• Home
  • Privacy and personal data protection policy

PRIVACY AND PERSONAL DATA PROTECTION POLICY

1. GENERAL PROVISIONS

1.1. This Privacy and Personal Data Protection Policy (hereinafter referred to as the "Policy") defines the procedure for the collection, processing, use, storage, disclosure, and protection of personal data of users of the website under the MILLORS brand (hereinafter referred to as the "Website"), and establishes the rights of personal data subjects and mechanisms for their implementation.

1.2. The controller of personal data is:

"MILLORS DEVELOPMENT" Limited Liability Company

USREOU/EDRPOU Code: 46153590

Registered Address: Office 32, Building 1/22, Akademika Filatova Street, Kyiv, 01042, Ukraine

Email: info@millors.expert

Phone: +38 095 597 83 77

(hereinafter referred to as the "Company").

1.3. The Policy is developed in accordance with the requirements of the legislation of Ukraine, in particular the Law of Ukraine "On Personal Data Protection", as well as taking into account generally recognized international standards in the field of personal data protection.

1.4. The Policy applies to all personal data that the Company receives:

1) directly from the Website users;

2) in the process of using the Website;

3) through communication channels (including email, telephone, instant messengers);

4) from third parties—in cases provided for by law.

1.5. By using the Website, filling out forms, sending requests, contacting the Company, or otherwise interacting with the Website, the User confirms that they:

1) have read and familiarized themselves with this Policy;

2) understand the scope and purpose of processing their personal data;

3) provide voluntary, specific, informed, and unambiguous consent to the processing of personal data within the limits defined by this Policy;

4) provide reliable, accurate, and complete personal data and bear responsibility for its relevance.

1.6. In cases where the consent of the User is required in accordance with the legislation, such consent is provided by performing an active action, in particular checking the corresponding box (checkbox), filling out a form, or sending a request.

1.7. If the User does not agree with the terms of this Policy, they must refrain from using the Website and from providing their personal data.

1.8. The Company processes personal data in compliance with the principles of legality, good faith, proportionality, data minimization, targeted use, and an appropriate level of protection.

2. COMPOSITION OF PERSONAL DATA

2.1. The Company processes the personal data of Users within the limits necessary to achieve the goals defined by this Policy, in compliance with the principle of data minimization.

2.2. Depending on the nature of the interaction with the Website, the Company may process the following categories of personal data:

1) Identification data:

  • first name, last name;

2) Contact data:

  • phone number;
  • email address;

3) Interaction and communication data:

  • the content of inquiries, applications, and messages;
  • information provided through forms on the Website;
  • the history of communication with the Company (including email, calls, instant messengers);

4) Data regarding real estate and investment requests:

  • type of request (including purchase, sale, rent, investment);
  • parameters of the property or investment;
  • budget or approximate volume of investments;
  • purposes of acquisition or investment (including residence, income generation, resale, etc.);
  • other information voluntarily provided by the User for the selection of relevant solutions;

5) Technical and behavioral data:

  • IP address;
  • cookie data;
  • device type, browser, and operating system;
  • data on activity on the Website (pages viewed, actions, session duration, etc.);

6) Data received from third parties:

  • information received from the Company's partners within the framework of the legislation;
  • data from public sources, if its use does not contradict the legislation.

2.3. The Company does not intentionally collect or process special categories of personal data (in particular, data on racial or ethnic origin, political, religious or other beliefs, health status, or biometric data), except in cases explicitly provided for by law.

2.4. All personal data is provided by the User voluntarily. The Company does not verify the reliability of the provided data, but assumes that the User provides accurate, complete, and relevant information.

2.5. The User has the right not to provide certain personal data, but in this case, some features of the Website or the ability to receive corresponding services may be limited or unavailable.

2.6. The Company has the right to clarify, update, or supplement the personal data of the User in cases where it is necessary to achieve the purpose of its processing or to fulfill obligations to the User.

