Privacy Policy

This Policy explains what personal data is processed when using the website smartsearch.com.ua, the customer account, the SmartSearch service, and SmartSearch search components integrated into customers' websites; why the data is processed, with whom it may be shared, and how individuals can exercise their data protection rights.

1. Who is responsible for data processing

1.1. The website administrator and provider of SmartSearch services under new agreements is ТОВ «ЮВІЖН», Ukrainian company registration code (EDRPOU): 46168192, registered address: Україна, 03057, м. Київ, вул. Марії Капніст, буд. 2 (the “Company”).

1.2. For personal data protection inquiries, contact hello@uvision.com.ua.

1.3. In connection with registration, communications, entering into and performing agreements, account administration, and its own website analytics, the Company generally determines the purposes and means of processing and acts as the controller of the relevant personal data.

1.4. When processing information about visitors to online stores through integrated SmartSearch search, the Company's role depends on the actual allocation of responsibilities and agreements with the customer. In particular, the Company may act as a personal data processor on behalf of the online store owner. Such processing may be further governed by the customer agreement.

1.5. This Policy does not replace the privacy policies of websites operated by SmartSearch customers. Each online store owner is separately responsible for informing its visitors about the processing it carries out.

2. Categories of information

2.1. Customer representative data: first name, surname and patronymic (where applicable), contact telephone number and email address, position, signatory authority, and details of a sole proprietor or legal entity. Company details are not always personal data in themselves, but information relating to sole proprietors and individuals may constitute personal data.

2.2. Contractual and account data: connected websites, plans and modules, requests, correspondence, agreements, invoices, payment statuses, and support history. The Company does not claim to collect full payment card details when new agreements are paid by bank transfer against an invoice.

2.3. Technical data: IP address, browser type, device specifications, referring pages, request times, error logs, service interaction data, and identifiers to the extent they are actually transmitted or recorded by relevant components.

2.4. Search usage data: entered search queries, selected language, categories and filters, numbers of results, clicks through to found products, and the technical browser identifier (clientId) created to operate and measure search. Certain integrations may process information about orders or their value if the customer's website supplies it.

2.5. Analytics data: information about visits and interaction events processed through Google Analytics 4 and, depending on website configuration, Google Tag Manager.

2.6. The Company does not ask users to enter passwords, payment details, medical information, or other sensitive personal data into search queries. If a user voluntarily enters such information, it may appear in technical search logs; users should therefore avoid including it in queries.

3. Purposes and legal grounds for processing

3.1. Data may be processed for registration and authentication, preparing and performing agreements, enabling SmartSearch features, indexing data on customer instructions, operating search, technical support, invoicing, and record keeping.

3.2. Technical data and statistics are used to diagnose failures, ensure information security, prevent misuse, assess search quality, improve functionality, and analyze service performance.

3.3. Depending on the activity, the legal ground for processing may be performing an agreement or taking steps requested by a person before entering into an agreement; complying with legal obligations; protecting the legitimate interests of the Company or a third party while respecting the rights of the individual; or consent, where required by applicable law.

3.4. Optional marketing communications are sent only where an appropriate legal basis exists. Where based on consent, that consent may be withdrawn through available channels.

3.5. Merely visiting the website is not regarded as blanket consent to every type of personal data processing.

4. Cookies, local storage, and analytics

4.1. The website and integrated search may use cookies, localStorage, and similar technologies. In particular, SmartSearch may store a local clientId identifier and recent search query history in the browser, and use a cookie to link certain search events.

4.2. Data in localStorage remains in the browser until the user clears it or it is removed by application code, unless a different deletion mechanism is implemented for a particular entry. Server-side record retention is addressed separately.

4.3. The SmartSearch website uses Google Analytics 4 (GA4) to analyze traffic and service usage. Google Tag Manager (GTM), if enabled, is used to manage tags; the presence of GTM does not itself mean every event is automatically sent to GA4.

4.4. GA4 may use cookies and other identifiers depending on actual settings. Analytics data may be processed by Google group companies and their service providers, including outside Ukraine, subject to applicable terms and law.

