1. General Provisions
This Privacy Policy (the "Policy") explains how plishka studio (hereinafter "we", "the Studio", "the Controller"), operating at plishkastudio.com, collects, uses, stores, and protects the personal data of the Site's users.
Personal data is processed in accordance with the Law of Ukraine "On Personal Data Protection" No. 2297-VI of 1 June 2010 (the "Law") and the Standard Procedure for Personal Data Processing approved by Order No. 1/02-14 of the Ukrainian Parliament Commissioner for Human Rights dated 8 January 2014.
By submitting your personal data through the contact form or by continuing to use the Site, you confirm that you have read this Policy and consent to the processing of your data for the purposes stated herein. If you do not agree, please do not provide your personal data.
2. Who Is the Controller of Your Personal Data
Pursuant to Article 1 of the Law, the controller of personal data is:
For any matters relating to the processing of personal data, please contact us using the details provided in Section 12.
3. What Personal Data We Collect
We collect the following categories of personal data:
- Contact data — first and last name, phone number, email address (provided by you voluntarily);
- Communication data — the content of your message and the description of your project or request;
- Technical data — IP address, browser type and version, operating system, device type, cookies, and session identifiers;
- Analytics data — the pages you view, the duration of your visit, and the source that referred you to the Site.
We do not collect or process sensitive (special) categories of personal data: racial or ethnic origin, political views, religious beliefs, health status, or biometric or genetic data.
4. Purposes and Legal Basis of Processing
Your personal data is processed solely for the following purposes and on the following legal grounds (Article 11 of the Law):
- Responding to enquiries and communication — handling requests submitted through the contact form (legal basis: your voluntary consent);
- Preparing and providing services — preparing a commercial proposal, concluding and performing a contract (legal basis: necessity to perform a contract or to take steps at the data subject's request prior to entering into it);
- Improving the Site and analytics — understanding how visitors interact with the Site and identifying technical errors (legal basis: the Studio's legitimate interest);
- Compliance with legal obligations — storing and disclosing data when required by competent authorities under applicable Ukrainian law (legal basis: compliance with legal requirements).
5. Personal Data Retention Periods
We retain personal data no longer than is necessary to achieve the purposes of processing:
- Contact form data (name, phone, email, message content) — up to 3 years from the last contact or until consent is withdrawn, whichever comes first;
- Data related to contract performance — as required by Ukrainian law, but no less than 3 and no more than 5 years after the contractual relationship ends;
- Technical data (cookies, logs) — according to the settings of the respective service providers (typically from 14 days to 26 months).
Once the applicable retention period expires, or upon your justified request, personal data is deleted or anonymised.
6. Sharing Personal Data with Third Parties
We do not sell, rent, or share your personal data with third parties for marketing purposes.
To operate the Site and provide our services, we engage the following service providers (data processors), who process data solely on our instructions and under confidentiality obligations:
- Web3Forms — processing and delivery of messages submitted through the contact form; terms: web3forms.com/privacy.
We may disclose personal data upon a lawful request from a court or other competent authorities in accordance with applicable Ukrainian law.
7. Cross-Border Transfers of Personal Data
Pursuant to Article 29 of the Law, cross-border transfers of personal data are permitted to countries that ensure an adequate level of protection (EEA member states and states party to the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data), or on other grounds provided for by the Law.
Our service provider Web3Forms is located in the United States of America, which is not on the list of countries ensuring an adequate level of protection under the Law. Data is transferred to this provider on the basis of your voluntary consent, given when you submit the contact form and/or continue using the Site, as well as under a data processing agreement concluded with this provider that guarantees a sufficient level of protection.
By submitting your personal data through the Site, you confirm your consent to its transfer to the services listed above.
8. Cookies and Web Analytics
The Site uses only strictly necessary cookies — small text files stored in your browser that enable the Site's basic operation (navigation, spam protection). We do not use analytics or marketing cookies and do not employ any third-party web analytics systems.
Ukrainian law does not currently impose specific cookie-consent requirements; however, we inform you about our use of cookies in line with the general transparency principles set out in the Law. You can disable or restrict cookies in your browser settings, although this may affect the proper functioning of certain Site features.
9. Your Rights as a Data Subject
Under Article 8 of the Law of Ukraine "On Personal Data Protection", you have the right to:
- Know the sources of collection — receive information about where your data was obtained, the purposes of its processing, its location, and the conditions for accessing it;
- Access your data — receive, free of charge and no more than once per calendar year, information about which of your data is being processed;
- Rectification — demand that your data be corrected or erased if it is processed unlawfully or is inaccurate;
- Object to processing — object to the processing of your personal data;
- Withdraw consent — withdraw previously given consent at any time; withdrawal does not affect the lawfulness of processing carried out before it;
- Protection from automated decisions — demand that decisions concerning you are not made solely on the basis of automated processing;
- Complain to the supervisory authority — lodge a complaint with the supervisory body (Section 10).
To exercise any of these rights, send a request to plishkastudio@gmail.com. We will consider your request within a reasonable time.
10. Supervisory Authority
The supervisory authority for personal data protection in Ukraine is the Ukrainian Parliament Commissioner for Human Rights (Ombudsman), who oversees compliance with personal data legislation pursuant to Law No. 383-VII of 3 July 2013.
If you believe that the processing of your personal data violates the law, you have the right to contact the Commissioner: ombudsman.gov.ua.
We encourage you to contact us directly first — we will do our best to resolve the matter promptly.
11. Changes to This Policy
We reserve the right to update this Policy. Changes take effect upon publication of the updated version on the Site. The date of the latest update is shown at the top of this page.
Upcoming legislative changes: The Verkhovna Rada of Ukraine is considering Draft Law No. 8153 "On Personal Data Protection", intended to align Ukrainian legislation with the GDPR. The bill passed its first reading on 20 November 2024 and is awaiting its second reading. Once in force, it will replace the current Law No. 2297-VI and may significantly expand data subjects' rights and liability for violations. We will update this Policy once the new law takes effect.
12. Contact
For any questions regarding this Policy or the processing of your personal data, please contact us:
Email: plishkastudio@gmail.com
Website: plishkastudio.com
Please also see our Terms of Use.