3. SOURCES OF PERSONAL DATA OBTAINMENT

3.1. The Company receives personal data of Users from the following sources:

1) Directly from the User:

  • when filling out forms on the Website (applications for property selection, investment requests, requests for consultation, etc.);
  • during communication via email, phone, instant messengers, or other communication channels;
  • when subscribing to information or marketing materials;

2) In the process of using the Website:

  • automatically when visiting the Website using cookies and other technologies;
  • through analytical tools that record the User's interaction with the Website (page views, actions, time spent, etc.);

3) From third parties:

  • from the Company's partners (developers, property owners, investment projects, consultants), if the User has given consent to the transfer of their data or if such transfer is necessary to fulfill the User's request;
  • from analytics and advertising services that act as independent controllers or processors of personal data in accordance with their own privacy policies;

4) From open sources:

  • from public registers, public resources, or other open sources, if such processing does not contradict the legislation of Ukraine.

3.2. The Company does not intentionally collect personal data without the knowledge of the User, except in cases where such data is obtained automatically in the process of using the Website or is legally provided by third parties.

3.3. In the case of receiving personal data from third parties, the Company assumes that such persons have appropriate legal grounds for transferring the relevant data and have fulfilled the obligation to inform the personal data subject.

3.4. The Company takes reasonable measures to verify the legality of the sources of personal data, but is not responsible for the actions of third parties who transferred such data in violation of the legislation.

3.5. In case of obtaining personal data indirectly (not directly from the User), the Company ensures the processing of such data in accordance with this Policy and applicable legislation.

4. PURPOSE OF PERSONAL DATA PROCESSING

4.1. The Company processes personal data of Users exclusively for specified, legitimate, and justified purposes that correspond to the nature of the Company's activities and the expectations of Users.

4.2. Personal data is processed for the purpose of:

1) Providing services in the field of real estate and investments:

  • providing consultations;
  • selection of real estate properties;
  • formation of individual investment proposals;
  • organization of interaction between the User and the Company's partners;

2) Processing User requests:

  • processing of applications, inquiries, and messages;
  • providing feedback;
  • accompanying the User at all stages of interaction;

3) Ensuring the functioning of the Website:

  • administration of the Website;
  • ensuring technical stability and security;
  • prevention of unauthorized access and fraud;

4) Analytics and service improvement:

  • analysis of User behavior;
  • evaluation of the effectiveness of content and services;
  • optimization of user experience;

5) Personalization of interaction:

  • formation of personalized offers;
  • adaptation of content and recommendations in accordance with the interests of the User;

6) Marketing and information communications:

  • sending informational messages;
  • informing about new properties, investment opportunities, analytics;
  • implementation of promotional and marketing activities;

7) Fulfillment of contractual and pre-contractual obligations:

  • preparation for the conclusion of contracts;
  • transaction support;
  • fulfillment of obligations to the User;

8) Compliance with statutory requirements:

  • record keeping;
  • fulfillment of requirements of state authorities;
  • compliance with regulatory legal acts;

9) Protection of rights and legitimate interests of the Company:

  • in the event of disputes;
  • to ensure legal protection.

4.3. The Company does not process personal data for purposes incompatible with those specified in this Policy.

4.4. In case of a change in the purpose of processing personal data, the Company ensures obtaining additional consent from the User, if provided for by law.

4.5. The scope and nature of personal data processing correspond to the stated purposes and are not excessive in relation to such purposes.

5. LEGAL GROUNDS FOR PERSONAL DATA PROCESSING

5.1. The processing of personal data of Users is carried out by the Company on legal grounds in accordance with the requirements of the legislation of Ukraine, as well as taking into account generally recognized international standards in the field of personal data protection.

5.2. The Company processes personal data on the following legal grounds:

1) Consent of the User:

  • in cases where the User voluntarily provides personal data through forms on the Website, subscribes to informational or marketing materials, or otherwise confirms consent to its processing;

2) Necessity of concluding and executing a contract:

  • for the implementation of pre-contractual measures at the request of the User;
  • for the preparation and support of transactions in the field of real estate and investments;

3) Legitimate interests of the Company:

  • to ensure the effective functioning of the Website;
  • for the development and improvement of services;
  • to analyze the interaction of Users with the Website;
  • to protect the rights and legitimate interests of the Company;

4) Compliance with statutory requirements:

  • in cases where the processing of personal data is necessary for the fulfillment of duties imposed on the Company by the legislation of Ukraine.

