Privacy policy

Updated: 16 November 2022

This Privacy Policy (hereinafter the "Policy") applies to the processing of personal data that "Boolat Play" LLC (hereinafter "Boolat Play") can receive from an individual (subject of personal data) (hereinafter the "User") during the use of the site and its subdomains, its programs, and its products (hereinafter the "Website") in accordance with the Constitution of Ukraine and the Law of Ukraine "On Personal Data Protection" dated 01.06.2010 No. 2297–VI (hereinafter the "Law"), as well as the General Data Protection Regulation (EU) 2016/679 dated 27.04.2016 (EU General Data Protection Regulation, hereinafter the "GDPR"), and any other applicable European data protection legislation, collectively referred to as the "Legislation".

1. Definitions

 "Personal data" means any information directly or indirectly related to a specific or identifiable individual (subject of personal data).

"Personal data processing" means any action (operation) or a set of actions (operations) performed upon personal data with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

"Site" means a collection of interconnected web pages hosted on the Internet at a unique address (URL) as well as its subdomains.

"Subdomains" means pages or a set of pages located on third-level domains belonging to the Site as well as other temporary pages with Boolat Play contact information at the bottom.

"User" means a person who has access to the Site via the Internet and uses the information, materials, and products of the Site.

"Cookies" means a small piece of data sent by the web server and stored on the user's computer that the web client or web browser sends to the web server in an HTTP request when trying to open a page of a corresponding site.

"IP address" means a unique network address of the node in the computer network through which the User accesses the Site.

2. General provisions

2.1. The use of the Site by the User means acknowledgment of this Policy and the conditions for processing the User's personal data.

2.2.  The Policy applies to all personal data of the User that can be obtained by Boolat Play during the User's use of the Site. This Policy applies to personal data obtained both before and after this Policy comes into force.

2.3. The purpose of this Policy is to provide the User with the necessary information to assess what personal data and for what objectives Boolat Play processes, methods of processing, and data security.

2.4. This Privacy Policy applies to the Site. Boolat Play does not control and is not responsible for third-party websites that the User can visit via the links available on the Website.

2.5. Boolat Play does not verify the accuracy of the personal data provided by the User, nor does it have the ability to assess User's legal capacity. However, Boolat Play assumes that the User acts prudently and in good faith, provides reliable and sufficient personal data and makes all necessary efforts to keep such data up to date and does not violate the rights of third parties.

3. Scope of Personal Data

3.1. In order to carry out its activities and to fulfill its obligations, Boolat Play processes the personal data of the User that the User provides when visiting the Site, both automatically and by filling out forms on the Site, and such personal data includes the following information:
3.1.1. last name, first name, and patronymic of the User;
3.1.2. email address (e-mail);
3.1.3. any other information available in the resume provided by the User via the functionality of the Site.

3.2. Boolat Play protects data that is automatically transmitted when visiting the Site:

- IP address;

- data from cookies;

- browser information;

- access time;

- referrer (address of the previous page);

3.2.1. Disabling cookies may result in the inability to access some parts of the Site;

3.2.2. Boolat Play collects statistics about IP addresses of the Site visitors. This information is used to prevent, detect, and resolve technical problems.

3.3.  Any other personal information not specified above (visit history, browsers used, operating systems, etc.) is subject to secure storage and non-distribution, except as provided in Paragraph 5.2. of this Policy.

4. Objectives and grounds for processing personal data 

4.1. Boolat Play may use the User's personal data for the following objectives:
4.1.1. contacting the User, including sending notifications, requests, processing requests and applications from the User;
4.1.2. determining the location of the User to ensure security and prevent fraud;
4.1.3. confirming the accuracy and completeness of personal data provided by the User;
4.1.4. notifying the User by e-mail;
4.1.5. providing the User with technical support in case of problems related to the use of the Site;
4.1.6. ensuring the correct and uninterrupted operation of the Site, improving the user experience of the User when visiting the Site.

4.2. The grounds for the processing of personal data are:
4.2.1. consent of the User to the processing of their personal data by Boolat Play;
4.2.2. conclusion and execution of an agreement that the User is a party to or which is concluded in favor of the User or for the implementation of activities preceding the conclusion of the agreement at the request of the User;
4.2.3. fulfillment of requirements stipulated by the legislation of Ukraine by Boolat Play.

5. Duration, principles, and methods of personal data processing

5.1. The duration of personal data processing is determined by the processing objectives, but shall not exceed the duration as determined by the Law.

5.2. The storage of personal data carried out in a form that allows to determine the subject of personal data shall not exceed the period required for the processing objectives if the period of personal data storage is not determined by the Law.

5.3. The processed personal data is subject to destruction or anonymization upon reaching the processing objectives or in the event of the loss of the need to reach them unless otherwise provided by the Law.

5.4. Boolat Play may also store the User's personal data in order to fulfill its legal obligations to the User or regulatory authorities.

5.5. The processing of the User's personal data is carried out in any legal way, including in personal data information systems with or without the use of automation tools.

5.6. The processing of personal data by Boolat Play is carried out on the basis of the following principles:
5.6.1. legality of the objectives and methods of personal data processing;
5.6.2. Boolat Play acting in good faith which is achieved by complying with the requirements of Ukrainian legislation regarding the processing of personal data;
5.6.3. achieving specific, predetermined objectives of the personal data processing;
5.6.4. compliance of the objectives of personal data processing with the objectives predetermined and declared upon collection of personal data;
5.6.5. compliance of the list and volume of processed personal data as well as methods of personal data processing with the stated processing objectives;
5.6.6. the accuracy of personal data, its adequacy for the processing objectives, the inadmissibility of personal data processing that is excessive in relation to the objectives of personal data processing;
5.6.7. ensuring, when processing personal data, the accuracy of personal data, its adequacy, and, if necessary, relevance to the objectives of personal data processing;
5.6.8. the inadmissibility of combining databases containing personal data, the processing of which is carried out for objectives incompatible with each other.

