Privacy Policy

Please read this Privacy Policy ("Policy") carefully to understand our principles regarding the processing of your Personal Data. This Policy applies to individuals who interact with LLC "ENERGY TRADE GROUP" (hereinafter referred to as ETG.UA) as consumers ("You"). This Policy explains how your Personal Data is collected, used, and disclosed by ETG.UA ("the Company", "We", "Us", or "Our"). It also describes how You can access, update, and choose how We use your Personal Data.

This Policy covers both our online and offline activities, including Personal Data that We collect through various channels such as websites, applications, social media, consumer interaction services, regional offices, and various events. Please note that We may collect Personal Data from different sources (websites, marketing activities, and events). Accordingly, We may combine Personal Data initially collected by different departments or partners. Please see Section 8 of this Policy for more information on how You may object to this.

If You do not provide the required Personal Data (We will notify You when this is the case, for example, by indicating this in registration forms), We will not be able to provide You with our products and/or services for which such data is required. This Policy may be updated from time to time (see Section 10).

This Policy contains important information on the following topics:

1. SOURCES OF PERSONAL DATA
2. WHAT PERSONAL DATA WE COLLECT AND HOW WE DO THIS
3. COOKIES/SIMILAR TECHNOLOGIES, LOG FILES, AND WEB BEACONS
4. USE OF YOUR PERSONAL DATA
5. DISCLOSURE OF YOUR PERSONAL DATA
6. USE OF PERSONAL DATA
7. STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA
8. ACCESS TO YOUR PERSONAL DATA
9. CHOICE ON HOW WE USE AND DISCLOSE YOUR PERSONAL DATA
10. CHANGES TO OUR POLICY
11. PERSONAL DATA OWNER (CONTROLLER)

1. SOURCES OF PERSONAL DATA

This Policy applies to Personal Data that We receive from or about You through the methods described below (see Section 2) from the following sources:

Websites. Consumer-directed websites operated by ETG.UA, including websites We operate under our own domains/URLs and pages we run on social media platforms such as Facebook ("Websites").

Mobile applications. Consumer-directed applications operated by ETG.UA, such as smartphone applications.

Email, text, and other electronic messages. Interactions between You and ETG.UA through electronic communications.

Regional offices. Communication with our Consumer Interaction Center.

Registration forms. Electronic, paper, or similar forms We collect via mail, at events, promotions, or campaigns.

Interaction with our advertisements. If You interact with our ads (e.g., on third-party websites), We may receive data regarding such interaction.

Data We create. During our interactions with You, We may generate Personal Data about You (e.g., information on purchases made on our Websites).

Data from other sources. Social media platforms (e.g., Facebook, Google), marketing research (if feedback is not provided anonymously), third-party data aggregators, ETG.UA’s partners in promotions, public sources, and data acquired through company purchases.

2. WHAT PERSONAL DATA WE COLLECT AND HOW WE DO THIS

Depending on how You interact with ETG.UA (online, offline, by phone, etc.), We collect different types of information as described below:

Personal contact information. Any information You provide to enable Us to contact You, such as name, mailing address, email address, social media details, or phone number.

Account login information. Information needed to access your account (e.g., email address, username, account number, password, and/or security question and answer).

Demographic information and interests. Information describing your demographics and behavior (e.g., date of birth, age or age range, gender, location, favorite products, hobbies, interests, and lifestyle).

Computer/mobile device information. Data about the computer system or device You use to access our Websites or applications (e.g., IP address, operating system, browser type/version). For mobile access, also device ID, advertising ID, geolocation, and similar device data when permitted.

Website usage information. Data automatically collected during your use of our Websites (e.g., link clicks, pages/content viewed, duration of visits, response times, errors, etc.) via technologies like cookies and web beacons. See Section 4 for opt-out details.

Market research and consumer feedback. Voluntary feedback You share regarding your experience with our products and services.

