This Policy is developed in accordance with the Law of Ukraine “On Protection of Personal Data” and other provisions of the current legislation of Ukraine regulating issues on protection of personal data.

This Policy defines the procedure for Personal Data Processing and safety measures applied by the Owner to protect Your rights and freedoms when Processing Your Personal Data, including protection of privacy, personal and family secrets, etc.

The document consists of the following sections:

In this Policy, the following terms are used with the following meaning: You, Your, Yours – You shall mean a personal data subject, whose personal data are processed.

The Owner shall mean PRIVATE ENTERPRISE “DLUXECONCIERGE”, Ukraine, identification code: 2989807330, who defines the purpose of Personal Data Processing, sets the Personal Data content and Processing procedure.

Website - Visitors to dluxeconcierge.com website that post, refer or are otherwise subject to this Privacy Notice. Such website referred to as our “Site”.

Messenger shall mean electronic programs that enable exchange of text, voice, graphics or video messages between their users. Messengers shall in particular, but not exclusively, include Instagram, WhatsApp, Facebook Messenger, etc.

Processing shall mean Processing Your Personal Data, which includes any action or set of actions, such as collecting, storing, usage, transferring, depersonalizing, or eliminating personal data also by means of (automated) informational systems.

Personal data shall mean information or collection of information about You, including: surname, name, patronymic, date of birth, taxpayer registration identification card number, series and number of passport, date and place of issue of passport, payment card details, photo, phone number, email address.

By reaching the Owner via Forms on site, messenger, by telephone, or by sending an email to the Owner's email address, You give Your consent to Process Your Personal Data and confirm that such consent is voluntary and informed.

In addition to the procedure for giving the consent, specified of this Policy, Your Personal Data Processing may be carried out in the view of the need to execute a legal transaction to which You are a party.

Your Personal Data are Processed openly and transparently, using tools and methods that meet specific goals of such Processing. Your Personal Data are Processed under the terms and conditions specified in this Policy.

By giving Your consent, You confirm that the scope and contents of the Personal Data is relevant, adequate and not excessive as for the purpose of Processing.

By giving Your consent to the processing of Personal data, You also consent to sending You electronic, push-up or other messages for informing You and / or providing You with promotional information about the Owner's goods / works / services and third parties with whom the Owner has relevant contractual relations.

The Privacy Policy constitutes the entire agreement between You and Owner pertaining to the processing of the Personal Data.

The purpose for Your Personal Data Processing is the need to provide You services in the field of Virtual Travel Concierge service by the Owner, as well as related services, providing You with the information and other services that the website offers in accordance with its functionality, also providing You with promotional information regarding to the Owner's goods / works / services and third parties with whom the Owner has relevant contractual relations.

Your Personal Data are Processed based on Your consent, provided in accordance with this Policy.

Your Personal Data are processed in a form that allows Your identification without exceeding the time limit required by the purpose of such Processing.

You have the right to withdraw the consent to Your Personal Data Processing without any reasoning. From the moment of withdrawal of Your consent, the Owner shall terminate Personal Data Processing, that shall mean cancellation of services provided to You by the Owner.

Your Personal Data shall be Processed within the time period required to provide You the services and within the timeframes for the achievement of the goals of the Processing.

Your Personal Data are collected by Your voluntarily provision of Personal Data by means of Messengers, by telephone or by sending an email to the Owner’s email address. Such Personal Data are stored in the relevant memory of Your electronic device, on which the Online forms, messenger is installed, and by the Owner. In this case, the Owner is not responsible for the security of your Personal data transmitted through Messenger, since the latter contains its own policy of working with Personal data.

Your Personal Data may be changed, removed or eliminated upon Your request in accordance with the procedure established by the current legislation of Ukraine. The change of Your Personal Data shall be carried out upon a motivated written request. Herewith, Your Personal data are subject to removal in case of:

• expiration of Personal Data storage period, specified by Your consent to the Processing;
• termination of legal relationship between You and the Owner;
• other cases, established by the current legislation of Ukraine.

The Owner shall inform You about any change, removal or elimination of personal data or restriction of access to them within ten (10) business days from the date when such actions took place.

Your Personal Data Processing by the Owner shall be based on the following principles:

• openness and transparency;
• using means and in a manner that corresponds to the specific Processing purposes;
• preventing excessive Personal Data Processing as for the stated Processing purpose;
• processing exclusively those Personal Data that meet the Processing purpose.

