Privacy policy

PRIVACY POLICY

LLC "ADROIT SERVICE"

Version dated July 1, 2026

Limited Liability Company "ADROIT SERVICE" (Ukrainian legal entity identification code 45129681; registered address: Ukraine, 02002, Kyiv, 19 Yevhena Sverstyuka Street; hereinafter — "the Company", "we", "us", "our") respects your right to privacy and takes care of the security of your personal data.

This Privacy Policy (hereinafter — the "Policy") describes what personal data we collect, for what purposes, on what legal grounds, how we process, store and protect it, as well as what rights you have in relation to your data.

The Policy applies to all interactions with the Company: visits to the website www.adroit.com.ua (hereinafter — the "Website"), completion of forms on the Website, ordering our services for the repair and maintenance of home appliances and consumer electronics, communication by phone, e-mail and messaging apps, as well as visits to the physical address of the service center.

By using the Website and/or ordering our services, you confirm that you have read this Policy and understand its terms. If you do not agree with any of its provisions, please do not use the Website and our services.

This Policy has been developed in accordance with the Constitution of Ukraine, the Civil Code of Ukraine, the Law of Ukraine "On Personal Data Protection", the Law of Ukraine "On Information", the Law of Ukraine "On Electronic Commerce", the Law of Ukraine "On Consumer Rights Protection" and other legal acts of Ukraine. When processing personal data of EU citizens, the Company additionally applies the principles of the General Data Protection Regulation (GDPR, EU 2016/679).

1. DEFINITIONS

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

•  Personal data — information or a set of information about a natural person who is identified or can be specifically identified.

•  Data subject (hereinafter — the "User", "you") — a natural person whose personal data is being processed.

•  Processing of personal data — any action or set of actions such as collecting, recording, accumulating, storing, adapting, changing, updating, using and disclosing (distributing, selling, transferring), depersonalizing, or destroying personal data.

•  Personal data controller — LLC "ADROIT SERVICE", which determines the purpose of processing personal data, sets the composition of such data, and defines the procedures for its processing.

•  Personal data processor — a natural or legal person authorized by the controller or by law to process personal data on the controller’s behalf (for example, delivery services, IT contractors).

•  Consent — a voluntary expression of will by a natural person (subject to being informed) granting permission for the processing of their personal data in accordance with the stated purpose.

•  Cookies — small text files stored on your device while you visit the Website.

•  Services — services for the diagnostics, repair and maintenance of home appliances and consumer electronics provided by the Company.

2. WHAT PERSONAL DATA WE COLLECT

We collect and process only the data that is necessary to provide you with services and to fulfil our legal obligations. The scope of data depends on the way you interact with us.

2.1. Data that you provide us with directly

When filling out the repair request form or the contact form on the Website, when contacting us by phone, e-mail, via messaging apps, or when visiting our service center in person, you may provide us with the following data:

•  surname, first name, patronymic (or business name — for individual entrepreneurs);

•  phone number;

•  e-mail address;

•  postal address, delivery service branch address;

•  information about the device submitted for repair (manufacturer, model, serial number, description of the fault);

•  the content of your requests, inquiries, complaints;

•  details of the identity document — only in cases required by law (for example, when preparing documents for large amounts or for warranty service through the manufacturer);

•  taxpayer identification number (RNOKPP) — where necessary for accounting and tax records.

2.2. Data collected automatically when visiting the Website

When you use the Website, we may automatically receive the following technical data:

•  IP address;

•  browser type and version;

•  device type and operating system;

•  time and date of visit, session duration, pages viewed;

•  source of your visit to the Website (referral URL, search query);

•  cookies and similar technologies (see Section 9 of this Policy).

In the future, the Company plans to implement web analytics systems (in particular, Google Analytics) and advertising network tools. Before using them, this Policy will be updated accordingly, and a separate notice (banner) on the use of cookies with the option to give or refuse consent will appear on the Website.

2.3. Data we receive from third parties

In certain cases, we may receive data about you from third parties — for example, delivery services (when you send us your device for repair via a carrier), device manufacturers (as part of warranty service), or partners through whom you have submitted a repair request. In such cases, we only process the data that is necessary to provide the relevant service.

2.4. Data we DO NOT collect

We do not collect or process data belonging to special categories (sensitive data) — data on racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties or trade unions, health, sex life, biometric or genetic data. If you provide such data on your own in the text of your request (which is not necessary for the provision of services), it will not be processed systematically and will be deleted at the earliest opportunity.

We do not collect or store the full details of your payment cards. Payments through payment systems (once introduced) are processed on the side of the respective acquiring bank/payment system, which acts as a separate personal data controller.

