Privacy Policy

This Privacy Policy has been developed in accordance with the requirements of the Law of Ukraine "On Personal Data Protection" and other regulatory acts of Ukrainian legislation governing legal relations related to the collection, processing, and storage of personal data, as well as the right of citizens to privacy and the right to self-expression. It has also been developed in compliance with European legislation, specifically the General Data Protection Regulation (GDPR; Regulation (EU) 2016/679).

1. Definitions

1.1. This Privacy Policy uses the following terms:

1.1.1. “Underwood Metal” – individual entrepreneur Mykola Mykhailovych Semeniuk, TIN: 2526811071, who is the owner of the online store “Underwood Metal” and engages in the sale of goods or services.

1.1.2. “Administration of the Underwood Metal online store website” (hereinafter referred to as the “Website Administration”) – authorized persons responsible for managing the website on behalf of the Underwood Metal online store, who organize the processing and collection of personal data, as well as determine the purposes of personal data processing, the composition of personal data to be processed and collected, and the actions or operations performed with personal data.

1.1.3. “Underwood Metal” online store – an online platform on the Internet, available at https://underwoodmetal.com.ua, where the User can purchase goods or services from “Underwood Metal”.

1.1.4. “Personal data” – any information that directly or indirectly relates to a specific or identifiable individual (subject of personal data), including the User of the website.

1.1.5. “Processing of personal data” – any action (operation) or a set of actions (operations) performed with or without the use of automation tools on personal data, including: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of the User's personal data.

1.1.6. “Confidentiality of personal data” – a mandatory requirement to prevent the dissemination of a subject’s (User’s) personal data without the individual’s personal consent or another legal basis, which is adhered to by the Website Administration or other persons who have access to personal data.

1.1.7. “User of the Underwood Metal online store website” or “User” – an individual who can be identified directly or indirectly, in particular by an identifier such as a name, identification number, location data, online identifier, or by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that individual (Article 4, Clause 1 of the GDPR). A User is also a person who purchases goods or services from “Underwood Metal” or simply visits the “Underwood Metal” online store.

1.1.8. “Cookie” – a small piece of data sent by a web server and stored on the user's computer, which a web client or web browser sends back to the web server in an HTTP request each time it attempts to open a page of the corresponding website.

1.1.9. “IP address” – a unique network address of a node in a computer network built using the IP protocol.

2. Subject of the Privacy Policy

2.1. By using the website or purchasing a product or service offered in the “Underwood Metal” online store, the User confirms their consent to “Underwood Metal,” the Website Administration, and its authorized persons for the collection and processing of personal data.

2.2. The User consents to the Website Administration and “Underwood Metal” processing the received information, including collection, systematization, accumulation, storage, clarification (updating, correction), use, distribution, anonymization, blocking, and destruction of personal data specified in the questionnaire. This is done for the purpose of creating a database of participants, compiling statistical reports, conducting marketing research, and interacting with the User, including through telecommunication networks, such as sending SMS messages and emails, until such consent is revoked.

2.3. The User confirms their consent that the Website Administration and “Underwood Metal” have the right to interact with the User through direct contact using various means of communication, including but not limited to: postal mail, email, the Internet, and others.

2.4. Personal data permitted for processing and collection under this Privacy Policy include, but are not limited to, the following information:

2.4.1. Client data (individual User):

first name and/or last name;
email address;
phone number;
company name;
organization number and address;
delivery address;
link to the individual’s social media profile;
IP address.

2.4.2. Transaction data:

payment information from the individual (User) and other details about services or goods ordered from the “Underwood Metal” online store.

2.4.3. Financial data:

information about the bank account, credit or debit card, account and invoice details, payment methods.

2.4.4. Contact data:

information or records created as a result of contact with “Underwood Metal” or the Website Administration. This may include phone conversations, online interactions, email communications, physical mail, or messaging apps such as Viber, Telegram, WhatsApp, and others.

