Privacy Policy

This policy explains what personal data Sole proprietor (FOP) Hlieb Pavlovych Tovsteniuk (the Controller) collects through tovsteniuk.com, why, how long it is kept and what rights you have. It follows the Law of Ukraine “On Personal Data Protection” and, for people in the European Union, Regulation (EU) 2016/679 (GDPR).

1. Controller

Sole proprietor (FOP) Hlieb Pavlovych Tovsteniuk, tax number 3881714637, [registered address], Lviv, Ukraine. Data protection contact: [email protected].

2. Data we collect

• Request data: name, phone or Telegram, email (optional), company and website, request text, chosen service, whether an invoice is needed.
• Service data: questionnaire answers, business information, access to ad accounts and analytics (for audits), meeting recordings (only with consent).
• Payment data: amount, date and status, invoice details. Card data is processed by the payment provider; the Controller never receives or stores it.
• Technical data: IP address, browser type, the page the request was sent from, UTM tags; analytics cookies only with your consent.

3. Purposes and legal bases

• Replying to a request and entering into a contract — consent and pre-contractual steps (GDPR Art. 6(1)(a), (b)).
• Delivering the services, invoices and acts — performance of a contract (Art. 6(1)(b)).
• Accounting and tax records — legal obligation (Art. 6(1)(c)).
• Spam protection and site security — legitimate interests (Art. 6(1)(f)).
• Visitor analytics — consent, which you may withdraw at any time (Art. 6(1)(a)).

4. Recipients

Data is never sold or shared for third-party marketing. Processors: Telegram (request delivery and messaging), the hosting provider and CDN (Cloudflare, Inc.), Google LLC (Meet, Workspace, Analytics — the latter only with consent), Zoom, Microsoft Clarity and Meta Pixel (only with consent), the payment provider, the bank and the accountant. Some processors are outside Ukraine and the EU; transfers rely on your consent, contract necessity or the standard contractual clauses these providers use (GDPR Chapter V).

5. Retention

Requests that did not lead to a contract — up to 12 months; client data and correspondence — for the contract term plus 3 years; accounting records — as required by tax law; meeting recordings — up to 6 months unless you ask to delete them sooner; analytics — up to 14 months.

6. Your rights

You may access, correct or delete your data, restrict or object to processing, withdraw consent at any time, receive your data in a portable format and lodge a complaint. Email [email protected]; we reply within 30 days. Complaints may be lodged with the Ukrainian Parliament Commissioner for Human Rights (ombudsman.gov.ua) or, in the EU, with your local data protection authority.

7. Security

The site is served over HTTPS only. Requests are accessible only to the Controller; accounts use two-factor authentication; tokens and keys are kept server-side only.

8. Children

The services are intended for adults and business representatives. We do not knowingly collect data from anyone under 16.

9. Changes

The current version is always on this page, with the update date below.