3. PURPOSES AND LEGAL GROUNDS FOR DATA PROCESSING

The Company processes your personal data exclusively for clearly defined, lawful purposes and on the following legal grounds provided for in Art. 11 of the Law of Ukraine "On Personal Data Protection" (and, where applicable, Art. 6 of the GDPR):

Your personal data is not used for making decisions based solely on automated processing that would have legal consequences for you.

4. MARKETING COMMUNICATIONS

The Company may send you advertising, informational or marketing communications (notifications about promotions, discounts, new services, tips on using the equipment) via e-mail, SMS, Viber, Telegram or other messengers — exclusively upon receiving your separate, clearly expressed consent.

Such consent is given by ticking a separate box (checkbox) in a form on the Website or by another clearly expressed method. The absence of such a tick means that marketing communications will not be sent to you.

You have the right to withdraw your consent to receive marketing communications at any time by using the "Unsubscribe" link in the communication itself, replying "STOP" to an SMS/messenger message, or sending a request to e-mail: info@adroit.com.ua. Withdrawal of consent to marketing does not affect the processing of data necessary for the performance of the contract.

5. SHARING OF DATA WITH THIRD PARTIES

We do not sell your personal data. We may share your data only to the extent necessary for the relevant purpose and only with the following categories of recipients:

•  Delivery services and logistics companies (in particular JSC "Ukrposhta", LLC "Nova Poshta" and other carriers) — to the extent necessary for delivering the device to the service center and returning it to you (full name, contact phone, delivery branch/address);

•  Manufacturers and official distributors of the equipment — to the extent necessary for fulfilling the manufacturer’s warranty obligations (contact details, serial number of the device, description of the fault);

•  Accounting, legal and IT contractors of the Company — acting on behalf of the Company under contracts that provide for confidentiality obligations and compliance with personal data protection legislation;

•  Banks, payment systems and acquiring companies — in the case of cashless payments (transfers to the Company’s account or payment via a payment terminal);

•  Telecommunication operators, postal services, messaging service providers — to the technical extent necessary for ensuring communication;

•  State authorities, courts, law enforcement agencies — in cases and in accordance with the procedure established by the laws of Ukraine, on the basis of official requests or orders.

The Company enters into contracts with all personal data processors, which provide for the obligation to maintain the confidentiality of the data received and to process it only within the scope determined by the Company.

5.1. Cross-border data transfers

At present, the Company does not carry out any transfers of personal data outside Ukraine. If in the future a need for cross-border data transfers arises (for example, in cooperation with foreign device manufacturers or when using cloud services located abroad), the Company will ensure that such transfers are made exclusively to countries that provide an adequate level of personal data protection, or on the basis of other safeguards provided for by law (in particular, standard contractual clauses).

6. DATA RETENTION PERIODS

We store your personal data no longer than necessary to achieve the purposes for which it was collected, or within the periods established by law. In particular:

•  Data related to the performance of a specific repair order — for the duration of the relevant contract and for 3 (three) years after its completion (the general limitation period under the Civil Code of Ukraine);

•  Primary accounting documents and tax documents — for the periods established by the Tax Code of Ukraine and the Law of Ukraine "On Accounting and Financial Reporting in Ukraine" (as a rule, at least 3 years, and longer for certain documents);

•  Data processed on the basis of consent to marketing — until consent is withdrawn;

•  Technical data and cookies — for the periods specified in Section 9 of this Policy;

•  Data necessary for the protection of the Company’s rights in disputes — until the completion of the relevant proceedings.

Once the processing purposes have been achieved or the established periods have expired, personal data is deleted or anonymized in the manner established by law and the Company’s internal procedures.

7. YOUR RIGHTS REGARDING PERSONAL DATA

In accordance with Art. 8 of the Law of Ukraine "On Personal Data Protection", and — for Users resident in the EU — also in accordance with the GDPR, you have the following rights:

•  Right to information — to know about the sources of collection and location of your personal data, the purpose of its processing, and the location of the controller or processor.

•  Right of access — to obtain information on whether your personal data is being processed, and a copy of that data.

•  Right to rectification — to demand the correction or supplementation of your personal data if it is inaccurate or incomplete.

•  Right to erasure ("right to be forgotten") — to demand the deletion of your personal data if it is no longer needed for the purposes for which it was collected, or if you have withdrawn consent, or if its processing is unlawful. This right does not apply to data whose retention is required by law (for example, accounting records).

•  Right to restriction of processing — to demand the temporary suspension of data processing in cases provided for by law.

•  Right to object — to object to the processing of your data, in particular for direct marketing purposes.

•  Right to withdraw consent — where processing is based on consent, to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

•  Right to data portability — to receive your data in a structured, commonly used, machine-readable format and to transfer it to another controller (applies to data processed on the basis of consent or a contract).

•  Right to lodge a complaint — to file a complaint with the Ukrainian Parliament Commissioner for Human Rights (https://ombudsman.gov.ua) or with a court. EU-based Users may also apply to the supervisory authority in their country.

