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Privacy Policy

In the context of using this website, personal data (hereinafter “personal data” or “data”) will be processed by us as the data controller and stored for the duration necessary to fulfill the specified purposes and legal obligations. Below, we inform you about what data is involved, how it is processed, and what rights you have in this regard.

Personal data, according to Art. 4 No. 1 of the General Data Protection Regulation (GDPR), refers to all information relating to an identified or identifiable natural person (hereinafter “data subject or user”).

1. Name and Contact Details of the Controller

This privacy information applies to data processing on the website www.klucco.com by the controller:

Herzhan Serhii
 Danili Galizkogo 9A
 49102 Dnipro, Ukraine
 (hereinafter “KLUCCO”)

Email: herzhan.serhii@gmail.com
 Phone: +380930599500

Tax Identification Number (ФОП): 3371714031

For questions regarding data protection law or your data subject rights, you can contact us directly at any time.

2. Processing of Personal Data and Purposes of Processing

a) Web Hosting

To provide this website, we use a web hosting service. The name of the hosting provider will be added here once the final hosting solution is implemented.

The use of a web hosting service is necessary to offer a website. The use is based on Art. 6 Para. 1 S. 1 lit. f GDPR due to our legitimate economic interest in maintaining our offering on this website. In connection with hosting, personal data that arises from the use of the website is processed by our hosting partner on our behalf.

We have concluded a data processing agreement with our hosting partner. Through this agreement, the service provider assures that it processes the data in accordance with the General Data Protection Regulation and guarantees the protection of the rights of the data subject.

b) When Visiting the Website

You can access the website www.klucco.com without disclosing your identity. The browser used on your device only automatically sends information to the server of our website (e.g., date and time of access, name and URL of the retrieved file, browser type and version, website from which access is made (referrer URL), HTTP status code, device, operating system, resolution, and preferred language).

This also includes the IP address of your requesting device. This is temporarily stored in a so-called log file and automatically deleted after one month.

The processing of the IP address is carried out for technical and administrative purposes of connection establishment and stability, to ensure the security and functionality of our website and to be able to prosecute any unlawful attacks if necessary.

The legal basis for processing the IP address is Art. 6 Para. 1 S. 1 lit. f GDPR. Our legitimate interest follows from the mentioned security interest and the necessity of trouble-free provision of our website.

From processing the IP address in the log file, we cannot draw direct conclusions about your identity.

In addition, we use cookies and analytics services when visiting our website. More detailed explanations can be found under sections 4 and 5 of this privacy policy.

c) Newsletter Registration (planned)

This service is in development. Once available, we will use your email address according to Art. 6 Para. 1 S. 1 lit. a GDPR only with your explicit consent to send you information about SEO and PPC services.

Unsubscribing will be possible at any time via a link in the newsletter or by email to herzhan.serhii@gmail.com.

[Information about the newsletter provider will be added here once the service is activated]

d) Using the Contact Form

We offer you the opportunity to make inquiries about our SEO and PPC services through the online contact form. We collect the following required information:

  • Last name, first name
  • Email address
  • Company/Website (optional)
  • Your personal message

We need your first and last name to know who the inquiry is from. We need your email address to be able to respond to your inquiry. Providing your company or website is voluntary and helps us properly categorize your inquiry.

This data processing is carried out in the context of answering the contact inquiry based on our legitimate interest in responding to inquiries according to Art. 6 Para. 1 S. 1 lit. f GDPR. If your inquiry aims at concluding a contract with us, Art. 6 Para. 1 S. 1 lit. b GDPR is the legal basis for data processing.

The personal data collected by us for using the contact form will be deleted once your inquiry has been conclusively answered and there are no legal retention obligations preventing deletion.

e) Contract Conclusion and Customer Service

When you use our SEO or PPC services, we process only the information necessary for service delivery:

  • Contact information for communication (name, email, phone)
  • Billing data as required
  • Project-related information about your website

Privacy Principles:

  • We collect only necessary data for executing the commissioned services
  • The data is used exclusively for communication and project work
  • After project completion, data will be deleted within 12 months
  • Upon your request, we will delete your data immediately at any time

Processing is carried out for contract fulfillment according to Art. 6 Para. 1 S. 1 lit. b GDPR. Tax-relevant documents are stored according to statutory retention periods.

3. Disclosure of Data

a) Disclosure of Personal Data to Third Parties

We only pass on your personal data to third parties if:

  • You have given your explicit consent according to Art. 6 Para. 1 S. 1 lit. a GDPR;
  • This is legally permissible and necessary according to Art. 6 Para. 1 S. 1 lit. b GDPR for the processing of contractual relationships with you;
  • In the event that there is a legal obligation for disclosure according to Art. 6 Para. 1 S. 1 lit. c GDPR; or
  • This is legally permissible and necessary according to Art. 6 Para. 1 S. 1 lit. f GDPR to protect our interests or those of third parties.

