This Privacy Policy (hereinafter – the “Policy”) provides you with information on how SIA “UGEARS INTERNATIONAL TRADE COMPANY” and LIMITED LIABILITY COMPANY “UKRAINIAN GEARS” (joint data controllers, hereinafter - “we”, “us” and “our”) process (collect, store, use, share, transfer disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destruct etc) personal data (personal information) collected via the website https://ugearsmodels.com/ (hereinafter - the “Site”).
This Policy applies only to the processing of personal data collected according to this Policy. If you provide your personal data to a third party or access a third party's website through a hyperlink found on the Site, the processing of your personal data will be subject to the policies and business practices of the respective third party. Joint data controllers are not responsible for such third party’s compliance with the legislation regulating processing of personal data.
Personal data processed, purposes and legal basis for processing
We may process the following types of your personal data: your given name, surname and middle name/patronymic, physical address, e-mail addresses, cell phone numbers, payment details/credentials, your device information and information about your use of the Site as well as interaction with the Site (browsing history, your IP address, geolocation, URL visited, consent and device data, user agent and language settings).
This data is processed for the following purposes:
a) to enable you to purchase UGEARS products (enter into a sales contract) and to fulfill your order;
b) to maintain our enterprise resource planning (ERP) system;
c) to provide you pre and post-sale support and services including but not limited to answer your request(s) or fulfill your request for replacement/spare/additional parts for UGEARS products;
d) to provide you with information about, offer, promote, and advertise UGEARS products,
e) to send you information, promotional and advertising messages via email, SMS and/or WhatsApp, Viber, Telegram, etc. as well as to invite you to purchase UGEARS products;
f) to conduct market research and/or to carry out marketing activities;
g) to run giveaways/prize draws, to select, announce, and notify the winners, to send you such giveaways/prizes;
h) to provide social media features;
i) to maintain sustainable functioning, test, improve, protect the Site against cyberattacks, customize the Site based on your IP address;
j) to analyze interaction with the Site, personalize content suggestion, improve the Site and user’s experience;
k) to secure implementation and functioning of consent management platforms such as Cookiebot Consent Management Platform;
l) for tax and accounting purposes;
m) for backup/recovery purposes.
We process your personal data based on your consent, necessity to process such data for the performance of a contract between you and us or legitimate interest we pursue as specified below.
When purchasing UGEARS products (entering into a sales contract) or joining giveaways/prize draws, the processing of your personal data is necessary for the conclusion of the sales contract, maintaining our enterprise resource planning (ERP) system as well as for tax and accounting purposes. All of the above will be impossible if you refuse to consent to the processing of your personal data.
Your consent to the processing of your personal data is also necessary to send you information, promotional and advertising messages via email, SMS and/or WhatsApp, Viber, Telegram, etc. as well as to invite you to purchase UGEARS products.
We may also process personal data if it is necessary for the purpose of our legitimate interests that are specified in clauses “c”, “d”, “f”, “g”, “h”, “i”, “j”, “k” and “m” above.
We do not collect special categories of personal data envisaged by Article 9 of the General Data Protection Regulation.
How personal data is collected and used
You provide your personal data when you create your account on the Site, place your order (enter into a sales contract), forward your request(s), fill out the form for replacement/spare/additional parts, join/enter giveaway/prize draws or other similar program/competition/game/campaign/activity, subscribe to our newsletters and/or information, promotional and advertising messages, consent to use of cookies etc.
If you have consented to the processing of your personal data, but have not paid for the product added to the cart (regardless of the reasons), automatic notifications may be sent to you via WhatsApp, Viber, Telegram etc., to the email address and/or cell phone number specified by you specifying the content of the cart and an inviting you to purchase the product.
The processing also involves the personal data you provided to third-party sites and platforms (including but not limited to Google, Meta, Pinterest, LinkedIn, X, TikTok, MailChimp, Randorm.org, Gleam), which you have consented to be subsequently provided/transferred/shared to or with us as well as personal data received from you and from any technical devices (including mobile phones) you are using during your access to and stay on the Site.
Information obtained during your stay on the Site, including information about your advertising preferences and communication with the joint controllers of personal data, is processed for the purposes specified in clauses “d”, “f”, “g”, “h”, “i” and “j” of “Personal data processed, purposes and legal basis for processing” section of this Policy. This information is retrieved from devices (including mobile phones) when you access the Site. Such information may include device ID or unique identifier, device type and unique device token, location information, including geolocation information from your mobile device, computer and connection information, such as page views, incoming and outgoing traffic, URL data, your IP address, your browsing history (you can learn more about this data from our Cookie Policy - https://ugearsmodels.com/cookies.html). The above data is processed with the IP address of the device you use to access the Site.
No conclusions are drawn about you from your visit to the Site and from the collected personal data.
We do not use automated decision-making systems including profiling while processing your personal data.
You may send a notice/request at any time that you object to the processing of your personal data or that you no longer wish joint data controllers to continue processing your personal or that you wish to withdraw your consent to the processing of your personal data or that you wish to restrict the processing of your personal data (to opt out from certain use of your personal data/ including but not limited to from direct marketing/personalized advertising) or to unsubscribe from our newsletters, information, promotional and advertising messages by contacting us at privacy@ugearsmodels.com. Please be aware that we may request additional information necessary to satisfy your notice/request.
Sharing personal data with third parties
Your personal data may be shared with third parties services providers we engaged to assist us with the activity specified in clauses “a” - “m” of “Personal data processed, purposes and legal basis for processing” section of this Policy.
