Privacy Policy

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Comes into force from 25.05.2018

The Privacy Policy (hereinafter the Policy) defines the legal basis for processing personal data during the use of the website and Tucha Virtual Infrastructure Services (Sections No. 01-15 of this Policy):

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Section No. 01 Terms and Definitions
  1. Personal data - any information related to a private person by which such a private person is identified or can be identified
  2. Processing - an operation or series of operations with personal data
  3. Controller - a person who determines the purposes and means of processing personal data. According to this Policy, this is the Contractor
  4. Operator - a person who processes personal data on behalf of the Controller
  5. Data subject - a private person whose personal data is processed
  6. Business entity - a private person, legal entity, and organizational unit that is not a legal entity that, according to the legislation carry out business or professional activities on their own behalf
Section No. 02 Information about the Contractor

1. The following Tucha cloud solution providers can be the Contractor:

1.1.   LIMITED LIABILITY COMPANY "KHMARA" company is registered in Ukraine, EDPNOU code 39481519 - the Controller responsible for the processing of personal data;

1.2.   LIMITED LIABILITY COMPANY "UPTIME" company is registered in Ukraine, EDPNOU code 37038333 - the Controller responsible for the processing of personal data;

1.3.   SOLE PROPRIETORSHIP SUKHOBOK KATERYNA VOLODYMYRIVNA registered in Ukraine, Registration number of taxes, and other liabilities payer's registry card 2974809628  - the Controller responsible for the processing of personal data;

1.4.   SOLE PROPRIETORSHIP MELNYK VOLODYMYR MYKOLAIOVYCH registered in Ukraine, Registration number of taxes and other liabilities payer's registry card 2915401614 - the Controller responsible for the processing of personal data;

2. Means of communication regarding confidentiality: 

3. email address:;

