Privacy Policy
Version 1.0
Issued on August, 2024
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1. Scope. Regulation
1.1. This privacy policy (the “Policy”) governs the privacy terms of our service (the “Service”) we provide via our website https://www.anhelina-hiryliuk.com/ (the “Website”). The Service is offered by an individual Anhelina Hiryliuk (“we”, “us”).
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1.2. The Policy is a legal statement which explains how we collect, retain, process, and transfer the Personal Data which is any information relating to an identified or identifiable living individual (“you”) we receive.
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1.3. We receive the Personal Data from various sources to provide our clients (the “Clients”) with the Service. The Clients are (1) legal entities; and (2) individuals who pay for the Service to use it on their own.
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1.4. Please, read the Policy carefully as it will help you to make informed decisions about sharing your Personal Data with us.
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2. Personal Data We Collect
2.1. We collect several types of the Personal Data for various purposes to provide the Clients with the Service and to improve it. The scope of your Personal Data we collect depends on how you interact with us.
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2.2. If you provide us with the Personal Data when you subscribing for a newsletter, you provide us with your email.
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2.3. We automatically collect the Usage Data when you visit, use or navigate the Service. We need this information to operate the Service, to maintain its security, and for our analytics purposes. The Usage Data may include:
2.3.1. the information about computer or mobile device. The examples of such information are device information, internet protocol (IP) address, browser type and version, operating system, language settings, mobile network information, mobile operating system, type of mobile browser and version, URL-links;
2.3.2. information about how you use the Service, such as account settings and preferences, the time you enter and exit the Website, which pages you visit and which features you use, technical information, such as Internet speed.
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2.4. We may receive the Personal Data from other sources, including third parties and publicly available sources which help us to update, expand, and analyze our records; prevent or detect fraud; process payments; or analyze how you use the Services (the “Third-Party Data”). The Third-Party Data may include without limitation the data from analytics providers (e.g., Google).
2.5. We do not process the Personal Data relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic and/or biometric data, data concerning health or sex life and/or sexual orientation.
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​3. How We Use Personal Data
3.1. To use the Personal Data, we must rely on one or more legal bases. The bases we rely on are:
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3.1.1. contract performance. If you are the Client, we process the Personal Data to perform the agreement with you or to take steps at your request before entering into the agreement;
3.1.2. consent. This will apply when you agree that we process the Personal Data, for example, accept the policy on the website;
3.1.3. legitimate interest. We may process the Personal Data when we have a legitimate business interest to do so: for example, to ensure that the Service is secure and safe to use;
3.1.4. to comply with our legal obligations. Sometimes we cannot comply with law without processing the Personal Data: for example, when the court or a public authority requests it.
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3.2. Please find a description of how we use the Personal Data and which legal bases we rely on. We have also identified our legitimate interests where appropriate:
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3.2.1. the Clients’/ Employees’ Data to provide you with the service and reach out to you;
3.2.2. the Usage Data, the Third-Party Data to
- to prevent fraud, deception and other illegal activities;
- to improve our counter-fraud practices;
- to keep the Service and the Website safe and secure;
- to analyze how the Service works, to evaluate and improve it;
- to detect, prevent and address technical issues of the Website and of the Service;
- to administer the Website for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to ensure that we present the content of the Website to our users in the most effective manner;
3.2.3. the Usage Data to
- optimize advertising based on your use of the Website;
- optimize and serve advertising for you based on your past use of Google, Facebook, Linkedin, Twitter
3.2.4. All types to
- respond in the course of legal, regulatory, arbitration procedures;
- to respond the mandatory requests for information issued by public authorities or other third parties;
- prevent harm as legally required. If we receive a subpoena or other legal request we may need to inspect the Personal Data we store to determine how to respond.
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4. When We Disclose Personal Data to Third Parties
4.1. We only share the Personal Data:
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4.1.1. to comply with laws;
4.1.2. to fulfil the business obligations (for example, if it is necessary to fill in the Personal Data to provide you a service);
4.1.3. if you agreed that we may do so.
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4.2. We may disclose the Personal Data only:
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4.2.1. to comply with laws. We may disclose the Personal Data where we are legally required to do so to comply with the applicable law, governmental requests, a judicial proceeding, court order, or legal process. For example, we may disclose the information in response to a court order, a subpoena, a public authorities’ request to meet national security or law enforcement requirements. We may also disclose your information when we conduct 3 or cooperate in investigations of fraud or other illegal activity, to prevent and detect fraud or crime;
4.2.2. to allow third parties to render the services. We may share your data with our business partners, service providers, contractors or agents performing the services for us or on our behalf and require access to such information to perform their obligations. The examples of such third parties’ services are payment processing, data analysis, email delivery, hosting, customer service, providing us with access to anti-fraud databases, screening. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect the data about how you interact with the Website over time;
4.2.3. if you agreed. We may disclose the Personal Data for other purposes if you granted us consent to do so.
