PRIVACY POLICY PJSC
«SAV ORBICO»
(version April 2, 2026)
1. GENERAL PROVISIONS
PJSC «SAV ORBICO» understands that the privacy of your personal data is extremely important, and therefore undertakes to respect your privacy and protect your personal data.
This Privacy Policy (further as: Policy) describes the way PJSC «SAV ORBICO» (identification code 42903398 and having its registered office at 27, Hetmana Kyryla Rozumovskoho Street, Kyiv, 03115, Ukraine, hereinafter: «SAV ORBICO», «We», «Our», «Company») processes your personal data as a Controller.
This Policy is harmonized in line with respect to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter: «GDPR») and legislation of Ukraine, in particular, taking into account the requirements of the Law of Ukraine «On Protection of Personal Data».
To better understand (or remind) you of the meaning of certain terms used in this Policy, please refer to the Terminology provided below:
Personal data – any information relating to an identified or identifiable natural person (“Data subject”) – an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing – any operation or set of operations which is performed on Personal data or on sets of Personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Controller/Data controller – Means the natural or legal person, public authority, agency or other body which alone or jointly with others determines the purposes and means of the Processing of Personal Data
Processor – a natural or legal person, public authority, agency or other body that processes personal data on behalf of the Controller.
Website — the Company’s official website, accessible at https://sav-orbico.com, including all of its subdomains, pages, sections, as well as any interactive elements, forms, and services hosted on it.
ORBICO GROUP – ORBICO d.o.o. Zagreb and companies, including PJSC «SAV ORBICO», in which ORBICO d.o.o. Zagreb holds a majority stake, or over which it exercises direct or indirect controlling influence.
2. SCOPE OF THIS PRIVACY POLICY
This Privacy Policy describes how we process personal data collected on websites where we provide authorized links or references to this Policy, as well as in situations where you interact with us — including through feedback forms available on our website or when communicating with us via social media. We process personal data in accordance with the applicable laws of Ukraine, as well as international standards such as the General Data Protection Regulation (GDPR).
This Policy applies exclusively to PJSC «SAV ORBICO» and regulates only those personal data processing activities carried out by us. It does not apply to the processing of personal data carried out by other ORBICO GROUP companies or companies managed by third parties.
Please note that our website may contain hyperlinks to third-party websites or platforms. Personal data collected by third-party websites or platforms is subject to the privacy policies of those websites or platforms. We recommend that you be mindful when you leave our website and read the privacy notices of other websites that may collect your personal data.
3. WHAT PERSONAL DATA WE PROCESS. PURPOSES AND LEGAL BASES FOR PERSONAL DATA PROCESSING.
How we get your personal data.
We get most of the personal data we hold about you directly from you or your interactions with us, our website, or social media sites, as well as via email, contact form, feedback forms, registration forms. We may also obtain your personal data from other sources, including business partners, technical maintenance subcontractors, payment and delivery services, advertising networks, data analysis providers, information search providers, fraud prevention databases and other third-party databases, including sanctions lists.
Processing of your personal data:
| When and why we process your personal data. | The personal data we may process about you. | Legal Basis for the Processing of Personal Data |
| Administrative communication. | ||
| We may contact you in response to inquiries you submit via the contact form/ feedback forms on this website or through other communication channels (including our social media profiles). | Depending on the purpose of your inquiry, we may collect and process some or all of the following personal data in order to process your request and provide a response: Your first name, last name, and middle name; residential address; email address; phone number; social media username; date of birth or photograph; education details, information about your work experience, as well as details about your employer and your position, technical data, including your Internet Protocol (IP) address. This list is not exhaustive and depends on the specific personal data you provide to us when filling out the contact form/ feedback forms on our website. | • Your consent (if necessary); • The legitimate interests of PJSC «SAV ORBICO». |
| Customer Service. | ||
| We use your personal data for customer service purposes, including responding to your inquiries regarding the products or services of PJSC «SAV ORBICO». Usually, this process requires the use of certain personal contact information and information regarding the reason for your inquiry (e.g., order status, technical issue, product-related question or complaint, general questions, etc.). | In order to respond to your inquiry regarding your rights as a consumer of our products or services, or when processing any other requests you may have regarding the products or services of PJSC «SAV ORBICO», we may collect and process some or all of the following personal data: Last name, first name, middle name, phone number, email address, details of purchases and other transactions you have made, including through our websites or other sales channels, such as delivery address and a description of the products purchased), content of communications (emails, call records, chats), technical data (in the case of online inquiries) – IP address, device data (type, OS, browser). This list is not exhaustive and depends on the specific personal data you provide to us. | • Your consent (if necessary); • Fulfilment of contractual obligations; • Legal obligations of PJSC «SAV ORBICO». |
| The information that we collect about your participation in our promotions, contests, sweepstakes and events. | ||
