/online platforms, information on passport data, and identification code.
This list of personal data is not exclusive and mandatory but depends on the needs and desires of the Buyer and the operations performed on the Pawwer Online Platform.
The Company collects most of the personal data directly from the Buyers when the Buyers provide personal data when using (registering) the Pawwer Online Platform, or when taking a survey (by filling out a questionnaire or otherwise), or during oral communication between the Buyer and the Site administration, or when making a payment on the Pawwer Online Platform (including when purchasing goods and/or services on credit/payment in instalments). However, the Company may also collect personal data of the Buyers from third parties through online platforms (for example, through a Facebook, Google, or AppleID account).
Personal data also means other information received by the Pawwer Online Platform legally from third parties and/or available from the Buyer’s social media accounts, in case of registration on the Pawwer Online Platform using social media authentication services. In this case, the Buyer agrees to the processing of information available from the relevant social media accounts.
Buyers are responsible for all information posted by them in public accounts. The Buyers are aware of all risks associated with disclosing their address or information about their exact location. If the Buyer decides to log in to the Pawwer Online Platform using a third-party authentication service, for example, information from the Facebook social media, the Company may receive additional information to which such third party has provided access.
The Company does not process a special category of personal data (the so-called «sensitive data») relating to racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, conviction to a criminal sentence, as well as health, sexual life, biometric or genetic data. Information that characterises the physiological characteristics of the Buyers, based on which their identity can be established, is also not processed.

3. Purpose, Grounds, and Terms of Personal Data Processing

The Company shall process personal data of the Buyers, in particular, for the following purposes:

  • To ensure that civil, commercial, and tax relations are duly implemented;
  • To perform the functions, powers, and duties assigned to the Company in accordance with the current legislation of Ukraine;
  • To identify the Buyer as a User of the Pawwer Online Platform;
  • To provide services to Buyers for the purchase and ordering of goods and/or services on the Pawwer Online Platform;
  • To process payments, conduct settlement transactions, provide reports, and maintain accounting and management records;
  • To create and implement bonus and loyalty programmes;
  • To provide financial services to Customers (to be usually provided by third parties and/or partners of the Company);
  • To create and implement the unified authorisation window-related projects on the Company’s partner platforms;
  • To improve the quality of goods/services;
  • To form ratings of the Pawwer Online Platform goods and offers, analyse the Customer’s actions, perform keyword searches, manage traffic on the Pawwer Online Platform, analyse and forecast preferences and interests of Customers to form the most relevant and profitable personal offers or promotional offers;
  • To conduct research and analytical work;
  • To protect the legitimate interests of the personal data owner or a third party to whom personal data is transferred;
  • To send information and marketing mailings (commercial offers, news, notifications of promotions, loyalty programmes, bonus programmes, promotional codes, discounts, personal recommendations, personal discounts and offers) containing information about the goods and/or services offered on the Pawwer Online Platform, and/or to send notifications regarding the functioning of the Pawwer Online Platform, by mail, e-mail, telephone number (Viber, SMS), as well as by sending information messages and alerts via the Pawwer Online Platform.

The Buyer may at any time refuse to receive information and marketing newsletters - through the appropriate settings, in the Mobile Application (User’s personal account - my newsletters) and/or by sending a message to the email address of the Online Platform: pawwer.com with a note in the subject line «Personal Data».

The Company may also process Data using the following technologies:

  • Cookies are a small amount of data that may include an anonymous unique identifier. Cookies are sent to the browser from the Resources and stored on the User’s device. Tracking technologies that are also used are beacons, tags, and scripts to collect and track information, as well as to improve services. The User can refuse all cookies (by changing the browser settings). By refusing to use cookies, the User agrees that some parts (functions) of the services may not be available for use.
  • Google Analytics (a web analytics service that tracks the traffic of the Website and the mobile application and may use the collected information to work with ads and notifications).
  • Hotjar is a service that helps to understand the User’s experience (for example, how much time the User spends on which pages, which links he/she chooses to click, what he/she likes and what he/she does not like, Hotjar uses cookies and other technologies to collect data about the behaviour of the User and his/her device (in particular, IP address of the device (collected and stored only in an anonymised form), device screen size, device type (unique device identification numbers), browser information, geographic location (country only), preferred language for displaying the Resources).

The Company shall process personal data of the Buyers on the following grounds:

  • Based on an agreement concluded and executed by and between the Company and the Buyer, or to implement measures preceding the conclusion of the agreement;
  • the need to fulfil the Company’s obligation under the law;
  • the need to protect the legitimate interests of the Company;
  • The Buyer’s (unambiguous) consent to the processing of his/her personal data as provided for in these Regulations, to the extent that such consent is required by the current legislation of Ukraine. In particular, consent is required when registering on the Pawwer Online Platform.

