1. General provisions

This policy of processing personal data is drawn up in accordance with the requirements of the Law of Ukraine of 23.02.2012, BVR, 2012, No. 50, Article 564 “On the Protection of Personal Data” (hereinafter - the Law on Personal Data) and defines the procedure for processing personal data and measures to ensure the security of personal data, introducedpsychologistina.webflow.io (hereinafter - the Operator).

1.1. The operator sets as its most important goal and condition for the implementation of itsactivity the observance of the rights and freedoms of a person and a citizen when processing hispersonal data, including the protection of the rights to privacy, personal and family secrets.
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1.2. This policy of the Operator regarding the processing of personal data (hereinafter - the Policy) applies to all information that the Operator may receive about visitors to the website http://estroy.biz/
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2. Basic concepts used in politics

2.1. Automated processing of personal data - processing of personal data withthe help of computer technology.

2.2. Blocking of personal data - temporary termination of processing of personal data (except when processing is necessary to clarify personal data).

2.3. Website - a set of graphic and informational materials, as well asprograms for computers and databases that ensure their availability on the Internetwith a network address http://estroy.biz/

.2.4. The information system of personal data is a set containing a databaseof personal data, and ensures their processing by information technologies andtechnical means.

2.5. Depersonalization of personal data - actions as a result of which it is impossible to determine without the use of additional information the belonging of the personal data to a specific User or other subject of personal data.

2.6. Processing of personal data - any action (operation) or set of actions (operations) carried out using automation means or not using such means with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking removal, deletion, destruction of personal data.

2.7. Operator - a state body, municipal body, legal or natural person, which independently or jointly with other persons organize and (or) carry out the processing of personal data, as well as determine the purposes of processing personal data, the composition of personal data to be processed, actions (operations) carried out with personal data.

2.8. Personal data - any information relating directly or indirectly to a particular or determined User of the Website http://estroy.biz/

2.9. Personal data authorized by the subject of personal data for distribution - personal data, access to an unlimited number of persons to whom the personal data subject has granted by the personal data subject by giving consent to the processing of personal data, authorized by the personal data subject for distribution in the order provided for by the Personal Data Act (hereinafter - personal data permitted fordistribution).

2:10 a.m. User - any visitor to the website http://estroy.biz/

2:11 a.m. Provision of personal data - actions aimed at disclosing personaldata to a specific person or a certain circle of persons.

2:12 a.m. Dissemination of personal data - any actions aimed at disclosingpersonal data to an indefinite circle of persons (transfer of personal data) or familiarization with personal data of an unlimited circle of persons, includingdisclosure of personal data in the media, placement of information and telecommunication networks or providing access to personal data taken in any other way.

2:13 a.m. Cross-border transfer of personal data - the transfer of personal dataon the territory of a foreign state to the authority of a foreign state, to a foreignnatural or foreign legal entity.

2:14 a.m. Destruction of personal data - any actions as a result of which personaldata is destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or the material carriers of personal data are destroyed.
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3. Basic Rights and Obligations of the Operator

3.1. The operator has the right to:
- receive from the subject of personal data reliable information and/or documents containing personal data;
- in case of withdrawal of consent to the processing of personal data by the subject of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on pro-personal data;
- independently determine the composition and list of measures necessary and sufficient forensuring the fulfillment of the obligations provided for by the Law on Personal Data andregulatory legal acts adopted in accordance with it, unless otherwise provided for by the Law on Personal Data or other laws.

3.2. The operator is obliged to:
- provide the personal data subject at his request with information pertaining to the processing of his personal data;
- organize the processing of personal data in the manner established by the current legislation of Ukraine;
- respond to requests and requests of personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law; -
notify the authorized body for the protection of the rights of personal data subjectsat the request of this body the necessary information within 30 days from the date of receipt of such a request;
- publish or otherwise provide unrestricted access to this Privacy Policy;
- take legal, organizational and technical measures to protect personal data from unlawful or accidental access to them, destruction, alteration, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions regarding personal data;
- stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;
- perform other duties provided for by the Law on Personal Data.

