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PERSONAL DATA PROCESSING AGREEMENT

1. Subjects, terms, and purpose of processing2. Categories of personal data being processed3. Legal grounds for processing4. Retention periods for personal data5. Transfer of personal data to third parties6. Cross-border transfer of personal data7. Cookies and similar technologies8. Marketing communications9. User Rights10. Measures for the protection of personal data11. Processing of minors' data12. Changes to the Agreement13. Contact Information14. Final Provisions

Effective date: [04.18.2026] Last revision: [04.18.2026]

This Personal Data Processing Agreement (the "Agreement", "Privacy Policy") defines the terms and conditions for the collection, storage, use, transfer, and protection of the User's personal data provided during the use of the website https://reds.cloud and related subdomains (the "Site").

By using the Site and/or providing any information through feedback forms, registration, ordering services, or in any other way, the User confirms that they have read the terms of this Agreement and consents to the processing of their personal data in accordance with the terms defined herein.

The processing of personal data is carried out in accordance with:

  • The Law of Ukraine "On Personal Data Protection" No. 2297-VI dated 01.06.2010 (hereinafter referred to as "PDPA");
  • General Data Protection Regulation (Regulation (EU) 2016/679, hereinafter referred to as "GDPR");
  • other applicable legislation of Ukraine.

1. Subjects, terms, and purpose of processing

1.1. The owner of personal data (Administrator / Controller): LLC "REDS CLOUD", EDRPOU code: 42645262, contact e-mail: tls@reds.cloud, phone: 067 744 55 22.

1.2. User (Subject of personal data) — an individual who visits the Site, uses the services of REDS CLOUD, and/or voluntarily provides their personal data through the Site.

1.3. Personal data — information or a set of information about an individual who is identified or can be specifically identified.

1.4. Processing of personal data — any action or set of actions performed with personal data, including collection, registration, accumulation, storage, adaptation, modification, renewal, use, and distribution (dissemination, implementation, transfer), depersonalization, destruction.

1.5. Purpose of processing personal data:

  • identification of the User and providing access to REDS CLOUD services;
  • conclusion, execution, and support of service agreements;
  • processing requests, applications, orders, and inquiries to the support service (ticket system);
  • communication with the User regarding technical and service issues;
  • billing and maintaining accounting and tax records;
  • ensuring the security of the Site and services, preventing fraud;
  • fulfilling obligations stipulated by the legislation of Ukraine;
  • sending marketing and informational materials (exclusively with the separate consent of the User);
  • analytics and improving the quality of the Site and services.

2. Categories of personal data being processed

2.1. The Owner may process the following categories of data:

  • first name, last name, patronymic;
  • email address;
  • contact phone number;
  • company name, position (for corporate clients);
  • payment information (account number, billing data) — without storing full payment card details;
  • IP address, type and version of the browser, operating system;
  • cookies and session identifiers;
  • service usage history and support requests;
  • other information provided by the User voluntarily.

2.2. Sources of data collection:

  • forms on the Site (registration, contact forms, orders);
  • ticket support system;
  • automatic collection by technical means (cookies, analytical tools);
  • during payment for services through payment systems.

**2.3. The Owner does not collect or process special categories of personal data (racial or ethnic origin, political opinions, religious beliefs, health status, biometric data, etc.), unless the User has provided them voluntarily on their own initiative.

3. Legal grounds for processing

3.1. Personal data processing is carried out on the following legal grounds:

  • User consent (Article 11 of the Law on Personal Data Protection, Article 6(1)(a) GDPR) — for marketing purposes, non-technical cookies;
  • performance of a contract (Article 11 of the Law on Personal Data Protection, Article 6(1)(b) GDPR) — for providing services, billing, technical support;
  • compliance with legal obligations (Article 11 of the Law on Personal Data Protection, Article 6(1)(c) GDPR) — for accounting, tax reporting, responding to requests from government authorities;
  • legitimate interest of the Owner (Article 6(1)(f) GDPR) — to ensure the security of the Site, prevent fraud, analytics.

3.2. User consent is free, specific, informed, and unambiguous. The User has the right to withdraw consent at any time, which does not affect the legality of processing prior to the withdrawal.

4. Retention periods for personal data

4.1. The Owner retains personal data no longer than necessary to achieve the purposes of processing:

  • data of active clients — for the entire duration of the service agreement;
  • after the termination of services — for 3 (three) years to resolve possible disputes;
  • accounting and tax documents — in accordance with the requirements of Ukrainian legislation (usually no less than 3 years, for certain documents — up to 1095 days or more);
  • data for marketing purposes — until the User withdraws consent;
  • technical logs and security journals — for up to 12 months;
  • support requests — for up to 2 years after the ticket is closed.

4.2. After the retention period expires, the data is deleted or anonymized.

5. Transfer of personal data to third parties

5.1. The Owner does not transfer personal data to third parties without the User's consent, except in cases:

  • when it is necessary to fulfill the contract (hosting and infrastructure partners, payment systems);
  • when it is provided for by current Ukrainian legislation (requests from law enforcement agencies, courts);
  • when it is necessary to protect the rights and legitimate interests of the Owner or third parties.

5.2. Categories of recipients to whom data may be transferred:

  • infrastructure partners (including OVHcloud SAS — for hosting services in data centers);
  • payment providers — for processing payments;
  • providers of analytical and technical services (in compliance with data protection requirements);
  • accounting and legal consultants — as needed.

5.3. All involved third parties (personal data processors) operate based on written contracts that comply with the requirements of Article 4 of the Law on Personal Data Protection and Article 28 of the GDPR.

