Privacy Policy

1. Who we are

Назва компанії (“Назва компанії”, “we”, “us”, “our”) operates the website pratsivnyk.com and the related client dashboard (together, the “Platform”), through which we help candidates find employment and relocate for work to Ukraine, Armenia, Moldova and the European Union, and through which we work with a network of partner agents.

Data controller: ТОВ «Назва компанії», registered address at Адреса не вказана, registration number 00000000 (“Назва компанії”).

This Privacy Policy explains what personal data we collect from clients, candidates, partners and website visitors, why we collect it, who we share it with, and the rights you have over it.

2. Scope of this policy

This policy applies to personal data processed through:

• The public website at pratsivnyk.com;
• The client questionnaire and case dashboard;
• Communications by phone, email, messaging apps (including WhatsApp) and in person;
• The services agreement and its annexes signed with clients; and
• Applications and referrals submitted by or through partner agents.

It does not cover third-party websites we may link to, such as employer career pages, which are governed by their own privacy notices.

3. Personal data we collect

3.1 Data you provide directly

• Identity and contact data: full name, date of birth, phone number, email address, home address.
• Identification and immigration data: passport details and copies, national ID, and other documents needed for employment, visa or consular processes.
• Professional data: resume/CV, work history, qualifications, references, and a photograph.
• Case data: your completed questionnaire (Annex No. 1 to the services agreement), the signed agreement itself, and correspondence about your case.
• Payment data: billing details and records of instalments paid; we do not store full card numbers ourselves (see section 7).

3.2 Data collected automatically

• Technical data: IP address, browser type, device identifiers, and pages visited on the Platform, collected via cookies and similar technologies (see section 10).

3.3 Data about partners

• Contact and business details of agents and recruiters who join our partner network, and records of the candidates they refer, for the purpose of tracking referrals and paying commission.

3.4 Data from other sources

• Where a candidate is referred by a partner agent, we receive the candidate’s contact details and initial profile information from that partner.

4. Why we process your data, and on what legal basis

We process personal data for the following purposes:

• To match candidates with suitable vacancies and assess eligibility — performance of the services agreement.
• To prepare and verify documents, and to support visa or consular applications — performance of the services agreement and, where applicable, compliance with legal obligations.
• To arrange accommodation — performance of the services agreement.
• To administer staged payments and maintain financial records — performance of the services agreement and legal obligations (accounting, tax).
• To communicate with you about your case — performance of the services agreement and our legitimate interest in providing responsive support.
• To operate, secure and improve the Platform — our legitimate interest in running a reliable service.
• To calculate and pay partner commissions — performance of the partner agreement.
• To send marketing communications about new vacancies or services — your consent, which you may withdraw at any time.
• To comply with legal, regulatory and law-enforcement requests — legal obligation.

Where local law (including the EU General Data Protection Regulation, for candidates relocating to the EU) requires a specific legal basis for a given processing activity, that basis controls, and we will identify it on request.

5. Who we share your data with

We disclose personal data only as needed to deliver the service, and never sell it. Recipients may include:

• Prospective employers, to the extent needed to match and place a candidate;
• Landlords, letting agents or accommodation providers, to arrange housing;
• Government, immigration, consular and visa authorities, where required for a work or travel authorisation;
• Payment processors and banks, to collect and confirm instalments;
• Partner agents, limited to the status of cases they referred;
• IT and hosting providers who process data on our behalf under a data processing agreement; and
• Professional advisers, auditors and authorities, where required by law or to establish, exercise or defend legal claims.

Consistent with the services agreement, we do not disclose your information to third parties beyond what is needed to perform that agreement, and we do not guarantee the decisions made by employers or by consular or immigration authorities — those decisions are outside our control.

6. International data transfers

Because our services involve relocation between Ukraine, Armenia, Moldova and EU/EEA countries, personal data is routinely transferred across borders to employers, accommodation providers and authorities in the destination country. Where we transfer personal data of an EU/EEA-based data subject outside the EU/EEA, we rely on the appropriate safeguard available under GDPR (such as an adequacy decision or standard contractual clauses) and will provide details on request.

7. Payment data

Card and bank payment details are processed by our payment service provider(s) and are not stored in full on our own systems. We retain only the records needed to confirm each instalment against your case, as described in the services agreement.

8. How long we keep your data

We keep personal data for as long as needed to deliver the service and for a period afterwards to meet legal, accounting, tax and dispute-defence obligations. As a general rule:

• Signed agreements, questionnaires and financial records: retained for 7 years after the case closes, to meet statutory recordkeeping requirements.
• Passport copies and other identity documents: retained only for the duration of the case, then securely deleted unless a longer period is required by law.
• Marketing consent records: kept until you withdraw consent, and for a short period afterwards to evidence that withdrawal.

Where you ask us to delete your data sooner, we will do so unless we are required or entitled to keep it (see section 9).

9. Your rights

Subject to applicable law (including Ukrainian data protection law and, where relevant, the GDPR), you have the right to:

• Access the personal data we hold about you;
• Correct inaccurate or incomplete data;
• Request erasure of your data, subject to our legal and contractual retention needs;
• Restrict or object to certain processing, including direct marketing;
• Receive a copy of your data in a portable format;
• Withdraw consent at any time, without affecting processing carried out before withdrawal; and
• Lodge a complaint with your local data protection authority.

To exercise any of these rights, contact us using the details in section 13. We may need to verify your identity before acting on a request.

10. Cookies and similar technologies

The Platform uses cookies and similar technologies to keep you signed in, remember your preferences, and understand how the site is used. You can control cookies through your browser settings; disabling some cookies may limit parts of the Platform, such as staying logged in to your case dashboard.

11. Security

We apply technical and organisational measures appropriate to the sensitivity of the data we hold — including access controls, encryption in transit, and confidentiality obligations on our staff and partners — to protect personal data against unauthorised access, loss or misuse. No system is completely secure, and we cannot guarantee absolute security.

12. Children’s data

The Platform is intended for adults seeking employment abroad. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will delete it.

13. How to contact us

For questions about this policy or to exercise your rights, contact us at:

• Email: info@example.com
• Phone: +380 00 000 00 00
• Postal address: Адреса не вказана

14. Changes to this policy

We may update this Privacy Policy from time to time, for example to reflect changes in our services or in the law. We will post the updated version on this page with a new “Last updated” date, and where changes are material we will take reasonable steps to notify active clients and partners.