4. Basic Rights and Obligations of Personal Data Subjects

4.1. Subjects of personal data have the right to:
- receive information regarding the processing of his personal data, except for cases provided for by federal laws. Information is provided to the personal data subject by the Operator in an accessible form and should not contain personal data related to other personal data subjects, except where there are legitimate grounds for disclosure of such personal data. The list of information and the procedure for obtaining it are established by the Law on personal data;
- require the operator to clarify his personal data, their blocking ordestruction if the personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;
- to put forward the condition of prior consent for the processing of personal data for the purposes of promotion in the market of goods, works and services; - to withdraw consent to the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjectsor in court the unlawful actions or inaction of the Operator in the processing of his personal data;
- to exercise other rights provided for by the legislation of Ukraine.

4.2. Subjects of personal data are obliged to:
- provide the Operator with reliable data about themselves; - notify the Operator of the clarification (update, change) of their personal data.

4.3. Persons who have transmitted to the Operator inaccurate information about themselves, whichinformation about another personal data subject without the consent of the latter, are not liable in accordance with the legislation of Ukraine.

5. The Operator may process the following personal data of the User

5.1. Surname, first name, patronymic.
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5.2. Phone numbers.

5.3. The site also collects and processes anonymized visitor data (including cookies) using Internet statistics services (Google Analytics and others).

5.4. The above data hereinafter referred to in the text of the Policy are combined with the general concept of Personal Data.

5.5. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life.

5.6. Processing of personal data permitted for distribution from the specialcategories of personal data specified in Part 1 of Art. 10 of the Personal Data Act, it is allowed if the prohibitions and conditions stipulated in Art. 10.1The Personal Data Act.

5.7. The User's consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of his personal data. In this case, the conditions stipulated in particular, Art. 10.1 of the Personal Data Act. Requirements for the content of such consent are established by the authorized body andprotection of the rights of personal data subjects.
- 5.7.1 Consent to the processing of personal data permitted for distribution, the User provides to the Operator directly.
- 5.7.2 The Operator is obliged, no later than three working days from the moment of receipt of the specified consent of the User, to publish information about the processing conditions, about the existence of prohibitions and conditions for processing an unlimited range of personal data allowed for distribution.
- 5.7.3 The transmission (distribution, provision, access) of personal data authorized by the personal data subject for distribution must be terminated at any time at the request of the personal data subject. This requirement should includesurname, first name, patronymic (if available), contact information (phone number, e-mail address or postal address) of the personal data subject, as well as a list of personal data whose processing is subject to termination.The personal data specified in this requirement can only be processed by the Operator to whom this action is subject directed.
-5.7.4 Consent to the processing of personal data authorized for distribution ceases to be effective from the moment the Operator receives the requirement specified in para. 5.7.3 data policy on the processing of personal data.

6. Principles of processing personal data

6.1. The processing of personal data is carried out on a lawful basis of openness andfairness.

6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not allowed.

6.3. It is not allowed to combine databases containing personal data, processingwhich is carried out for purposes incompatible with each other.

6.4. Only personal data that meet the purposes of processing are subject to processing.

6.5. The content and volume of processed personal data correspond to the stated objectives of the processing. It is not allowed to overuse the processed personal data for the stated purposes of their processing.

6.6. The processing of personal data ensures the accuracy of personal data, their adequacy, and, if necessary, relevance in relation to the target processing of personal data. The operator takes the necessary measures and/ orensures their adoption with the deletion or clarification of incomplete or inaccurate data.

6.7. The storage of personal data is carried out in a form that allows to determinethe subject of personal data for no longer than the purposes of processing personal data require, unless the term of storage of personal data is established by federal law, the contract to which the party, the beneficiary or guarantor of which the personal data subject is. The processed personal data is destroyedor defaced after the achievement of the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by law.

7. Objectives of personal data processing

7.1. Purpose of processing personal data of the User: - conclusion, execution and termination of civil law contracts

7.2. Also, the Operator has the right to send the User notifications about newproducts and services, special offers and various events. The user can always opt out of receiving information messages by sending the Operator List to the e-mail address (hidden) marked “Refusal of notifications about new products and services and special offers”.

7.3. The anonymized user data collected using the Internet statistics service serves to collect information about the actions of users on the site, improve the quality of the site and its content.

8. Legal bases for the processing of personal data

8.1. The legal grounds for the processing of personal data by the Operator are:
- contracts concluded between the operator and the subject of personal data;
- laws, other legal acts in the field of personal data protection;
- consent of users to the processing of their personal data, to the processing of personal data authorized for distribution.