| We may process information contained in your questionnaires and registration records, whether provided by you or created by us, for your participation in promotions, contests, sweepstakes, or events organized by our company or in collaboration with our partners. We may also make this personal data accessible to third parties who may need such information to deliver a prize. Some of our promotions, contests, sweepstakes, or events may be held on third-party websites and/or social media platforms. For more information about our promotions, contests, sweepstakes, or events, please review the official rules and detailed information, which are published separately during the relevant promotion, contest, sweepstakes, or event. | For the purpose of conducting promotions, contests, sweepstakes, events, and organizing the distribution of prizes to winners, we may collect and process some or all of the following personal data: Last name, first name, middle name, nickname, or pseudonym (if used on social media), participant ID (if applicable), date of birth or age (if necessary to verify age restrictions), email address, phone number, mailing address (if the prize requires delivery), IP address, device data, browser data, log files regarding the submission of the application/participation, social media account information (if registration is via social media or the promotion is held there), banking or tax information (only if the prize requires reporting or a money transfer), payment information/invoice details (if the contest/giveaway involves the purchase of a specific product or service from the company), other information provided when participating/commenting/sharing (depending on the contest mechanics) | • Your consent (if necessary); • Fulfilment of contractual obligations; • Legal obligations of PJSC «SAV ORBICO». |
Processing of Children’s Personal Data
We do not consciously collect or process information about children. If we find that such data has been collected unintentionally, we will promptly delete it from our systems and records. If you become aware of instances of children using the Website or of us receiving data from children without verifying parental consent, please notify us immediately and we will take measures to delete this information.
Processing of sensitive or special categories of personal data
The Company does not collect or process any personal data that poses a particular risk to the rights and freedoms of data subjects, including data regarding racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties and trade unions, criminal convictions, as well as data concerning health, sex life, biometric, or genetic data.
Any actions involving personal data processed by the Company comply with the requirements of Ukrainian legislation in the field of personal data protection.
Under any circumstances does PJSC «SAV ORBICO» carry out automated individual decision-making based on your personal data, or profiling personal data subjects for this purpose.
4. RETENTION PERIOD FOR YOUR PERSONAL DATA
We will use all reasonable procedures and security measures to prevent unauthorized access, loss, disclosure, or alteration of the personal data we collect.
The retention period for your personal data depends primarily on the purpose for which such data was collected or the basis on which we process it, including compliance with any legal requirements, accounting or tax reporting requirements, and ensuring the performance of contracts we enter into with customers. We guarantee that we do not retain your personal data for longer than is necessary to achieve the purpose for which it was collected.
When determining the appropriate retention period for personal data, we take into account not only the purposes of processing and the nature and categories of the data, but also the potential risk of harm resulting from unauthorized use or disclosure of the data, as well as the relevant requirements of applicable law.
If the processing of personal data is based on your consent, we retain your personal data for the duration of such consent or until it is withdrawn.
If the processing of personal data is based on our legitimate interest, we retain your personal data for as long as such legitimate interest exists.
If the processing of personal data is based on our legal obligation, we retain your personal data for the period specified by the law that serves as the basis for such processing.
If we process personal data based on your consent to processing (in particular, for marketing purposes), you have the right to withdraw your consent at any time or to request that the data be deleted or that processing be temporarily suspended. To do so, please contact us by sending an email to privacy@sav-orbico.com.ua
5. COOKIES/SIMILAR TECHNOLOGIES AND WEB BEACONS.
Our website https://sav-orbico.com uses cookies to distinguish you from other users. They help make your experience on our website enjoyable and ensure that the content is relevant to you.
What are cookies and web beacons?
Cookie is a small piece of data (a text file) that a website, when visited by a user, asks your browser to store on your device in order to remember information about you, such as language preferences or login details. These cookies are set by us and are called first-party cookies. We also use third-party cookies (cookies from a domain different from the website you are visiting) for our advertising and marketing activities.
Web beacons (also known as “web bugs” or “tracking pixels”) are small strings of code that are graphic images embedded in web pages or emails for the purpose of transmitting data back to us. Information collected through web beacons includes data such as IP addresses, as well as information about how you respond to a marketing message (for example, the time an email is opened, which links you click on in the email, etc.). We use web beacons on our websites and include them in the emails we send to you. We use web beacons for various purposes, including site traffic reporting, counting unique visitors, advertising, email auditing and reporting, and personalization.
The term “cookie” as used in this Policy, also includes all similar technologies, such as web beacons, log files, and pixel tags.
Consent.
