Privacy Policy
Version 2026-09-30, effective 2026-09-30
This policy explains how PE Klimovych Anastasiia, an individual entrepreneur (ФОП) registered in Ukraine, taxpayer number (RNOKPP) 3478811607, 18 Myru St., Vodychky village, Khmelnytskyi district, Khmelnytska region, 31334, Ukraine (Adminka, we) processes personal data in connection with the site datastudio.adminka.pro (the Site) and the Adminka Connect service (the Service). It is written to meet the Law of Ukraine "On Personal Data Protection" and, for people in the EU/EEA, the General Data Protection Regulation (GDPR).
Contact for any privacy question: info@adminka.pro.
1. Two different roles
- We are the controller for data about Site visitors, people who send us the call-back form, and users of Accounts (sections 2–4).
- We are the processor for the data the Service reads from our customers' CRMs (for example, the customer's clients, contacts and deals). The customer is the controller of that data; we process it only on the customer's instructions under the Data Processing Agreement. If you are a customer's client and want to exercise your rights over that data, contact the company whose CRM holds it; we will help them.
2. What we collect and why
| Data | When | Purpose | Legal basis (GDPR) |
|---|---|---|---|
| IP address, browser type, requested pages, time (server logs) | Every Site visit | Security, troubleshooting | Legitimate interest (Art. 6(1)(f)) |
| Name, contact (phone, email or Telegram), company, message, what you asked for, the page and campaign tags (UTM) you came from | You send the call-back form | Contact you back and handle your request | Steps before a contract at your request (Art. 6(1)(b)); legitimate interest |
| Google account name and email | You sign in | Open and secure your Account | Contract (Art. 6(1)(b)) |
| Your acceptance of our documents (version, time, IP) | Sign-up | Prove what was agreed | Legal obligation / legitimate interest |
| Your CRM API key (stored encrypted), account settings | You connect a CRM | Provide the Service | Contract |
| Billing records (plan, amounts, status); card payments are handled by WayForPay — we never see card details | You subscribe | Billing, accounting | Contract; legal obligation (Art. 6(1)(c)) |
| Support correspondence | You write to us | Answer you | Contract / legitimate interest |
We do not use advertising or analytics trackers on the Site, and we do not sell personal data.
3. Cookies and browser storage
The Site uses only what it needs to work:
- a session cookie and an XSRF-TOKEN cookie — to protect the call-back form against forgery (strictly necessary);
- a locale cookie — only if you switch the language yourself, to remember your choice.
We do not use analytics, advertising or third-party cookies, so we do not show a cookie banner. If that changes, we will ask for your consent first.
4. Who receives the data
| Recipient | Role | Location |
|---|---|---|
| Hetzner Online GmbH | Hosting and backups (all Site and Service data) | Germany (EU) |
| KeepinCRM (our own CRM account) | Stores call-back requests as leads | Ukraine |
| Telegram | Internal notification to our team about a new call-back request | Outside the EU |
| WayForPay | Card payments and recurring billing | Ukraine |
| Sign-in with Google; Data Studio (at the customer's instruction) | Global | |
| Microsoft | Our email (Microsoft 365) | EU / global |
Our team works from Ukraine. We share data with authorities only where the law requires it.
5. International transfers
Data is stored in Germany. It is accessed by our team in Ukraine and, for the services above, by providers outside the EU/EEA. For transfers from the EU/EEA to countries without an EU adequacy decision (including Ukraine) we rely on the European Commission's Standard Contractual Clauses or the provider's equivalent safeguards. You can request a copy of the relevant safeguards at info@adminka.pro.
6. How long we keep data
| Data | Retention |
|---|---|
| Server logs | Short-term: size-limited and overwritten automatically, and deleted on every redeploy of the Site |
| Call-back requests | Up to 3 years after the last contact, unless you become a customer |
| Account data | While the Account exists, then up to 30 days |
| Customer Data (CRM data) | While the subscription or trial runs, then deleted within 30 days (see the Terms) |
| Backups | Rotated out within 21 days |
| Billing and acceptance records | As long as accounting and tax law requires |
7. Security
Encrypted connections (HTTPS); CRM API keys encrypted at rest; a separate database for each customer; administrative access limited to named staff and possible only through a VPN; nightly backups.
8. Your rights
You have the right to access your data, have it corrected or deleted, restrict or object to processing, receive it in a portable format, and withdraw consent where processing is based on consent (GDPR Articles 15–21; Article 8 of the Law of Ukraine "On Personal Data Protection"). Write to info@adminka.pro; we answer within 30 days.
You may also complain to a supervisory authority: in the EU/EEA — the data protection authority of your country; in Ukraine — the Ukrainian Parliament Commissioner for Human Rights.
9. Children
The Site and the Service are intended for businesses and are not directed at children.
10. Changes
We will publish changes to this policy on this page, with the new version and date at the top, and notify Account holders of material changes by email.