2.4.5. Technical data:

IP address, date and time of request, request content, access status/HTTP status code, referring website, browser, operating system and its interface, language, and browser software version.

2.5. During any communication between the User and “Underwood Metal” or the Website Administration, the latter reserves the right to record conversations with the User or store any communication data between the User and “Underwood Metal” or the Website Administration to improve service quality.

3. Cookie Policy

3.1. “Underwood Metal” and the Website Administration collect information about the User’s visits to the “Underwood Metal” online store to gather visit statistics, assess efficiency, create a personalized experience, and adapt to each User’s interests. The Website Administration and “Underwood Metal” use various technologies to achieve this, one of which is cookies. These are data files that a website can send to a browser, which are then stored on the User’s computer for future identification by the website.

3.2. Cookies are used to evaluate website performance (e.g., measuring the number of visitors and the duration of their stay on the “Underwood Metal” online store), identify the most interesting and frequently visited topics and pages, and enhance navigation and usability without collecting any personal information. Cookies may also be used to create a personalized experience based on the User’s or any other person’s past interactions with the “Underwood Metal” online store and their preferences. Over time, this information helps improve the overall user experience.

3.3. Cookies are text files sent by the “Underwood Metal” online store to the User’s device, allowing for the improvement of the “Underwood Metal” online store website. Cookies are unique to the User’s account or browser.

3.4. The User will be notified about the use of cookies during their first visit to the “Underwood Metal” online store website. If the User objects to the collection of information through cookies, they can adjust their preferences at any time through the Cookie Settings Center.

3.5. Browsers provide Users with the ability to manage cookies according to their preferences. The User can manage and/or delete, restrict, or block cookies from the website at any time by modifying the browser settings. If the User does not wish to use cookies on the “Underwood Metal” online store website, they should first disable cookies in their browser.

3.6. Through browser settings, the User can choose which cookies to accept and which to reject. These settings depend on the browser the User is using:

If the User decides to block certain functional cookies, some services of “Underwood Metal” may become unavailable. In addition to settings available on the “Underwood Metal” online store website, the User may opt out of specific cookies.

4. Collection and Use of Personal Data

4.1. “Underwood Metal” and the Website Administration collect personal data in the following cases:

when the User visits the “Underwood Metal” online store website;
when the User fills out contact forms on the “Underwood Metal” online store website;
when the User subscribes to a newsletter available on the “Underwood Metal” online store website;
when the User contacts “Underwood Metal” or the Website Administration by phone, including via messengers, email, live chat on the website, or social media;
“Underwood Metal” and the Website Administration may receive personal data when the User clicks on social media buttons such as “Like,” “Follow,” or interacts with official “Underwood Metal” pages on Facebook, LinkedIn, Instagram, and other platforms.

5. Purpose of Collecting and Processing Personal Data

5.1. The “Underwood Metal” online store and the Website Administration use the User's personal information for the following purposes:

5.1.1. Contractual Purpose:

to enter into a contract, including contractual information about the individual such as name, surname, phone number, email, and delivery address;
to conclude, execute, manage, and ensure compliance with services or product sales, including any related contracts, additional documents such as annexes, amendments, etc.;
to share personal data with partners for the provision of services or sale of goods to the individual;
to manage payments, commissions, and fees;
to inform the User about changes/modifications to all services or products provided or sold through the “Underwood Metal” online store, as well as the Privacy Policy and Cookie Policy;
when “Underwood Metal” and the Website Administration send ordered goods to the User, either through their own delivery service or via a logistics (postal) company;
to notify the User about the estimated service delivery time or product shipment.