Consumer-generated content. Content You create and share with Us via social media or upload to our Websites or applications (e.g., photos, videos, stories). We may collect and share such content in connection with events, contests, or promotions where permitted.

Social media information. Any publicly shared or profile information from social media networks that You allow them to share with Us (e.g., name, email, gender, birthdate, city, profile photo, friends list, etc.). We receive such data when You interact with our social media pages, plugins (e.g., Facebook Connect), or contact Us through social media platforms.

Payment and financial information. Data needed to fulfill orders or complete purchases (e.g., cardholder name, card number, expiry date), processed in compliance with applicable laws and security standards.

Call center and regional office recordings. Communication with our Consumer Interaction Center may be recorded or monitored for operational purposes (e.g., quality control, training), excluding card payment data.

Sensitive Personal Data. We do not seek to process sensitive data during standard operations. If required, We rely on your prior explicit consent or legal grounds such as (i) crime detection/prevention (including fraud) and (ii) legal compliance.

3. COOKIES / SIMILAR TECHNOLOGIES, LOG FILES, AND WEB BEACONS

Cookies / Similar Technologies. See our Cookie Policy for detailed information about the cookies We use, how to manage your settings, and their purpose.

Log files. We collect website activity data in log files for statistical and technical analysis, including page visits, troubleshooting, and security improvements.

Web beacons. Also called "web bugs", these small code strings are embedded in websites or emails to collect data such as IP addresses, email open times, link clicks, etc. We use them for site traffic, advertising, email tracking, and personalization.

4. USE OF YOUR PERSONAL DATA

We use your Personal Data for the purposes outlined in Section 4. Please note that not all purposes will apply to every consumer.

5. DISCLOSURE OF YOUR PERSONAL DATA

We disclose your Personal Data to the following third parties:

ETG.UA group companies. (see Section 8).

Service providers. Third parties engaged to support our operations (e.g., order processing, payments, fraud prevention, data analysis, site management, research, promotions, etc.). They access your data solely to perform tasks as per our instructions under confidentiality.

Credit bureaus/debt collectors. As permitted by law, to check creditworthiness or collect debts.

Third parties for marketing. We do not sell or authorize the use of your data by third parties for their marketing without your consent. We will notify You if this applies.

Lawful or merger/acquisition-related disclosures. We disclose data based on legal grounds or during mergers/acquisitions (see Section 4 for details).

6. USE OF PERSONAL DATA

We retain your data only as long as necessary for the purposes stated in Section 4 or to comply with legal requirements.

7. STORAGE AND/OR TRANSFER OF YOUR PERSONAL DATA

We take appropriate measures to ensure the confidentiality and secure storage of your Personal Data. However, these measures do not apply to data you choose to publish publicly (e.g., on social networks).

Who May Access Your Personal Data. Your Personal Data will be processed by our authorized employees or by authorized personnel of agencies, depending on the specific purposes for which your Personal Data was collected (for example, our employees responsible for consumer protection matters will have access to your consumer account).

Measures Implemented in the Operational Environment. We store your Personal Data in an operational environment that employs appropriate security measures to prevent unauthorized access. We adhere to high standards for the protection of Personal Data. However, the transmission of information via the Internet is not completely secure, and while We will do our utmost to protect your Personal Data, We cannot guarantee the full security of data transmitted through our websites/applications.

What We Expect from You. It is important that You also contribute to the security of your Personal Data. When registering an online account, please ensure that You choose a password that is difficult for others to guess and never share it with anyone. You are responsible for maintaining the confidentiality of your password and for any activity conducted through your account. If You use a public or shared computer, never select the option to remember your username/email address or password and always make sure to log out of your account before leaving the computer. You should also make use of the privacy settings We provide on our website/application.

8. YOUR RIGHTS

Access to Personal Data. You have the right to access your Personal Data and request a physical or electronic copy of all Personal Data We hold about you. You also have the right to receive information regarding the source from which your Personal Data was collected.