4.5. Where the law requires prior consent for particular analytics technologies, they must be used only after such consent has been obtained. Users may manage cookies through their browser settings and any privacy controls provided on the website.

4.6. The use of GA4 on the SmartSearch website does not imply that the Company automatically uses GA4 on every customer's website. Analytics on customer websites is configured with due regard to their own systems and privacy obligations.

5. Sharing data with third parties

5.1. Authorized employees and contractors of the Company may access data solely to the extent necessary to perform their duties.

5.2. Data may be shared with providers of server infrastructure, hosting, electronic document management, email, analytics, technical support, and other services where necessary to provide the service and where an appropriate legal ground exists.

5.3. Documents may be transmitted using agreed electronic document management services, including “Vchasno,” where such a service is used to enter into or perform an agreement.

5.4. Information is disclosed to government authorities or other parties only on a proper legal basis and in accordance with the procedures established by law.

5.5. The Company does not sell users' personal data as a separate product.

6. Data location and international transfers

6.1. SmartSearch's main server infrastructure and databases are located in Ukraine.

6.2. The use of third-party services, including GA4, electronic document management, message delivery, and technical integrations, may involve access to certain data or its processing outside Ukraine. Such transfers occur only where permitted by law and subject to applicable personal data protection requirements.

6.3. [VERIFY: actual list of third-party services, processing locations, contractual safeguards for international transfers, and whether any backups or logs are stored abroad.]

7. Retention periods

7.1. The Company retains personal data no longer than necessary for specific lawful processing purposes and for periods required by law for accounting, tax, and other mandatory records.

7.2. The retention period for account information depends on the period of service use and on the need to complete contractual relationships, comply with legal obligations, and resolve potential claims.

7.3. Retention periods for search statistics, technical logs, backups, and identifiers are set separately by data category and must be documented by the Company. [VERIFY BEFORE PUBLICATION: specific periods or criteria for search statistics, clientId, logs, backups, correspondence, and requests; these periods have not yet been approved.]

7.4. Retention in GA4 depends on the Google Analytics property settings and Google's rules. [VERIFY: the actual GA4 Admin → Data retention settings and document the applicable value.]

7.5. At the end of the necessary retention period, data is deleted, anonymized, or processed further only where a separate lawful basis applies.

8. Information security and incidents

8.1. The Company implements organizational and technical measures to prevent unauthorized access, accidental loss, alteration, disclosure, and other unlawful processing of personal data.

8.2. Access to personal data is granted according to job responsibilities and legitimate need.

8.3. In the event of a security incident, the Company assesses its consequences, takes necessary response measures, and notifies competent parties or individuals where and as required by law.

8.4. No information system can guarantee absolute security; nevertheless, this does not release the Company from obligations imposed by law.

9. Rights of individuals

9.1. Individuals have rights under Ukrainian law, including the right to know the sources and purposes of collection of their personal data, obtain information about processing, request correction or deletion in circumstances provided by law, withdraw consent, object to processing within the limits established by law, and lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or a court.

9.2. To exercise these rights, write to hello@uvision.com.ua with sufficient details of the request. To prevent unauthorized disclosure, the Company may require reasonable verification of the requester's identity.

9.3. If a request concerns data processed by the Company solely on behalf of an online store owner, the Company may refer the requester to that owner or assist the owner in responding within its contractual and legal authority.

9.4. Requests are considered within the time limits and procedures established by Ukrainian law.

10. Policy updates

10.1. The Company may update this Policy due to changes in legislation, the operation of the service, processing methods, or the providers it engages.

10.2. The current version is published at https://smartsearch.com.ua/privacy with its effective date. Where the law requires separate notice or consent for new processing, the Company will comply with those requirements.

11. Contact details

ТОВ «ЮВІЖН»
Ukrainian company registration code (EDRPOU): 46168192
Address: Україна, 03057, м. Київ, вул. Марії Капніст, буд. 2
Privacy email: hello@uvision.com.ua