To exercise any of these rights, please send a written request to e-mail: info@adroit.com.ua or by post to the address specified in Section 11 of this Policy. The Company will consider your request within 30 (thirty) calendar days from the moment of its receipt and provide a response via the same channel through which the request was submitted, unless you specify otherwise. To verify your identity, the Company may request additional information.

8. PERSONAL DATA PROTECTION MEASURES

The Company takes reasonable organizational and technical measures to protect your personal data against unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as other unlawful actions, in particular:

•  restricting access to personal data to those employees who need it to perform their job duties;

•  entering into non-disclosure agreements with employees;

•  the use of passwords, encryption and other means of protecting information systems;

•  regular backups and ensuring the security of data storage media;

•  control of access to the physical premises where documents containing personal data are stored;

•  entering into contracts with contractors and partners that include confidentiality and data protection provisions.

Despite the measures taken, transmission of information via the Internet cannot be guaranteed as absolutely secure. In the event of unauthorized access to personal data, the Company will promptly take steps to mitigate the consequences and, in the cases provided for by law, will notify the Ukrainian Parliament Commissioner for Human Rights and the affected data subjects.

9. USE OF COOKIES AND SIMILAR TECHNOLOGIES

The Website uses cookies to ensure its proper functioning and to improve the quality of service. Cookies are small text files stored in your browser when you visit the Website.

9.1. Categories of cookies we use

•  Strictly necessary cookies — provide basic functions of the Website (loading pages, keeping the session state, security). Without them, the Website cannot function properly. These cookies are used on the basis of the Company’s legitimate interest and do not require separate consent.

•  Functional cookies — remember your choices (for example, language settings, pre-filled form fields) to make using the Website more convenient.

•  Analytics cookies — help us understand how visitors use the Website (which pages they view, how long they stay, where they come from). If Google Analytics or similar services are implemented, the relevant cookies will be set only with your consent.

•  Marketing/advertising cookies — may be used in the future to display relevant advertising on third-party resources (Google Ads, Meta, etc.). Such cookies will be set only after obtaining your separate consent via the cookie banner.

9.2. Managing cookies

You can manage cookie settings in the following ways:

•  via the cookie notice banner on the Website (once implemented) — by choosing which categories of cookies you agree to accept;

•  via your browser settings — by blocking or deleting cookies entirely or for specific sites. Instructions for popular browsers are usually available in the "Help" or "Privacy settings" sections.

Please note: disabling strictly necessary cookies may result in incorrect operation of certain Website features.

10. CHILDREN’S DATA PROTECTION

The Website and the Company’s services are intended for persons who have reached the age of majority (18 years) or have full civil capacity under Ukrainian law. The Company does not knowingly collect personal data of children. If you become aware that a child has provided us with their personal data without the consent of parents or legal representatives, please contact us and we will delete such data.

11. CONTACT INFORMATION

For all matters relating to the processing of personal data, the exercise of your rights, as well as for submitting requests, complaints or withdrawing consent, you can contact us:

Personal data controller: Limited Liability Company "ADROIT SERVICE"

Registered address: 02002, Ukraine, Kyiv, 19 Yevhena Sverstyuka Street

Service center actual address: 67 Berestejskyi Ave., Building G, Kyiv, 03062

Legal entity identification code: 45129681

Contact phone: +380 44 490 7777

E-mail: info@adroit.com.ua

Website: www.adroit.com.ua

When contacting us, please indicate the essence of your request and provide information sufficient to identify you as the data subject.

12. CHANGES TO THE PRIVACY POLICY

The Company reserves the right to periodically update this Policy, in particular due to changes in legislation, business processes, or the introduction of new technologies (for example, web analytics systems or marketing tools).

The current version of the Policy is always available on the Website at www.adroit.com.ua. In the event of material changes, the Company will notify you by posting an informational notice on the homepage of the Website at least 10 (ten) calendar days before the changes take effect and, in cases required by law, will additionally notify you by e-mail or another available communication channel.

Continued use of the Website and our services after the updated version of the Policy takes effect means your acceptance of its new terms. If you do not agree with the updates, you have the right to stop using the Website and to contact us for the deletion of your data to the extent provided for by law.

13. FINAL PROVISIONS

This Policy is governed by the substantive law of Ukraine. Any disputes that may arise in connection with the processing of personal data are subject to resolution in the courts of Ukraine in accordance with the jurisdiction established by applicable law, taking into account the consumer rights provided for in Art. 22 of the Law of Ukraine "On Consumer Rights Protection".

If any provision of this Policy is found to be invalid or unenforceable, this does not affect the validity and enforceability of the other provisions.

This Policy is an integral part of the Public Contract (offer) for the provision of services for the maintenance and repair of home appliances and consumer electronics, published on the Website.

Thank you for choosing LLC "ADROIT SERVICE".

Your privacy is our priority.