Privacy and Cookie Policy

1. General Provisions

1.1. This Privacy and Cookie Policy (the “Policy”) governs the processing and protection of personal data of visitors to the website serviceenergysolutions.com, including its English version at serviceenergysolutions.com/en/ (the “Website”).

1.2. The controller (owner) of personal data is Limited Liability Company “SERVISNI ENERHETYCHNI RISHENNIA” (Service Energy Solutions), EDRPOU code 45271117, registered office: 18th km of Boryspilske Highway, Kyiv, 02121, Ukraine (the “Company”, “we”).

1.3. Contact for personal data matters: e-mail a.pylypchuk@serviceenergysolutions.com, tel. +38 (093) 253 26 23.

1.4. The Policy is drawn up in accordance with the Law of Ukraine “On Personal Data Protection” No. 2297-VI dated 1 June 2010 (the “Law”), the Law of Ukraine “On Electronic Commerce” and other applicable legislation of Ukraine. Section 10 of this Policy additionally applies to visitors located in the European Economic Area or the United Kingdom.

1.5. The terms “personal data”, “processing”, “controller”, “processor”, “data subject's consent” and others are used as defined in the Law.

1.6. By using the Website and/or submitting the contact form, you confirm that you have read this Policy. The Policy does not cover third-party websites that may be linked from the Website.

1.7. The Website is intended for a business (B2B) audience and is not directed at persons under 18; we do not knowingly collect children's personal data.

2. Personal Data We Collect

2.1. Contact form data (provided by you): name; company name; e-mail address; phone number; subject of inquiry (selected from the list of services); project description / message text.

2.2. Cookie and analytics data (only with your consent): anonymised statistics on Website visits collected by Google Analytics 4 (see Section 4).

2.3. Server log data (collected automatically): IP address, browser and device type (user-agent), date and time of the request, URLs of the requested pages.

2.4. The Website does not provide user accounts, does not accept online payments and does not collect payment data; localStorage / sessionStorage technologies are not used to store personal data; no third-party advertising trackers are installed; no profiling or automated decision-making concerning data subjects is carried out.

3. Purposes and Legal Grounds of Processing

3.1. We process personal data for the following purposes and on the following grounds:

3.2. Providing data in the contact form is voluntary; without it, we will not be able to handle your inquiry.

4. Cookies

4.1. Cookies are small text files stored in your browser when you visit the Website.

4.2. The Website uses the following cookies:

4.3. Analytics cookies (Google Analytics 4 via Google Tag Manager) are not technically loaded or set until you click “Accept” in the cookie banner. If you click “Decline”, only the strictly necessary ses-consent cookie recording your refusal is set; analytics is not activated. By default, Google Analytics 4 does not log or store visitors' IP addresses.

4.4. You can change your earlier choice by deleting cookies for the Website in your browser settings (the banner will reappear on your next visit) or via the “Cookie settings” link in the Website footer.

4.5. You may block cookies in your browser settings; this will not restrict access to the Website content, although the strictly necessary cookie is required to remember your choice. To opt out of Google Analytics specifically, the official browser add-on is available at tools.google.com/dlpage/gaoptout.

5. Disclosure to Third Parties. Cross-Border Transfers

5.1. We do not sell personal data and do not share it with third parties for their own marketing purposes.

5.2. For the technical operation of the Website, personal data is processed by the following processors: (a) Netlify Inc. (USA) — Website hosting, processing of the contact form (Netlify Forms), server logs; (b) Google LLC (USA) — delivery of copies of form submissions to the corporate mailbox (Gmail) and, subject to your consent, web analytics (Google Analytics 4, Google Tag Manager).

5.3. These providers are located in the United States of America, a country not included in the list of states ensuring adequate protection of personal data within the meaning of Art. 29 of the Law. The cross-border transfer is carried out on the basis of your unambiguous consent (para. 1, part 3, Art. 29 of the Law), which you give: for the form data — by ticking the consent checkbox in the form; for the analytics data — by clicking “Accept” in the cookie banner.

5.4. In addition, both providers are bound by data processing agreements (DPA): the agreement with Netlify Inc. incorporates the EU Standard Contractual Clauses (SCC), and Google LLC is certified under the EU–U.S. Data Privacy Framework.

5.5. Personal data may be disclosed to competent state authorities only in the cases and in the manner provided for by law.

