Privacy Policy

HARLIB ("we", "us", "our") respects your privacy and is committed to processing your personal data lawfully, transparently and responsibly. This Privacy Policy (the "Policy") explains what personal data we collect through our website harlib.com.ua (the "Website"), how and why we process it, and the rights available to you.

This Policy does not apply to information provided to us in the course of a client engagement, which is protected by professional secrecy, legal privilege and confidentiality obligations under the relevant engagement terms and applicable law.

1. What personal data we collect

1.1. Consultation and contact form. When you complete the form on the Website, you may provide your name, email address, telephone number (if you choose to), the organisation you represent (if provided) and a brief description of your enquiry, which you enter voluntarily. Please share only high-level information at this stage and do not submit confidential or privileged details through the form.

1.2. Direct contact. If you contact us by email, telephone or messenger using the details on the Website, we process your contact data and the content of your message in order to respond.

1.3. Cookies. The Website uses cookies — small text files stored on your device by your browser. This section serves as our cookie notice; we do not maintain a separate cookie policy. We use two categories:

2. How we obtain your personal data

You are not required to provide any personal data. Where we hold data about you, we have obtained it because you provided it — by completing the contact form, contacting us directly, or consenting to optional cookies — or generated it automatically as limited technical data when you browse the Website.

3. How we use your personal data

We use your personal data to receive and respond to your enquiries; to communicate with you and, where relevant, prepare for a possible engagement; to operate, secure and improve the Website; to comply with our legal, regulatory and professional obligations; and to establish, exercise or defend legal claims. We do not sell your personal data and do not use it for automated decision-making that produces legal effects on you.

4. Legal basis for processing

Where the GDPR applies, we rely on your consent (for enquiries and optional cookies), on steps taken at your request before a possible engagement, on our legitimate interests (operating and securing the Website and protecting our rights), and on compliance with our legal obligations. Where Ukrainian law applies, we process data on the grounds permitted by the Law of Ukraine "On Personal Data Protection", including your consent and our legitimate interests.

5. Who we share your personal data with

We treat your personal data as confidential and disclose it only where necessary: to trusted service providers acting on our behalf under appropriate safeguards (website hosting, IT and email providers, and Google for analytics); to public authorities, courts or regulators where required by law or a lawful request; to a successor in connection with a reorganisation or merger, subject to appropriate protections; and to other recipients with your consent. Processors are bound by contract to process data only on our instructions and to apply appropriate security measures.

6. International transfers

To operate the Website and respond to enquiries, your data may be processed in or transferred to countries outside your own jurisdiction, including through service providers located abroad. Where transfers involve data protected under the GDPR, we ensure an appropriate transfer mechanism is in place. In particular, where you consent to analytics cookies, data collected through Google Analytics may be transferred to Google servers, including in the United States, supported by safeguards such as the EU–U.S. Data Privacy Framework and standard contractual clauses.

7. How long we keep your personal data

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required to meet our legal, regulatory and professional obligations. Enquiry data is kept for the period needed to handle your request and assess a possible engagement, after which it is deleted or anonymised, unless a longer period is justified — for example, to comply with statutory requirements or to defend legal claims.

8. How we protect your personal data

We apply technical and organisational measures appropriate to the data to protect it against unauthorised access, loss, misuse or disclosure, and anyone processing data on our behalf is bound by confidentiality obligations. No transmission over the internet is completely secure, so please avoid sending confidential information through the Website form.

9. Your rights

Subject to applicable law, you have the right to access your personal data; to have it corrected or deleted; to restrict or object to certain processing; to data portability; to withdraw your consent at any time without affecting processing carried out beforehand; and to lodge a complaint with a supervisory authority. In Ukraine, this is the Ukrainian Parliament Commissioner for Human Rights; if you are in the EEA or the UK, you may also contact your local data-protection authority. To exercise your rights, contact us using the details below; we may need to verify your identity first.

10. Changes to this Policy

We may update this Policy from time to time to reflect changes in our practices or applicable law. The current version is always available on the Website. We encourage you to review it periodically.

11. Data Controller

The controller responsible for personal data processed through the Website is:

Correspondence address: GNRTR Coworking, 3 Mykhaila Hrushevskoho St., Kyiv, 01001, Ukraine
Email: matosian@harlib.com.ua

The Website and this Policy are governed by the laws of Ukraine, without prejudice to any mandatory rights you may have under the data-protection law of your country of residence.