Version dated 9 September 2026

This Privacy and Personal Data Processing Policy (the ‘Policy’) sets out how the personal data of users of namriyano.com.ua and Customers and Guests of the Namriyano holiday complex is collected, used, stored, protected and otherwise processed.

The personal data controller is:

Sole Proprietor Serhii Viktorovych Pryshchepa
Taxpayer identification number / EDRPOU: 3336912515
IBAN: UA893052990000026001016713026
Bank: JSC CB PRIVATBANK

hereinafter the ‘Controller’, ‘Provider’ or ‘Namriyano’.

1. GENERAL PROVISIONS

1.1. This Policy applies to personal data the Controller receives through namriyano.com.ua, the booking system, telephone enquiries, email, messengers, social media and other communication channels with users, Customers and Guests.

1.2. Personal data is processed in accordance with Ukrainian law, including legislation on personal data protection, electronic commerce, consumer protection and other applicable legislation.

1.3. By providing personal data to the Controller, the user confirms that they have read this Policy.

1.4. Where the law requires the data subject’s consent to a particular type of processing, that processing takes place after the relevant consent has been obtained.

2. DATA THAT MAY BE PROCESSED

2.1. Depending on how you interact with Namriyano, the following may be processed:

first and last name;
telephone number;
email address;
booking information;
check-in and check-out dates;
number of guests;
selected house and additional services;
information needed to process and identify payments;
enquiry and communication history;
information the user voluntarily provides when booking or communicating with Namriyano representatives;
technical information about website use to the extent collected by the relevant technologies and services.

2.2. The Controller does not seek to collect personal data that is unnecessary for the purposes set out in this Policy.

3. PURPOSES OF PERSONAL DATA PROCESSING

Personal data may be processed for the following purposes:

making and confirming bookings;
performing the agreement and providing services;
identifying the Customer;
communicating about bookings;
arranging check-in and check-out;
processing payments;
providing additional services;
handling enquiries and requests;
resolving complaints and disputes;
maintaining accounting and tax records;
meeting statutory obligations;
ensuring website operation and security;
analysing website performance and improving service quality, where there is an appropriate legal basis;
sending marketing communications, where the necessary user consent has been obtained.

4. LEGAL BASES FOR PROCESSING

4.1. Personal data is processed where there is an appropriate legal basis, in particular in connection with:

the need to enter into and perform an agreement with the Customer;
the need to comply with legal requirements;
protecting the Controller’s lawful rights and interests in cases provided for by law;
the data subject’s consent, where required.

4.2. Refusing to provide data that is objectively necessary to make and fulfil a booking may make it impossible to provide the relevant service.

5. MARKETING COMMUNICATIONS

5.1. Namriyano may use the user’s contact details to send advertising and information materials only where there is an appropriate legal basis and, where consent is required by law, after obtaining it.

5.2. These messages may include:

promotions;
special offers;
promo codes;
discounts;
seasonal offers;
information about new houses;
information about new services;
Namriyano news;
personalised offers.

5.3. Communications may be sent by email, SMS, telephone and messengers, depending on the contact details provided by the user.

5.4. Consent to marketing messages is voluntary. Refusing consent does not affect the ability to make a booking or use Namriyano’s core services.

5.5. The user may opt out of marketing messages at any time using the available unsubscribe function or by contacting Namriyano.

5.6. Opting out of advertising messages does not apply to service messages needed to fulfil an existing booking or agreement.

6. COOKIES AND TECHNICAL DATA

6.1. The namriyano.com.ua website may use cookies and similar technologies to ensure the website functions properly.

6.2. Depending on the services actually connected to the website, cookies and other technologies may also be used for:

saving user preferences;
operating the booking system;
analysing website traffic and usage;
assessing advertising campaign performance;
creating audiences for advertising campaigns;
displaying relevant advertisements.

6.3. Where applicable law requires prior user consent for certain categories of cookies or similar technologies, those technologies must be used only after the relevant consent has been obtained.

6.4. The user can manage cookies through the relevant website mechanism, if implemented, and through their browser settings.

7. ANALYTICS AND ADVERTISING SERVICES

7.1. The website may use third-party analytics, advertising and technology services.

7.2. Depending on the website’s actual configuration, these services may include web analytics systems, advertising platforms, remarketing services, CRM, an online booking system, email services and other technology providers.

7.3. Such providers may receive certain technical and other data to the extent necessary for the relevant service to operate and in accordance with applicable law.

7.4. Once the specific analytics and advertising systems connected to namriyano.com.ua have been identified, further details may be added to this Policy and/or the cookie management tool.

8. SHARING DATA WITH THIRD PARTIES

8.1. To support Namriyano’s operations, personal data may be shared with or made accessible to service providers responsible, in particular, for:

website operation and hosting;
the booking system;
CRM;
payment transactions;
email and messaging;
accounting and other professional services;
analytics and advertising technologies, where there is an appropriate legal basis.

8.2. Data may also be provided to public authorities and other persons in cases provided for by Ukrainian law.

8.3. The Controller does not sell users’ personal data as a database to third parties.

9. RETENTION PERIOD

9.1. Personal data is retained no longer than necessary to achieve the relevant processing purpose, perform the agreement, meet accounting, tax and other statutory obligations, and protect the parties’ lawful rights and interests.

9.2. Where certain data is processed solely on the basis of consent, the data subject may withdraw that consent. Withdrawal does not affect the lawfulness of processing carried out before withdrawal and does not require processing to stop if another legal basis remains available.

10. PERSONAL DATA SECURITY

10.1. The Controller takes organisational and technical measures to protect personal data against unlawful or accidental access, loss, destruction, alteration and other unlawful processing.

10.2. Access to personal data is granted only to persons and service providers who need it to perform their respective functions.

11. USER RIGHTS

Users have the rights regarding their personal data provided for by Ukrainian law, including the right to obtain information about processing, request access, request correction or protection of their data and, where provided for by law, object to processing, request that it cease or withdraw consent.

Each right is exercised within the scope and according to the procedure established by current Ukrainian law.

12. OTHER GUESTS’ DATA

12.1. If the Customer provides other guests’ personal data when booking, they confirm that there are lawful grounds for providing that data to the Provider.

12.2. The Customer should not provide more personal data about other persons than is necessary to make and fulfil the booking.

13. CHANGES TO THE POLICY

13.1. The Controller may amend this Policy to reflect changes in legislation, website functionality, the services used or personal data processing procedures.

13.2. The current version of the Policy is published at namriyano.com.ua.

14. PERSONAL DATA CONTROLLER’S CONTACT DETAILS

For matters relating to personal data, users may contact the Provider using the contact details published at namriyano.com.ua.

Personal data controller:

Sole Proprietor Serhii Viktorovych Pryshchepa
Taxpayer identification number / EDRPOU: 3336912515

Website: namriyano.com.ua

Privacy Policy