6. Retention Periods

6.1. Contact form data is kept for 3 (three) years from receipt of the inquiry (with regard to the general limitation period under Art. 257 of the Civil Code of Ukraine) or until you withdraw your consent, whichever occurs earlier. If a contract is concluded as a result of the inquiry, the data is kept for the term of the contract and the statutory retention periods for the relevant documents.

6.2. The ses-consent cookie — 180 days; Google Analytics cookies (_ga, _ga_*) — up to 2 years. Data in Google Analytics 4 — 14 months (the retention period configured at the service level).

6.3. Server logs are kept short-term in accordance with the policy of Netlify Inc.

6.4. Upon expiry of the above periods, personal data is deleted or anonymised.

7. Rights of the Data Subject

7.1. Under Art. 8 of the Law, you have the right: to know the sources of collection and the location of your personal data, the purposes of its processing and the location of the controller; to receive information on the conditions of access to personal data; to access your personal data; to receive, within thirty calendar days of the request, a reply as to whether your personal data is being processed, as well as the content of such data; to submit a reasoned objection to the processing of your personal data; to submit a reasoned request to change or destroy your personal data if it is processed unlawfully or is inaccurate; to protection of your personal data from unlawful processing and from failure to provide information; to file complaints about the processing of your personal data with the Ukrainian Parliament Commissioner for Human Rights (ombudsman.gov.ua) or with a court; to use legal remedies in the event of a breach of personal data protection legislation; to enter reservations limiting the right to process your personal data when giving consent; to withdraw your consent to the processing of personal data; to know the mechanism of automated processing of personal data; to protection from an automated decision that has legal effects on you.

7.2. To exercise your rights, send a request to the contacts specified in clause 1.3. A reply is provided within the time limits established by the Law. Withdrawal of consent does not affect the lawfulness of the processing carried out before the withdrawal.

8. Data Security

8.1. The Company applies organisational and technical safeguards, in particular: the connection to the Website is protected by HTTPS (TLS); access to submissions is limited to authorised Company employees within their duties; the data-minimisation principle is applied — only the data necessary to handle the inquiry is collected; data processing agreements are in place with the processors; in the event of a security incident posing a risk to data subjects' rights, the Company will act as required by law.

9. Personalised Advertising

9.1. As of the date of this version, the Website does not use advertising cookies or remarketing technologies (Meta Pixel and other advertising pixels are not installed).

9.2. The Company may use Google Ads to place advertising on the Google network. If remarketing or personalised advertising is enabled in the future, third-party vendors, including Google, will use advertising cookies to serve ads based on your previous visits to the Website; this will be communicated by updating this Policy and the cookie banner.

9.3. You may opt out of personalised advertising by Google at any time in Google Ads Settings: adssettings.google.com. Additional opt-out tools for third-party vendors: www.youronlinechoices.com, optout.aboutads.info.

10. Provisions for Users in the EEA and the United Kingdom (GDPR / UK GDPR)

10.1. If you are located in the European Economic Area or the United Kingdom, Regulation (EU) 2016/679 (GDPR) or the UK GDPR, respectively, additionally applies to the processing of your personal data.

10.2. Legal bases for processing: Art. 6(1)(a) GDPR — consent (contact form, analytics cookies); Art. 6(1)(b) — steps taken at your request prior to entering into a contract (handling your inquiry); Art. 6(1)(f) — legitimate interests (Website security, server logs).

10.3. You have the rights provided for by Arts. 15–22 GDPR: access, rectification, erasure (the “right to be forgotten”), restriction of processing, data portability, objection, withdrawal of consent, as well as the right to lodge a complaint with the supervisory authority of your country.

10.4. Transfers of data to the USA are based on the EU Standard Contractual Clauses (SCC) and/or the recipient's certification under the EU–U.S. Data Privacy Framework.

10.5. Analytics cookies are set only after your prior consent, in line with Directive 2002/58/EC (ePrivacy).

11. Final Provisions

11.1. We may update this Policy from time to time. The new version is published on this page with its date indicated; material changes will additionally be announced on the Website.

11.2. This Policy is made in Ukrainian and English. In the event of any discrepancies, the Ukrainian version shall prevail.

11.3. Questions regarding this Policy and personal data processing: a.pylypchuk@serviceenergysolutions.com, tel. +38 (093) 253 26 23; postal address: 18th km of Boryspilske Highway, Kyiv, 02121, Ukraine.

Version 1.0. Effective date: 12 June 2026.