Privacy Policy

Version: 1.01.
Last updated: 01 November 2023.
  1. 1. General provisions

    1. 1.1.
      This Privacy Policy (hereinafter referred to as the "Policy") applies to the services provided by the search service Kupno, which is available at the web address (hereinafter referred to as the "Site" or "Kupno"). The policy describes the procedure for processing personal data collected and related to the Site services and tools that allow users to register on the Site, publish or view in real-time already published information, and use others related to the above services of Kupno.
    2. 1.2.
      In all specified cases, users' data is processed under the requirements of the Law of Ukraine "On the Protection of Personal Data". This Policy is developed following the provisions of the specified document.
    3. 1.3.
      Personal data of Kupno users is processed by the owner of personal data, which is private entrepreneur Lisnyi Roman Vasyliovych, TIN 3284219853, registered at the address: Lviv region, Zolochivskyi district, Zakomaria village. The owner of personal data is the owner of the database of Kupno users’ personal data.
    4. 1.4.
      The subject of personal data, by registering and/or authorizing on the Site, posting vacancies, posting resumes and/or other data on the Site, communicating on the Site, using the Site or related services and tools of Kupno in any other ways or performing any other actions on the Site, certifies his full and unconditional agreement with this Policy and the purposes and conditions of processing his personal data specified in it.
    5. 1.5.
      The basis for the processing of personal data by the owner is the conclusion and implementation of the Terms of Use between the owner and the subject of personal data.
  2. 2. Definition of terms

    1. 2.1.
      In this Policy, the following terms are used with the following meanings:
      1. personal database - a named set of organised personal data in electronic form and/or in the form of personal data files;
      2. the owner of personal data (or owner) - a natural or legal person who determines the purpose of personal data processing, establishes the composition of this data and the procedures for their processing unless otherwise determined by law;
      3. consent of the subject of personal data - a voluntary expression of the will of a natural person (provided that he is informed) regarding the granting of permission for the processing of his data by the formulated purpose of their processing, expressed in writing or in a form that makes it possible to conclude that consent has been given;
      4. depersonalisation of personal data - the removal of information that makes it possible to directly or indirectly identify a person;
      5. card file - any structured personal data accessible according to defined criteria, regardless of whether such data is centralised, decentralised or divided according to functional or geographical principles;
      6. processing of personal data - any action or set of actions, such as collection, registration, accumulation, storage, adaptation, change, renewal, use and distribution (distribution, implementation, transfer), depersonalization, destruction of personal data, including using information (automated) systems;
      7. personal data - information or a set of information about a natural person who is identified or can be specifically identified;
      8. The administrator of personal data - a natural or legal person who is authorized by the owner of personal data or by law to process this data on behalf of the owner;
      9. subject of personal data (or user) - a natural person whose personal data is processed;
      10. third party - any person, except the Subject of personal data, the Owner or manager of personal data and the Commissioner of the Verkhovna Rada of Ukraine for Human Rights (hereinafter - the "Commissioner"), to whom the owner or manager of personal data transfers personal data.
  3. 3. Personal data processed

    1. 3.1.
      Depending on how the Subject of personal data uses the Site, the owner may collect and process the following personal data:
      1. Registration on the Site: when the user creates an account on the Site, he must specify his first name, last name, valid e-mail address and create a password.
      2. Creating a resume: photo, region, position applied for, category to which the position belongs, level of English language proficiency and year of experience, domains in which experience is available, minimum salary applied for, type of employment, experience jobs, contact details, technical skills, additional information about yourself, languages you can work with, social media links, etc. The user can also attach a PDF document from which personal data will be processed by this Policy.
      3. Creating a company profile: name, logo, region, number of employees, year founded, company description, company type, company website, social media links, technology stack, benefits, phone, billing information, company offices (address, phone, photo, description), etc.
      4. Announcements and agreements: within the scope of the Site, the owner may post information, including personal and contact information, necessary for the execution of agreements between the company and the candidate, for the interaction of users with each other (including communication on the Site), and for making payments.
      5. Technical support: when users contact the customer service department, if necessary, the owner may, during the operation of the Site, collect personal data necessary to fulfil the user's request and receive feedback. The owner may also contact the user using the existing account contact information provided for this purpose. The Owner may also collect other information when communicating with users, such as any support requests, including message content and metadata provided by users or any feedback provided by them.
      6. Website and mobile data: the owner may automatically receive and record on its servers information from the user's browser or any device, including computer information (IP address, geographic location, browser type and version, operating system, etc.), information about visits and use of the Site (referral sources, duration of visits, viewed pages and ways of navigating the Site, etc.), information generated when using the Site (time, frequency and conditions of its use). Additional information on how users can control and/or block such information collection is provided below in the sections of this Policy.
      7. Information obtained as a result of surveys: the owner may collect and store information obtained as a result of surveys that may be conducted by the owner or contractors (third parties) engaged by the owner, namely information about Kupno activities, new projects, Kupno development, goals, etc.
    2. 3.2.
      The user is responsible for all information posted by him on the Site. The user must carefully understand all the risks associated with the fact that he publishes personal data or information of a public nature.
    3. 3.3.
      Before disclosing the personal data of a third party to Kupno, the user must obtain the consent of that person both for the disclosure and for the processing of this information by this Policy.
  4. 4. Use of personal data