5.3. In cases where the processing of personal data is carried out on the basis of the User's consent, such consent can be withdrawn by the User at any time by contacting the Company or using the corresponding functionality of the Website.

5.4. Withdrawal of consent does not affect the lawfulness of personal data processing carried out prior to its withdrawal.

5.5. The Company ensures that each operation of processing personal data has a proper legal basis and is carried out within the limits necessary to achieve the corresponding purpose.

6. TRANSFER OF PERSONAL DATA TO THIRD PARTIES

6.1. The Company may transfer personal data of Users to third parties exclusively in cases where such transfer is necessary to achieve the goals defined by this Policy, and subject to compliance with the requirements of the legislation.

6.2. Personal data may be transferred to the following categories of third parties:

1) Partners in the field of real estate and investments:

  • developers;
  • real estate property owners;
  • investment projects;
  • brokers, consultants, and other market participants;

exclusively for the purpose of:

  • processing the User's request;
  • selection of relevant properties or investment opportunities;
  • organization of interaction between the User and the relevant partner;

2) Professional advisors:

  • legal;
  • tax;
  • financial consultants;

exclusively within the limits necessary for the provision of relevant services to the Company;

3) Technical and IT service providers:

  • hosting providers;
  • CRM systems;
  • data analytics and processing services;

exclusively within the limits necessary for the provision of relevant services to the Company;

4) Marketing and advertising partners:

  • digital advertising services;
  • analytics and remarketing platforms;

subject to the provision of the corresponding consent by the User;

5) State authorities and authorized institutions:

  • in cases provided for by the legislation of Ukraine or on the basis of mandatory requirements.

6.3. The transfer of personal data to the partners specified in clause 6.2.1 is carried out:

1) within the limits necessary to process a specific request of the User;

2) at the initiative of the User or in connection with their inquiry;

3) on the condition that the User reasonably expects such transfer or has provided the corresponding consent.

6.4. The Company does not transfer personal data to third parties for their independent use for marketing purposes without the separate consent of the User.

6.5. All third parties to whom personal data is transferred are obliged to:

  • ensure the confidentiality of the received information;
  • use personal data exclusively for the purpose for which it was transferred;
  • comply with the requirements of the legislation on personal data protection.

6.6. The Company takes reasonable measures to verify the reliability of third parties, but is not responsible for the subsequent processing of personal data by such persons if it is carried out outside the control of the Company or in violation of the terms of this Policy.

6.7. In cases where third parties act as independent controllers of personal data, its processing is carried out in accordance with their own privacy policies, with which the User has the opportunity to familiarize themselves independently.

7. CROSS-BORDER TRANSFER OF PERSONAL DATA

7.1. Within the scope of its activities, the Company may transfer personal data of Users outside of Ukraine, in particular to foreign jurisdictions, including member states of the European Union and other countries.

7.2. Such transfer may be carried out, in particular, in cases of:

1) interaction with foreign partners in the field of real estate and investments;

2) use of international IT services, cloud solutions, CRM systems, and analytical platforms;

3) provision of services to Users located outside of Ukraine;

4) organization of international communication or support of investment projects.

7.3. Cross-border transfer of personal data is carried out:

1) in the presence of legal grounds defined by this Policy;

2) within the limits of the purposes of personal data processing;

3) in compliance with the principle of minimizing the volume of transferred data.

7.4. The User, by accepting the terms of this Policy, provides their explicit, informed, and unambiguous consent to the cross-border transfer of their personal data, confirming their understanding of the potential risks associated with such transfer, including to jurisdictions that may not provide a level of personal data protection equivalent to the level established by the legislation of Ukraine.

