1. Who we are

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This Privacy Policy explains how Limited Liability Company Functionsoft / ТОВ «Фанкшнсофт» (“Functionsoft”, “we”, “us”) collects and uses personal data of visitors to functionsoft.net and of individuals who contact us through the website contact form, email or other channels. We are the controller of this personal data.

Controller: Limited Liability Company Functionsoft / ТОВ «Фанкшнсофт»
Company registration number (USREOU / EDRPOU code): 45258227 [to be verified against the registration certificate]
The USREOU / EDRPOU code is the unique identification code of a legal entity in the Unified State Register of Enterprises and Organizations of Ukraine - the Ukrainian equivalent of a company registration number.
Address: Dniprovska Naberezhna, 23, Kyiv, 02081, Ukraine [verify exact building/block]
Privacy contact: [email protected] [a corporate-domain email is recommended]
This Policy reflects the Ukrainian Law “On Personal Data Protection” and, where you are located in the European Economic Area (EEA) or the United Kingdom, the EU General Data Protection Regulation (GDPR) and the UK GDPR.

It applies to the website functionsoft.net and to initial communications about IT consulting, software development, web development, UI/UX design, technical support and related services.

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2. The personal data we collect

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Category	Examples	Source
Contact data	name, email, phone, company name, position	you, via a form, email or phone
Inquiry / project data	project description, business needs, budget/timeline expectations, technical requirements	you, in your message or communication
Communication data	correspondence, replies, call arrangements, inquiry history	created during communication
Technical website data	IP address, browser type, device, approximate location, date/time of visit, pages viewed	collected automatically when you use the website
Cookie / analytics data	cookie identifiers, analytics events, traffic source, preferences	according to Section 4 and your settings

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We do not ask for special categories of personal data through the website. Please do not include such information unless it is strictly necessary for your inquiry.

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3. How we use your data and our legal bases

Processing activity	Personal data used	Legal basis
Receiving, reviewing and responding to your inquiry; arranging calls; clarifying details	contact, inquiry/project, communication	pre-contractual steps at your request / performance of a contract; legitimate interests in B2B communication
Preparing an estimate, proposal, NDA, contract or invoice	contact, inquiry/project	pre-contractual steps / performance of a contract
Operating, securing and troubleshooting the website	technical website data	legitimate interests in protecting and maintaining the website and systems
Measuring and improving website use	cookie / analytics	your consent where required by law for the relevant cookies
Keeping accounting, contractual and legal records	contact, communication	legal obligations; legitimate interests in protecting rights and claims

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4. Cookies and similar technologies

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The website may use cookies for operation, security, settings, analytics and improving the experience. Essential cookies are used without separate consent where necessary to provide the website. Non-essential cookies (analytics or marketing) are enabled only after your consent where such consent is required by law. A cookie list, retention periods and controls are provided in a Cookie Policy/banner where such cookies are used.

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5. Who we share data with

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We share data only with providers and parties that help us run the website and respond to your inquiry. Indicative categories are below; confirm the actual providers before publication.

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Provider / recipient	Purpose	Location
Webflow (website platform / hosting / forms)	hosting and receiving form submissions	USA / EEA
Email and CRM [confirm]	receiving, storing and managing your inquiry	[confirm]
Analytics [e.g. Google Analytics - confirm]	website usage statistics	USA / EEA
Calendar / video tools [confirm]	arranging and holding calls	[confirm]
Advisers; contractors involved in your inquiry	preparing a proposal; legal, accounting support	Ukraine / EEA
Public authorities, courts	where required by law or to protect our rights	Ukraine

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We do not sell website visitors’ personal data and put appropriate processing terms in place with our providers.

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6. International transfers

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Because we use international IT services, personal data may be processed in Ukraine, the EEA, the United Kingdom, the United States or other countries. Where additional safeguards are required, we use available contractual, technical and organisational measures (including standard contractual clauses with providers). You can request a copy of the relevant safeguards using the email in Section 1.

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7. How long we keep data

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Data	Indicative retention period
contact form and email inquiries where cooperation does not start	up to 24 months after the last communication, unless a longer period is needed to protect our rights
client data connected with a contract	during cooperation and afterwards per tax, accounting, contractual and limitation periods
technical security logs	a short period needed for security, diagnostics and abuse prevention
cookies	as set out in the cookie banner / Cookie Policy

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8. Your rights

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Subject to applicable law, you may: be informed and access your data; have it corrected or erased; restrict or object to processing; data portability; and withdraw consent where processing is based on it. To exercise your rights, use the email in Section 1. We respond within a reasonable time (generally one month) and may ask you to verify your identity or to clarify a broad request.

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9. Automated decision-making and profiling

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We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects, and we do not carry out such profiling through the website.

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10. Children

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The website and our services are aimed at businesses and are not directed at children. We do not knowingly collect children’s personal data. If you believe a child has provided us with data, contact us and we will delete it.

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11. How to complain

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If you have a concern, please contact us first using the email in Section 1; we will review it and tell you the outcome. You also have the right to complain to a competent supervisory authority: in Ukraine, the Ukrainian Parliament Commissioner for Human Rights (ombudsman.gov.ua) - a dedicated independent data protection authority is being established under reform. If you are in the EEA or the UK, you may contact your local authority (for example, the ICO in the United Kingdom).

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12. Security

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We use reasonable technical and organisational measures (access controls, encryption in transit where appropriate, need-to-know access) to protect personal data. However, no method of internet transmission or storage is completely secure, so we cannot guarantee absolute security.

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13. Changes to this Policy

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We may update this Policy from time to time. The current version is identified by the “Last updated” date above and takes effect when published, unless stated otherwise.

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14. Contact

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For any question about this Policy, contact us at [email protected].