In order to execute the agreement concluded under the terms of the Policy or other agreements in Your favor, the Owner shall have the right to exercise a cross-border (foreign individual or foreign legal entity) or local transfer of Your Personal Data. The Owner shall have the right to entrust Processing of Your Personal Data to another person, unless other established by the legislation of Ukraine, on the basis of an agreement concluded with such a person. A person carrying out Personal Data Processing on behalf of the Owner shall be obliged to adhere to the principles and rules of Personal Data Processing, stipulated by this Policy and the current legislation of Ukraine.

The Owner shall not take any decisions on the basis of the solely automated Personal Data
Processing that may cause legal consequences in relation to You or otherwise affect Your rights and legal interests.

You have the right to:

• know about the sources of collection, location of Your Personal Data, purpose of their Processing, location or place of residence (stay) of the Owner;
• get information about the terms and conditions of granting access to the Personal Data, including information about any third parties to which Your Personal Data is transferred;
• access to Your Personal Data;
• receive information as to whether Your Personal Data is processed within no more than thirty (30) calendar days from the date of receipt of the request, except as provided for by the current legislation, and also to receive the contents of such Personal Data;
• provide a motivated request to the Owner with objection to Your Personal Data Processing;
• provide a motivated request to the Owner as for the change or elimination of Your Personal Data by the Owner;
• protection of Your Personal Data from illegal Processing and accidental loss, elimination, damage caused by intentional concealment, failure to provide or untimely provision thereof, as well as protection against providing information that is unreliable or causes damage to Your honor, dignity and business reputation;
• file complaints related to Your Personal Data Processing in accordance with the procedure established by the current legislation of Ukraine;
• apply remedies in case of violation of the legislation on Protection of Personal Data;
• include clauses on limitation of the right to Your Personal Data Processing when giving consent;
• withdraw Your consent to the Personal Data Processing;
• know the mechanism of automatic Personal Data Processing;
• protection against an automated solution that has legal consequences for you.

The Owner hereby states that in order to ensure safety of Your Personal Data Processing, special technical protection measures are taken, including prevention of unauthorized access to the Processed Personal Data and work of technical and software complex by means of which Personal Data Processing is carried out.

Your Personal Data are processed in a way that prevents accesses of any third parties.

The Owner takes technical, organizational and legal measures, or ensures their adoption, to protect Your Personal Data from unauthorized or accidental access, collection, storage, usage, transmission, blocking or elimination, as well as other unlawful actions.

In order to protect Your Personal Data, the Owner shall in particular carry out the following:

• appoint officials responsible for the organization and protection of Personal Data Processing;
• ensure the registration and storage of material carriers of information and their circulation, which shall excludes theft, substitution, unauthorized copying and elimination;
• detect unauthorized access to the corporate network of the Owner that violates or causes violation of the established requirements for the Personal Data protection;
• teach the workers using information protection tools used in the Personal Data systems, the rules for their operation;
• restrict and regulate the staff of the Owner, having access to Personal Data;
• make employees of the Owner aware of the requirements of Ukrainian legislation;
• determine security threats as for the Personal Data while Processing, form a model of threats on their basis;
• carry out antivirus control, preventing the introduction of malware (virus programs) and software bookmarks into the corporate network of Owner;
• provide password protection for the users’ access to the Personal Data System;
• use means of access control (including physical) to communication ports, input-output equipment, removable media carriers and external storage media;
• monitor user activity, decides on violations of Personal Data protection requirements (if any);
• check readiness and efficiency of information protection means usage;
• develop, on the basis of the model, any threats to the Personal Data Protection system for the corresponding class of information systems;
• implement an authorization system for the access to the information resources, software and hardware processing means and information security;
• if necessary, register and record actions of Personal Data information system users;
• keep record of the used information protection means, respective operational and technical documentation;
• carry out centralized management of the of Personal Data Protection System.

Provisions of this Policy may be amended by the Owner, and the Owner shall notify You thereof by appropriate means of communication (including, but not exclusively, in the Messengers). The implementation of the actions specified in this Policy, after making changes to it, is a new consent with this Policy on new terms.

By following the steps outlined. You hereby agree to receive messages from Owner by sending an email or in messengers, as well as other means of communication regarding services that will or may be provided by Owner or another person specified by Owner.

If it is necessary to contact the Owner on the Policy or implementation of Your rights, You can use the following contact details: order@dluxeconcierge.com.

You can get acquainted with the list and conditions of providing services in the web page dluxeconcierge.com.