This Cookie Policy was updated on the 6th of February 2025 

1. Identity and contact details of the Data Controller
2. Categories of personal data, purposes and legal basis for its processing
3. Data recipients
4. Personal data transfers
5. Your rights
6. Contact details

Through our website (umgi.com, hereinafter the “Site”), we can collect some of your personal data in the manner and for the purposes described below.

We care about the privacy of the Site visitors and we will process your personal data in accordance with the applicable legislation.

This Cookie Policy describes the types of information we collect through the Site, including information relating to identified or identifiable natural persons (“Personal Data”), for what purposes we process such Personal Data, to whom we may communicate the Personal Data, and your rights in relation to the Personal Data collected. This Cookie Policy also describes how you can contact us in order to exercise your rights.

The Cookie Policy is provided only for the Site and not for other websites that may be visited by the visitors through links. The Data Controller (as defined below) shall not be responsible for any personal information provided by the visitors to external parties or to any website connected to the Site.

Please read this Cookie Policy carefully: It applies when you access the Site and simply choose to browse it by using our services without filling out any form, and when you request certain information from us concerning, for example, our activities.

As further detailed in Section 2 below, we will process the Personal Data for the purposes of:

• maintaining and upgrading the Site;
• providing information about the company’s activities;
• keeping the data on the Site users’ personal preferences and settings;
• improving the products and (or) services and developing the new ones;
• gathering statistics about users; and
• monitoring the status of the user’s session (access).

1. Identity and contact details of the Data Controller

In relation to the Personal Data, the company LIMITED LIABILITY COMPANY “UMG INVESTMENTS” (the “Data Controller”) acts as the data controller, according to Article 4(7) of the GDPR.

You can contact the Data Controller at the following address:

LIMITED LIABILITY COMPANY “UMG INVESTMENTS”

 04053, Kyiv, Bekhterevsky lane, 12b, Ukraine

+38 044 334 7910

 https://umgi.com

2. Categories of personal data, purposes and legal basis for its processing

a) Personal data collected through the Site forms

By filling in the Site forms, you can provide us certain personal and contact details (i.e., name, e-mail address and phone number).

Such Personal Data is processed in order to provide you with the information requested (e.g., news, announcements, etc.) and to communicate with you.

The above-mentioned Personal Data will be stored for 36 months. At the end of this period, such Personal Data will be deleted or anonymised.

The legal basis for the processing is your consent, according to Article 6(1), lett. A) of the GDPR. We inform you that your consent can be freely withdrawn at any time by sending an e-mail to: office@umgi.com and your Personal Data will be immediately deleted or anonymised.

b) Automatically collected data

Whenever the visitor accesses the Site, certain information about his/her device is automatically collected. In particular:

• the type and version of the browser
• the operating system
• the IP address

The processing of such information is necessary in order to allow the viewing of the Site contents. Such information will be deleted once the purposes for which it was collected have been accomplished and, in any case, at the end of the session (when the user leaves the Site).

The information automatically collected by the Site is not matched with other information about the Site visitors.

The legal basis for such processing is the Data Controller’s legitimate interest in ensuring the proper technical functioning of the Site.

c) Cookies

A cookie is a small text file that is sent to the visitor’s terminal equipment (i.e., visitor´s browser) by the Site; the cookie is stored in the visitor’s terminal equipment to be then re-transmitted to the Site on the user’s subsequent visits to the Site.

We inform you that the cookies used by the Site (the “Cookies”) may be either “session cookies” (i.e., cookies that expire at the end of a browser session) or “persistent cookies” (i.e., cookies that remain stored after the visitor’s browser session ends). Furthermore, Cookies may be set directly by the Site (so-called “first-party cookies”) or by other websites (so-called “third-party cookies”).

Cookies used by the Site:

Browsing or session technical Cookies

The Site uses browsing or session technical Cookies to ensure normal and efficient navigation and use of the Site. Such Cookies do not require your prior explicit consent. You may disable these Cookies by adjusting your browser settings (as specified below); however, this may affect the functionality of the Site.

Functional technical Cookies

The Site uses functional technical cookies that remember your preferences (i.e. the language selected) to enhance the services it provides. Functional cookies improve browsing quality and experience. Please note that your consent is not required to set functional technical Cookies.

Analytics Cookies

These third-party Cookies are used to collect information about how visitors use the Site (e.g., number of visitors, pages visited, time spent on the Site, etc.) to conduct statistical analysis and improve our Site. The Cookies collect information in a way that does not directly identify anyone.

By providing your consent through the banner displayed when accessing the Site, you agree to the use of analytics Cookies. We inform you that your consent will be required only upon your first access to the Site and we use a technical Cookie to track the consent obtained. As specified below, you may withdraw your consent at any time.

We use the following categories of Cookies:

You can change your Cookie preferences at any time by clicking on the option to opt out of being tracked by Google Analytics across all websites at http://tools.google.com/dlpage/gaoptout.

Please note that most web browsers allow some control of most cookies through the browser settings. Find out how to manage cookies on popular browsers:

Internet Explorer  |  Edge  |  Safari  |  Chrome  |  Firefox   | Opera

3. Data recipients

The Personal Data will not be disseminated and may be accessible (in a limited manner, and some content may be displayed incorrectly to the respective field of competence) to the employees and/or collaborators of the Data Controller authorised to process it.

