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Privacy policy

1. General Provisions

1.1. This Privacy Policy (hereinafter — the "Policy") defines the procedure for processing and protecting the personal data of individuals whose personal data is processed by KLASESTRANSFER Limited Liability Company (hereinafter — the "Company" or the "Carrier") in connection with ordering and providing passenger transportation services.

1.2. The controller of personal data within the meaning of the Law of Ukraine "On Protection of Personal Data" is KLASESTRANSFER Limited Liability Company (EDRPOU code 46036918, registered office: 101 Zhylianska Street, Kyiv, 02000, Ukraine).

The following contact details may be used for inquiries regarding the processing of personal data and the exercise of the rights of a personal data subject:

Email: tomshinaeliz@gmail.com

Phone: +380 96 206 47 24

1.3. The Policy has been developed in accordance with the Constitution of Ukraine, the Law of Ukraine "On Protection of Personal Data", the Law of Ukraine "On Information", and other legal acts of Ukraine governing personal data protection, taking into account the practice of their application.

1.4. The Company processes personal data on the principles of lawfulness, fairness, proportionality, data minimization, accuracy, relevance, and proper protection against unauthorized access, loss, destruction, or other unlawful processing.

1.5. This Policy is publicly available and published on the Company's official website. When an order is placed by phone, email, through the official website, or other official communication channels of the Company, the Company takes reasonable measures to provide an opportunity to review this Policy before personal data is provided.

2. Definitions

In this Policy, the terms are used with the following meanings:

Personal data — information or a set of information about an individual who is identified or can be specifically identified.

Processing of personal data — any action or set of actions performed on personal data, including their collection, registration, accumulation, storage, adaptation, alteration, use, dissemination, transfer, anonymization, deletion, or destruction.

Personal data subject — an individual whose personal data is processed by the Company.

Customer — an individual or legal entity that contacts the Company to order passenger transportation services, regardless of whether they are a Passenger.

Passenger — an individual to whom the Company directly provides passenger transportation services.

Payer — an individual or legal entity that pays for the Company's services, regardless of whether they are the Customer or the Passenger.

3. Categories of Personal Data Processed by the Company

3.1. The Company processes only the personal data necessary for handling requests and inquiries, providing consultations, calculating the cost of services, accepting, arranging, fulfilling, and supporting orders, providing passenger transportation services, making settlements, maintaining accounting and tax records, complying with the legislation of Ukraine, resolving possible disputes, and protecting the Company's legitimate rights and interests.

3.2. Depending on the way an order is placed, the type of services, and the specifics of their provision, the Company may process the following categories of personal data:

  • last name, first name, and, if available, patronymic;
  • phone number;
  • email address;
  • information about the transportation route, including the pick-up point, drop-off point, date and time of the trip, and, if necessary, intermediate stops;
  • information about the number of passengers, baggage, and other details necessary for arranging the transportation;
  • information about the specifics of the transportation, if such information is voluntarily provided by the Customer or the Passenger (including regarding the transportation of children, animals, oversized baggage, or other circumstances that may affect the provision of services);
  • details necessary for making settlements, confirming payment, and maintaining accounting and tax records;
  • the content of inquiries, messages, and other communication with the Customer, Passenger, or Payer;
  • audio recordings of phone calls — if the Company records them;
  • technical data automatically collected while using the website, including information about the user's device, browser, IP address, and other technical details necessary to ensure the operation of the website, its security, and web analytics;
  • other personal data voluntarily provided to the Company by a person when placing an order or receiving services.

3.3. If the Customer arranges transportation for the benefit of another person, the Company may process the personal data of both the Customer and the Passenger to the extent necessary for concluding and performing the transportation agreement.

3.4. If the services are paid for by a Payer who is not the Customer or the Passenger, the Company may process their personal data solely to the extent necessary to confirm the payment, maintain accounting and tax records, and comply with the legislation of Ukraine.

3.5. The Company does not process special categories of personal data (including data on racial or ethnic origin, political, religious, or ideological beliefs, health status, biometric or genetic data), except where such information is voluntarily provided by the personal data subject, its processing is objectively necessary for the proper provision of services, or is expressly required by the legislation of Ukraine.

3.6. The Company is not obliged to verify the accuracy of the personal data provided by the Customer, Passenger, or Payer, and assumes that such data is up-to-date, accurate, and provided on lawful grounds.

