Privacy Policy on the Processing of Personal Data

1. Terms and Definitions Personal Data (hereinafter – PD or personal data or data)

Personal Data (hereinafter – PD or personal data or data) – any information related to an identified or identifiable natural person (the data subject).

Data Subject, User – a natural person (individual, client, visitor of BUGSTREAM’s website, consumer of BUGSTREAM’s services, whether potential or active) whose personal data is processed by BUGSTREAM. In this document, it refers to an individual intending to use BUGSTREAM’s services.

Data Operator – BUGSTREAM.

Processing of PD – any action (operation) or a set of actions performed with or without automation tools involving personal data, including collection, recording, systematization, accumulation, storage, updating (modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction of personal data (data processing).

Automated Processing of PD – processing of personal data using computing technologies.

Non-automated Processing of PD – processing of personal data contained in an information system or extracted from such a system with human participation.

Cross-border Transfer of PD – transfer of personal data to the territory of a foreign state, to the authority of a foreign state, a foreign natural or legal person.

2. General Provisions

2.1. The Policy is developed in accordance with the legislation of Ukraine on personal data protection. It defines the procedure and conditions for processing PD by BUGSTREAM as the data operator and establishes rules for working with PD, PD protection requirements, as well as the rights, obligations, and responsibilities of BUGSTREAM managers and employees.

2.2. The objectives of this Policy are:

• 2.2.1. to define the procedure for processing PD;
• 2.2.2. to ensure that the PD processing procedure in BUGSTREAM complies with Ukrainian legislation;
• 2.2.3. to ensure the protection of PD.

2.3. The tasks of this Policy are:

• 2.3.1. to define principles of PD processing;
• 2.3.2. to define conditions of PD processing and protection methods;
• 2.3.3. to define the rights of data subjects and the rights and obligations of BUGSTREAM during PD processing.

2.4. This Policy comes into force upon approval and remains valid until replaced by a new version.

2.5. Decisions affecting your rights or interests will not be made solely based on automated processing of your personal data.

2.6. BUGSTREAM ensures recording, systematization, accumulation, storage, updating (modification), and extraction of personal data of indiviruals using databases located on the territory of Ukraine.

2.7. This Policy comes into force upon approval and remains valid until replaced by a new version.

2.8. BUGSTREAM reviews and updates this Policy when necessary, in particular:

• 2.8.1. in case of changes in PD processing procedures at BUGSTREAM;
• 2.8.2. based on inspection results by the authority for PD protection, revealing non-compliance with Ukrainian law;
• 2.8.3. in case of amendments to Ukrainian legislation regarding PD protection and processing;
• 2.8.4. in case of significant violations detected during internal audits of PD protection.

2.9. The provision of PD belonging to another subject without their consent is prohibited. You are responsible for any consequences caused by violating this requirement.

3. Collection and Use of Personal Data

3.1. The Operator collects and stores only the personal data necessary for the use of BUGSTREAM’s websites, services, applications, products, and/or services (hereinafter – Services).

4. Use of Cookies and Technical Data

4.1. BUGSTREAM uses cookies and other tracking technologies to ensure proper website functionality, improve user experience, analytics, and content personalization.

5. Cases of Disclosure to Third Parties

5.1. We may disclose your personal data to our employees, other companies within the BUGSTREAM Group, and trusted BUGSTREAM partners who will process it on behalf of BUGSTREAM.

6. Consent to Personal Data Processing

6.1. By this, you, as the data subject, provide consent to BUGSTREAM to process your personal data, as specified in this Policy.

7. Where and How We Store Your Data

BUGSTREAM guarantees that the data received from you is stored in a secure environment.

8. Record Updates

If you detect inaccuracies in your personal data or need to update it (e.g., change of name, address, etc.), please contact us so we can make the changes.

9. Questions

If you have any questions regarding this Policy, please contact us.

10. Amendments to the Policy

BUGSTREAM reserves the right to periodically update this Policy. The previous version loses validity on the date the new version is issued.