Privacy Policy

Publication date: 06 July 2026

1. General provisions

1.1. this Privacy Policy (the “Policy”) sets out the procedure for processing personal data and other data of users of euroformat.com and its subdomains (collectively, the “Website”), the controller/operator of which is LIMITED LIABILITY COMPANY “EUROFORMAT PLANT”, Ukrainian company registration code 31724919 (the “Controller”). The contact address stated on the Website is: 21 Kurenivska Street, Building G, Kyiv, 04073, Ukraine.

1.2. scope. this Policy applies to euroformat.com and all of its subdomains. The subdomain(s) are primarily intended for informational and SEO content. Regardless of the specific technical distribution of content between the main Website and its subdomain(s), the same data processing regime established by this Policy applies to all such resources.

1.3. single-controller qualification. this Policy applies as a single document provided that the same legal entity acts as the controller/operator of both resources, namely the main euroformat.com Website and its subdomain(s). If the main Website and any subdomain are operated by different legal entities, a separate legal determination by Euroformat’s legal advisers will be required, which may include adopting separate privacy documents.

1.4. this Policy has been prepared in accordance with Ukrainian personal data protection legislation, primarily the Law of Ukraine “On Personal Data Protection” No. 2297-VI, and, given that the Website is also intended for users in the European Union, with due regard to the requirements of the EU General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) and Directive 2002/58/EC (ePrivacy Directive).

1.5. reviewing this Policy does not in itself constitute consent to the processing of personal data where consent is the applicable legal basis for processing, including in relation to analytics and marketing cookies. Consent to the use of such cookies is provided separately through the cookie consent management banner/platform (CMP) when the user first visits the Website, and not merely by using the Website. (see section 4)

1.6. if a user does not agree with this Policy, the user should discontinue use of the Website; non-essential categories of cookies will not be placed without the user’s consent.

2. Data we collect

2.1. technical and analytics data collected automatically

When a user visits the Website, the following data may be collected automatically:

• cookies and similar technologies, including cookie identifiers (cookie IDs);
• IP address;
• technical information about the visit, including browser type and version, device type and operating system;
• Website pages visited, time and duration of the visit, and referral source;
• web analytics data generated by analytics services and advertising tools, such as website traffic analytics services and advertising pixels, that may be used on the Website.

Legal classification. IP addresses, cookie identifiers and other online identifiers that may be used to single out a user are treated as personal data within the meaning of Article 4(1) GDPR and are processed in accordance with this Policy. This Policy does not use wording suggesting that such data “does not allow a person to be identified”.

2.2. data you provide directly through the consultation form

The Website includes a “Get a Consultation” form through which a user may contact the Controller. When completing the form, the user may provide:

• name;
• telephone number;
• email address;
• text of a comment/enquiry, in which the user may voluntarily provide additional information.

Such information constitutes personal data and is processed for the purposes described in section 3. Providing information through the form is voluntary; however, without such data, the Controller may be unable to process the enquiry or contact the user.

The existence of the form and its fields has been confirmed based on the current Website. The actual list of web analytics services used on the Website is described in this Policy in general terms and may be clarified or updated.

3. Purposes of processing and legal bases

The Controller processes data for the purposes described below. The relevant legal basis is specified for each purpose.

Data is processed only to the extent necessary to achieve the relevant purposes.

4. Cookies and consent

4.1. cookies are small text files stored in a user’s browser when the user visits the Website. The Website uses the following categories of cookies:

• strictly necessary (technical) cookies – required for the basic operation of the Website, including saving the user’s selected language; these are placed without consent on the basis of the Controller’s legitimate interest where legally permitted;
• analytics cookies – used to collect statistics about Website visits and user behaviour; these are placed only after consent has been obtained;
• marketing cookies – used for displaying and measuring advertising and for remarketing; these are placed only after consent has been obtained.

Certain third-party services embedded in the Website, such as maps, videos or social media elements, may place their own cookies when used. Such cookies are also governed by the privacy policies of the relevant third-party providers.

4.2. consent (opt-in). analytics and marketing cookies are placed only after the user has actively provided consent through the cookie management banner/platform (CMP) during the first visit to the Website. Non-essential cookies are not placed before consent is obtained. Silence, inactivity or merely continuing to browse the Website does not constitute consent.

4.3. withdrawal of consent. a user may withdraw previously given consent or change cookie category settings at any time through the Website’s cookie banner/consent management centre and may also manage cookies through browser settings, including allowing, blocking or deleting cookies. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

4.4. unified consent management mechanism. the Controller provides a unified consent management mechanism (CMP) for euroformat.com and its subdomains, allowing users to provide, modify and withdraw consent to the use of cookies consistently across the main Website and its subdomain(s).