4. Purpose and Legal Grounds for Processing Personal Data

4.1. The Company processes personal data solely for the purpose of:

  • handling requests and inquiries and providing consultations;
  • calculating the cost of services;
  • accepting, arranging, organizing, fulfilling, and supporting orders;
  • providing passenger transportation services;
  • interacting with Customers, Passengers, Payers, representatives of legal entities, and other persons who contact the Company;
  • making settlements and maintaining accounting and tax records;
  • complying with the legislation of Ukraine;
  • handling claims and resolving possible disputes;
  • protecting the Company's legitimate rights and interests;
  • ensuring service quality control, handling claims, and resolving disputed situations by processing recordings of phone calls;
  • analyzing the use of the website, improving its operation, and enhancing the quality of the Company's electronic services;
  • performing other actions necessary to support the Company's operations and provide services in accordance with the legislation of Ukraine.

4.2. Personal data is processed on the basis of one or more legal grounds provided for by the legislation of Ukraine, including:

  • a person contacting the Company to obtain information, a consultation, a cost estimate, to arrange transportation, or on other matters related to the Company's activities;
  • the necessity to conclude, perform, or ensure the performance of an agreement or other legal relations related to the Company's activities and the provision of its services, including where an order is placed, arranged, or paid for in the interests of another person;
  • the personal data subject's consent to the processing of their personal data, where such consent is required under the legislation of Ukraine;
  • the necessity for the Company to fulfill obligations established by the legislation of Ukraine;
  • the necessity to protect the Company's legitimate rights and interests in the cases and in the manner provided for by the legislation of Ukraine.

4.3. The Company processes personal data only to the extent necessary to achieve the defined purposes and does not use it in a manner incompatible with the purpose of its collection or contrary to the requirements of the legislation of Ukraine.

4.4. If the personal data of a Passenger, Payer, or another person is provided by the Customer, a representative of a legal entity, or another person contacting the Company, the Company has the right to assume that such person has proper legal grounds for transferring the relevant personal data and has fulfilled the obligation to notify the personal data subject where required by the legislation of Ukraine. Further processing and transfer of such personal data is carried out in accordance with this Policy and the requirements of the legislation of Ukraine.

5. Procedure for Processing Personal Data

5.1. The Company processes personal data in accordance with the requirements of the legislation of Ukraine using automated, non-automated, or mixed processing methods.

5.2. Personal data is processed in the forms and by the methods defined by the legislation of Ukraine and this Policy.

5.3. Access to personal data is granted only to employees, drivers, authorized representatives, engaged contractors, and other persons involved in organizing or supporting the provision of services, solely to the extent necessary to perform their functions, contractual, or other lawful obligations.

5.4. To accept, arrange, fulfill, and support orders and to interact with Customers, Passengers, Payers, and other persons, the Company may use telephone communication, email, messengers, CRM systems, web services, software, and other information and communication tools necessary for the proper organization and provision of services.

5.5. To ensure the operation of the website, the Company may use information systems, software, and other technical solutions necessary for the proper functioning of the website and electronic services. The specifics of the use of cookies and other similar technologies are set out in Section 10 of this Policy.

5.6. The Company keeps personal data up to date based on information received from the personal data subject or another person who lawfully provided such data, but is not obliged to verify its accuracy unless otherwise provided by the legislation of Ukraine.

5.7. Once the purpose of processing personal data has been achieved, or upon expiry of the storage periods defined by this Policy or the legislation of Ukraine, personal data is subject to deletion, destruction, or further storage only in the cases provided for by the legislation of Ukraine.

6. Transfer of Personal Data to Third Parties

6.1. The Company does not disclose or transfer personal data to third parties, except in the cases provided for by this Policy or the legislation of Ukraine.

6.2. The Company does not transfer personal data to third parties for use for their own purposes, except in the cases provided for by this Policy or the legislation of Ukraine.

6.3. The Company may transfer personal data to third parties solely to the extent necessary to achieve the purposes of its processing, in particular to:

  • the Company's employees, drivers, authorized representatives, and engaged contractors;
  • persons engaged by the Company to organize or support the provision of services;
  • persons providing accounting, legal, information technology, or other support for the Company's activities;
  • providers of information and communication, software, cloud, and other services used by the Company to support its activities;
  • banks, payment institutions, and other persons involved in making settlements;
  • state authorities, local self-government bodies, law enforcement agencies, courts, customs, border, supervisory, and other competent authorities — in the cases provided for by the legislation of Ukraine, or where such transfer is necessary for the performance of the transportation agreement, the execution of international passenger transportation, or compliance with lawful requirements of competent authorities.

6.4. The Company transfers personal data solely to the extent necessary for organizing and providing services, performing the agreement, making settlements, complying with the legislation of Ukraine, and achieving other purposes of personal data processing defined by this Policy.

6.5. Persons to whom personal data is transferred in connection with supporting the Company's activities or providing services are obliged to ensure the confidentiality and protection of personal data and to use it solely within the scope of their functions, contractual, or other lawful obligations, unless otherwise provided by the legislation of Ukraine.