    1. 4.1.
      To provide its services, the owner may use the information they collect and places for the following purposes:
      1. to provide user service, including creating and managing user accounts, solving technical difficulties and accessing various functions;
      2. to adapt offers and experiences, including advertising on its services or services of third parties;
      3. to control general and individual user activity, such as keyword searches, ad posting and transaction activity, as well as manage traffic on the Site;
      4. to communicate with users, including for service, user support or permitted marketing communications through any available communication channels;
      5. to carry out research and analytical activities to improve Kupno;
      6. to ensure compliance with the agreement with Kupno users, taking into account the fight against fraud and abuse;
      7. to evaluate certain factors of personal information, in particular, to analyze and predict personal preferences, interests, behaviour and location.
    2. 4.2.
      The Owner will retain personal data for the longest of the following periods:
      1. the time necessary to achieve the purposes for which they were collected, taking into account the owner's business needs and legal requirements, including to comply with any legal, accounting or reporting requirements;
      2. the end of the period during which legal proceedings or investigations may arise about the Services;
      3. as long as the user account exists.
      This includes data that has been provided by the user or others, as well as data obtained as a result of the user's use of the services.
    3. 4.3.
      To determine the appropriate storage period, the owner takes into account the volume, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of the personal data, the purpose for which the owner processes the personal data, and whether the owner can achieve these purposes by other means and appropriate legal requirements.
    4. 4.4.
      If you have any questions about the data retention period, please contact us at:
  5. 5. Access to personal data

    1. 5.1.
      Access to personal data by a third party is carried out by Art. 16, 17 of the Law of Ukraine "On the Protection of Personal Data" and is not provided if the specified person refuses to undertake obligations to ensure the fulfilment of the requirements of this law or is unable to ensure them.
    2. 5.2.
      The owner shall notify the subject of personal data within ten working days about the transfer of personal data to a third party, except for the cases provided for in Art. 14 of the Law of Ukraine "On Personal Data Protection".
    3. 5.3.
      The Owner discloses the personal and other data of the subject of personal data exclusively for the purposes related to the publication of vacancies by such subject on Kupno and access to the content of these vacancies by other Kupno users. By agreeing to this Policy, the subject of personal data consents to the disclosure of the data entered by him in vacancies on Kupno to all users of the Site, taking into account the conditions and restrictions established by this Policy.
    4. 5.4.
      The Owner reserves the right, under the requirements of the current legislation of Ukraine, to exchange personal data with state authorities to prevent fraud on the Site; settle disputed situations and clarify circumstances that are or may be the cause of violation of the current legislation, as well as in the case of detection by the Owner of illegal actions of the subject of personal data and/or receipt of claims, complaints, appeals of third parties
    5. 5.5.
      If the owner's business or a part of this business is sold or reorganized and the owner transfers all or almost all of its assets to a new owner, then the personal data of users may be transferred to the buyer to ensure the continuity of the Site.
    6. 5.6.
      The Owner may transfer certain de-identified information to third-party service providers, trusted partners or authorized researchers to better understand which advertisements or services may be of interest to users, to improve the overall quality and efficiency of the services on the Site, or to ensure its contribution to scientific research that, in the opinion of the Owner, can bring great social benefit.
    7. 5.7.
      The Owner may transfer the information it collects to third parties that provide services to the Owner (in particular, analytics, hosting, and customer relationship management services) to conduct research or provide services to users, while the data transferred is the subject of this Politicians and involved third parties have no right to use the received information other than to provide services to the owner.
  6. 6. Use of cookies