In case of the activity specified in clause “e” of “Personal data processed, purposes and legal basis for processing” section of this Policy such information, promotion and advertising messages may be forwarded to you via or using the services provided by third parties service providers that, in turn, may involve sharing personal data with or importing personal data to systems of such service providers and subsequent sharing of personal data with companies that help third parties service providers to promote, provide, or support the corresponding service
Your personal data may also be shared with other enterprises, members of the UGEARS group, who may ship your order, giveaway/prize to you due to logistics reasons.
The third parties service providers independently determine the list and procedures for processing of personal data. Given the above, it is recommended to read the privacy policies of such third parties to understand how exactly your personal data is processed by the relevant companies (see for example links to the privacy policies of payment systems: https://stripe.com/privacy, https://www.paypal.com/legalhub/privacy-full, or postal service/logistics companies: http://www.dhl.com/en/legal.html#privacy, https://www.fedex.com/en-lv/privacy-policy.html).
The sharing above may result in transferring your personal data out of the EEA. Any transfer of personal data out of the EEA shall take place if the EU Commission has decided that the corresponding country ensures an adequate level of protection of personal data or if appropriate safeguards are provided in the form of the Standard Contractual Clauses for the protection of personal data. You may contact us to obtain a copy of such safeguards.
To who and when access to your personal data is provided
Access to your personal data (disclosure by transmission, dissemination or otherwise making your personal data available) may be provided to regulatory, law enforcement and/or other agencies:
- on the basis of a request provided that there are sufficient grounds to believe that it is necessary according to the applicable law;
- if there is a reason to believe that providing access to your personal data is necessary to track, prevent, or investigate fraud, unauthorized use of the account or payment credentials, violation of the Terms of use (https://ugearsmodels.com/terms-of-use.html), other harmful or illegal acts;
- if granting access to your personal data is necessary for the protection of joint data controllers’ rights and/or compliance with our obligation arising out of an investigation or trial.
Storage period
The personal data storage period is determined based on the applicable regulations (for example, those governing the storage period for tax and/or accounting purposes or establishing limitation periods).
At the end of the respective period, the relevant data will be systematically deleted, provided it is no longer required for the fulfillment of contractual obligations, protection of legal interests, compliance with the request lodged by a supervisory or law enforcement agency or an obligation arising in connection with the investigation or trial.
Security
The employees engaged in processing of your personal data are obliged to adhere to the security principles and current provisions on personal data protection.
Reasonable and appropriate measures are taken to protect your personal data, including against the risks of unintentional or unlawful destruction, manipulation, damage, alteration, or unauthorized disclosure or access.
We urge you to choose a unique password while creating an account on the Site and keep your password strictly confidential.
Your rights
You have the following rights:
- the right to obtain confirmation as to whether or not your personal data are being processed, and, where that is the case, to access to such personal data and information;
- the right to obtain the rectification (correction) of your inaccurate personal data including the right to have your incomplete personal data completed;
- the right to obtain the erasure of your personal data;
- the right to obtain restriction of processing (the right to opt out from certain use of your personal data, including but not limited to from direct marketing/personalized advertising);
- the right to request information on the recipients of your personal data;
- the right to receive your personal data that you have provided, in a structured, commonly used and machine-readable format and the right to transmit such data to another controller (data portability);
- the right to object at any time to processing of your personal data;
- the right not to be a subject to a decision based solely on automated processing, including profiling;
- the right to withdraw consent to the processing of your personal data at any time, without affecting the lawfulness of processing based on consent before the withdrawal;
- the right to lodge a complaint with the competent supervisory authority or court;
- other rights provided by applicable laws.
If you have any questions about your rights or would like to exercise your rights, you may send a message to: privacy@ugearsmodels.com. Please be aware of our necessity to perform unambiguous identification of your person.
Age restrictions
We do not knowingly process personal data of children.
By using the Site, you confirm that you have reached the majority age in accordance with the laws applicable in your place of residence.
Please contact us at privacy@ugearsmodels.com if you have provided us with any personal data about children so we will be able to erase the data. Please be aware that we may request additional information necessary to identify your information and satisfy your request.
Confidentiality notice
By using the Site and/or consenting to the processing of your personal data, you confirm that your personal data is not classified as confidential.
Date of entry into force and change to this Policy
This Policy becomes effective upon posting at https://ugearsmodels.com/privacy-policy.html.
Joint data controllers reserve the right to change this Policy at any time. Changes to the Policy take effect immediately after their posting at https://ugearsmodels.com/privacy-policy.html and apply to users of the Site who have consented to the processing of personal data of visited the Site after the corresponding changes have been posted at https://ugearsmodels.com/privacy-policy.html.
To avoid misunderstandings, we urge you to revise this Policy each time you use the Site.
Contact details:
Joint data controllers:
LLC “UKRAINIAN GEARS”
Ukraine, 03151, Kyiv, street Ochakivska/Ochakivskyi lane, building 5/6
(role, responsibility and liability of this joint controller for compliance with obligations under GDPR, in particular as regards the exercising of your rights and duties to provide information envisaged by the GDPR: please consult clauses “b” “c”, “d”, “e”, “f”, “h”, “i”, “j”, “k” and “m” of “Personal data processed, purposes and legal basis for processing” section of this Policy)
SIA “UGEARS INTERNATIONAL TRADE COMPANY”
LV-2167, Latvia, Mārupes nov., Vētras, “Asarīši 3"
(role, responsibility and liability of this joint controller for compliance with obligations under GDPR, in particular as regards the exercising of your rights and duties to provide information envisaged by the GDPR: please consult clauses “a”, “b” “c”, “d”, “e”, “f”, “g”, “h”, “i”, “j”, “k” “l” and “m” of “Personal data processed, purposes and legal basis for processing” section of this Policy)
Joint controllers agreed to work in close cooperation to secure the most efficient exercise of your rights.
