The present Privacy Policy (hereinafter – the Privacy Policy and/or the Policy) is posted for SMART BUSINESS LLC in Ukraine on the domain  (hereinafter – the Website). The owner of the Website is SMART BUSINESS LLC (hereinafter referred to as SMART, us, or we). The Privacy Policy outlines our policy with regard to gathering, use, and disclosure of certain personal data of yours by SMART, including relating to the use of the present Website by any parties. Your use of the present Website means your understanding of and agreement with terms and conditions of this Privacy Policy.

In what cases do we collect your personal data?

Personal Data collected via this Website. We receive your personal data when you submit to us e-mail requests or Feedback requests via the present Website. We also receive personal data as part of our staff recruitment process. Whenever you submit an online application to a vacancy, you create a “Network Profile” about you and provide personal data to us. Such personal data is stored only for the time necessary to process your request or to consider your job application.

List of personal data we collect via this Website:

–        your name, postal address, phone number, e-mail address;

–        biographical or demographic data if they are inseparable from personal data;

–        information about your company, such as the name, number of employees, location, and your post at the company;

SMART may collect other information through your activities on the Website and beyond, which do not demand your personal identification or are not directly or individually related to you. Such information may include:

–        unique identifier, such as cookie, that is available on your computer, cell phone, or any other device;

–        IP (internet protocol) address and information derived from it, such as geographical location data;

–        information about your device available in HTTP Headers or other internet signaling transport protocol, browser or device type and version, operating system, information about apps used or missing on your mobile device, screen extension, and selected language;

–        behavior data, such as visited websites and content areas, dates and times of activities; and

–        Web search you use to identify locations and to navigate internet resources.

Besides, we may from time to time collect your personal data through other forms available on this Website, from e-mail correspondence, and also through other online tools. Necessary personal data will be collected in the minimum amount and solely in order to allow prompt processing of your requests or questions by SMART. In some cases, additional information may be requested, which will allow us to give the most relevant response to your request or question, or to submit additional information to you when you state your desire to get it. In case of requests for additional personal information, the case will be recorded and its provision will be voluntary.

The purpose of personal data collection is to ensure the possibility to contact you, to give you personal consultation, send marketing materials to you and/or contact you within the scope of the recruitment process if you filled-in an open vacancy form. If hired by SMART, your personal data may be further used to formalize your employment with SMART, as well as for management and communication on the job.

Personal Data collected by signing a contract with SMART. Concluding a contract with SMART and during the validity of the contract SMART collects and keeps your personal data.

The personal data that we receive through a contract with SMART includes: name, surname, position, e-mail, phone number.

The purpose of personal data collection by signing a contract with SMART is to provide the opportunity to conduct economic relations, including but not limited to negotiate, to provide consultations, to fully exercise their rights and obligations as legal entities. Providing personal data for this purpose is voluntary. However, if you do not provide such personal data, we will not be able to conduct business with your company.

Personal Data collected by SMART from public sources. SMART may collect information about you received from public sources such as Trade Registers, Commercial Registers, publicly available Internet resources, etc.

We do not collect your sensitive personal data. Sensitive personal data includes information relating to race or ethnic background, political views, religious or similar convictions, membership in labor unions, physical or mental health, or criminal legal relations. When you provide sensitive personal data within the scope of staff recruitment, such provision of information will be deemed an express and unambiguous agreement to the use of such information by SMART for the purposes it was provided.

You may apply to SMART with a request to send you your personal data in a portable format for their further use at your own discretion. Moreover, if you don’t want SMART to keep on processing your personal data, you may send a message to SMART with a request to limit their processing.

You may also send a request for information about location and personal data security standards implemented by SMART.

Please send your requests to:

Response to your request will be sent to the e-mail address stated in that form. If you are willing to receive response to your request to another e-mail address, please specify it in the text of your request.

Your request will be processed as soon as possible, however, it should not take longer than one month.

Use of Personal Data

Your personal data will be used for the specific purposes it was provided for. When making a request for materials or to contact you, you may be offered to receive additional information from us, which is of interest to you. If you agree to such offer, we will use your personal data in order to keep on informing you about our products and/or services, which you, in our opinion, may find interesting. You may cancel your subscription to SMART notifications at any time by clicking the unsubscribe link available in all messages.

Do we share your personal data?

We do not share, sell, or distribute your personal data to other parties.