    1. 6.1.
      During the operation of the Site, the owner may collect certain information using technologies such as cookies, which are small text files that store information directly on the user's computer, mobile phone or other device. With the help of cookies, the web server can save, for example, preferences and settings on the user's computer, mobile phone or other device, which are then automatically restored on the next visit. In other words, cookies are designed to make the use of the Site more convenient, for example, so that the user does not have to repeat the login process during the next visit.
    2. 6.2.
      The owner uses both persistent and session cookies. Persistent cookies remain on the user's computer for a longer period, and session cookies are automatically deleted when the browser window is closed. In particular, the owner uses authorization, analytical, and marketing cookies, as well as user CID storage and auxiliary cookies to save information about the user's language, etc.
    3. 6.3.
      The Owner may allow third parties, such as advertising and/or analytics service providers, to collect information using these types of technologies directly on the Site. The data they collect is subject to protection under the applicable privacy policies of those third parties.
  7. 7. Rights of Subjects of personal data and user control

    1. 7.1.
      The Subject of personal data has the right to:
      1. to know about the sources of collection, the location of their data, the purpose of their processing, the location or place of residence (residence) of the owner or manager of personal data or to give an appropriate order to obtain this information to persons authorized by him, except for cases established by law;
      2. to receive information about the conditions of providing access to personal data, in particular, information about third parties to whom his data is transferred;
      3. to access your data;
      4. to receive an answer about whether his data is being processed, as well as to receive the content of such personal data no later than thirty calendar days from the date of receipt of the request, except in cases provided by law;
      5. to make a reasoned demand to the owner of personal data with an objection to the processing of his data;
      6. to make a reasoned demand for the change or destruction of your data by any owner and manager of personal data, if these data are processed illegally or are unreliable;
      7. to protect your data from illegal processing and accidental loss, destruction, or damage due to intentional concealment, failure to provide or untimely provision of them, as well as protection from providing information that is unreliable or disgraces the honour, dignity and business reputation of a natural person ;
      8. to file complaints about the processing of your data with the Commissioner or the court;
      9. to apply legal remedies in case of violation of the legislation on the protection of personal data;
      10. to offer the limitation of the right to process your data when giving consent;
      11. to withdraw consent to the processing of personal data;
      12. to know the mechanism of automatic personal data processing;
      13. to protect against an automated decision that has legal consequences for it.
    2. 7.2.
      Right of access, correction and deletion: Users who have created an account or posted a company profile on the Site may access, correct or delete the information they provide. The user is responsible for the accuracy and reliability of the data provided. Posted information can be changed or deleted from the user's account on the Site. The owner may stop the processing of the user's data upon receipt of written notification of the user withdrawing his consent to the processing of personal data.
    3. 7.3.
      To exercise any of the above-mentioned rights (clauses 7.1, 7.2) or in case of any questions regarding the use of personal data, users can send a request to the owner by e-mail:
    4. 7.4.
      Cookies: most major computer web browsers (eg Safari, Firefox, Internet Explorer, Chrome, Opera) provide controls that allow the user to limit or block the installation of cookies on users' systems. However, disabling cookies for domains of the first category (sites visited) and other domains (sites related to the sites visited) may result in limited functionality of these websites in some cases.
  8. 8. Data security

    1. 8.1.
      All information collected on the Site is reasonably protected by technical means and security procedures to prevent unauthorized access or use of data. Trusted partners and independent service providers undertake to use the information received from the owner by its security requirements and this Privacy Policy.
  9. 9. Amendments to the Policy

    1. 9.1.
      The Owner may update this Privacy Policy from time to time. The new version of the Policy enters into force from the moment of its posting on the Internet on the Site, unless otherwise provided by the new version of the Policy.
    2. 9.2.
      In case of any comments, wishes or claims regarding this Policy and personal data processed by its provisions, users can contact the indicated email address:
    3. 9.3.
      If the owner has made any changes to the Policy, with which the user does not agree, he must stop using the Site. The fact of continued use of the Site is a confirmation of consent and acceptance by the user of the appropriate version of the Privacy Policy.