5.1.2. Legal Purpose:

for statistical analysis and market research;
to analyze and improve “Underwood Metal” products and services;
to send products to the User via mail (logistics companies);
to provide the User's personal data to authorized government authorities in accordance with the law;
to maintain “Underwood Metal” business processes;
to monitor, verify, and record communications between the User and “Underwood Metal”;
to occasionally send the User marketing information, useful content, newsletters, new offers, and “Underwood Metal” store hours;
to notify the User about the results of claim reviews (if applicable);
to inform the User about the contact person from “Underwood Metal” who will communicate with them;
to offer the User participation in various promotions, programs, and loyalty systems organized by “Underwood Metal”;
to facilitate the participation of Users in “Underwood Metal” promotions, programs, and loyalty systems, including registering Users in its participant database;
to allow the User to join various policies, rules, and guidelines that govern “Underwood Metal” promotions, programs, and loyalty systems;
to inform Users about the procedure for participating in promotions, programs, and loyalty systems organized by “Underwood Metal,” as well as any changes to policies, rules, and guidelines related to these initiatives;
to comply with other legal obligations.

6. User Rights

6.1. Regarding their personal data provided for collection, accumulation, processing, storage, and use by “Underwood Metal” and the Website Administration, the User, under the Law of Ukraine “On Personal Data Protection” and the General Data Protection Regulation (GDPR; Regulation (EU) 2016/679), has the following rights:

to know the sources of collection, location of their personal data, and the purpose of its processing;
to receive information about the conditions of access to personal data;
to access their personal data;
to obtain information on whether their personal data is being processed;
to submit a justified request to “Underwood Metal” objecting to the processing of their personal data;
to submit a justified request for modification or deletion of their personal data if it is processed unlawfully or inaccurately;
to protect their personal data from unlawful processing, accidental loss, destruction, or damage due to intentional concealment, non-provision, or untimely provision, as well as from providing inaccurate or defamatory information that affects their honor, dignity, and business reputation;
to file complaints regarding the processing of their personal data with competent authorities or courts;
to exercise legal remedies in case of violation of personal data protection laws;
to impose restrictions on the right to process their personal data when giving consent;
to withdraw consent for the processing of personal data;
to know the mechanisms of automatic processing of personal data;
to request corrections to incomplete or inaccurate personal data;
to request the deletion of personal data if they have successfully exercised their right to object to data processing;
to refuse consent for the processing of personal data at any time;
to object to the use or processing of their personal data by “Underwood Metal” and the Website Administration if they believe it affects their rights and freedoms.

6.2. To exercise the above rights, the User should contact “Underwood Metal” via email at info@underwoodmetal.com.ua. If “Underwood Metal” receives a request from a User regarding any of the mentioned rights, “Underwood Metal” may ask the User to verify their identity before processing the request. This is necessary to ensure the protection and security of personal data.

7. Transfer and Disclosure of Personal Data

7.1. “Underwood Metal” and the Website Administration do not transfer or disclose any personal data about the User without their consent, except for the purposes mentioned in this Privacy Policy or if required by law.

7.2. “Underwood Metal” and the Website Administration may use third-party services to provide and sell products to the User. All processors acting on behalf of “Underwood Metal” process User data only in accordance with the instructions of “Underwood Metal” and strictly comply with this Privacy Policy, the Cookie Policy, and the laws of Ukraine and the European Union.

7.3. “Underwood Metal” and the Website Administration may transfer the User's personal data outside the European Union and Ukraine in accordance with the obligations of this Privacy Policy, the Cookie Policy, or legal requirements in the following cases:

Ukraine and the European Commission or another authorized body have recognized that the destination country of the personal data transfer ensures an adequate level of personal data protection;
The service provider/seller of goods, in accordance with this Privacy Policy, is bound by appropriate and specific contractual obligations required under applicable data protection laws.

8. User Personal Data Protection Measures

8.1. “Underwood Metal” and the Website Administration take measures to ensure the protection and security of the User’s personal data at all stages of processing, including through organizational and technical measures.

8.2. “Underwood Metal” and the Website Administration take all necessary measures to prevent accidental loss, unauthorized use or access, modification, or disclosure of the User’s personal data.

