PRIVACY STATEMENT
FOR USERS OF THE WEBSITE https://www.elagro.com.ua/ AND MOBILE APPLICATION "ELAGRO.UA"

1. General Provisions

LIMITED LIABILITY COMPANY "ELAGRO.UA", identification code EDRPOU – 45921268, registered office: Ukraine, 01054, Kyiv, 5 Leontovycha Street, Office 406 (hereinafter – LLC "ELAGRO.UA" or the "Controller"), by this "Privacy Statement for Users of the Website https://www.elagro.com.ua/ https://*.elagro.com.ua/ and Mobile Application 'ELAGRO.UA'" (hereinafter – the "Statement") establishes the principles and procedures for collecting, processing, using, and protecting personal data of Users of the website https://www.elagro.com.ua/ https://*.elagro.com.ua/ (hereinafter – the "Website") and mobile application "ELAGRO.UA" (hereinafter – the "Application"). This Statement has been developed in accordance with the Law of Ukraine "On Personal Data Protection" and the General Data Protection Regulation (EU) 2016/679 (GDPR).

The Website and "ELAGRO.UA" Application are intended exclusively for use by adults of legal age.

2. Specifics of Processed Information

"ELAGRO.UA" receives anonymized general information resulting from aggregated counting data, such as: the total number of visits to the Website/Application, the number of visits to each page of the Website/Application, etc. This information is used solely for evaluating the rating of the Website/Application, further improving their performance, and enhancing the service provision process.

"ELAGRO.UA" collects and processes the following User data during their use of the Website/Application:

• 2.1. data provided by Users both when completing registration forms on the Website/Application and during the use of the Website/Application;

• 2.2. cookies;

• 2.3. IP addresses;

• 2.4. parameters and settings of internet browsers;

• 2.5. data regarding the User's mobile device and use of the Application by the User, specifically information about the operating system and Application version, information on Application usage (such as periods of active use of the Application, Application features accessed and used by the User, error messages logged by the system during Application use), as well as hashed phone book data of Application Users.

LLC "ELAGRO.UA" includes User data in the personal data database from the moment the User first begins using the Website/Application, continuously throughout the term of using LLC "ELAGRO.UA" services, and for five subsequent years following the closure of the account (Personal Account) on the Website/in the Application and termination of using LLC "ELAGRO.UA" services.

LLC "ELAGRO.UA" processes User personal data for the purpose of proper service provision to the User (identification, authentication, authorization, password recovery, sending subscription informational materials, responding to User requests and letters, as well as for other actions necessary for proper service delivery).

Legal bases for personal data processing pursuant to Article 6 of the GDPR and the legislation of Ukraine are: the User's consent to personal data processing; performance of a contract to which the User is party; compliance with legal obligations of the Controller; and the legitimate interests of LLC "ELAGRO.UA".

"ELAGRO.UA" uses anonymized data for targeting advertising and/or informational materials by age, gender, and other metrics; conducting statistical research; and in any other lawful manner.

Subject to obtaining consent from the User in full compliance with the applicable legislation of Ukraine, LLC "ELAGRO.UA" has the right to transfer User personal data (in whole or in part) to third parties without additional notice to the User, specifically in the following cases: to persons into whose possession, use, or ownership the Website/Application is transferred; related/affiliated entities of LLC "ELAGRO.UA"; a new owner of LLC "ELAGRO.UA" for processing for purposes provided by this Statement and applicable legislation of Ukraine; other third parties if the relevant functionality is provided on the Website/in the Application and such persons undertake to comply with personal data protection legislation and internal policies of LLC "ELAGRO.UA".

During the use of the Website/Application, third-party internet resource codes may be present on its pages, resulting in such third parties receiving the data specified in points 2.2, 2.3, and 2.4 of this Statement. Such third-party internet resources include:

• visit statistics collection systems (for example, LiveInternet counters, Google Analytics, etc.);

• social plugins (blocks) of social networks (for example, Facebook, etc.);

• banner display systems (for example, AdRiver, etc.);

• other resources.