7.5. In cases of cross-border transfer, the Company takes reasonable and appropriate measures to ensure the protection of personal data, in particular:

1) selects counterparties that comply with personal data protection standards;

2) concludes corresponding contracts or other legal mechanisms providing for confidentiality obligations;

3) applies technical and organizational security measures.

7.6. The Company is not responsible for the level of personal data protection in the jurisdictions of third countries, but makes reasonable efforts to minimize the risks associated with such transfer.

8. PROFILING AND PERSONALIZATION

8.1. In order to improve the quality of service provision and ensure the most relevant interaction with Users, the Company may process personal data by analyzing, summarizing, and evaluating it (hereinafter referred to as "profiling").

8.2. Profiling may include, in particular:

1) analysis of information provided by the User in requests and forms on the Website;

2) evaluation of parameters related to the User's request, in particular the budget, investment goals, property type, or other criteria;

3) analysis of the User's behavior on the Website, including pages viewed, interaction with content, and other actions;

4) summarizing information obtained in the process of communication with the User.

8.3. Profiling is carried out exclusively for the purpose of:

1) selection of real estate properties that meet the request of the User;

2) formation of individual investment proposals;

3) personalization of communication and interaction with the User;

4) increasing the efficiency of the Company's services.

8.4. Profiling does not involve automated decision-making that has legal consequences for the User or otherwise significantly affects their rights and legitimate interests.

8.5. Profiling is carried out:

1) within the limits of the goals defined by this Policy;

2) based on the legal grounds provided for in Section 5 of this Policy;

3) in compliance with the principles of proportionality, minimization, and purpose limitation;

4) with the application of appropriate technical and organizational measures to protect personal data.

8.6. The User has the right to:

1) receive information regarding the implementation of profiling;

2) object to the processing of personal data through profiling in cases provided for by law;

3) contact the Company with a requirement to restrict such processing.

9. COOKIES AND ANALYTICS

9.1. The Website uses cookies and other similar technologies to ensure proper functioning, analytics, personalization of user experience, and implementation of marketing communications.

9.2. Cookies are small text files stored on the User's device when visiting the Website, allowing the Website to recognize the User's device, save their settings, and record interaction with the Website.

9.3. The Company uses the following categories of cookies:

1) Necessary (technical) cookies:

  • required for the functioning of the Website;
  • provide basic capabilities (navigation, access to functionality);
  • cannot be disabled, because without them the Website does not work correctly;

2) Analytical cookies:

  • used to collect statistical data regarding the use of the Website;
  • allow analyzing the behavior of Users;
  • contribute to the improvement of the Website's functionality;

3) Functional cookies:

  • ensure remembering the settings of the User;
  • allow personalizing interaction with the Website;

4) Marketing cookies:

  • used to display personalized advertising;
  • applied for remarketing;
  • allow evaluating the effectiveness of advertising campaigns.

9.4. Third-party analytics and advertising services may be used on the Website, including, but not limited to:

  • Google Analytics
  • Meta Pixel

as well as other similar tools.

9.5. Necessary cookies are used without obtaining the separate consent of the User, as they are technically required for the functioning of the Website.

9.6. Analytical, functional, and marketing cookies are used exclusively under the condition of providing prior consent by the User, in particular by:

1) confirming the relevant request (cookie banner);

2) choosing cookie settings.

9.7. The User has the right to:

1) provide or withdraw consent to the use of cookies;

2) change cookie settings in their browser;

3) restrict or prohibit the storage of cookies;

4) delete previously saved cookies.

9.8. Restricting or disabling certain categories of cookies may affect the availability or correctness of certain functions of the Website.

9.9. Third-party services used on the Website may independently process User data in accordance with their own privacy policies, for which the Company is not responsible.

9.10. Detailed terms of cookie usage may be defined in a separate Cookie Policy published on the Website.

10. MARKETING COMMUNICATIONS

10.1. The Company may implement marketing and information communications with the User for the purpose of informing about services, real estate properties, investment opportunities, analytical materials, and other proposals that may be relevant to the User.