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5. Cookies
Cookies are small files of letters and numbers downloaded onto your computer or access device when you access certain websites. The use of cookies is standard on the internet and many websites use them to improve the user experience. There are different types of cookies (described further below). For more information about cookies and how they work see allaboutcookies.org
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By using Anhelina Hiryliuk Illustrations, you agree that we can place the following types of cookies on your device:
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5.1. Cookie Policy Strictly necessary cookies – These cookies make our Site work. These cookies are essential in order to enable you to move around our Site and use our features, such as accessing secure areas. Without these cookies, we would not be able to remember your previous actions, determine whether you are logged in or not or enable you to see the electronic programme guide tailored to your chosen provider/region.
5.2. Performance cookies – These cookies improve the performance of our Site. These cookies collect information about how visitors use our Site, for instance which pages visitors go to most often, and if visitors get error messages from web pages. These cookies don’t identify you personally. All information these cookies collect is aggregated and anonymous. These cookies enable us to manage errors and the performance and design of the Site, to track ad response rates and your visits to our affiliate websites, and to show you which shows are most popular.
5.3. Functionality cookies – These cookies save you time. These cookies remember your user name and can also be used to remember settings that you can customise. These cookies allow us to remember choices you make (e.g. whether you want to share your activity on Facebook) and provide enhanced, more personal features. They may also be used to provide services you have asked for such as watching a video or commenting. Without these cookies, we won’t be able to distinguish you from other users and, as a result, save you time.
5.4. Targeting or advertising cookies – These cookies make the advertising you see relevant. These cookies are used to deliver adverts or links more relevant to you and your interests. They are also used to limit the number of times you see an ad as well as help measure the effectiveness of ad campaigns. They may be placed by us, or advertising networks with our, or our affiliate’s, permission. Without these cookies, you may still receive advertising – the advertising, however, will be less relevant to you.
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5.5. Third party cookies – Our Site allows third parties to set cookies on your device (e.g. Facebook). This means that when we display content from a third party, this third party may set their own cookies or similar technologies onto your device. We do not control the use of such cookies and in many instances have no access to the data collected by these third parties. Third party use of cookies is subject to their respective privacy policies.
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6. With Whom We Share Personal Data
6.1. We may share your cookies and the Usage Data for analytics purposes and to personalize the content of the Service: for example, to offer you not all our services but the ones in which you might be interested:
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6.1.1. Google Analytics operated by Google: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (https://policies.google.com/privacy). You can opt out by installing the add-on for your browser https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en.
6.1.2. Google Ads operated by Google (https://policies.google.com/privacy). You can opt out as described at https://policies.google.com/tec hnologies/ads, in the section How you can control advertising cookies.
6.1.3. Facebook Ads operated by Facebook: (1) Facebook Inc., 1601 Willow Road, Menlo Park, CA 94025, USA, – if you live outside the EU; or (2) Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, – if you live in the EU (https://www.facebook.com/about/privacy/). You can opt out via your Facebook account settings.
6.1.4. Linkedin operated by Linkedin: (1) LinkedIn Corporation, 1000 W. Maude Avenue, Sunnyvale, CA 94085, USA if you live outside the EU, EEA, and Switzerland, or (2) LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland if you live in the EU, EEA or Switzerland (https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_ footer-privacy-policy). You can opt out as described at https://www.linkedin.com/help/linkedin/answer/62931?trk=microsites-frontend_legal_privacypolicy&lang=en.
6.1.5 Wix.com, Inc: 100 Gansevoort Street, New York, NY 10014. You can opt out as described in https://www.wix.com/about/privacy/do-not-sell-my-personal-information.
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6.2. We may share your cookies, the Usage Data (clauses 6.2.1, 6.2.2), and sometimes unique device identifiers (clause 6.2.3) for advertising purposes: for example, to optimize advertising based on your use of the Website:
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​6.2.1. Microsoft Advertising operated by Microsoft: Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052-6399 (https://privacy.microsoft.com/privacystatement). You can opt out as described at https://privacy.microsoft.com/privacystatement, in the section Cookies and similar technologies.
6.2.2. Google AdSense operated by Google (https://policies.google.com/privacy). You can opt out by installing the add-on for your browser https://chrome.google.com/webstore/detail/iba-opt-out-by-google/gbiekjoijknlhijdjbaadobpkdhmoebb
6.2.3. Facebook Audience Network operated by Facebook (https://www.facebook.com/about/privacy/). You can opt out via your Facebook account settings.