The personal data of the Buyers may be processed only if at least one of the grounds specified above is present.
Terms of processing of Buyers’ personal data. The Buyers’ personal data shall be stored no longer than necessary to achieve the purpose of their processing as defined above, unless otherwise provided by the legislation in the field of archival affairs and record keeping. The Buyers’ personal data are kept in Ukraine.

4. Access to Personal Data

The following persons (and only in case of official necessity) may have access to the Buyers’ personal data:

  • The Company’s personnel - the Company’s employees who have to work with such data to perform their labour and functional duties;
  • The Company’s related parties, if it is appropriate and necessary to achieve the purpose established by these Regulations;
  • Sellers to fulfil the order to the extent necessary to identify the Buyer, execute and process the Buyer’s order (including for the purpose of proper payment for goods and/or services, ensuring that the Buyer receives financial services, registration of the Buyer’s personal accounts on the Seller’s resources, etc;
  • Counterparties to provide services to the Company, in particular, to fulfil an order (in such cases, the Counterparties shall not be authorised to use personal data received through the Pawwer Online Platform other than to fulfil the order and provide services) or to conduct contests, promotions and promotions, determine the winner (in case of winning/victory, if contests, promotions and promotions are conducted by the Counterparties, such Counterparties may independently contact the Buyers on related issues;
  • governmental, regulatory, and law enforcement authorities, if it is necessary for the purpose specified above and if it is provided for by law, or if the Company is obliged to fulfil a statutory obligation or protect its legitimate interests.

5. Transfer of Personal Data to Third Parties

The Company may transfer personal data to third parties, including foreign subjects of relations related to personal data, in particular, related parties of the Company, for the purpose of processing personal data as defined in these Regulations. For example, the data may be transferred to the Company’s partners and contractors who provide services to the Company to ensure the Company’s business activities. In this case, the Company shall make necessary and reasonable efforts to ensure the protection of personal data that is transferred, including by entering into appropriate agreements. In this case, the Buyer shall give his/her unequivocal consent to the transfer of his/her personal data to any third party for the purpose of processing personal data in accordance with these Regulations outside Ukraine to countries that are not recognised as ensuring adequate protection of personal data. No transfer of personal data will require the Buyer’s separate consent or provision of a separate notice to the Buyer.

6. Measures to Protect Personal Data

The Company takes measures to ensure the protection of Buyers’ personal data at all stages of their processing, including through organisational and technical measures.

Organisational measures taken by the Company include the following:

I. Control of access to personal data of the Customers by employees/authorised persons of the Company:

  • The Company shall keep records of employees/authorised persons who have access to the Buyers’ personal data.
  • The Company has developed and implemented the levels of access of the Company’s employees to these subjects, each of these employees has access only to the personal data (or any part thereof) of the Buyers that is necessary for them in connection with the performance of their professional or official duties or employment. All other employees of the Company shall have the right to full information only regarding their own personal data.
  • Employees/authorised persons who have access to personal data shall give a written undertaking not to disclose personal data entrusted to them or which they have become aware of in connection with the performance of their professional, official or employment duties. Such obligation shall be valid after they cease to perform activities related to personal data, except in cases established by law.
  • The Company shall take measures to prevent unauthorised persons from accessing the Buyers’ personal data.

II. Keeping records of operations related to the processing of and access to Buyers’ personal data:

  • The Company keeps information on the date, time and source of personal data collection; change of personal data; review of personal data; any transfer (copying) of the subject’s personal data; date and time of deletion or destruction of personal data; employee who performed one of the above operations; purpose and grounds for changing, reviewing, transferring and deleting or destroying personal data.
  • When processing personal data using a software product and/or an automated system, such a product and/or system shall automatically record the specified information. In the case of relevant transactions with personal data in paper form, their accounting is carried out by recording actions and transactions (e.g., in relation to personnel issues, business transactions, etc.) within the framework of which the relevant processing of personal data is carried out, by executing documents that are usually executed in the Company in connection with such actions and transactions.
  • The Company shall keep the relevant information for three years from the end of the year in which the said transactions were carried out, unless otherwise provided by the applicable legislation of Ukraine.

III. The Company has developed an action plan in case of unauthorised access to personal data, damage to technical equipment, and emergencies.

IV. The Company regularly arranges training for the Company’s employees involved in personal data processing to raise awareness of international legal standards and provisions of national legislation in the field of personal data protection, effective implementation and compliance with the Company’s internal rules for the collection, storage, use or other actions constituting personal data processing.

The Company also complies with the requirements of the Standard Procedure for Personal Data Processing approved by the Order of the Verkhovna Rada of Ukraine No. 1/02-14 dated 8 January 2014 (available here) to the extent that it relates to personal data.

