Privacy policy

  1. What is the purpose of this Privacy Policy?

In this privacy policy (hereinafter referred to as the Privacy Policy), we provide you with information on how Pontic Trading (hereinafter referred to as the Company) processes your personal data obtained: when the Company provides services and sells goods to customers or receives services or purchases goods (where the other party to the contract is a natural person); when the Company carries out direct marketing; when selecting candidates; in order to ensure the protection of confidential information and the continuity of business activities; in order to perform contracts concluded between the Company and its contracting parties (legal entities); in order to protect legitimate interests in the event of disputes or breaches; when you visit the Company’s website or social media accounts; when making enquiries; when carrying out video surveillance. All persons whose data is processed by the Company are hereinafter referred to as Data Subjects. 


  1. About the Company

Company means Pontic Trading, registration No. 000000000, head office address: Kolcevaja str. 4, Proliski, Kyiv region, Ukraine, data of the Company are collected and stored in the Register of Legal Entities of the Republic of Lithuania. Contact email for personal data protection issues 


  1. What is personal data?

Personal data means any information collected by the Company about a Data Subject that can be used to identify the Data Subject and is stored electronically or otherwise. 

Personal data include any information, including the name, surname, address of the Data Subject, which the Company collects about Data Subjects for the purposes set out in this Privacy Policy or in the Data Subject’s individual consent or agreement with the Company. 


  1. Personal data processed in connection with the receipt or provision of services or the sale or purchase of goods by the Company
Personal data processedGrounds for processingDuration of the processing
Name, surname, national identification number, address, business certificate/self-employment certificate number (service provider’s), bank account number. Any information collected about the Data Subject that can be used to identify the Data Subject.  Article 6(1)(b) of the GDPR (contract)  10 years after the end of the contract 


5. Direct marketing 

We will send offers for the sale of the Company’s goods or services, newsletters, and other promotional materials, as well as notifications about the Company’s news, by electronic means (email) to persons aged 14 years or older who have provided their contact details and have expressed an interest in receiving information about the Company’s offers of goods and/or services. 

For direct marketing, the Company will process your email address (mandatory data without which we will not be able to send you direct marketing communications). Your data will be processed for the purpose of direct marketing for a period of 3 years from the date of your consent. 

If you have purchased goods or services sold by the Company and have not objected to receiving direct marketing communications from the Company (e.g., by ticking the opt-out box on the direct marketing consent form or by informing us of your objection by email as set out in the Policy), we will, on the basis of our legitimate interest, send you communications by email or SMS about goods or services that are similar to those sold to you. In this case, your data will be processed for the purpose of direct marketing for a period of 3 years after the last purchase of goods or services. 

You have the right to object to or opt-out of receiving direct marketing communications at any time by contacting us at the email address set out in Section 2. 


  1. Selection of candidates

We collect and process your personal data (name, surname, preferred position, work experience (employer, position, person who can recommend you), education, other data provided in your CV, application form or cover letter and/or other information provided by you) for the purpose of your participation in the recruitment process, for the purpose of carrying out the recruitment process, on the basis of the consent that you have given to the Company by sending your CV and/or cover letter. Without your CV and/or cover letter, we will be unable to assess your suitability for the job. 

In the event that you do not express your individual consent to the processing of your personal data, at the end of the selection process, we will delete and/or destroy your personal data within 3 days after the signature of the contract with the successful candidate or the decision to terminate the selection process, except in the case of a separate consent for the retention of the candidate’s personal data for a period of time specified in the consent. 

If we are required by law to check your health before employing you, we will process data about your health for the purpose of verifying your suitability in order to fulfil this legal obligation. 

Based on your consent, we will keep the data for the period specified in the consent. 

Based on our legitimate interest, we will process the data (name, surname, email address, telephone number, information provided by the person) about the person (a former employer or a referee) indicated by the candidate for the purpose of selecting a candidate. In this case, we have a legitimate interest in selecting the right candidate for the position. We will destroy this data after the selection process. 

We may receive your data directly from you, from the online platforms on which you apply for vacancies we advertise or from recruitment agencies. 


  1. Protecting confidential information of the Company and ensuring business continuity

To ensure its legitimate interest in the protection of the Company’s confidential information and the continuity of the Company’s business, the Company may review the correspondence of its employees with contracting parties. For these purposes, the Company processes the following personal data of its employees and of persons who send or receive emails from its employees: email address, the information contained in the electronic work devices, date. This data are retained for 4 years. 


  1. Performance of the Company’s contracts with contracting parties

To ensure its legitimate interest in the performance of the Company’s contracts with its contracting parties, the Company processes the personal data of the employees of these entities, i.e., their name, surname, email address, telephone number, and the content of correspondence. Data relating to the performance of contracts are retained for 10 years after the end of the contract. 


