Gnome Agency respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we use and look after your personal data when you visit our website (regardless of where you visit it from).

Please also use the Glossary at the end of this privacy policy to understand the meaning of some of the terms used in this privacy policy.

Purpose of this privacy policy and who we are

This privacy policy aims to give you information on how Gnome Agency collects and processes your personal data through your use of this website, https://gnomeagency.com/  including any data you may provide through our website when you 

• contact us through the contact form on our website, https://gnomeagency.com/pages/contact-us
• leave your request by filling in the form on the pages of our website https://gnomeagency.com/
• contact us via post or our email hello@gnomeagency.com
• chat with us on WhatsApp (whatsapp://send/?phone=380683430034)
• purchase a service from us directly.

 

Controller

Mykhailo Syrotiuk, owner of Gnome Agency is the controller and is responsible for your personal data (collectively referred to as "Gnome Agency," "we," "us" or "our" in this privacy policy).
If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact Mykhailo Syrotiuk using the details set out below.

Full name of an individual entrepreneur: Mykhailo Syrotiuk
Email address: hello@gnomeagency.com
Postal address: Ukraine, Lviv, Velychkovskogo St. 10/50, 79002

 

Changes to this privacy policy 

We keep our privacy policy under regular review. This version was last updated on 9th January 2023

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name; last name;
• Contact Data includes billing address; email address; telephone numbers;
• Technical Data includes internet protocol (IP) address; the time and date the services were used; browser type and version; time zone setting and location; browser plug-in types and versions; operating system and platform and other technology on the devices you use to access the services; error data;
• Profile Data includes purchases or orders made by you; your feedback about our services;
• Usage Data includes information about how you use our services including how you interact with our products; we receive and analyze content, communications, and information that you provide when you use our services.

We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity Data, Contact Data, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you: 
apply for or use our services
give us feedback or contact us

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below: 

• analytics providers such as Google;
• advertising networks such as Facebook;
• search information providers such as Google
• Contact Data, Financial Data, and Transaction Data from providers of technical and payment services.

 

In the event our site contains links to third-party sites and services, please be aware that those sites and services have their own privacy policies. After following a link to any third-party content, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to any of your activities after you leave our site.

 

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• For the performance of a contract, we are about to enter or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Please read Glossary, Lawful Basis below to find out more about the types of lawful basis that we will rely on to process your personal data. Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your data. 

Third-party marketing

We will not share your personal data with any third party for marketing purposes.
 

Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out above:

• Third parties who provide payment gateway services.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

Data retention. How long will we use your personal data?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances you can ask us to delete your data, please read Your legal rights below for further information.
In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. 

 

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see “YOUR LEGAL RIGHTS” below to find out more about these rights. If you wish to exercise any of these rights, please contact us at hello@gnomeagency.com

No fee is usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed
to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated. 

 

Glossary

LAWFUL BASIS

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering such a contract.

Complying with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

 

YOUR LEGAL RIGHTS

You have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request rectification of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request the erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. 
• Right to withdraw consent at any time where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. 
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.