By using the website https://sav-orbico.com/, you agree to the use of cookies in accordance with this Policy. When you first visit the Website, you will see a pop-up notice with options to adjust your settings. Although it will typically not appear again on subsequent visits, you may withdraw your consent at any time by following the instructions provided in this Policy.
What types of cookies are used on the Website?
To improve the efficiency of the Website and provide personalized content, we use persistent cookies. We also use session cookies, which are automatically deleted when you close your browser.
Our Website also uses Google Analytics tools, which employ cookies to analyze visitor behaviour. We use this data to generate analytical reports and improve the performance of the Website. Cookies collect information in an anonymous form, including the number of visitors, the sources of traffic to our Website, and the pages they visited.
You can always see which cookies are used on this Website by clicking on the “Cookie Management” icon, located in the lower-left corner of the page.
On the Website, we use the following types of cookies:
| Cookie Categories |
| a) Strictly Necessary Cookies |
| These cookies are essential for the operation of the Website and cannot be disabled in our systems. They are usually set only in response to actions made by you that amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site may not function properly. |
| b) Functional Cookies |
| These cookies enable enhanced functionality and personalization of the Website. They may be set by us or by third-party service providers. Functional cookies allow us to remember the choices you make while browsing the Website. If you disable these cookies, certain parts of the Website may not function properly for you. These cookies are not used to track your browsing activity on other websites. |
| c) Analytical Cookies |
| These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website. They help us understand which pages are the most and least popular and see how visitors move around the site. All information collected by these cookies is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our Website. |
| d) Marketing and Advertising Cookies (also known as Targeting Cookies) |
| These cookies collect information about your browsing activity on your devices and are used to display advertising relevant to you and your interests. They are also used by services provided by third parties on the Website, such as “Like” and “Share” buttons, in addition to providing the requested functionality. These third parties provide such services in exchange for recognizing that you (or, more precisely, your device) have visited a particular website. These third parties set advertising cookies when you visit the Website, use their services, and when you leave the Website. If you disable these cookies, you will not see targeted advertising related to our products, special offers, news, and other information. You can opt out of advertising cookies set by such third parties at: http://www.youronlinechoices.com/uk/your-ad-choices |
Managing Cookie Settings
You can view which specific cookies are used on this Website, their purposes, and how long they are stored by clicking on “Settings” in the cookie management pop-up and selecting the relevant type of cookies.
You can review and change your cookie settings at any time by clicking on the “Cookie Management” icon, located in the lower-left corner of the page.
Most web browsers allow you to control cookies through your browser settings. To learn more about cookies, including how to see which cookies have been set and how to manage and delete them, please visit http://www.allaboutcookies.org .
Disabling Cookies
If you do not agree to our use of cookies on the Website, you can disable them by adjusting the relevant settings directly in your browser or by clicking on the “Cookie Management” icon located in the lower-left corner of the page. Please note that certain features of the Website and services provided on it may not function properly if cookies are disabled.
Some browsers allow you to indicate your preference not to be tracked online. Disabling tracking may affect your experience of using the Website and the services provided on it.
This Policy may be updated from time to time, so we recommend that you review it periodically to stay informed about how we use cookies.
6. DISCLOSURE AND TRANSFER OF PERSONAL DATA TO THIRD PARTIES
Depending on the type of processing activity under which we process your personal data, we may transfer certain personal data to third parties or grant them remote access to such data, including:
- companies within the ORBICO GROUP, of which PJSC «SAV ORBICO» is a part;
- external consultants and other service providers: we may provide your personal data to third-party service providers and/or consultants who act on our behalf and require access to your data to perform their work, such as website maintenance, invoice processing, accounting and legal support, CRM systems, etc. These service providers are authorized to use your personal data only as necessary to provide services to the Company;
- governmental, local, and other regulatory, administrative, or law enforcement authorities, as well as courts: we may disclose your personal data to such third parties if (1) we believe that disclosure is reasonably necessary to comply with applicable laws or regulations, or for legal proceedings, (2) we receive a court order, administrative decision, or governmental request (such as a search warrant, subpoena, court order, data breach notification, etc.), (3) it is necessary to protect the security or integrity of the Website, or (4) to protect the Company and our customers from harm or unlawful activities.
We may transfer your personal data to third countries or territories whose privacy laws may differ from those of your country of residence. Some recipients of personal data may be located in Ukraine, while others may be located in countries within the European Economic Area. Please note that the Company transfers your personal data outside of Ukraine only where necessary and for the purposes set out in this Policy, provided that adequate safeguards for your rights and freedoms as a data subject are ensured. In such cases, we ensure compliance with Article 29 of the Law of Ukraine “On Protection of Personal Data”. In addition, we require all recipients of personal data to ensure an appropriate level of protection and security.
You should be aware that we never sell your personal data to third parties.