The Personal Data recipients will act as autonomous data controllers, according to Article 4(7) of the GDPR, or as data processors appointed by the Data Controller, according to Article 28 of the GDPR.  

The Personal Data may be communicated to companies, which provides certain services to the Data Controller and to the others companies of the Inwire Group.

Further to that, we provide you with the following information:

a)   Google Analytics

Google Analytics (i.e., the company Google LLC (“Google”), 1600 Amphitheater Parkway, Mountain View, CA 94043, USA) sets certain Cookies, which collect information about how you visit the Site.

Google can distinguish the individual visitors; limit the frequency of demands; remember the number and time of your previous visits; record the traffic source; determine the beginning and end of sessions; remember the values of the visitor level user-declared variables. Information about your device (i.e., about your browser and your operating system) may be accessible for Google.

Please note that we use a mechanism that automatically masks your IP address and the information processed by Google will not be combined with other Google data.

Google will use the received information for statistical analysis and reporting, which will help to optimise the Site, making it more comfortable for the visitors. Your Personal data will be stored for 36 months.

4. Personal data transfers

The recipients identified in Section 3 above may be located in countries outside the EU. All transfers of your Personal Data will be conducted in accordance with the GDPR and the applicable data protection laws, including transfers to non-EU companies of Metinvest Group. As specified above, certain Personal Data collected by Cookies may be transferred to Google. Google complies with the EU-US Privacy Shield Framework as designed by the US Department of Commerce and the European Commission and Swiss Administration (the “Privacy Shield”), providing an adequate level of protection, according to the GDPR and the applicable data protection laws. The Privacy Shield is available at: privacyshield.gov.

5. Your rights

Under the GDPR, the Data Controller ensures the exercise of the following rights:

a) The right to access your personal data (Article 15 of the GDPR).

You have the right to obtain confirmation from the Data Controller as to whether or not Personal Data concerning you is being processed and, if so, access to such Personal Data and the information outlined in Article 15 of the GDPR (e.g. the purposes of processing, the categories of Personal Data involved, the recipients to whom the Personal Data have been or will be disclosed, etc.).  

b)  The right to rectification (Article 16 of the GDPR):

You have the right to obtain from the Data Controller the rectification of inaccurate Personal Data concerning you. Taking into account the purposes of the processing, you also have the right to have incomplete Personal Data completed.

In order to exercise the right referred to in Article 16, your request should include a clear indication of the inaccurate and/or incomplete Personal Data.

c)  The right to erasure or “the right to be forgotten” (Article 17 of the GDPR)

You have the right to obtain from the Data Controller the erasure of your Personal Data in accordance with Article 17 of the GDPR (e.g., when the Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed; when your withdraw your consent or object to the processing and there are no overriding legitimate grounds for the processing, etc.).

d)  The right to restriction of processing (Article 18 of the GDPR):

You have the right to obtain from us a restriction of processing where one of the grounds referred to in Article 18 of the GDPR applies (e.g., you contest the accuracy of the Personal data, for a period enabling the Data Controller to verify its accuracy; the processing is unlawful and you oppose the erasure of the Personal Data and request the restriction of its use instead; we no longer need the Personal Data for the purposes of processing, but it is required by you for the establishment, exercise or defence of legal claims, etc.).

e)   The right to data portability (Article 20 of the GDPR):

According to Article 20 of the GDPR, you have the right to receive certain Personal Data in a structured, commonly used and machine-readable format and to transmit such Personal Data to another data controller without any hindrance from us, where: (i) the Personal Data processing is based on your consent; and (ii) it is carried out by automated means.

f)  The right to object to the processing (Article 21 of the GDPR):

You have the right to object, on grounds relating to your particular situation, at any time, to your Personal Data processing that is based on our legitimate interests, according to Article 6(1), lett. f) of the GDPR. We will no longer process the Personal Data concerned unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You have the right to object, at any time, to the processing of your Personal Data for direct marketing purposes.

g)  The right to withdraw your consent (Art. 7(3) of the GDPR):

 By contacting us at the address below (Section 6), you may at any time withdraw your consent. The withdrawal of your consent will not affect the lawfulness of the processing carried out before such withdrawal.

h) The right to lodge a complaint with a competent supervisory authority:

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the country where you live, work or where the alleged infringement occurred, if you believe that the processing of your Personal Data infringes any applicable data protection laws.

If you are in a Member State of the EU, you can lodge a complaint with one of the European supervisory authorities.

If you are in Ukraine, you can lodge a complaint with the Human Rights Commissioner of the Verkhovna Rada.

Please note that we will provide information on the action taken in response to a request under Articles 15 to 21 of the GDPR as quickly as possible and, in any case, within one month of receiving your request. If strictly necessary, that period may be extended by two additional months. The exercise of your rights is free of charge unless your request is manifestly unfounded or excessive.

6. Contact details

If you have any questions about this Cookie Policy or wish to exercise your rights listed in Section 5 above, you may contact the Controller at the following addresses, specifying “Attention: Legal Department”:

E-mail: office@umgi.com

Address: LIMITED LIABILITY COMPANY “UMG INVESTMENTS”, 04053, Kyiv, Bekhterevsky lane, 12b, Ukraine

Please indicate “Attention: Legal Department” on the envelope.