6.2.4. Wix.com, Inc: 100 Gansevoort Street, New York, NY 10014. You can opt out as described in https://www.wix.com/about/privacy/do-not-sell-my-personal-information.
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6.3. We may share your cookies and the Usage Data to test content performance and features (A/B testing): for example, to analyze how your web-traffic or behavior changes in response to changes of the structure, text, or any other component of the Website:
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6.3.1. Google Optimize operated by Google (https://policies.google.com/privacy). You can opt out as described at https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en
6.3.2. Wix.com, Inc: 100 Gansevoort Street, New York, NY 10014. You can opt out as described in https://www.wix.com/about/privacy/do-not-sell-my-personal-information.
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6.4. We may share the Personal Data, Usage Data and email address specified in Wix’s privacy policy to handle payments: for example, to process payments by credit card, bank transfer; to manage landing and invitation pages, for example to create, publish and use webpages for some of our services:
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6.4.1. Wix.com, Inc: 100 Gansevoort Street, New York, NY 10014.
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6.5. We may share your cookies and the Usage Data to optimize and serve advertising for you based on your past use of these services:
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6.5.1. Google Ads Remarketing operated by Google (https://policies.google.com/privacy). You can opt out as described at https://policies.google.com/technologies/ads, in the section How you can control advertising cookies.
6.5.2. Remarketing with Google Analytics operated by Google (https://policies.google.com/privacy). You can opt out by installing the add-on for your browser: https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en
6.5.3. Facebook Remarketing operated by Facebook (https://www.facebook.com/about/privacy/). You can opt out via your Facebook account settings.
6.5.4. Linkedin operated by Linkedin (https://www.linkedin.com/legal/privacy-policy?trk=homepage-basic_footer-privacy-policy). You can opt out as described at https://www.linkedin.com/help/linkedin/answer/62931?trk=microsites-frontend_legal_privacypolicy&lang=en
6.5.5. Twitter Remarketing, operated by Twitter: Twitter Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103 USA (https://privacy.x.com/en). You can opt out via your Twitter account settings.
6.5.6. Twitter Tailored Audiences, operated by Twitter (https://privacy.x.com/en). You can opt out via your Twitter account settings.
6.5.7. Facebook Custom Audience, operated by Facebook (https://www.facebook.com/about/privacy/). You can opt out via your Facebook account settings.
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6.6. We may share the Usage Data to manage tags we use in the Service:
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6.6.1. Google Tag Manager operated by Google (https://policies.google.com/privacy).
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7. Transfer of Personal Data
7.1. The countries to which we or the third parties we engage transfer the Personal Data may not have the same data protection laws as your jurisdiction. In these cases, we take reasonable security measures which the applicable laws prescribe to ensure that the Personal Data are properly protected when they are transferred outside your jurisdiction.
7.2. You agree to such transfers pursuant to the consent for processing of the Personal Data you grant. If you do not agree to such transfers, you will no longer be able to use the Service. When we make such transfers, we: (1) comply with our legal and regulatory obligations; (2) estimate if the country to which we intend to transfer the Personal Data provides for sufficient level of data protection; (3) implement the appropriate safeguards such as executing standard data protection clauses. We will take all the steps to ensure that your data are treated securely and in accordance with the Policy.
7.3. The Policy applies regardless of the location in which we store or process the Personal Data.
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8. Retention Of Personal Data
8.1. We retain the Personal Data as long as we provide you with the Service. We retain the Personal Data after we cease directly or indirectly providing you with Service:
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8.1.1. if it is reasonably necessary to comply with our legal and regulatory obligations. Legal and regulatory obligations may include, without limitation, handling your complaint or a potential litigation with you.
8.2. In any other circumstances, we will retain the Personal Data for no longer than necessary, taking into account the following:
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8.2.1. the purpose(s) and use of the Personal Data both now and in the future (such as whether it is necessary to continue to store the Personal Data in order to continue to perform our obligations under a contract with you or to contact you in the future);
8.2.2. whether we have any legal obligation to continue to process the Personal Data (such as any record-keeping obligations imposed by relevant law or regulation);
8.2.3. whether we have any legal basis to continue to process the Personal Data (such as your consent);
8.2.4. how valuable the Personal Data is (both now and in the future);
8.2.5. any relevant agreed industry practices on how long the Personal Data should be retained;
8.2.6. the levels of risk, cost and liability involved with us continuing to hold the Personal Data;
8.2.7. how hard it is to ensure that the Personal Data can be kept up to date and accurate;
8.2.8. any relevant surrounding circumstances (such as the nature and status of our relationship with you).