In the event of a merger, reorganization, or similar corporate event, or the sale of the Company or part of its assets, the information we have collected, including personal data, may be transferred to another company (in the case of a merger or acquisition). All such transfers will, without exception, be carried out in accordance with applicable law and our obligations as set out in this Policy.
SPECIAL NOTICE FOR INTERNATIONAL USERS
This Website is hosted in Ukraine, and by providing your personal data through the Website, you consent to the transfer of your data to Ukraine.
7. DATA SUBJECT RIGHTS
Access to Personal Data
You may access your Personal Data and submit a request to obtain a physical or electronic copy of all your Personal Data stored by us. You also have the right to receive information about the sources of collection of your Personal Data.
You may exercise these rights by sending us a request to the email or postal address specified in Section 12, indicating your full name, place of residence (or place of stay), and the details of the identification document of the person submitting the request, in accordance with paragraph 1 of part four of Article 16 of the Law of Ukraine “On Protection of Personal Data”. If the request is submitted by another person on your behalf without providing proof that it has been lawfully made in your name, the request will be rejected. Please note that any information about your identity provided to us will be processed only in accordance with and within the limits permitted by applicable law.
Other rights (such as the right to modify or delete personal data).
We guarantee the exercise of your rights to the protection of your personal data and other rights provided for Article 8 of the Law of Ukraine “On Protection of Personal Data”. In particular, as a data subject, you have the following rights:
- To know the sources of collection, the location of your personal data, the purpose of their processing, and the location or place of residence (stay) of the controller or processor of personal data, or to authorize designated persons to obtain this information on your behalf, except as provided by law;
- To receive information about the conditions for granting access to personal data, including information about third parties to whom your personal data is transferred;
- To access your personal data;
- To receive, no later than thirty calendar days from the date of receipt of the request (except as provided by law), a response as to whether your personal data is being processed, as well as to receive the content of such personal data;
- To submit a reasoned request to the controller objecting to the processing of your personal data;
- To submit a reasoned request to any controller or processor to amend or delete your personal data if such data is processed unlawfully or is inaccurate;
- To protection of your personal data against unlawful processing and accidental loss, destruction, or damage due to intentional concealment, failure to provide, or untimely provision, as well as protection against the provision of information that is inaccurate or defamatory to the honor, dignity, and business reputation of an individual;
- To lodge complaints regarding the processing of your personal data with the supervisory authority or with a court;
- To apply legal remedies in case of violations of personal data protection legislation;
- To make reservations regarding the restriction of the right to process your personal data when granting consent;
- To withdraw consent to the processing of personal data;
- To be informed of the mechanism of automated processing of personal data;
- To protection against automated decisions that have legal consequences for you.
Please note that when you contact us, you will need to undergo an identification process and submit your specific requests so that we can process your request and respond on lawful grounds. If we are unable to identify you based on your communications or have reasonable doubts about your identity, we may request additional proof of identity. This is necessary to prevent unauthorized disclosure of your data to someone impersonating you, and therefore the identification process is carried out in your best interests. Any additional information collected for verification purposes will be used solely for identity confirmation.
Please note that, in accordance with Article 15 of the Law of Ukraine “On Protection of Personal Data” personal data shall be deleted or destroyed in the following cases:
- upon expiry of the data retention period determined by the data subject’s consent or by law;
- upon termination of the legal relationship between the data subject and the controller or processor, unless otherwise provided by law;
- upon issuance of a relevant order by the supervisory authority;
- upon entry into legal force of a court decision on the deletion or destruction of personal data.
8. PERSONAL DATA SECURITY.
We also inform you that PJSC «SAV ORBICO» implements a wide range of data security measures to ensure the confidentiality and integrity of your personal data.
At the same time, given the nature of the Internet, please note that data transmission over the Internet (including via email) may involve certain security risks, and complete protection of data against unauthorized access by third parties cannot be guaranteed. Nevertheless, as noted above, PJSC «SAV ORBICO» pays significant attention to the protection of personal data and, taking into account the specific nature of such data transmission, has implemented and applies appropriate technical and organizational security measures.
9. CHANGES TO THIS POLICY
If we change the way we process your personal data, we will update this Policy. We reserve the right to make changes to our personal data processing practices and to this Policy at any time, so we encourage you to review this Policy periodically for any updates or changes.
12. DATA CONTROLLER
PJSC «SAV ORBICO» acts as the Data Controller for your personal data.
If you have any questions or comments regarding this Policy, or if you wish to submit a complaint regarding our compliance with personal data protection legislation, please contact us:
Email: privacy@sav-orbico.com.ua
Postal address: 27, Hetmana Kyryla Rozumovskoho street, Kyiv, 03115 Ukraine