8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website http://estroy.biz/or sent to the Operator via e-mail. By filling in the appropriate forms and/or sending their personal data to the Operator, the User expresses his consent to thispolicy.

8.3. The Operator processes anonymized data about the User if this is allowed in the User's browser settings (the saving of cookies and the use of JavaScript technology is included).

8.4. The subject of personal data independently decides on the provision of hispersonal data and gives consent freely, by his will and in his own interest.

9. Terms of processing of personal data

9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of his personal data.

9.2. The processing of personal data is necessary to achieve the objectives stipulated by the international treaty of Ukraine or by law, for the implementation of the functions, powers and duties assigned by the legislation of Ukraine to the operator.

9.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to enforcementin accordance with the legislation of Ukraine on enforcement proceedings.

9.4. The processing of personal data is necessary for the performance of a contract by a partywhich is either the beneficiary or guarantor under which the personal data subject is, as well as for the conclusion of a contract on the initiative of the personal data subject ora contract under which the subject of personal data will be the beneficiary orthe guarantor.

9.5. The processing of personal data is necessary for the exercise of the rights and legalinterests of the operator or third parties or for the achievement of socially significant objectivesprovided that the rights and freedoms of the subject of personal data are not violated.

9.6. Processing of personal data is carried out, access to an unlimited number of persons whichis granted by the subject of personal data or at his request (hereinafter - publicly available personal data).

9.7. Processing of personal data subject to publication orcompulsory disclosure in accordance with the law of Ukraine is carried out.

10. Procedure for the collection, storage, transfer and other types of processing of personal data.

The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

10.1. The operator ensures the safety of personal data and takes all possiblemeasures that exclude access to personal data of unauthorized persons.

10.2. Personal data of the User will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of the current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.

10.3. In case of inaccuracies in personal data, the User canto update them independently, by submitting to the relevant Operator the e-mail address of the Operator (hidden) marked “Updating personal data”.

10.4. The term of processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless another term is stipulated by the contract or by applicable law.The User may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator by e-mail to the Operator's e-mail address (hidden) marked “Withdrawal of consent to the processing of personal data”.

10.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by such persons (Operators) in accordance with their Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to independently familiarize themselves with the specified documents in a timely manner. The operator is not responsible for the actions of third parties, including the service providers specified in this paragraph.

10.6. The prohibitions established by the subject of personal data on the transfer (except the provision of access), as well as on the processing or processing conditions (other than obtaining access) of personal data allowed for distribution, do not apply in cases of processing of personal data in the state, public and other public interests defined by the legislation of Ukraine.

10.7. The operator ensures the confidentiality of personal data when processing personal data.

10.8. The operator shall store personal data in a form that allowsto identify the subject of personal data for no longer than required by the processing of personal data, if the period of storage of personal data is not established by federal law, the contract to which, the beneficiary or guarantor to which the personal data subject is a party.

10.9. The condition for the termination of the processing of personal data may be the achievement of the purpose of processing personal data, the expiration of the consent of the personal data subject or the withdrawal of consent by the subject of personal data, as well as the detection of unlawful processing of personal data.

11. List of actions performed by the Operator with the receivedpersonal data

11.1. The operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.

11.2. The operator carries out automated processing of personal data with the receipt and/or transfer of the received information over information and telecommunication networks or without it.

12. Cross-border transfer of personal data
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12.1. The operator before the start of cross-border transfer of personal datamust make sure that the foreign state, to whose territory it is supposed to transfer personal data, ensures reliableprotection of the rights of the subjects of personal data.

12.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements may be carried out only if there is a written consent of the personal data subject to the transbordertransfer of his personal data and/or the execution of a contract to which the personal data subject is a party.

I'm 13. Confidentiality of personal data
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The operator and other persons who have gained access to personal data are obliged to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by the law of Ukraine.

I'm 14. Final positions

14.1. The User can obtain any clarifications on the necessary questions pertaining to the processing of his personal data by contacting the Operator via e-mail (hidden)

14.2. This document will reflect any changes to the policy of processing personal data by the Operator. The policy is valid indefinitely until it is replaced by a new version