7. Rights of the Buyers as a Subject of Personal Data.

In accordance with Article 8 of the Law of Ukraine «On Personal Data Protection», the Buyer has the right to:

  • Know about the sources of collection, location of their personal data, the purpose of their processing, location and/or place of residence (stay) of the owner or manager of these personal data or to give an appropriate order to obtain this information to persons authorised by him/her, except in cases established by law;
  • receive information about the conditions for granting access to personal data, including information about third parties to whom his/her personal data is transferred;
  • to have access to their personal data;
  • receive a response on whether his/her personal data is stored no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, and receive the content of his/her personal data;
  • Submit a reasoned request to the personal data controller with an objection to the processing of their personal data;
  • Submit a reasoned request to change or destroy his/her personal data by any owner or manager of personal data, if such data is processed illegally or is unreliable;
  • protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is inaccurate or discrediting the honour, dignity, and business reputation of an individual;
  • file complaints about the processing of their personal data to the Ukrainian Parliament Commissioner for Human Rights (hereinafter referred to as the «Commissioner») or to the court;
  • apply for legal remedies in case of violation of the legislation on personal data protection;
  • make reservations regarding the restriction of the right to process their personal data when giving consent;
  • withdraw consent to the processing of personal data;
  • know the mechanism of the automatic processing of personal data;
  • be protected against an automated decision that has legal consequences for him/her.

8. The Procedure for Handling Requests from the Buyer and Third Parties for Access to Personal Data.

The Buyer shall have the right to obtain any information about himself/herself from the Company. The Buyer’s access to data about himself/herself is free of charge.
The Buyer shall submit a request for access (hereinafter referred to as the «Request») to personal data to the Company.

The Request shall include the following:

  • Surname, first name, and patronymic, place of residence (place of stay), and details of the Buyer’s identity document;
  • surname, name, and patronymic, as well as other information that allows the individual to be identified with respect to whom the Request is made;
  • information about the personal data in respect of which the Request is made, or information about the owner or manager of personal data;
  • a list of personal data requested;
  • Purpose and/or legal grounds to submit the Request.

The term for studying the Request for its satisfaction may not exceed 10 business days from the date of its receipt.
Within this period, the Company shall notify the Buyer that the Request will be satisfied, or the relevant personal data shall not be provided, indicating the grounds specified in the relevant regulatory legal act.
The Request shall be satisfied within 30 calendar days from the date of its receipt, unless otherwise provided by law.

9. Deletion of the Buyer’s Personal Data

The Buyer’s personal data may be deleted at the Buyer’s request by performing the following actions:

  • Submission of a written request to delete personal data to the e-mail address Pawwer.ua@gmail.com with a note in the subject line «Personal Data»;
  • Performing actions to delete the Buyer’s data from the Buyer’s personal account, which is located on the Pawwer Online Platform.

In the event of inactivity in the Buyer’s account for a period exceeding five (5) years, the Company reserves the right to delete the Buyer’s account, including all personal data stored in the account, which means that the Buyer will no longer be able to access and use it. The procedure for deleting the Buyer’s personal data from the Company’s internal databases is governed by the Company’s internal policies.

10. Withdrawal of Consent to the Personal Data Processing

The Buyer may at any time withdraw consent to the processing of personal data by sending a request to the following email address: Pawwer.ua@gmail.com with a note in the subject line «Personal Data». In this case, the Company’s employees shall consider such a request for deletion of personal data and delete the Buyer’s personal data from the Company’s information systems.

The withdrawal of the Buyer’s consent to the processing of his/her personal data shall not affect the processing of personal data that was carried out before such withdrawal and shall not prevent the processing of personal data on other legal grounds.

11. Personal Data of Order Recipients

Informing personal data subjects about the processing of their personal data is important for the Company. The Company is bound by this obligation even if the personal data is not received from the personal data subject, namely, if the personal data is received from the Buyer about the recipient of the order. In some cases, the Company does not have sufficient information about the recipient of the order (including the lack of contact details), so the Company cannot directly contact the recipient of the order and/or inform him/her immediately after the Company receives data about him/her from the Buyer.
In cases where the Buyer is not the subject of personal data, the Company offers and recommends that the Buyer inform the recipient of the order about the existence of these Regulations. The Buyer is obliged to share a link to these Regulations with the order recipient in advance, and hereby the Buyer confirms that he/she has done so and has received unequivocal consent to the processing of personal data in accordance with these Regulations from the order recipient and that he/she will provide such consent upon the Company’s request.

12. Amendments to the Regulations

The Company may, from time to time, unilaterally update these Regulations. The Company shall notify the Buyers of any significant additions or changes to these Regulations. If the Buyer does not agree to any such material additions or changes that may be made in the future, he/she shall not use the Website and/or the Mobile Application. The Company may also make other changes to this Regulation without prior notice to the Buyer, so the Company recommends that you regularly check this Regulation.
The new version of the Regulations shall enter into force from the moment it is posted on the Pawwer Online Platform, unless otherwise provided by the new version of the Regulations. 

 

Date of the last revision: 15 May 2025