Privacy Policy

1. General Provisions

This Privacy Policy describes how LLC "Razom UA" (hereinafter — "we", "us", "Company"), operating through the website razomua.media and the mobile application Razom UA, collects, uses, stores, and protects your personal data.

We comply with the requirements of:

• EU Regulation 2016/679 (GDPR) — for individuals located in the European Economic Area;
• California Consumer Privacy Act / CPRA (CCPA/CPRA) — for California residents (USA);
• Ukrainian legislation on personal data protection (Law No. 2297-VI).

2. Personal Data We Collect

Data you provide voluntarily: email address (when subscribing or registering), name and surname (if provided), comments and messages sent via feedback forms.

Data collected automatically: IP address (in anonymized form), browser type and operating system, pages you viewed, time and duration of visit, geographic location (at country/city level), mobile device identifier (in the app).

We do not collect special categories of personal data (racial origin, health, biometrics, religious beliefs, etc.) without your explicit consent.

3. Legal Basis for Processing (GDPR)

• Your consent (Art. 6(1)(a) GDPR) — for analytical and marketing cookies, newsletter subscription;
• Legitimate interest (Art. 6(1)(f) GDPR) — for website security and fraud prevention;
• Performance of a contract (Art. 6(1)(b) GDPR) — for providing services you registered for.

4. Analytics Platforms and Third Parties

We use the following analytics services to improve our platform:

4.1. Google Analytics 4

Operator: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Analytics collects anonymized data about user behavior. We have enabled IP anonymization and disabled data sharing for advertising purposes. Standard Contractual Clauses (SCC) apply for EU users. You may opt out by installing the browser extension: https://tools.google.com/dlpage/gaoptout. Learn more: Google Privacy Policy.

4.2. PostHog

Operator: PostHog, Inc., 965 Mission St, San Francisco, CA 94103, USA. PostHog is used for product analytics and understanding user behavior in the app. Data may be stored on servers in the USA or EU (depending on configuration). We use anonymized identifiers and do not share with PostHog any data that would allow direct identification of a person. Learn more: PostHog Privacy Policy.

Both services act as data processors under GDPR, and we have concluded Data Processing Agreements (DPA) with them.

5. International Data Transfers

Some data may be transferred and processed outside Ukraine and the EU (in particular, to the USA). We ensure the protection of such transfers through: EU Standard Contractual Clauses (SCC), certification of providers under the EU-US Data Privacy Framework, or other appropriate safeguards.

6. Purpose of Data Use

• Ensuring operation of the website and mobile application;
• Traffic analysis and content improvement;
• Sending news and updates (only with your consent);
• Ensuring security and fraud prevention;
• Fulfillment of legal obligations.

7. Data Retention

We retain personal data only as long as necessary to achieve the purposes set out in this Policy:

• Analytical data — up to 14 months;
• Newsletter subscriber data — until unsubscription;
• Security logs — up to 12 months;
• Backups — up to 30 days after deletion of primary data.

8. Your Rights

Under GDPR and applicable Ukrainian law you have the right to:

• Right of access — obtain a copy of your personal data;
• Right to rectification — correct inaccurate or incomplete data;
• Right to erasure ("right to be forgotten") — request deletion of your data;
• Right to restriction of processing — limit processing of your data in certain cases;
• Right to data portability — receive data in a structured, machine-readable format;
• Right to object — object to processing based on legitimate interest;
• Right to withdraw consent — at any time without affecting the lawfulness of prior processing.

For California residents (CCPA/CPRA): you also have the right to know what categories of personal data we collect, the right to opt out of sale or sharing of data (we do not sell your data), and the right to non-discrimination for exercising your rights.

To exercise any of the above rights, contact us: privacy@razomua.media. We will respond within 30 days (CCPA) or 1 month (GDPR).

9. Data Security

We apply technical and organizational measures to protect your data: connection encryption (TLS/HTTPS), access control, regular security audits. In the event of a data breach posing a risk to your rights, we will notify the relevant supervisory authority within 72 hours (pursuant to Art. 33 GDPR) and you — as soon as reasonably possible.

10. Children

Our website and application are not intended for persons under 16 years of age. We do not knowingly collect data from children. If you become aware that a child has provided us with personal data, please contact us for deletion.

11. Complaints

If you believe we are violating your rights, you have the right to lodge a complaint with:

• The Ukrainian Parliament Commissioner for Human Rights (Ombudsman);
• The supervisory authority in your country of residence (for EU residents).

12. Changes to the Policy

We may update this Policy. In case of material changes, we will notify you by email (if you are subscribed) or via a prominent notice on the website no later than 30 days before the changes take effect.

13. Contact

For privacy and data protection inquiries:
LLC "Razom UA"
Address: 58 Teplychna St., Sviatopetrivske, Kyiv Oblast, 08141, Ukraine
Phone: 096 702 2602
Email: privacy@razomua.media
Website: razomua.media