4. Data Protection Officer - Melnyk Volodymyr Mykolaiovych, email address:

Section No. 03 This Policy is an integral part of such documents
  1. Public Agreement (offer) for the provision of services for temporary use of the virtual infrastructure of Tucha 
  2. The contractual obligation that binds the Contractor to the data subject and/or business entity
Section No. 04 Personal data that shall be processed
  1. Personal data about a private person:
    1.    Surname, name, patronymic name
    2.    Place of residence: postal code, region, locality, street, house, building, office, apartment
    3.    Actual address (address for correspondence): postal code, region, locality, street, house, building, office, apartment
    4.    Email address
    5.    Telephone
    6.    Registration number of the taxpayer's registration card or series and number of the passport for persons who refuse to accept the registration number of the taxpayer's registration card due to their religious or other beliefs and have a mark in the passport
    7.    Bank details (account number, bank name, MFO)
    8.    Data used for verifying an e-signature
    9.    Symbols that identify the end of the telecommunications network
    10.    Data subject identification markers based on the data specified in clause 1
  2. Information about the business entity:
    1.    Information about the business entity and their officials are public data
  3. Contact persons
    1.    Surname, name, patronymic name
    2.    Email address
    3.    Telephone
Section No. 05 Receiving personal data
  1. The Contractor does not independently collect personal data of the data subjects
  2. Personal data is provided to the Contractor by the data subject or business entity independently and voluntarily during the establishment of business relations
  3. The Contractor receives personal data from the data subject or business entity when establishing the business relationship and concluding the document defined in Section No. 03
  4. When using the site
    1. Cookies are processed in the order defined by the Політикою про файли Cookies
    2. Site may contain links to third-party sites (this Policy does not apply to such sites. We recommend to read the privacy policy on these sites separately)
  5. The Contractor does not establish business relations with the data subjects who have not reached the age of majority
  6. This Policy applies to personal data of the Contact persons
    1.    The business entity takes sufficient and effective measures that would reach this Policy to the data subjects which are identified as the Contact persons
Section No. 06 Grounds for processing personal data
  1. Processing is carried out for the execution of the Document in accordance with Section No. 03, or for the establishment of the business relationship and the conclusion of such a document
  2. To comply with the legal obligation that extends to the Contractor
  3. Consent of the data subject for the processing of the personal data for one or more special purposes
  4. Processing is necessary for the legitimate interests of the Сontractor, except cases when the interests of the fundamental rights and freedoms of the data subject prevail over such interests
Section No. 07 Purposes of personal data processing
  1. Execution of the Document in accordance with Table No. 03, in particular, but not exclusively implies communication with you, for that purpose we may use personal data to communicate with you. For example, to inform you about a change in the services or to send you important messages and other similar messages that relate to the order that you have made and to contact you for the purpose of servicing and executing the Document.
  2. The execution of the obligation prescribed by legislation, which extends to the Contractor, the requirements of tax and labour legislation; accounting; court decisions, etc
  3. The execution for the legal interests of the Contractor, - examination of the functioning of the site and services; development of new services; business expansion; protection of the Virtual Infrastructure; compliance with the economic interest of the Contractor, etc
  4. Special purposes - marketing, advertising, social networks are performed with the consent of the data subject, clause 3, Section No. 06
  5. Change of the processing purposes
    1.    Change of the processing purposes of the personal data processing is carried out by setting out this Policy in a new version
  6. The Contractor as the Operator:
    1.    The Contractor may be the Operator. Processing of the personal data by the Contractor as the Operator is carried out in the name of the Controller in accordance with the Data Processing Agreement
    2.    This Policy is mandatory for the Contractor as the Controller and as the Operator
Section No. 08 Security measures
  1. Personnel:
    1.    formed corporate culture and values
    2.    authorized and sector access of the personnel to the personal data in the Contractor's CRM system
    3.    privacy mode
  2. Technical:
    1.    use of geographically distributed data centers with the level not lower than Tier III
    2.    authentication system
    3.    network control – block of the unauthorized traffic
    4.    implemented system logs
    5.    backups
Section No. 09 Disclosure of personal data
  1. For the protection of the rights and interests of the Contractor
  2. For the prevention, detection and counter fraud
  3. For the protection against improper use, illegal or unauthorized use of the site and Virtual Infrastructure Services of Tucha
  4. For the compliance with any legal obligation that may arise in response to any judicial or similar official request for personal data
  5. If the other is required by applicable legislation (for example, under anti-money laundering legislation)
  6. Personal data is not transferred to third parties without the individual consent of the data subject
Section No. 10 Personal data maintenance
  1. Personal data is stored for the period of execution of the Document under Section No. 03 or fulfillment of the goals under Section No. 07
  2. After the termination of the Document under Section No. 03 or the completion of the goals under Section No. 07, personal data will be deleted automatically after 10 years
  3. Data may be stored for more than 10 years if the dispute is resolved in court. In this case, the personal data will be deleted after full implementation of the relevant court decision
Section No. 11 Rights of data subjects
  1. Right to access personal data
  2. Right to correct/erase personal data
  3. Right to withdraw personal data
  4. Right to object the processing of personal data
  5. Right to restrict the processing of personal data, in the following cases:
    1.    to clarify personal data;
    2.    if personal data is used without legal grounds, but you do not wish to exercise the right to delete your personal data
    3.    if there is a need to store personal data after the conditions under clause 2 of Section No.10, however, the data subject needs them to establish, implement or protect legitimate claims
    4.    in case of the execution of the right to object the processing of personal data at the time of verification by the Contractor, if there is an overwhelming legal basis for the processing of personal data 
  6. Right to transfer the personal data of the data subject or to the third party identified by the data subject
  7. Right to withdraw consent for the processing of personal data at any time, if the data is processed on the basis of such consent
  8. Exercise of the rights in accordance with clauses 1-7 is free of charge
  9. The Contractor has the right to charge a reasonable fee if the request is clearly unfounded, repetitive or excessive
    1.    Alternatively, the Contractor can refuse to execute the request in these circumstances
Section 12 Time for processing the data subject's request
  1. The Contractor processes the data subject's request within one month
  2. If the request takes longer to process, the data subject will be further informed
Section No. 13 Generation of complaints
  1. In the case of disputes between the Contractor and the data subject, as well as with the participation of the third parties, the Contractor will take all legal and ethical measures to protect the legal and ethical interests of the data subject
  2. The supervisory authority for personal data protection:
    1.    Commissioner of the Verkhovna Rada of Ukraine for human rights (website address:; address: 01008, m. Kyiv, vul. Instytutsʹka, bud. 21/8, hotline: 044-253-75-89; 0800-50-17-20 (free of charge))
Section No. 14 Documents regulating the processing of personal data
  1. Law of Ukraine "On Telecommunications"
  2. Law of Ukraine "On Personal Data Protection"
  3. Rules for providing and receiving telecommunications services
  4. International legal acts ratified by Ukraine or having extraterritorial effect
Section No. 15 Update of this Policy
  1. The Contractor has the right to change, add and/or issue part of this Policy at any time
  2. For data subjects with whom the business relationships are established, the Contractor will take all reasonable steps to inform about the update of this Policy. Such messages will be made taking into account technical and other capabilities
  3. For data subjects with whom the business relationship has not been established, we recommend checking updates of this Policy regularly
  4. The Policy published on the Site is current
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