We may disclose, transfer, sell, or assign any of the abovementioned information, including sensitive data, to third parties as a result of or within the scope of preparation for sale, merger, consolidation, changes in management, transfer of significant assets and/or restructuring.

We may also provide personal data in response to a court ruling or any other legitimate demand. We also reserve the right to inform law-enforcement agencies about any activities, which we reasonably deem illegitimate, and to disclose any information about you to the extent we deem necessary or expedient in order to meet any legislative provisions  or other legal requirements; to ensure proper Website functioning; to protect our rights and/or rights or security of our users; or in cases when you are involved (or are reasonably suspected of the involvement) in any illegal or dangerous activities, even when there is no court notice and ruling or court order. We may share some personal data when we believe that such provision is necessary to protect rights, ownership, or security of other parties and of ourselves.

Consent to Data Processing

Your consent to the processing of personal data is mandatory for SMART.

By providing any personal data on the Website and/or in a contract with SMART, you fully realize the implications of and give explicit consent to the transfer, processing, and storage of such data to the extent admissible by the present Privacy Policy. You also give your consent to the use of your personal data as stipulated herein.

How can you withdraw your consent to processing your personal data for certain purpose?

You may withdraw your consent in any time by sending written request containing the following:

–         Your name and surname, i.e. the name and surname of the person withdrawing his/her consent, his/her address of residence and date of birth, i.e. the details we need to identify you;

–         Recipient, i.e. identification data of a person the withdrawal of consent is addressed to, i. e. SMART in this case;

–         In your consent withdrawal request, you have to declare that you do not wish any further processing of your personal data for certain purposes by our company. If you wish to get information about selected products or services only, kindly specify the details you wish to get and we will be happy to provide you with it;

–         Your signature by your own hand.

The consent to processing of personal data can be withdrawn by a declaration in writing delivered to the address of SMART as follows: 03056, Ukraine, Kyiv, Poliova str. 21, building B.

You acknowledge that you have been informed of your rights as a personal data subject, and namely the right to access personal data, the right to change personal data, the right to transfer personal data, the right to decline automated individual decision-making, including profile creation, as well as the right to demand limited processing of personal data, the right to object to personal data processing, and of the fact that your personal data may be deleted at your request. You also have the fide to file a complaint if your rights have been violated.


SMART finds your personal data security important. SMART takes technological and administrative (management) measures to ensure security of your personal data. Generally accepted technical and operational data security requirements have been introduced to protect personal data against loss, illegitimate use, modification, or destruction. However, as you may know, no transfer of data via Internet may be completely safe. Despite our ongoing reasonable efforts to protect your personal data, we can not guarantee that any information you share with us may be secured against unauthorized use or access by third parties. In case of unauthorized access to your personal data, you will be immediately informed thereof in a letter sent to your e-mail address stating the scope of such personal data and potential implications of such unauthorized access. Should it be required by any laws, SMART will also inform competent authorities about such unauthorized access/loss.

Please, use caution when sending personal data by e-mail. Electronic mail is not believed to be a safe means of data transfer.

Data Access and Update

We can not keep your personal data accurate and up-to-date without your involvement. If your personal data gets outdated, please contact us to update such information.

Meanwhile, we guarantee you access to your personal data and the possibility to update and/or change it.

Third Parties

We have no control over the information tracked or collected by third parties through their websites, links to which are available on our Website. We bear no liability or obligations for any kind of data tracking and collection or for any other activities of third parties.


When accessing the Website, you agree that Ukrainian laws will be applicable to all and any issues concerning the Website use. Nonetheless, whenever necessary, we reserve the right to lodge claims/complaints in any court or courts of any country of residence of one of the parties.

This Policy is developed in accordance with the following legal basis:

European legislative framework and decisions by the European Commission:

–        The Charter of Fundamental Rights of the European Union;

–        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/ES (General Data Protection Regulation);

–        Commission Decision of 5 February 2010 on standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Council.

National legislative framework:

–        The Constitution of Ukraine and the Law of Ukraine ‘On Personal Data Protection’.

Who may be contacted in case of questions or issues?

You may report any suspicions of security violation, ask questions, or complain about breach of confidentiality by writing to us:

Will any changes be made to this Privacy Policy?

In case of any changes in this Privacy Policy, we will inform you thereof and will post such changes here. Changes and amendments to the Privacy Policy become effective upon their posting. Please visit this page from time to time to keep yourself updated on the amendments introduced to our Privacy Policy.