Privacy Policy

Processing of personal data of SAMO-TRANS platform users Edition of 05.08.2026

This Policy forms an integral part of the User Agreement and describes how we collect, use and protect your personal data. Processing is carried out in accordance with the Law of Ukraine "On Personal Data Protection" of 01.06.2010 No. 2297-VI.

By using the Platform, you confirm that you have read this Policy and consent to the processing of your personal data on the terms it sets out.

Data controller

Individual entrepreneur O.V. Rybalko

1. What data we collect

You provide yourself: full name, email, phone, company name, company or tax registration number (if any), city and country, password (stored solely as a cryptographic hash), the content of listings, data of employees and contact persons, support enquiries, chat messages, reviews and replies to them, advertising materials.

Collected automatically: IP address, browser and device type, operating system, screen resolution, date and time of visit, pages viewed, referral source, approximate location by IP, session identifiers, cookies, and anonymised records of on-page interaction (cursor movement, clicks, scrolling) for interface usability analytics.

Technical error data: when a failure occurs, we record the circumstances of the error, including the account identifier, the page address and technical parameters of the request.

On payment: tariff plan, amount, currency and date of payment, transaction identifier, masked payment instrument identifier, Wallet transaction history.

We do not receive, process or store your payment card details. The number, expiry date and CVV are transmitted directly to the LiqPay payment system.

2. Why we process data

Providing access to the Services and performing the contract · creating and maintaining an account · identification and authentication · processing payments, Wallet top-ups, refunds and bonus credits · providing advertising services and displaying advertising · communication about the Services, changes to terms and maintenance · service notifications, including by email and through messengers if you have connected them · handling enquiries, complaints and claims · content moderation · Platform security, fraud and abuse prevention · detecting and fixing technical errors · accounting and tax records · analytics and service improvement · protecting the rights and legitimate interests of the controller, including in disputes · informational and promotional mailings (which you can opt out of in your account settings or via the link in the email).

3. Who we share data with

• Other Users — contact details from your profile and listings become available to those whose tariff includes viewing contacts. By posting a listing, you understand and accept this.
• Integrators via the API — if your data appears in public listings, it may be passed to the third-party systems (TMS/CRM) of other Users who work with the Platform through the application programming interface.
• Service providers acting on our instructions and under contract:
  • LiqPay — payment acceptance;
  • Railway — application and database hosting;
  • Cloudflare — web traffic protection and delivery;
  • S3-compatible object storage — storage of uploaded images and files;
  • Resend — email delivery;
  • Sentry — technical error monitoring;
  • Microsoft Clarity — on-page behaviour analytics;
  • Google (Google Tag Manager and the analytics tools connected through it) — web analytics;
  • Crisp — support live chat;
  • Telegram — message delivery and publication of listings in the Platform's official channels, if you have used that feature.
• Public authorities — upon written request in the cases provided for by law, and to protect the controller's rights.
• A successor — in the event of reorganisation or transfer of the business, subject to this Policy.

We do not sell your personal data.

4. Transfers outside Ukraine

Some of the service providers listed in Section 3 are located outside Ukraine (in particular in the European Union and the United States). Data is transferred to such providers to the extent necessary to supply the Services, under contracts providing for data protection. By using the Platform, you understand and accept such transfers.

5. How long we keep data

For the life of the account plus 3 years after its deletion (the limitation period, Article 257 of the Civil Code of Ukraine). Accounting and tax records — for the period required by tax law. Technical and security logs — up to 12 months. Anonymised statistics may be kept indefinitely.

Data relating to a dispute, claim or court proceedings is kept until it is finally resolved.

6. Your rights

Under Article 8 of the Law you have the right to: know about the processing of your data, access it, request its correction or deletion, withdraw consent, object to processing, and lodge complaints with the Ukrainian Parliament Commissioner for Human Rights.

How to exercise them: send a request to [email protected] from your account email. We reply within 30 calendar days. Most profile data can be changed yourself in your account.

Please note: deleting some data may make further use of the Platform impossible, and data we are required to keep by law, or that we need to defend our rights in a dispute, is kept until the relevant period expires.

7. Cookies and analytics

Technical and functional cookies are used on the basis of performing the contract with you. Analytics and advertising cookies are used to keep the Platform running, secure and improving; by continuing to use the Platform after the cookie banner is shown, you agree to their use.

You can restrict or delete cookies in your browser settings and use the opt-out tools provided by the relevant analytics services. Disabling technical cookies makes use of the Platform impossible.

8. Data security

HTTPS/TLS on all pages · passwords stored solely as cryptographic hashes and cannot be recovered · access segregation · activity logging · backups · limited staff access to data.

That said, no method of transmitting or storing data over the internet is absolutely secure. We do not guarantee absolute security and are not liable for the consequences of third-party actions, or for a compromise caused by the User (in particular by sharing a password or access with third parties).

9. Minors

The Platform is intended for persons aged 18 and over. We do not knowingly collect children's data. Report any such case to [email protected] and we will delete it.

10. Changes to this Policy

We may amend this Policy. A new edition takes effect once published on the Platform. Continued use constitutes acceptance of the changes. We recommend reviewing this page from time to time.

This Policy is drawn up in Ukrainian. Where versions in other languages exist, the Ukrainian version prevails.