8.3. “Underwood Metal” and the Website Administration have implemented a process for handling personal data security breaches or incidents and will inform the User and any relevant regulatory authority about any suspected breach or incident if “Underwood Metal” or the Website Administration is legally required to do so.

8.4. If “Underwood Metal” or the Website Administration transfers the User’s personal data, “Underwood Metal” will require third parties to take measures to protect personal data. “Underwood Metal” and the Website Administration do not grant third parties any rights to use personal data for their own purposes. A third party may use the User’s personal data only for a specific purpose and in accordance with the instructions of “Underwood Metal.”

9. Additional Information About User Personal Data

9.1. “Underwood Metal” and the Website Administration are not obligated to provide the User’s personal data to third parties.

9.2. “Underwood Metal” and the Website Administration retain personal data only as long as necessary. When storing personal data, “Underwood Metal” and the Website Administration take into account the following:

the duration of the purposes for which “Underwood Metal” and the Website Administration collect personal data and the period during which “Underwood Metal” and the Website Administration are required to provide services or sell products;
ensuring and managing the relationship between “Underwood Metal,” the Website Administration, and the User;
“Underwood Metal” and the Website Administration also retain the User’s personal data to comply with regulatory requirements, accounting, reporting, and legal obligations or directives.

9.3. Processing is lawful only if the data subject (User) has given consent to the processing of their personal data for one or more specific purposes. The processing of a child’s personal data is lawful if the child is at least 16 years old. If the child is under 16, such processing is lawful only if consent is given by a parent or authorized guardian responsible for the child.

9.4. The “Underwood Metal” online store may contain links to other websites. However, if the User follows these links, they should be aware that “Underwood Metal” and the Website Administration do not control these websites. Therefore, “Underwood Metal” and the Website Administration are not responsible for the protection and privacy of any information the User provides while visiting such sites, and these sites are not governed by this Privacy Policy. The User should exercise caution and review the privacy policy applicable to the respective website.

10. Additional Terms

10.1. “Underwood Metal” reserves the right to amend the Privacy Policy without the User’s consent, providing notification 30 (thirty) calendar days before the changes take effect. Changes to the Privacy Policy will be made by posting a new updated version at the following link: https://underwoodmetal.com.ua/privacy-policy/. The latest and active version of the Privacy Policy can always be found at this link.

10.2. The new Privacy Policy comes into effect from the moment it is published on the “Underwood Metal” online store website, unless otherwise stated in the updated version of the Privacy Policy.

10.3. If the amendments significantly affect the User’s privacy rights, “Underwood Metal” or the Website Administration will send an additional notification via email to the User. If the User disagrees with the changes to this Privacy Policy, they must contact “Underwood Metal” at info@underwoodmetal.com.ua.

10.4. If the User disagrees with any changes made to the Privacy Policy, they must stop using the “Underwood Metal” online store and may request that the Website Administration and “Underwood Metal” delete their personal data. If “Underwood Metal” or the Website Administration does not receive a refusal from the User regarding the updated version of the Privacy Policy, it will be assumed that the User agrees with the new version.

10.5. Users (for citizens of the European Union) may file a complaint regarding violations by “Underwood Metal” or the Website Administration of the General Data Protection Regulation (GDPR; Regulation (EU) 2016/679) with a court or the European Data Protection Supervisor. Contact details for the European Data Protection Supervisor can be found at the following link: https://edps.europa.eu/about-edps/contact_en

10.6. Users (for citizens of countries other than those specified in clause 10.5 of this Privacy Policy) may file a complaint regarding violations of personal data protection laws by “Underwood Metal” or the Website Administration with a court or the Commissioner of the Verkhovna Rada of Ukraine for Human Rights in the field of personal data protection. Contact details for the Commissioner of the Verkhovna Rada of Ukraine for Human Rights in the field of personal data protection can be found at the following link: https://ombudsman.gov.ua/about