10.2. Marketing communications can be carried out through:

1) email (email newsletters);

2) phone calls;

3) messages in instant messengers (in particular, Telegram, Viber, WhatsApp or others);

4) other communication channels provided by the User.

10.3. Sending marketing and informational messages is carried out exclusively under the condition of providing prior consent by the User, except in cases explicitly provided for by law.

10.4. Providing consent to receive marketing communications can be carried out, in particular, by:

1) checking the corresponding box (checkbox) in forms on the Website;

2) subscribing to newsletters;

3) providing consent through other interfaces of the Website or communication channels.

10.5. The Company has the right to personalize marketing messages taking into account information about the User, in particular their requests, interests, and interaction with the Website, in the manner defined by this Policy.

10.6. The User has the right at any time to refuse to receive marketing communications by:

1) clicking on the link to unsubscribe in the corresponding message;

2) changing the communication settings (if such functionality is available);

3) sending a corresponding request to the Company at the contact details specified in this Policy.

10.7. Refusal of the User to receive marketing communications does not affect the receipt by the User of informational messages that are necessary for processing their requests or providing services.

10.8. The Company takes reasonable measures to ensure that marketing communications are relevant, appropriate, and do not violate the rights of Users.

11. PROTECTION OF PERSONAL DATA

11.1. The Company considers the protection of personal data as one of the key elements of its activities and ensures its processing in compliance with high standards of information security, confidentiality, and data integrity.

11.2. The Company implements a comprehensive personal data protection system, which includes technical, organizational, and legal measures aimed at preventing:

1) unauthorized access to personal data;

2) accidental or unlawful loss, destruction, or damage of information;

3) illegal disclosure or distribution of personal data;

4) any other forms of improper processing of personal data.

11.3. In particular, the Company applies the following protection measures:

1) use of modern cryptographic protocols (SSL/TLS) to protect data during transmission;

2) restriction of access to personal data based on the principle of need-to-know;

3) authentication and access control to information systems;

4) access segmentation and monitoring of user actions in systems;

5) use of secure infrastructure with an appropriate level of physical and network protection;

6) regular risk assessment and updating of security measures;

7) implementation of internal policies and procedures for personal data processing.

11.4. Employees and persons engaged by the Company who have access to personal data:

1) are obliged to respect the regime of confidentiality;

2) undergo appropriate briefings or training;

3) bear responsibility for violating the requirements for personal data protection in accordance with the legislation and internal documents of the Company.

11.5. In case of involving third parties in the processing of personal data, the Company ensures the conclusion of contracts or other legal mechanisms providing for an appropriate level of personal data protection, including obligations regarding confidentiality, security, and limitation of processing purposes.

11.6. The Company implements response procedures for information security incidents, including:

1) detection and recording of incidents;

2) limitation of their consequences;

3) data integrity restoration;

4) analysis of causes and prevention of recurrence.

11.7. Despite the use of modern security tools, data transmission over the Internet cannot be completely secure from all risks. The Company does not guarantee absolute security of data transmission, but takes all reasonable and appropriate measures to protect it.

12. PERIOD OF PERSONAL DATA STORAGE

12.1. The Company stores the personal data of Users no longer than is necessary to achieve the goals of its processing defined by this Policy, unless otherwise provided by the legislation of Ukraine.

12.2. Depending on the category of data and the purposes of its processing, personal data is stored for the following periods:

1) Data provided in requests and forms:

  • during the period of processing the relevant request and subsequent interaction with the User;
  • but no more than 3 (three) years from the moment of the last active interaction, unless otherwise specified by the nature of the request;

2) Data for communication and support:

  • during the period of actual interaction with the User;
  • and additionally within a reasonable period to ensure service continuity;

3) Data used for marketing communications:

  • until the moment of withdrawal of consent by the User to its processing;
  • or until the moment of termination of the relevant activity by the Company;

4) Data necessary for the fulfillment of legislative obligations:

  • within the time limits established by the legislation of Ukraine (in particular, in the field of accounting, taxation, and financial control);

5) Data related to potential disputes or protection of rights:

  • during the limitation period or until the full settlement of the relevant dispute.