6. Cross-border transfer of personal data

6.1. REDS CLOUD services may be provided using server infrastructure located in various countries: Ukraine, Poland, Germany, France, the United Kingdom, the USA, Canada, Singapore. The choice of location is made by the User when ordering the service.

6.2. The transfer of personal data to EU/EEA countries is carried out based on a decision on an adequate level of protection (for EU countries) or appropriate safeguards.

6.3. The transfer of data to countries outside the EU/EEA (USA, Canada, Singapore, the United Kingdom) is carried out using appropriate safeguards provided for in Article 46 of the GDPR, including Standard Contractual Clauses, as well as in compliance with the requirements of Article 29 of the Law on Personal Data Protection.

6.4. By choosing a server location outside of Ukraine, the User consents to the corresponding cross-border transfer of data.

7. Cookies and similar technologies

7.1. The site uses cookies — small text files stored on the User's device to ensure the functionality of the Site and improve service quality.

7.2. Types of cookies used:

  • Necessary (technical) cookies — provide basic functionality of the Site, authorization, security. Do not require User consent.
  • Functional cookies — remember User settings (language, region).
  • Analytical cookies — collect anonymized information about the use of the Site to improve the service. Used with User consent.
  • Marketing cookies — used for personalizing advertisements. Used only with separate User consent.

7.3. The User can manage cookies through browser settings (block, delete, limit storage). Disabling some cookies may affect the functionality of the Site.

7.4. By continuing to use the Site without changing cookie settings, the User confirms consent to the use of cookies in accordance with this section.

8. Marketing communications

8.1. The Owner may send the User informational and advertising messages (news, promotional offers, information about new services) only with separate voluntary consent.

8.2. Consent to marketing communications is provided separately (for example, through a separate checkbox in the form) and is not a condition for providing basic services.

8.3. The User has the right to refuse to receive marketing messages at any time:

  • by following the “unsubscribe” link in the email;
  • by sending a corresponding request to the e-mail: tls@reds.cloud;
  • through the personal account on the Site.

8.4. Service messages (regarding the status of services, accounts, account security) are sent regardless of consent to marketing, as they are necessary for the performance of the contract.

9. User Rights

9.1. According to Article 8 of the Law of Ukraine on Personal Data Protection and Articles 15–22 of the GDPR, the User has the following rights:

  • the right to information about the processing of their personal data;
  • the right of access to their personal data;
  • the right to rectification of inaccurate or incomplete data;
  • the right to erasure of data (“the right to be forgotten”);
  • the right to restriction of processing in cases provided by law;
  • the right to data portability — to receive data in a structured, machine-readable format;
  • the right to object to processing, including for direct marketing purposes;
  • the right to withdraw consent at any time;
  • the right not to be subject to automated decision-making, including profiling;
  • the right to lodge a complaint with a supervisory authority (the Commissioner of the Verkhovna Rada of Ukraine for Human Rights or the relevant EU authority at the place of residence).

9.2. To exercise their rights, the User can contact the Controller via e-mail: tls@reds.cloud.

9.3. The Controller reviews the User's request and provides a response within 30 (thirty) calendar days from the moment of receipt. In complex cases, the period may be extended to 60 days with prior notification to the User.

9.4. The consideration of appeals is carried out free of charge, except in cases where requests are clearly unreasonable or excessive.

10. Measures for the protection of personal data

10.1. The owner applies appropriate technical and organizational measures to protect personal data from unauthorized access, accidental loss, destruction, alteration, or disclosure, including:

  • data encryption during transmission (SSL/TLS) and storage;
  • access control and user authentication;
  • regular backups;
  • security monitoring and incident detection;
  • training employees on data protection;
  • physical protection of server equipment;
  • entering into non-disclosure agreements with employees and contractors.

10.2. In the event of an incident that leads to a breach of personal data protection, the owner takes measures to eliminate it and, if necessary, notifies the user and competent authorities in accordance with legal requirements (within 72 hours according to GDPR).

11. Processing of minors' data

11.1. The REDS CLOUD website and services are intended for individuals who are 18 years of age or older. The owner consciously does not collect personal data from individuals under 18 years of age without the consent of their parents or legal representatives.

11.2. If the owner becomes aware of the collection of data from a minor without proper consent, such data will be deleted.

12. Changes to the Agreement

12.1. Володілець залишає за собою право вносити зміни до цієї Угоди. Актуальна версія Угоди завжди доступна за адресою: https://reds.cloud/privacy (or the relevant link).

12.2. Users are notified of significant changes via the Site and/or email at least 14 days before they take effect.

12.3. Continuing to use the Site after the changes take effect means the User accepts the new version of the Agreement.

13. Contact Information

For questions regarding the processing of personal data and the exercise of rights, the User can contact:

  • Owner: LIMITED LIABILITY COMPANY “REDS CLOUD”
  • EDRPOU Code: 42645262
  • Email for inquiries regarding personal data: tls@reds.cloud
  • Support Service: ticket system on the Site
  • Phone: 067 744 55 22

Supervisory authority in Ukraine: The Commissioner of the Verkhovna Rada of Ukraine for Human Rights Address: 01008, Kyiv, Instytutska St., 21/8 Website: https://www.ombudsman.gov.ua

14. Final Provisions

14.1. This Agreement is governed by the legislation of Ukraine. All disputes are subject to resolution in accordance with the current legislation of Ukraine.

14.2. If any provision of this Agreement is found to be invalid, it does not affect the validity of the other provisions.

14.3. This Agreement is an integral part of the service provision contract with REDS CLOUD.