4.5. processing carried out by third-party analytics services and advertising tools is also governed by the privacy policies of the relevant service providers.

5. Disclosure to third parties and international data transfers

5.1. the Controller does not sell users’ personal data. Personal data is disclosed to third parties only to the extent and for the purposes described below.

5.2. recipients of consultation form data. data submitted through the consultation form described in section 2.2 may be sent to the Controller’s general email address (zavod@euroformat.com) or to the relevant departmental email address depending on the subject matter of the enquiry, for example: lift equipment – lift@euroformat.com; enclosures and metal products – korpus@euroformat.com; metal doors – dveri@euroformat.com. The routing mechanism described above is considered probable and has not been confirmed by the Website developers as the precise technical mechanism. Form data may also be processed by service providers responsible for receiving and processing enquiries.

5.3. recipients of analytics data. technical and analytics data may be transmitted to providers of web analytics services and advertising tools used on the Website in accordance with their respective privacy policies.

5.4. international data transfers. if recipients of personal data are located outside Ukraine and/or the European Economic Area (EEA), such transfers will be carried out using an appropriate legal transfer mechanism, including, where applicable, an adequacy decision of the European Commission or Standard Contractual Clauses (SCCs) within the meaning of Chapter V GDPR. The specific mechanism applicable to each recipient will be determined in accordance with applicable law.

5.5. personal data may be disclosed to competent public authorities where expressly required by law and pursuant to a lawful request.

6. Retention periods

6.1. personal data is retained no longer than necessary for the purposes for which it is processed, in accordance with the storage limitation principle:

• consultation form data – for 1 year from the date of the most recent enquiry where no subsequent contractual relationship arises; the maximum retention period is 3 years, corresponding to the general limitation period under Ukrainian law, or until consent is withdrawn where consent is the applicable legal basis;
• analytics data and cookies – up to 14 months for analytics data; analytics and marketing cookies – up to 13 months, depending on the settings of the relevant services;
• technical system logs – from 6 to 12 months.

6.2. upon expiry of the applicable retention period, personal data is deleted or anonymised.

7. Rights of data subjects

7.1. in relation to their personal data, users have the following rights to the extent provided by the GDPR and Ukrainian law:

• right of access – to obtain confirmation as to whether personal data is being processed and to receive a copy of such data;
• right to rectification – to request correction of inaccurate or incomplete personal data;
• right to erasure (“right to be forgotten”) – to request deletion of personal data where the applicable legal requirements are met;
• right to restriction of processing;
• right to data portability – to receive personal data in a structured, commonly used and machine-readable format;
• right to object to processing based on legitimate interests and to processing for direct marketing purposes;
• right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
• right not to be subject to a decision based solely on automated processing that produces legal effects or similarly significantly affects the user, where applicable.

7.2. right to lodge a complaint with a supervisory authority. a user has the right to lodge a complaint with the relevant supervisory authority:

• in Ukraine – with the Ukrainian Parliament Commissioner for Human Rights;
• in the EU – with the competent Data Protection Authority (DPA) in the Member State of the user’s habitual residence, place of work or place of the alleged infringement.

7.3. rights under Ukrainian law, including the Law of Ukraine No. 2297-VI, are exercised in accordance with the procedure established by that legislation and do not exclude rights available under the GDPR where the GDPR applies.

7.4. to exercise these rights, a user may contact the Controller using the contact details set out in section 10.

8. Language versions

8.1. the Ukrainian-language version of this Policy is the primary and authoritative version. The English-language and other language versions are provided for users’ convenience.

8.2. in the event of any discrepancy between language versions, the Ukrainian-language version shall prevail.

9. Amendments to this Policy

9.1. the Controller may amend this Policy. A new version takes effect from the date it is published on the Website unless otherwise stated in the updated version.

9.2. where material amendments concern the scope of personal data processed, the purposes of processing or users’ rights, the Controller will provide notice by a method available on the Website, such as a banner or notification, before such changes take effect.

9.3. the Controller recommends that users periodically review the current version of this Policy.

10. Contact details

10.1. for questions regarding personal data processing or the exercise of data subject rights, users may contact the Controller:

LIMITED LIABILITY COMPANY “EUROFORMAT PLANT”
Contact address stated on the Website: 21 Kurenivska Street, Building G, Kyiv, 04073, Ukraine
Email: zavod@euroformat.com
Telephone: +38 (044) 494-35-35

10.2. person responsible for personal data protection. until a separate data protection contact person is formally appointed, requests relating to personal data may be submitted to: zavod@euroformat.com