Exclusively for the purpose of improving the functionality of the Website/Application, "ELAGRO.UA" may use third-party services that additionally allow the collection and processing of the following User data during Website use:

• screen resolution of the User's device;

• type of device, operating system, and internet browser of the User;

• User geolocation (country only);

• display language of the Website/Application;

• mouse movements and clicks; keyboard keystrokes on the User's device;

• visited pages of the Website/Application, time and date of visits to the Website/Application pages;

• URL address, domain.

The aforementioned data do not constitute personal data within the meaning of the Law of Ukraine "On Personal Data Protection".

3. User Rights Regarding Personal Data Protection

The User possesses all rights regarding personal data protection provided by the Law of Ukraine "On Personal Data Protection" and the General Data Protection Regulation (GDPR), including: the right to access their data; the right to rectification or updating of data; the right to erasure ("right to be forgotten"); the right to restriction of processing; the right to object to processing; the right to data portability; as well as the right to withdraw consent to personal data processing at any time and the right to lodge a complaint with a supervisory authority.

Personal data processing is carried out in data centers housing equipment that ensures the operation of the Website/Application. "ELAGRO.UA" takes all measures provided by law to protect User personal data and prevent unauthorized access. Such measures are specifically designed to protect personal data against loss, unauthorized access, disclosure, alteration, or destruction, as well as other forms of misuse. To protect personal data, "ELAGRO.UA" may use encryption, security protocols, security gateways, physical locks and key systems, internal access restrictions, password protection, and other security measures to prevent unauthorized access to personal data. Specifically, data processing is carried out on equipment located in secure facilities with strictly controlled access. Furthermore, "ELAGRO.UA" utilizes modern security protocols and mechanisms for confidential information exchange and continuously improves methods of collecting, storing, and processing personal data, including physical security measures, to prevent unauthorized access to "ELAGRO.UA" systems for phishing or other fraudulent activities.

In the event of transferring personal data outside Ukraine or the European Economic Area (EEA), LLC "ELAGRO.UA" ensures an adequate level of data protection in accordance with Standard Contractual Clauses (SCCs) or other recognized legal mechanisms for data transfer under the GDPR.

4. Use of IP Addresses

An Internet Protocol address (IP address) is a unique sequence of numbers automatically assigned to a User's computer during an internet session when connected via a local network to their Internet Service Provider (ISP).

"ELAGRO.UA" and/or third parties providing technical maintenance for the Website/Application may collect IP addresses for system administration purposes and auditing Website/Application usage. "ELAGRO.UA" may use IP addresses to identify Website/Application Users when necessary to safeguard service provision, the Website/Application itself, or other Users.

By visiting the Website/Application, the User grants consent to "ELAGRO.UA" and/or third parties providing technical maintenance for the Website/Application to collect and use IP addresses for the purposes specified in this section.

5. Cookies

The Website/Application utilizes Cookie technology.

A cookie is a small text file stored on Users' hard drives by the Website/Application server. These files add functionality to the Website/Application or assist in analyzing Website/Application usage more efficiently and accurately.

For example, the server may use Cookies so that the User does not need to enter a password (where required) more than once during a session on the Website/Application.

By visiting the Website/Application, the User consents to "ELAGRO.UA" and third parties providing technical maintenance for the Website/Application collecting, processing, and using data within the context of Cookie technology usage.

At the same time, the User has the option to choose whether to accept or decline Cookie technology. Most web browsers automatically accept Cookies, but Users can modify browser settings to decline Cookies or receive a warning whenever such files are stored on their device. Detailed information regarding these options can be found in the web browser's user manual.

6. Links to Third-Party Websites

The "ELAGRO.UA" Website may contain links to other websites created by third parties whose personal data and information protection policies differ from those of "ELAGRO.UA". We recommend reviewing the privacy statements of all third-party websites prior to using them or submitting personal data or any other information to or through such websites.

7. Other Terms

This Statement enters into force upon its publication on the Website https://www.elagro.com.ua/ and remains valid until amended, supplemented, or restated in a new edition.

LLC "ELAGRO.UA" reserves the right to amend this Statement at any time, with changes taking effect immediately upon posting on the Website. LLC "ELAGRO.UA" recommends regularly reviewing this Statement. Users possess rights under applicable Ukrainian legislation providing access to processed personal data, the right to correct, erase, or block such personal data, and the right to object to certain processing activities. To exercise these rights, a written request should be submitted using our contact details listed on the Website.