PRIVACY POLICY

AND PERSONAL DATA PROTECTION

Revision dated: 25.11.2025

The JustBuy website (justbuy.com.ua) (hereinafter referred to as the “Online Store” or the “Website”) respects the confidentiality (personal) information of all visitors to the Website, as well as those who use its services. We strive to protect the confidentiality of personal data by creating the most comfortable conditions for using the Website’s services for each user.

This Privacy Policy (hereinafter referred to as the “Policy”) establishes the procedure for collecting, using, disclosing, and protecting the personal data of Online Store Users.

1. GENERAL PROVISIONS

1.1. The User’s use of the Website involving active actions (clicking interface elements) means acceptance of this Privacy Policy and the terms of personal data processing.

1.2. If the User does not agree with the terms of the Policy, they must stop using the Website.

1.3. This Policy applies only to the Online Store. The Online Store does not control and is not responsible for third-party websites that the User may access via links available on the Website.

1.4. The Website Administration does not verify the accuracy of personal data provided by the User.

2. SUBJECT OF THE PRIVACY POLICY

2.1. This Policy establishes the obligations of the Website Administration to ensure non-disclosure and protection of the confidentiality of personal data provided by the User during registration on the Website or when placing an order.

2.2. The personal data we collect may include:

2.2.1. When placing an order / registering:

- last name, first name, and patronymic;

- contact phone number;

- email address;

- delivery address (post office / physical address);

- taxpayer identification number (RNOKPP);

- date of birth.

2.2.2. Automatically when using the Website:

- IP address;

- browser and operating system information;

- cookie data (see Section 4);

- browsing and purchase history;

- access time.

3. PURPOSE OF COLLECTING PERSONAL DATA

The Website Administration may use the User’s personal data for the purpose of:

3.1. Identifying the User to place an order and/or conclude a distance sales contract.

3.2. Providing the User with access to personalized Website resources.

3.3. Establishing feedback, including sending messages and requests related to Website usage, service provision, and processing inquiries and applications.

3.4. Verifying the accuracy and completeness of the personal data provided by the User.

3.5. Processing and receiving payments.

3.6. Providing effective customer and technical support in case of issues related to Website usage.

3.7. Providing the User, with their consent, information about product updates, special offers, pricing information, newsletters, and other information on behalf of the Online Store.

4. COOKIES

4.1. The Website uses cookie technology to collect statistical information, determine content popularity, improve Website performance, and personalize the User experience.

4.2. The User has the right to change browser settings at any time to refuse the storage of cookies or to receive notifications about their use. However, this may affect the proper functioning of some Website features.

5. METHODS AND TERMS OF PERSONAL DATA PROCESSING

5.1. The processing of the User’s personal data is carried out for no longer than necessary to achieve the purposes for which it was collected, using any lawful method, including in information systems with or without automation tools.

5.2. The User’s personal data may be transferred to authorized government authorities of Ukraine or other countries only on the grounds and in the manner prescribed by Ukrainian law or international legal requirements. Such transfer is carried out on the basis of the User’s consent through active actions (clicking interface elements). Authorized authorities are required to ensure adequate protection of the received personal data.

5.3. The Website Administration does not sell, exchange, or transfer the User’s personal data to third parties, except when necessary to fulfill the User’s order, namely:

delivery services (e.g., Nova Poshta, Ukrposhta) for shipment of goods;

banking and financial institutions for payment processing;

third-party services used for analytics and marketing (e.g., Google Analytics, advertising platforms), with data transferred in anonymized form where possible.

6. DATA TRANSFER OUTSIDE THE EU

(COUNTRIES THAT DO NOT ENSURE ADEQUATE PROTECTION)

6.1. These provisions apply if we transfer or provide access to personal data of Users located in the European Economic Area (EEA) to entities located outside the EEA, including but not limited to Ukraine and the United States of America.

6.2. We transfer personal data to third countries only on an appropriate legal basis and while ensuring an adequate level of personal data protection.

6.3. Data transfer is carried out, in particular, on the following grounds:

6.3.1. Performance of a Contract

The transfer is necessary for the performance of a contract concluded between the User and the Data Operator, or for taking steps at the User’s request prior to entering into such a contract (e.g., transferring a delivery address to a logistics company).

6.3.2. Explicit Consent

The transfer is based on the User’s clear and informed consent after they have been informed of the possible risks associated with such transfer.

6.4. If personal data is transferred to a country for which the European Commission has not adopted an adequacy decision, we undertake to implement appropriate safeguards:

6.4.1. Standard Contractual Clauses approved by the European Commission.

6.4.2. Additional technical and organizational measures (e.g., encryption, pseudonymization) where necessary to ensure data protection.

7. PERSONAL DATA PROTECTION

7.1. The Website Administration implements necessary organizational and technical measures to protect the User’s personal information from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, or other unlawful actions by third parties.

7.2. Data transmission is carried out via a secure connection (SSL encryption).

8. USER RIGHTS

8.1. The User has the right to:

- receive information about the processing of their personal data;

- request clarification, updating, portability, modification, erasure, or deletion of personal data;

- withdraw consent to personal data processing;

- restrict or object to the processing of their data;

- submit requests for the exercise of their rights using the contact details specified in Section 9.

9. CHANGES TO THE PRIVACY POLICY

9.1. The Website Administration has the right to make changes to this Privacy Policy without the User’s consent.

9.2. The new version of the Privacy Policy comes into force from the moment it is published on the Online Store Website, unless otherwise provided by the new version.

10. CONTACT INFORMATION

All suggestions or questions regarding this Privacy Policy should be sent to:

Email: justbuy.office@gmail.com

Phone: 0800 33 49 82