12.3. After achieving the purpose of processing or expiration of the storage period, personal data is subject to:

1) erasure;

2) anonymization;

3) or subsequent storage exclusively in cases provided for by law.

12.4. The Company carries out a periodic review of personal data for the purpose of:

1) removing outdated or irrelevant information;

2) ensuring compliance of the data volume with the stated processing purposes.

12.5. In case of withdrawal of consent by the User to the processing of personal data, the Company terminates its processing and ensures its erasure, except in cases where further processing is necessary in accordance with the requirements of the legislation or to protect the legitimate interests of the Company.

13. RIGHTS OF THE USER

13.1. The User as a personal data subject has the rights provided for by the legislation of Ukraine in the field of personal data protection, as well as generally recognized international standards in this field.

13.2. In particular, the User has the right to:

1) Right to information:

  • know about the sources of collection of their personal data;
  • receive information about the composition of personal data being processed;
  • know the purpose of personal data processing and the legal grounds for such processing;

2) Right to access:

  • receive confirmation of the fact of processing their personal data;
  • gain access to such data;

3) Right to rectification:

  • demand the rectification of inaccurate or outdated personal data;
  • demand the supplementation of incomplete personal data;

4) Right to erasure (Right to be forgotten):

  • demand the erasure of personal data in cases provided for by law;
  • in particular, if the data is no longer necessary to achieve the purpose of its processing or is processed unlawfully;

5) Right to withdraw consent:

  • at any moment withdraw the provided consent to the processing of personal data;

6) Right to restriction of processing:

  • demand the restriction of personal data processing in cases provided for by law;

7) Right to object:

  • object to the processing of personal data, in particular for direct marketing or profiling purposes;

8) Right to protection:

  • file complaints with the authorized body for personal data protection;
  • appeal to the court to protect their rights and legitimate interests.

13.3. The implementation of the User's rights is carried out by sending a corresponding request to the Company at the contact details specified in this Policy.

13.4. The Company considers User requests within the timeframes provided for by the legislation of Ukraine, but in any case no later than within 30 (thirty) calendar days from the moment of receiving the request, unless otherwise provided by law.

13.5. If necessary, the Company has the right to request additional information to identify the User in order to prevent unauthorized access to personal data.

13.6. The implementation of certain rights of the User may be limited in cases provided for by the legislation of Ukraine, in particular if the processing of personal data is necessary for the performance of legal obligations or the protection of legitimate interests of the Company.

14. USER REQUESTS AND ERASURE OF PERSONAL DATA

14.1. The User has the right to contact the Company with a request regarding the implementation of their rights provided for by this Policy and the legislation of Ukraine, in particular regarding access to personal data, its rectification, updating, restriction of processing, or erasure.

14.2. A User request can be submitted:

1) by sending an electronic message to the address: info@millors.expert;

2) by other means of communication specified in this Policy, if it allows proper identification of the User.

14.3. In the request, the User must state:

1) last name, first name (and, if any, patronymic);

2) contact data allowing identification of the User;

3) the essence of the request;

4) other information necessary for its consideration (if available).

14.4. The Company has the right to request additional information or documents from the User necessary to confirm the identity, in order to prevent unauthorized access to personal data.

14.5. User requests are considered by the Company within the timeframes provided for by the legislation of Ukraine, but in any case no later than within 30 (thirty) calendar days from the moment of receiving the request, unless otherwise provided by law.

14.6. Based on the results of the request consideration, the Company:

1) provides a response on the merits of the request;

2) takes necessary measures to implement the User's rights;

3) or provides a reasoned refusal in cases provided for by law.

14.7. Erasure of personal data is carried out in cases of:

1) withdrawal of consent by the User to the processing of personal data;

2) achievement of the purpose of personal data processing;

3) detection of unlawful processing;

4) in other cases provided for by the legislation of Ukraine.