8.3. After the retention period ends, we will either delete, or anonymize the Personal Data. If we anonymize it, we may use such anonymized data for research or statistical purposes or to improve the Service. We may use it indefinitely without further notice to you.
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9. Use by Minors
9.1. The Service is not directed to individuals under the age of 18 years old. Please, do not provide us with your Personal Data if you are younger.
9.2. If you provide us with the Personal Data from minors via the Service, you undertake to provide us with such Personal Data:
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9.2.1. only if a parent or a guardian consented to such transfer and further processing of this information by us. You also undertake to notify us immediately if a parent or a guardian withdraws his/her consent or limits the processing to which he or she consents;
9.2.2. you received documents confirming a minor’s emancipation.
9.3. We collect, process, store and disclose the minors’ data as described in the Policy.
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10. Security of Personal Data
10.1. Where we have given you (or where you have chosen) a password, which enables you to access our Website, you are responsible for keeping this password confidential. Please, do not share a password with anyone.
10.2. We adopt appropriate physical, electronic, management and technical measures to protect security of the Personal Data we process. However, please also remember that we cannot ensure or warrant security of the Personal Data which you transmit to the Service. Although we will do our best to protect the Personal Data, their transmission to and from our Service is at your own risk. Please, access the Service only in a secure environment: for example, use firewalls, choose the provider which encrypts the traffic, etc. After we receive the Personal Data, we use strict procedures and security features to try to prevent unauthorized access. However, we will not be liable for any damages which relate to unauthorized access to the Personal Data.
10.3. The Personal Data we collect is only accessible by a limited number of employees. Any of them have special access rights to the systems where we store the Personal Data. They are all bound by obligations of confidentiality. If we use subcontractors to store the Personal Data, we will ensure the same level of data protection as if we stored them on our own.
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10.4. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that security of your account has been compromised), please contact us immediately as specified in clause 11.2.
11. Your Data Protection Rights
11.1. Your data protection rights are:
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11.1.1. to access the Personal Data which means you may obtain a confirmation if we process your Personal Data, and / or to access your Personal Data and the information, how we use your Personal Data;
11.1.2. to rectify inaccurate Personal Data which means you may request that we correct any incomplete or inaccurate Personal Data about you;
11.1.3. to object to processing which means that you may object to processing your Personal Data if we process them based on the legitimate interests, use them for statistical purposes;
11.1.4. to make your Personal Data portable which means that you may request that in certain circumstances we provide you with a copy of your Personal Data in structured, commonly used and machine-readable format. If you wish to have a copy of your Personal Data, we will aim to provide you with them within 14 days;
11.1.5. to have your Personal Data erased which means that you may request that we delete your Personal Data in some circumstances: for example, we no longer need them, or you withdraw your consent which was the basis for processing;
11.1.6. to withdraw consent to processing your Personal Data which means that you may withdraw your consent for processing your Personal Data. Such withdrawal will only affect processing of your Personal Data after it is given;
11.1.7. to restrict processing which means that you may ask us to restrict or stop collection, use, processing and/or disclosure of your Personal Data;
11.1.8. to be informed about the safeguards which we arrange to transfer your Personal Data transfer to a third country or an international organization which means that you may ask us about these safeguards.
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11.2. If you wish to exercise any of the rights specified in clause 11.1, or have any questions concerning the Policy and / or your Personal Data, please contact our Data Protection Officer (“DPO”), who is responsible for overseeing this Privacy Policy, at anhelina.hiryliuk@gmail.com. DPO will review your request and offer a resolution or help to begin a dialogue to find a way out.
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11.3. Please keep in mind that there may be exceptions to these rights under the English data protection law, with which we must comply, or under the legislation, with which a data processor we engage must comply. Thus, we may reject the request about execution of your rights where permitted or required by these laws.
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11.4 If we reject your request, we will describe the grounds for it in our response.
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11.5. Please, note that we may ask you to verify your identity before we respond to the request and, in certain circumstances, charge a fee to cover our costs. Our time limit to respond is one month after we receive the request. If it takes longer to process your request, we will notify you. In any case, we cannot extend the response timeframe for more than two months after the first month for response passes.
12. Automated Decision Making
We do not apply automated decision making based only on automated Personal Data processing.
13. Third Party Links
We may post links to our partners’ websites from time to time. Please note that we are not liable for data protection at such websites; please refer to privacy policies of these websites to understand how the Personal Data are processed there.
14. Changes to Policy
Although most changes are likely to be minor, we may modify the Policy at any time. If we make material changes to the Policy, we may notify you via the Service or email. We will also change the version number and issue date at the beginning of the Policy. Any changes we make to the Policy are effective on or after the issue date and replace any prior versions of the Policy. We encourage you to review the Policy frequently to be informed of how we protect your Personal Data.
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