Personal Data Processing Policy

Version of 31 August 2026.

This policy explains what personal data EURO CLASS TECHNOLOGY LLC receives through the website euroclasstechnology.com.ua, why it is processed, who it is shared with, how long it is kept and what rights the person whose data is processed has. The document follows the Law of Ukraine “On Personal Data Protection” No. 2297-VI of 1 June 2010.

1. Who processes the data

The data controller is EURO CLASS TECHNOLOGY Limited Liability Company.

The company does not maintain any database containing special categories of data as defined in Article 7 of the Law.

2. What data is collected

The quotation enquiry form collects the data a person enters themselves:

• name and company name;
• telephone number;
• email address (optional);
• message text — details of equipment, products and production that the person chooses to share.

Together with the form, the processing service technically records the sender's IP address and the time of submission; this serves as protection against automated spam.

Fonts are loaded from Google Fonts, and during that request the browser passes its IP address to Google — a standard condition of any external font repository.

2a. Cookies and analytics

There are no advertising pixels on the website, visitors are not profiled, and personalised advertising is not configured.

Cloudflare Web Analytics counts page views and works without cookies: it creates no visitor identifier and does not allow a person to be followed across sites. It therefore requires no separate consent.

Google Analytics 4 does require consent and does not start without it. On a first visit a request appears at the bottom of the screen:

• while no decision has been made, the tag runs in a restricted mode: no cookies are set, and Google receives anonymous page-view information with no visitor identifier;
• after «Accept», the cookies _ga and _ga_* are set for up to two years; they are what distinguishes a returning visit from a new one;
• after «Decline», the tag is not loaded at all on subsequent pages.

Google Analytics receives anonymous information about behaviour on the site: which pages were viewed, which equipment data sheets were downloaded, which source the person arrived from, the device type and the approximate city derived from the IP address. Advertising signals are switched off. Name, telephone number and email address are not passed to Google — that data is submitted only through the form and only to the form processing service.

The decision is stored in your browser and is not transmitted anywhere. You can change it at any time:

Change the cookie decision

3. Purpose of processing

Data is processed solely in order to:

• consider the enquiry set out in the message;
• prepare and send a commercial proposal;
• contact the person directly by the means they provided, within the scope of that enquiry;
• conduct further correspondence and negotiations regarding equipment supply.

Data is not used for bulk mailings, is not sold and is not passed to third parties for advertising purposes.

4. Legal basis

The basis is the consent of the data subject (Article 11(1)(1) of the Law), given by ticking the corresponding box in the form before submission. Without that tick the form is not sent.

5. Who receives the data

No other party receives the data, except where the law expressly requires it.

6. Transfer abroad

The form processing service, together with Google and Cloudflare, is located in the United States, so submitting an enquiry — and, where you have consented, the operation of analytics — constitutes a cross-border transfer of data (Article 29 of the Law). By giving consent, the person also agrees to that transfer. If this is not acceptable, the ordinary route remains available: call, or write directly to kyuri@ec-cibo.kiev.ua, and the data will not reach the external service at all.

7. Retention period

Data is kept while the enquiry is being handled and thereafter for up to ten years from the date of last contact. This period follows from the nature of industrial equipment supply: manufacturers provide spare parts throughout the entire service life of a line, which spans decades. To select a spare part or an assembly, it is necessary to know which configuration was discussed and supplied to a particular plant, and to have a contact person there. Without those records, servicing previously supplied equipment becomes impossible.

After that period the data is deleted. If consent is withdrawn earlier, the data is deleted within thirty days of receiving the request.

8. Rights of the data subject

Article 8 of the Law gives a person the right to:

• know the sources of collection, the location of their data, the purpose of processing and the location of the controller;
• receive information about the conditions of access to the data, including about third parties it is transferred to;
• access their personal data;
• receive an answer as to whether their data is being processed, no later than thirty calendar days from the date of the request;
• submit a reasoned objection to the processing;
• demand that data be amended or destroyed if it is processed unlawfully or is inaccurate;
• be protected against an automated decision producing legal effects;
• lodge complaints with the Ukrainian Parliament Commissioner for Human Rights or with a court;
• apply legal remedies in the event of a breach of personal data protection legislation;
• withdraw consent to processing;
• know the mechanism of automatic data processing;
• be protected against an automated decision producing legal effects for them.

9. How to withdraw consent or make a request

Send an email to kyuri@ec-cibo.kiev.ua or call +38 044 225 93 72. No special form is needed — simply state the phone number or email address the enquiry was sent from. A reply is provided within thirty calendar days.

10. Changes to this policy

The company may update this policy. The version in force is the one published at euroclasstechnology.com.ua/en/privacy.html; the version date appears at the top of the page.