Privacy Policy

This Policy explains what personal data is collected through sunnyct.com, why, who it is shared with, how long it is kept and what rights you have. It is based on the Constitution of Ukraine and the Law of Ukraine “On Personal Data Protection” No. 2297-VI (the “Law”) and constitutes the notice that Article 12(2) of the Law requires at the moment data is collected.

This English version is provided for convenience. In case of any discrepancy, theUkrainian version prevails.

1. Data controller

The controller of your personal data is Oleksandr Skrypnyk, founder of SunNY Consulting.

• Address: Naberezhna Peremohy 124, Dnipro, Ukraine
• E-mail: alex@sunny.net.ua
• Phone: +38 (067) 679-66-88

Please send any question about your personal data to this e-mail address.

2. What data we collect

Data you provide when you fill in a request form on the site:

• name — required;
• phone number — required;
• e-mail address — required;
• company name — optional;
• industry — in the form of the “Contact” section;
• description of your challenge — optional.

If you contact us directly — by phone, e-mail, Telegram or LinkedIn — we process the data you share in that message.

Technical data. The web server hosting the site automatically keeps request logs: IP address, date and time of the request, the page requested, browser and device type. These records keep the site stable and secure and are not used to identify you.

The site uses no cookies, analytics or advertising trackers — see Cookies for details.

We do not collect, and ask you not to send through the forms, special categories of data (health, religious or political beliefs, etc. — Article 7 of the Law) or payment card details.

3. Purposes of processing

• to get back to you about your request and hold a consultation;
• to prepare a proposal, and to conclude and perform a consulting services agreement;
• to correspond with you about your enquiry;
• to keep the site secure and operational (technical logs).

We do not send marketing e-mails without your separate consent, we do not sell personal data, and we do not make decisions about you based solely on automated processing.

4. Legal grounds

Under Article 11 of the Law we process data on the following grounds:

• your consent, given by ticking the box in the request form — the form sends no data before that;
• steps taken at your request prior to entering into an agreement, and performance of the agreement;
• compliance with legal obligations (for example, accounting and tax records if we sign an agreement);
• the controller’s legitimate interest in protecting the site from abuse (technical logs).

5. Who receives the data

Access to your data is limited to those needed to achieve the purposes above:

• Web3Forms (operated by Web3Creative, India; servers on Amazon Web Services in the USA) — the service that receives form submissions and forwards them to the controller’s e-mail;
• the controller’s mail server (sunny.net.ua domain), where requests and correspondence are stored;
• the hosting provider whose servers host the site and its technical logs;
• public authorities — only in the cases and in the manner expressly required by law.

No other third parties have access to your data.

6. International transfers

Form data passes through Web3Forms servers in the USA. The USA is not among the states that Article 29(3) of the Law recognises as providing an adequate level of personal data protection. The transfer is therefore based on yourunambiguous consent (Article 29(4)(1) of the Law), which you give by ticking the box in the form.

If you do not want your data transferred abroad, do not use the form — call or write to us directly:alex@sunny.net.ua, +38 (067) 679-66-88.

7. Retention

• requests and business correspondence — until the purpose is achieved, but no longer than 3 yearsafter our last interaction, or until you withdraw consent, whichever comes first;
• if an agreement is signed — for its term plus the document retention periods set by law;
• web server technical logs — no longer than 30 days;
• Web3Forms keeps its service records under its own rules.

When the period expires, the data is deleted or destroyed (Article 15 of the Law).

8. Security

We take organisational and technical measures to protect data against accidental loss, destruction and unlawful processing (Article 24 of the Law): data is encrypted in transit (HTTPS), only the controller has access to requests, and accounts are password-protected. No method of transmission over the Internet is, however, completely secure.

9. Your rights

Under Article 8 of the Law you have the right to:

• know the sources and location of your data, the purpose of processing and the controller’s location;
• receive information on the conditions of access to your data, including the third parties it is shared with;
• access your data and, within 30 calendar days, learn whether it is processed and what it contains;
• submit a reasoned objection to the processing of your data;
• demand that your data be changed or destroyed if it is processed unlawfully or is inaccurate;
• have your data protected against unlawful processing, accidental loss, destruction or damage;
• set restrictions on the processing when giving consent;
• withdraw your consent;
• know how any automated processing works and be protected from automated decisions with legal effects;
• complain to the Ukrainian Parliament Commissioner for Human Rights or to a court.

10. How to exercise your rights

Send a request to alex@sunny.net.ua. So that we can identify you and act on it, include your name, the contact you used in your request and what you are asking for: access, correction or deletion of data, or withdrawal of consent (Article 16 of the Law).

Within 10 working days we will tell you whether the request will be fulfilled, and we will fulfil it within 30 calendar days of receipt. Withdrawing consent does not affect the lawfulness of processing before the withdrawal.

11. Complaints

If you believe your rights have been violated, you may contact the Ukrainian Parliament Commissioner for Human Rights, who supervises compliance with personal data protection law (ombudsman.gov.ua), or go to court. We would appreciate the chance to resolve the issue first — please write to us.

12. Changes to this Policy

We may update this Policy, for example when the law or the services used by the site change. The new version is published on this page with its date. If the purpose of processing changes, we will ask for your consent again (Article 6 of the Law).