The disclosed data may only be used by the third party for the stated purposes.

b) Transfer of Personal Data to Third Countries

A transfer of personal data to a third country or an international organization only takes place if we inform you about it and the requirements of Arts. 44 et seq. GDPR are met.

A third country is defined as a country outside the European Economic Area (EEA) in which the GDPR is not directly applicable. A third country is considered unsafe if the EU Commission has not issued an adequacy decision for that country according to Art. 45 Para. 1 GDPR.

The USA is a so-called unsafe third country. When transferring personal data to the USA, there are risks regarding access by US authorities due to various surveillance programs.

We only transfer your personal data if sufficient guarantees according to Art. 46 GDPR are provided for the protection of personal data, for example through standard contractual clauses.

4. Cookies and Similar Technologies

We use so-called cookies and similar functions on our website to technically provide our website and to statistically record and evaluate the use of our website for optimization purposes.

a) Cookies

Cookies are small files that your browser automatically creates and that are stored on your device when you visit our site. Cookies do not cause any damage to your device.

The use of cookies serves to make the use of our website more pleasant for you. We use both session cookies (automatically deleted after leaving the site) and temporary cookies (for a fixed period).

Most browsers automatically accept cookies. However, you can configure your browser so that no cookies are stored. Complete deactivation of cookies may result in you not being able to use all functions of our website.

b) Consent Management

To manage consents for the use of cookies and tracking technologies, we use a consent management tool. The date and time of the visit, browser information, information about consent, and the anonymized IP address are processed. The legal basis is Art. 6 Para. 1 S. 1 lit. f GDPR.

5. Web Analytics

The tracking measures listed below are carried out on the basis of Art. 6 Para. 1 S. 1 lit. a GDPR.

a) Google Analytics

We use Google Analytics on our website, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter “Google”).

Google Analytics uses cookies and similar technologies to analyze the use of the website. The information generated by the cookie about your use of this website is transmitted to and stored on a Google server.

The use of Google Analytics is based on your consent according to Art. 6 Para. 1 S. 1 lit. a GDPR. You can withdraw your consent at any time via our consent management tool.

We use Google Analytics with activated IP anonymization. This means that the IP address of users is shortened by Google. The IP address is not merged with other data from Google.

The data collected by Google Analytics may also be transferred to Google servers in the USA. Google relies on standard contractual clauses approved by the EU Commission as a guarantee for an adequate level of data protection.

You can prevent the installation of cookies by adjusting your browser software settings or disable tracking by Google Analytics via our consent management tool.

6. Social Media (optional)

If we create social media profiles (planned: Instagram), the privacy policies of the respective platforms apply. We use these channels only to provide information about our services and do not collect any additional data beyond the platform’s own functions.

7. Data Subject Rights

You have the following rights regarding your personal data:

  • Access (Art. 15 GDPR): You can ask at any time what data we have about you
  • Rectification (Art. 16 GDPR): We will correct incorrect data immediately
  • Erasure (Art. 17 GDPR): Upon request, we will delete your data immediately (except tax-relevant documents)
  • Restriction (Art. 18 GDPR): You can have the processing of your data restricted
  • Data Portability (Art. 20 GDPR): You will receive your data in a readable format upon request
  • Withdrawal (Art. 7 Para. 3 GDPR): You can withdraw given consents at any time
  • Complaint (Art. 77 GDPR): In case of problems, you can contact a data protection authority

It’s that simple: Just send us an email to herzhan.serhii@gmail.com with your request. We will respond within 30 days and implement legitimate requests immediately.

8. Right to Object (Art. 21 GDPR)

You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you that is based on Art. 6 Para. 1 S. 1 lit. f GDPR.

If you wish to exercise your right to object, an email to herzhan.serhii@gmail.com is sufficient.

9. Data Security

All data transmitted by you is encrypted using the secure TLS (Transport Layer Security) standard. You can recognize a secure TLS connection by the “https://” in the address bar and the lock symbol in your browser.

We use appropriate technical and organizational security measures to protect your data against manipulation, loss, destruction, or unauthorized access.

10. Currency and Amendment of this Privacy Policy

This privacy policy is currently valid and dated September 23, 2025.

Due to the further development of our website, it may become necessary to change this privacy policy. The current privacy policy can be accessed at any time on the website at https://klucco.com/en/privacy-policy/.

Contact for Privacy Questions: Herzhan Serhii
 Email: herzhan.serhii@gmail.com
 Address: Danili Galizkogo 9A, 49102 Dnipro, Ukraine

Applicable Law: This privacy policy is subject to Ukrainian law. In the event of disputes, Ukrainian law applies.