You may exercise these rights by sending a request to the email or postal address indicated in Section 11, providing your surname, first name and patronymic, place of residence (or stay), and details of the identity document of the person submitting the request, in accordance with Paragraph 1, Part Four, Article 16 of the Law of Ukraine "On Personal Data Protection."
If the request is submitted by another person on your behalf without proof that the request is legally made in your name, the request will be rejected.
Please note that any personal information you provide to us will be processed solely in accordance with, and within the limits permitted by, applicable legislation.

Other Rights (e.g., Modification or Deletion of Personal Data). You may: (i) submit a justified request for the modification, correction, or deletion of your Personal Data in cases provided by law; (ii) raise objections regarding limitations to the right of Personal Data processing when giving consent; and (iii) withdraw your consent to any data processing operations.

In accordance with applicable law, you also have the right to file a justified objection against the processing of your Personal Data.

Please note that in certain circumstances, we may not be able to delete your Personal Data without also deleting your account.
In some cases, we are legally required to retain your Personal Data even after receiving your deletion request, either under current legislation or in connection with the performance of a contract.

Please also note that we require our registered users to verify their identity (e.g., login/email address, password) before they can access or make changes to their account. This is to help prevent unauthorized access to your account.

We hope that we are able to meet your expectations regarding the way we process your Personal Data. However, if you have unresolved concerns, you also have the right to lodge a complaint with the relevant data protection authorities.

9. CHOICE ON HOW WE USE AND DISCLOSE YOUR PERSONAL DATA

We provide you with the ability to control what Personal Data you provide to us through the following mechanisms:

Cookies / Similar Technologies. You manage your consent through (i) the built-in tool on the website or (ii) your browser settings, allowing you to refuse all or some cookies / similar technologies and enabling us to notify you when they are in use. See section above for details.

Marketing and Promotional Communications. You may give your consent for ETG.UA to use your Personal Data for promoting its products or services by checking the appropriate boxes in registration forms or by responding to questions from our contact center representatives.
If you decide you no longer wish to receive marketing communications from us, you may opt out at any time by following the instructions included in each message. To unsubscribe from marketing communications delivered by any method, including third-party social networks, you may at any time use the opt-out link provided in each message, visit our website/app or third-party platforms, update your user preferences in your account, uncheck the relevant boxes, or call our contact center.

Please note that even if you opt out of marketing communications, you will still receive administrative messages from us, such as order or transaction confirmations, account activity notices (e.g., account verification, password changes), and other important non-marketing communications.

Personalization (Offline and Online). If you wish for your Personal Data to be used by ETG.UA to provide a personalized experience and targeted advertising/content, you can indicate this by checking the relevant boxes in the registration form or by responding to our call center representatives. If you later decide you no longer want to receive personalized experiences from ETG.UA, you may opt out at any time by updating your preferences in your user account via the website/app, unchecking the relevant boxes, or calling our call center.

Targeted Advertising. We work with advertising networks and other advertising service providers ("Ad Providers") who deliver advertisements on our behalf and on behalf of unrelated companies across the Internet. Some of these ads are tailored to your interests based on information collected over time on ETG.UA sites or non-affiliated websites. You may visit www.etg.ua to learn more about this type of advertising and how to opt out of such advertising.

10. CHANGES TO THIS POLICY

If We change how We process your Personal Data, We will update this Policy. We reserve the right to revise this Policy at any time, so please review it regularly for updates.

11. PERSONAL DATA OWNER (CONTROLLER)

LLC "ENERGY TRADE GROUP" acts as the Controller of your Personal Data.

If You have questions or complaints regarding our Policy or data protection compliance, please contact us:

Phone: +38 (044) 390-99-89
Email: info@etg.ua

You may also send a message to our Data Protection Officer at the following email address: dataprotection@ua.nestle.com
Mailing Address: 01010, Kyiv, Ivana Mazepy Street, Ukraine