Privacy Policy

This Privacy Policy (hereinafter — the «Policy») describes how Sofiivka Montazh Limited Liability Company (hereinafter — the «Company», «we», «us») collects, uses, stores and protects the personal data of users of the website termojet.com.ua (hereinafter — the «Website»).

Data Controller details:

• Full legal name: Sofiivka Montazh Limited Liability Company
• Company registration code (EDRPOU): 37074476
• Registered address: 08131, Kyiv Oblast, Bucha District, village of Sofiivska Borshchahivka, Kyivska Street, building 3
• Actual address: Kyiv, urban-type settlement Sofiivska Borshchahivka, Kyivska Street, 3, 08131
• Email: termojet@sofievka.kiev.ua
• Phone: +380 (50) 718-91-65, +380 (50) 450-64-24

By using the Website or providing us with your data through the Website's forms, you confirm that you have read this Policy and agree to its terms.

• Personal data — information or a set of information about a natural person who is identified or can be specifically identified.
• Processing of personal data — any action performed on personal data (collection, storage, use, transfer, destruction, etc.).
• Data Controller — the Company that determines the purposes and means of processing personal data.
• Data subject — a natural person whose personal data are processed (a Website user).
• Cookies — small text files stored in the user's browser and used to ensure the Website functions correctly, as well as for analytics and marketing purposes.

3.1. Contact and identification data: first name, last name, phone number, email address, job title and company name (for B2B orders).

3.2. Order data: delivery address, payment method, order composition and total amount, order comments.

3.3. Request and communication data: information from consultation, feedback and equipment selection forms; object type and technical parameters; correspondence history.

3.4. Technical data: anonymised IP address, browser and device type, pages visited, time spent on site, referrer URL, UTM tags, cookies and similar technologies.

3.5. Marketing communication data: email address for newsletters, subscription date and IP, email interaction history, push subscription identifiers, messenger identifiers when using the chatbot.

The Website is not intended for persons under the age of 16. We do not knowingly collect personal data from minors.

• Order fulfilment — processing and fulfilment of orders, delivery, warranty service. Legal basis: performance of a contract.
• Communication with you — responding to requests and consultations. Legal basis: taking steps at the request of the data subject prior to entering into a contract.
• Compliance with legal requirements — accounting and tax record-keeping. Legal basis: compliance with a legal obligation.
• Analytics and Website improvement — visitor statistics. Legal basis: your consent via the cookie banner.
• Marketing and advertising — personalised advertising, remarketing, email newsletters. Legal basis: your consent via the cookie banner and/or subscription checkbox.
• Website security — protection against bots and fraud. Legal basis: the Company's legitimate interest.

We do not sell your personal data. We share it with a limited circle of third parties solely for the purposes set out in clause 4:

• Delivery services (Nova Poshta and others) — name, phone number, delivery address, order composition.
• Payment systems — order amount, identifier, email for receipt. Card data is processed exclusively by the payment system.
• Analytics, advertising and marketing services — detailed in clause 7 of this Policy.
• Hosting and infrastructure — Cloudflare (CDN, DDoS protection).
• Messengers — Telegram (order status notifications, if you have selected this channel).
• Public authorities — solely on the basis of an official request in accordance with applicable Ukrainian law.

Some of our processors (Google, Meta, SendPulse) have server infrastructure outside Ukraine, including in the United States and EU member states. Transfers are carried out on the basis of Standard Contractual Clauses (SCC) and the EU–U.S. Data Privacy Framework.

The Company uses third-party services. All of them set cookies and/or other tracking technologies. Legal basis: your consent via the cookie banner.

• Google Analytics 4 — analysis of user behaviour, measurement of traffic and conversions. Data: anonymised IP, Client ID, e-commerce events. Retention period: up to 14 months.
• Google Ads (remarketing, Conversion Tracking, Enhanced Conversions) — personalised advertising across Google networks. Enhanced Conversions: email, phone number and name are transmitted in SHA-256 hash format.
• Google Tag Manager — a tag management tool. Does not independently collect personal data.
• Google Merchant Center / Shopping — listing products in Google Shopping.
• Google reCAPTCHA — protection of Website forms against bots. Legal basis: legitimate interest.
• Google Maps — display of an interactive map showing the office location.
• Meta Pixel — measurement of advertising effectiveness on Facebook/Instagram, creation of Custom Audiences. Retention period: up to 180 days.
• Meta Conversions API (CAPI) — server-side transmission of conversion events to Meta in hashed (SHA-256) format.
• Meta Custom Audiences — creation of audiences based on hashed contact data of customers who have consented to marketing.
• TikTok Pixel and Events API — measurement of campaign effectiveness in TikTok Ads.
• LinkedIn Insight Tag — measurement of LinkedIn Ads effectiveness for B2B communication.
• SendPulse — email newsletters (Double Opt-In), web push notifications, chatbot in messengers. Retention period: until unsubscription or 36 months without interaction.

The Website uses cookies and similar technologies. Categories:

• Necessary — ensure the basic functionality of the Website (shopping cart, security). No consent required.
• Functional — remember your preferences (language, currency). Consent required.
• Analytical — visitor statistics (_ga, _gid). Consent required.
• Marketing — personalised advertising (_gcl_au, _fbp, NID, IDE). Consent required.

You can manage your consent via the cookie banner on the Website or through your browser settings.

We implement technical and organisational measures: HTTPS/TLS encryption, role-based access control, regular backups, security monitoring, and the conclusion of Data Processing Agreements (DPA) with all processors.

Personal data retention periods:

• Consultation requests and feedback — 12 months from the date of submission.
• Order data — 3 years in accordance with accounting requirements (Article 44 of the Tax Code of Ukraine).
• Reviews — until withdrawal of consent or deletion upon your request.
• Email marketing data — until unsubscription or 36 months without interaction.
• Technical data (logs, IP) — up to 90 days.
• Remarketing audiences — up to 540 days (Google Ads), up to 180 days (Meta).

Upon expiry of the retention period, data is deleted or anonymised.

In the event of a personal data security breach that may give rise to a significant risk to the rights of data subjects, the Company notifies the Ukrainian Parliament Commissioner for Human Rights without undue delay, and in cases provided for by the GDPR — the relevant supervisory authority within 72 hours.

In accordance with the Law of Ukraine «On Personal Data Protection» and the GDPR, you have the right to:

• To know — to obtain information about what data of yours we process, for what purpose and to whom we transfer it.
• Of access — to receive a copy of your personal data.
• Of rectification — to request the correction of inaccurate or incomplete data.
• Of erasure («right to be forgotten») — to request the deletion of your data.
• Of restriction of processing — to request a temporary suspension of processing.
• Of data portability — to receive your data in a structured, machine-readable format.
• To object — to object to processing based on legitimate interest or for direct marketing.
• To withdraw consent — at any time without affecting the lawfulness of prior processing.
• To lodge a complaint — — to the Ukrainian Parliament Commissioner for Human Rights ( ombudsman.gov.ua) or the supervisory authority in your country of residence (for EEA residents).

Please send your requests to: termojet@sofievka.kiev.ua. In your request, please state your full name, contact details and the nature of your enquiry. Response time — no later than 30 calendar days.

We reserve the right to update this Policy in response to changes in legislation or the Company's services. We notify users of material changes by publishing the new version on this page with an updated effective date, and by email to current subscribers — at least 7 calendar days before the changes take effect.

Continued use of the Website after the changes take effect constitutes your acceptance of the updated version of the Policy.

Date of last update: 03.05.2026