1. General provisions and scope
Under this Privacy Policy on the processing and protection of personal data (the “Policy”), FOP Herasymenko V.O., tax ID 3870701564 (the “Provider”), processes the personal data of individuals (“Users”) who buy and sell goods remotely in the online shop at https://www.platinummed.eu/ (the “Site”).
The Provider is the controller of Users' personal data. In this Policy, personal data means information, or a body of information, about an identified or identifiable individual.
Processing by the Provider includes, but is not limited to: collection, registration, accumulation, storage, adaptation, modification, updating, use and dissemination (distribution, transfer), anonymisation and destruction of personal data, including by means of automated systems.
Other terms carry the meanings given to them in the Law of Ukraine “On Personal Data Protection”.
By registering on the Site and starting to use the online shop, or by placing an order without registering, the User gives their voluntary and unambiguous consent to the processing of their personal data on the terms set out in this Policy, and confirms that they have read and understood it.
The Site may link to other websites for information only. This Policy does not extend to them. Before sending any data by which you can be identified, read the privacy policy of the site you have moved to.
The online shop may create individual User accounts — for convenient sign-in, faster ordering and payment.
Definitions
- “Online shop” — as defined by the Law of Ukraine “On Electronic Commerce”, a means of selling goods or services through an electronic sale-and-purchase transaction.
- “Site” — the online shop's software at https://www.platinummed.eu/, whose services Users access through a personal account over the internet.
- “Site administration” — the people the Provider has duly authorised to run the online service and serve the shop's Users.
- “Personal account” — the User's electronic account with a unique ID inside the Site's system.
- “Registration” — filling in the Site's forms so the Provider can create the account and give access to the Site's services.
- “Goods” — the cosmeceutical and medical products, accessories, components and related items listed in the online shop.
- “Provider”, “Commission agent” — FOP Herasymenko V.O. or their authorised representative, who sells the Goods in the shop in their own name but on the Principal's (Seller's) behalf and account, for a commission.
- “User” — the Seller or the Buyer of goods listed in the online shop.
- “Seller”, “Principal” — the person who has instructed the Provider to sell their goods in the shop on these terms.
- “Buyer” — the person who buys goods listed in the shop on these terms.
- “Partner” — a wholesale Buyer purchasing under these terms.
- “Medic” — a Buyer who is a medical or cosmetology professional, or a clinic, purchasing under these terms.
- “Order” — the selection of individual items from the product list for purchase.
- “Security payment” — money the User transfers to the Provider's bank account; it appears on the User's balance and, under art. 546(2) of the Civil Code of Ukraine, secures performance of their monetary obligations.
- “Balance” — the User's account balance and the information about it.
Where a term is not unambiguously defined here, the meaning given by Ukrainian law and by the Site applies.
2. What data is collected and where it comes from
The Provider may process: first name, surname, patronymic, phone number, email address, date of birth, whether the User has children, gender, interests, whether they have pets, whether they own a car and its VIN, preferred language, delivery address, social-network or platform accounts, and passport and tax-ID details.
The list is neither exhaustive nor mandatory: it depends on what the User chooses to provide and on what they do on the Site.
Most data comes directly from Users — at registration, in surveys, in conversation with the Site administration, or when paying (including instalments or credit). The Provider may also receive data from third parties through online platforms such as a Facebook, Google or Apple ID account.
Personal data also covers other information lawfully obtained from third parties or available from the User's social-network accounts where they sign in through a social authentication service. In that case the User consents to the processing of the information those accounts expose.
Users are responsible for everything they publish in public accounts and accept the risks of disclosing an address or precise location. Signing in through a third-party authentication service may give the Provider additional information that the third party has made available.
The Provider does not process special categories of data: racial or ethnic origin, political, religious or philosophical beliefs, party or trade-union membership, criminal convictions, health, sex life, or biometric and genetic data. Nor does it process data on physiological characteristics that could identify a User.
