# PRIVACY POLICY **Last updated:** 19.09.2026 --- ## 1. WHO WE ARE The data controller is **RENOVA Hospitality** (the **Company**, "we"), Kyiv, Ukraine. This Policy explains what data we collect on **renovahospitality.net** (the **Site**) and in our Telegram bot, why we collect it, who we share it with, and what rights you have. Privacy contact: **office@renovahospitality.net**. We comply with the Law of Ukraine "On Personal Data Protection" and, for users in the European Union, with the General Data Protection Regulation (GDPR). --- ## 2. WHAT DATA WE COLLECT ### 2.1. Data you provide Through the request forms on the Site ("Start a conversation", the forms on service, glossary and Bukovel pages) or through our Telegram bot you may provide: - your name; - a phone number or email address; - the service you are interested in and a description of your idea or project; - in Telegram — your Telegram user ID and username and the content of your messages. ### 2.2. Data recorded automatically with a request - IP address — for spam protection and rate limiting; - the language of the page the request was sent from; - the referring source and advertising tags (UTM parameters, Google click ID, Facebook click ID) — so we know which campaign a request came from. ### 2.3. Cookies and analytics The Site uses **cookies** and browser local storage: - **necessary** — remember your cookie choice and the page variant shown to you (A/B test); they work without consent; - **analytics and marketing** — Google Analytics 4, Google Ads and Meta Pixel. They collect anonymised information about page views, device, approximate location and advertising performance. **These tools are enabled only after you click "OK" in the cookie notice.** You can also manage cookies in your browser settings. To withdraw consent, clear the Site's data in your browser or write to us. --- ## 3. WHY AND ON WHAT LEGAL BASIS - **Responding to your request, preparing a proposal, providing consulting services** — name, contact details, project description, language. Basis: performance of a contract or steps prior to entering into one. - **Spam and abuse protection** — IP address, technical request data. Basis: legitimate interest (security). - **Measuring advertising performance and improving the Site** — UTM/click IDs, referrer, analytics data. Basis: your consent. - **Compliance with the law** — any of the above. Basis: legal obligation. We do not make automated decisions with legal effects on you and do not process data in a way incompatible with these purposes. --- ## 4. WHO WE SHARE DATA WITH We do not sell personal data. It is accessible only to authorised Company staff and the providers below, who act on our instructions: - **hosting provider** (Ukraine) — hosting of the Site and storage of requests; - **Cloudflare, Inc.** — content delivery network and protection of the Site (traffic proxying); - **Telegram Messenger Inc.** — notifying our team about new requests and running the Telegram bot; - **Google Ireland Ltd.** — Google Analytics 4 and Google Ads (only with your consent); - **Meta Platforms Ireland Ltd.** — Meta Pixel (only with your consent); - an email service — delivering a copy of your request to our mailbox. Some providers (Google, Meta, Telegram, Cloudflare) may process data outside Ukraine and the EU. For EU users such transfers rely on the European Commission's Standard Contractual Clauses or other mechanisms provided for by the GDPR. We may also disclose data where required by law or a court order. --- ## 5. HOW LONG WE KEEP DATA - requests and correspondence — up to **3 years** after the last contact, or until you ask us to delete them; - technical logs (IP, spam protection) — up to **12 months**; - analytics data — according to the providers' settings (Google Analytics — up to 14 months). After that, data is deleted or anonymised. --- ## 6. SECURITY The Site runs over HTTPS; requests are stored in a password-protected area of the server; access to the administrative area is restricted and logged. No method of transmitting data over the internet is completely secure, but we keep improving our safeguards. --- ## 7. YOUR RIGHTS You have the right to: - know what data we process about you and receive a copy of it; - correct inaccurate or incomplete data; - request erasure of your data ("right to be forgotten"); - restrict or object to processing; - withdraw consent (to analytics and marketing) at any time — this does not affect the lawfulness of processing before withdrawal; - for EU users — receive your data in a structured format (data portability); - lodge a complaint: in Ukraine — with the Ukrainian Parliament Commissioner for Human Rights; in EU countries — with your national data protection authority (for example, UODO in Poland). To exercise your rights, write to **office@renovahospitality.net**. We respond within 30 days. --- ## 8. CHILDREN The Site is intended for entrepreneurs and is not directed at persons under 18. We do not knowingly collect children's data. --- ## 9. CHANGES TO THIS POLICY We may update this Policy. The current version is always available on the Site with the date of the last update. We will announce material changes on the Site. --- ## 10. CONTACT - **Company:** RENOVA Hospitality, Kyiv, Ukraine - **Email:** office@renovahospitality.net - **Website:** renovahospitality.net