5.7. The processing of personal data may be carried out by Boolat Play for statistical or other research purposes, subject to mandatory anonymization of such personal data.

5.8. Boolat Play does not process personal data relating to racial or ethnic origin, political, religious, or ideological beliefs, membership in political parties and trade unions, criminal convictions, as well as data relating to health, sexual life, biometric, and genetic data.

5.9. The processing of personal data is carried out in compliance with the conditions determined by the legislation of Ukraine.

5.10. Boolat Play undertakes all necessary organizational and technical measures to protect the User's personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions by third parties.

5.11. Boolat Play, together with the User, undertakes all necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the User's personal data.

6. Individuals authorized to process personal data

6.1. To achievethe goals of this Policy, your personal data can only be processed by those Boolat Play employees that have such an obligation in accordance with their official (work) duties. Access to other employees may be granted only in cases provided for by the Law. Boolat Play guarantees that its employees will respect the confidentiality and security of personal data during processing.

6.2. Boolat Play has the right to transfer personal data to third parties in the following cases:
- the User has expressed their consent to such actions in writing;
- the transfer is provided for by Ukrainian or other relevant legislation in accordance with the procedures established by such legislation. At the same time, access to personal data is not provided to third parties if they cannot or refuse to assume obligations to ensure compliance with the requirements of the Law.

6.3. Unless otherwise provided for by the legislation of Ukraine, Boolat Play has the right to entrust the processing of personal data to a third party with the consent of the User on the basis of an agreement concluded with that third party. Such an agreement shall include confidentiality and non-disclosure of personal data.

6.4. Representatives of public authorities (including regulatory, supervisory, law enforcement, and other bodies) may access personal data processed by Boolat Play in the extent and manner defined by the legislation of Ukraine.

7. Rights of the personal data subject

7.1. In accordance with the legislation of Ukraine, personal data subjects have the right to:
7.1.1. know the sources of data collection, where their personal data is stored, processing objectives, the location of the personal data processor, or instruct authorized persons to obtain such information, except as otherwise provided by the Law;
7.1.2. receive information about the conditions for granting access to personal data, including information about third parties that personal data is transferred to;
7.1.3. access their personal data;
7.1.4. receive information about whether their personal data is being processed, and what data is being processed;
7.1.5. submit a motivated objection to the processing of their personal data;
7.1.6. submit a motivated request to change or destroy all their personal data if such data is processed illegally or is inaccurate;
7.1.7. protect their personal data from illegal processing and accidental loss, destruction, damage in connection with intentional concealment, failure to provide or untimely provision of personal data, as well as protect themselves from the provision of information that is inaccurate or discrediting the honor, dignity, and business reputation of an individual;
7.1.8. file complaints about the processing of their personal data to the administrative body for the protection of personal data in Ukraine—the Department for Personal Data Protection of the Secretariat of the Commissioner for Human Rights of the Verkhovna Rada of Ukraine—or to the court;
7.1.9. enforce legal remedies against violation of legislation on the protection of personal data;
7.1.10. make reservations about limiting the right to process their personal data when giving consent;
7.1.11. withdraw consent to the processing of personal data.

8. Implementation of personal data protection

8.1. Processing personal data in information systems by Boolat Play is inextricably linked with the protection of the confidentiality of the information received by Boolat Play, provided it is not contrary to the applicable law.

8.2. The personal data protection system includes organizational and (or) technical measures based on current threats to the security of personal data and information technologies used in information systems. Boolat Play will update such measures as needed with the advent of new technologies.

8.3. The exchange of personal data processed in information systems is carried out via communication channels protected by technical means of information protection.

8.4. Boolat Play implements the following requirements of the Ukrainian legislation in the field of personal data:

⦁ requirements for the confidentiality of personal data;

⦁ requirements to ensure the exercise of rights by the subjects of personal data;

⦁ requirements to ensure the accuracy of personal data, and, if necessary, relevance in relation to the objectives of personal data processing (with the adoption (ensuring the adoption) of measures to delete or clarify incomplete or inaccurate data);

⦁ requirements for the protection of personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;

⦁ other requirements of the Law.

8.5. In accordance with the Law, Boolat Play independently determines the structure and list of measures necessary and sufficient to ensure the fulfillment of its obligations in accordance with the legislation in the field of personal data in relation to unauthorized or illegal processing, unintentional loss, destruction, or damage. 

8.6. The cookies used on the Site do not identify an individual User—they only identify the computer or mobile device used by the User. Cookies and other tracking technologies on the Site may be used in a variety of ways, including for the purpose of operating the Site, analyzing traffic, or for advertising purposes. In particular, cookies and other tracking technologies are used to improve the quality and efficiency of the Site's services. Some Internet browsers can be configured to block cookies and other tracking technologies. At the same time, if some cookies are disabled, the functionality of the Site may be limited, and some pages may not work correctly.

9. Additional terms and conditions

9.1. Boolat Play has the right to amend this Policy without the consent of the User.

9.2. The new Policy comes into force from the moment it is posted on the Boolat Play's Site, unless otherwise provided by the new version of the Policy.

9.3. Any suggestions or questions regarding this Policy should be directed to:

9.4. The effective Policy is available at