6.6. In the case of international passenger transportation, personal data may be transferred and processed outside Ukraine solely to the extent necessary for organizing and carrying out such transportation, performing the transportation agreement, and complying with lawful requirements of competent authorities.

7. Personal Data Storage Periods

7.1. The Company stores personal data for no longer than is necessary to achieve the purposes of its processing, unless a different period is established by the legislation of Ukraine or this Policy.

7.2. The Company may store personal data for the period necessary for:

  • handling inquiries, requests, applications, claims, and other messages;
  • organizing, fulfilling, and supporting passenger transportation;
  • making settlements and fulfilling financial obligations;
  • maintaining accounting, tax, and other mandatory records;
  • complying with the legislation of Ukraine;
  • protecting the Company's rights and legitimate interests in the event of disputes, claims, or court proceedings.

7.3. Recordings of phone calls made for the purpose of service quality control, handling inquiries and claims, and resolving disputed situations are stored for the period necessary to achieve these purposes, but, as a rule, for no more than six months from the date of the recording, unless a longer storage period is required under the legislation of Ukraine or for the protection of the Company's rights and legitimate interests.

7.4. Where the legislation of Ukraine establishes a mandatory storage period for certain documents or information containing personal data, the Company has the right to store such personal data for the period defined by the legislation of Ukraine.

7.5. Once the purposes of personal data processing have been achieved, or upon expiry of the storage periods defined by the legislation of Ukraine or this Policy, the Company deletes or destroys the personal data, unless otherwise provided by the legislation of Ukraine.

8. Rights of the Personal Data Subject

8.1. The personal data subject has the rights provided for by the legislation of Ukraine, including the Law of Ukraine "On Protection of Personal Data".

8.2. In particular, the personal data subject has the right to:

  • receive information about the processing of their personal data;
  • receive information about the sources of collection, composition, and content of their personal data in the cases provided for by the legislation of Ukraine;
  • demand the correction, updating, or supplementation of inaccurate or incomplete personal data;
  • demand the termination of processing or the deletion of personal data in the cases provided for by the legislation of Ukraine;
  • contact the Company regarding the processing of personal data;
  • apply to the Ukrainian Parliament Commissioner for Human Rights or to the court in the event of a violation of their rights.

8.3. To exercise their rights, the personal data subject may contact the Company using the contact details specified in clause 1.2 of this Policy.

8.4. The Company reviews inquiries from personal data subjects and takes the necessary measures based on the results of their review in the manner and within the time limits established by the legislation of Ukraine.

9. Personal Data Protection

9.1. The Company takes the necessary organizational, technical, and other security measures to protect personal data from unlawful or accidental loss, destruction, alteration, disclosure, unauthorized access, or other unlawful processing.

9.2. Access to personal data is granted only to employees, authorized representatives, engaged contractors, and other persons who need such access to perform their functions or provide services to the Company and who are obliged to maintain the confidentiality of the information received.

9.3. The Company processes personal data in compliance with the requirements of the legislation of Ukraine and implements measures aimed at preventing unauthorized access, loss, alteration, or unlawful dissemination of personal data.

9.4. Despite the protection measures taken by the Company, the transfer of information over the Internet involves certain risks and cannot guarantee absolute security. In this regard, the Company is not liable for data security breaches caused by circumstances beyond its reasonable control.

10. Use of Cookies

10.1. The Company uses cookies and other similar technologies to ensure the proper operation of the website, maintain its security, remember certain user settings, analyze the use of the website, generate statistical information, improve the website's functionality, and enhance the quality of the user experience.

10.2. Cookies are small text files stored on the user's device when visiting the website that make it possible to recognize the user's device, save certain settings, and obtain information about the use of the website.

10.3. While using the website, technical data may be collected automatically, including information about the type of device and browser, IP address, date and time of the visit, pages viewed, referral source, duration of the visit, and other technical data necessary to ensure the proper functioning of the website, its security, and web analytics.

10.4. To analyze the use of the website, the Company may use third-party analytics and statistics services that process information in accordance with their own privacy policies and terms of use.

10.5. The user has the right to change their browser settings regarding the use of cookies at any time, to restrict their use, or to refuse them entirely. However, disabling certain cookies may affect the proper operation of certain website features.

11. Changes to the Privacy Policy

11.1. The Company has the right to amend this Privacy Policy at any time in the event of changes to the legislation of Ukraine, the specifics of the Company's activities, or the procedure for processing personal data.

11.2. A new version of the Privacy Policy takes effect from the moment it is published on the website, unless otherwise specified in such version of the Policy.

11.3. Users are advised to periodically review the current version of the Privacy Policy.