14.8. The Company has the right to refuse to erase personal data or restrict its erasure in cases when:

1) processing of such data is necessary to comply with the requirements of the legislation;

2) data is necessary for the protection of rights and legitimate interests of the Company;

3) there are other legal grounds for further processing.

14.9. In case of satisfaction of the request for erasure of personal data, the Company takes measures to erase or anonymize it within a reasonable period, unless otherwise provided by law or technical features of processing.

14.10. The Company ensures proper recording of User requests and measures taken based on the results of their consideration.

15. DATA OF THIRD PARTIES

15.1. In cases where the User provides the Company with personal data of third parties (in particular co-investors, representatives, contact persons, recipients of information, or other related persons), the User guarantees that they:

1) have appropriate legal grounds for transferring such personal data;

2) have obtained the consent of the respective persons to transfer their personal data to the Company, if such consent is necessary;

3) have properly notified such persons about the transfer of their personal data and the conditions of its processing.

15.2. The User bears responsibility for the legality of transferring personal data of third parties, as well as for compliance with the rights of such persons in accordance with the requirements of the legislation.

15.3. The Company processes personal data of third parties received from the User exclusively:

1) within the limits of the goals defined by this Policy;

2) in the volume necessary to process the relevant request or provide services.

15.4. The Company is not obliged to verify whether the User has legal grounds for transferring personal data of third parties, but has the right to demand confirmation of such grounds in case of reasonable doubts.

15.5. In case of appeals by third parties regarding the processing of their personal data received from the User, the Company carries out the consideration of such appeals in accordance with the provisions of this Policy and the requirements of the legislation.

16. AMENDMENTS TO THE POLICY

16.1. The Company has the right at any time to make changes and/or additions to this Policy, taking into account changes in legislation, personal data processing practices, technology development, or business processes of the Company.

16.2. The current edition of the Policy is always available on the Website and comes into force from the moment of its publication, unless explicitly provided otherwise by the relevant edition.

16.3. In case of making material changes that may affect the scope of the User's rights or the procedure for processing personal data, the Company may additionally notify the User by accessible methods, including through the Website or electronic means of communication.

16.4. Continued use of the Website after the entry into force of a new edition of the Policy is considered confirmation of the User's familiarization with such changes and acceptance of their terms.

16.5. In case of disagreement with the changes made, the User must stop using the Website and, if necessary, contact the Company with a demand to terminate the processing of their personal data.

17. LIMITATION OF LIABILITY

17.1. The Company is responsible for processing personal data of Users within the limits defined by this Policy and the legislation of Ukraine.

17.2. The Company is not liable for any losses, damages, or other consequences arising from:

1) provision by the User of unreliable, inaccurate, or outdated personal data;

2) actions or omissions of third parties who are not under the control of the Company;

3) unauthorized access to personal data that occurred due to circumstances beyond the reasonable control of the Company;

4) the User's use of third-party services, platforms, or resources, access to which can be carried out through the Website.

17.3. The Company is not liable for the processing of personal data of the User by third parties who are independent controllers of personal data and carry out such processing in accordance with their own privacy policies.

17.4. The Company does not guarantee continuous, error-free, or fully secure operation of the Website, but makes all reasonable efforts to ensure its proper functioning and security.

17.5. Limitations of liability provided for in this section apply to the maximum extent permitted by the legislation of Ukraine.

17.6. Nothing in this Policy limits the liability of the Company in cases where such limitation is explicitly prohibited by law.

18. CONTACT INFORMATION

18.1. For questions related to the processing of personal data, implementation of the User's rights, or the application of this Policy, the User can contact the Company using the following contact details:

  • Entity: "MILLORS DEVELOPMENT" Limited Liability Company
  • Email: info@millors.expert
  • Phone: +38 095 597 83 77

18.2. The Company ensures the consideration of User inquiries within a reasonable timeframe and within the limits provided for by the legislation of Ukraine.

18.3. If necessary, the User can contact the Company regarding any issues concerning the processing of their personal data, and the Company, within its competence, ensures the provision of relevant information or explanations.