3. Why, on what basis and for how long data is processed
The Provider processes personal data for the following purposes:
- giving effect to civil, commercial and tax relations;
- performing the functions, powers and duties Ukrainian law places on the Provider;
- identifying the User;
- providing the sale, purchase and ordering services on the Site;
- processing payments and settlements, reporting, and financial and management accounting;
- creating and running loyalty programmes;
- offering financial services from the Provider's partners (banks and finance companies);
- building single sign-on across the Provider's partner platforms;
- improving the quality of the goods and services;
- ranking products and offers, analysing User activity, keyword search, managing traffic on the Site, and analysing and predicting preferences in order to make relevant personal or promotional offers;
- research and analytics;
- protecting the legitimate interests of the controller or of a third party the data is passed to;
- creating personalised accounts;
- sending information and marketing messages (offers, news, promotions, loyalty and bonus programmes, promo codes, discounts, personal recommendations) by post, email, phone, messenger or through the Site.
A User may opt out of information and marketing messages at any time.
The legal bases for processing are:
- concluding and performing the Public Offer agreement on the Site;
- compliance with a legal obligation of the Provider;
- the Provider's legitimate interests;
- the User's unambiguous consent, to the extent Ukrainian law requires it — in particular, at registration.
Data is processed only where at least one of these bases applies.
4. Where the data is held
Users' personal data is held in Ukraine.
5. Who has access
Access is granted only where the work requires it, to:
- the Site administration (managers);
- contractors providing services to the Provider — fulfilment, delivery, competitions and promotions;
- state, regulatory and law-enforcement bodies, as Ukrainian law requires.
6. Sharing data with third parties
The Provider may pass personal data to third parties, including foreign ones and affiliated companies, for the purposes set out in this Policy — for example to partners and contractors whose services support the business.
7. How the data is protected
The Provider applies organisational and technical safeguards at every stage of processing, in line with the Law of Ukraine “On Personal Data Protection”.
8. Your rights as a data subject
Under art. 8 of the Law of Ukraine “On Personal Data Protection”, a User has the right to:
- know the sources and location of their data, the purpose of processing and everything else the Law requires;
- be told on what terms access is granted, and to whom the data is passed;
- access their own data;
- receive, within thirty calendar days of a request unless the law says otherwise, an answer on whether their data is held, and its content;
- object to the processing with a reasoned demand to the controller;
- demand that any controller or processor correct or erase data that is unlawful or inaccurate;
- have their data protected from unlawful processing and accidental loss, destruction or damage, and from the release of inaccurate or defamatory information;
- complain to the relevant state authorities;
- seek legal remedies where data-protection law is breached;
- attach limits to their consent when giving it;
- withdraw consent;
- know how automated processing works;
- be protected from automated decisions that have legal effects for them.
9. Access requests
A User may obtain any information the Provider holds about them, free of charge. The request goes to the Site administration.
The request must state:
- the User's full name, place of residence and identity-document details;
- the name and other details identifying the person the request concerns;
- which data the request concerns, or which controller or processor;
- the list of data requested;
- the purpose and/or legal basis of the request.
The request is reviewed within 10 working days. Within that period the administration tells the User whether it will be granted or refused, with the ground for refusal. A granted request is fulfilled within 30 calendar days unless the law provides otherwise.
10. Deleting your data
A User can have their data deleted:
- by sending a written request to the Site administration;
- by deleting the data themselves from their account on the Site.
Data is also deleted where a court judgment to that effect takes legal force. When a User deletes data from their account, it is removed from the Site's systems automatically. Users may also delete the account itself from within it.
11. Withdrawing consent
A User may withdraw consent at any time by writing to the Site administration, which will review the request and remove the data from the shop's systems.
Withdrawal does not affect processing carried out beforehand, nor processing on another lawful basis.
12. Changes to this Policy
The Provider may update this Policy unilaterally from time to time. A User who disagrees with a future material change should stop using the Site. A new version takes effect when it is published on the Site.
Company details
- Trademark: PlatinumMed ™
- FOP Herasymenko V.O., tax ID 3870701564
- Office: 7 Dvorianska St., Odesa 65023, Ukraine
- IBAN: UA753348510000000026007272891, PUMB Bank, Odesa
- Phone: +380 (50) 568-12-46
- Email: platinummedod@gmail.com