  1. Protection of property and persons

To ensure the safety of customers, visitors, employees, and other persons entering the surveillance area, the property of these persons and the Company, to collect evidence of violations, and to protect its rights, the Company carries out video surveillance. Video surveillance is carried out on the basis of the legitimate interest of these persons and the Company. In the context of video surveillance, the Company processes the following personal data: image, trajectory, possessions, date. The data are retained for 1 month. 


  1. Protecting legitimate interests in the event of disputes, theft and other criminal or administrative offences

The Company, based on its legitimate interest to protect its rights, including in the event of a civil dispute, theft and other criminal offences, or in the event of an administrative offence, processes the names, surnames, national identification numbers of the offenders or suspects and other persons involved in the case, the circumstances of the case, any other information relevant to the case, and any other information available in the public domain. The data may be passed on to insurance companies, law enforcement authorities or debt collectors. The data will be destroyed 3 years after the final settlement of the case and the full satisfaction of the Company’s claims (if awarded). 


  1. Contact us

There are several ways in which you can contact the Company: by telephone, by email, by filling in an online enquiry form. We receive, review, and respond to all messages ourselves. If you contact us, we may process the data you provide to us, i.e., name, company name, telephone number, email address, project description and the information contained therein (if attached). 

Such data will be processed on the basis of your consent in order to answer your questions and process your suggestions. If you do not provide your contact details, it will be impossible to contact you. 

Correspondence details will be retained for 1 year from the date of receipt of the message, except for information whose storage is subject to other time limits set out in the Privacy Policy or legislation. 

Any personal data you provide when you interact with us are only used for the purposes set out above and to process messages and administer and manage communication flows. We undertake not to use your personal data in any media channels in such a way that it is possible to identify you without your explicit consent. 

Please note that we may need to contact you by post, email, or telephone. Please notify us of any changes to your personal data. 


  1. Website

Our website uses cookies. 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer with your consent. We use different cookies for different purposes. Cookies help us to distinguish you from other users of the Website and thus ensure a more enjoyable browsing experience and improve our Website. 

Most browsers allow you to reject all cookies and some browsers allow rejecting only third-party cookies. You may take advantage of these options. However, please note that rejecting all cookies will have a negative impact on the use of the Website and you will not be able to use all services provided on the Website without cookies. For more details, please visit or 

Third-party cookies may also be saved when you visit the Website, the specific number and functions of which are not under the control of the Company and the Company does not have access to the information collected by them. You can find detailed information about the functions of the cookies used by third parties (Facebook, Google, etc.) and the personal data they collect in the privacy/cookie policies of these third parties (for example, Facebook Cookie Policy, Google Cookie Policy) or by contacting the contact person of the third party that sends cookies. 


  1. Social Media

The information provided by you using social media (including the use of Like and Follow buttons and other communication) is controlled by the manager of the social network. 

We process the information contained in our accounts for the purpose of administering the accounts on the basis of your consent. 

We recommend that you read the privacy notices of third parties and contact the service providers directly if you have any questions as to how they use your personal data and what cookies are collected on these websites. 


  1. Newsletter

On our website, you may be offered to receive newsletters from our company about the latest products and services by providing your email address. Once we have your consent to send you newsletters, we are fully entitled to do so. You can unsubscribe at any time by clicking on the “Unsubscribe” button in the email you receive and confirming your unsubscription in the next email. Your email address will be processed for the purpose of sending newsletters until you unsubscribe. When a newsletter is sent and you  click on a link in the newsletter, data may be collected. Your email address may be passed on to third parties providing special newsletter services for the sole purpose of sending you newsletters via their platform. If you have any questions about the newsletter, please contact us at 


  1. Receipt and disclosure of data

We receive your data from you, your devices, our employees and our contracting parties. 

We may disclose information about you to our employees, agents, service providers such as debt management or collection companies, marketing service providers, IT service providers or sub- contractors as reasonably necessary for the purposes set out in this Privacy Policy. 

In addition, we may disclose information about you: 

  1. if we are required to do so by law 
  2. to protect our rights or interests (including the transfer of your data to third parties with the purpose of recovering your debt to us) 
  3. when we intend to sell the Company’s business or part of its assets by disclosing your personal data to a potential buyer of the business or part of it (on the basis of our legitimate interest in finding an investor) 
  4. following the sale of the Company’s business or a substantial part of its assets to a third party. Except as provided in this Privacy Policy, we do not provide your personal data to any third parties. 

The list of recipients or categories of recipients specified in the Privacy Policy is subject to change; therefore, if you wish to be informed about changes in the recipients of your personal data, please notify us by sending us an email to the address specified in this Privacy Policy, indicating in the body of the email “I wish to receive information about changes in the recipients of my personal data, name, surname”. 


  1. Security of personal data

Your personal data will be processed in accordance with the requirements of the General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania and other legislation. When processing your personal data, we implement organisational and technical measures to protect personal data against accidental or unlawful destruction, alteration, disclosure as well as from any other unauthorised form of processing. 


  1. Your rights

In this section, we provide information about your rights in relation to our processing of your personal data and cases in which you can exercise these rights. If you would like to receive more information about your rights or to exercise your rights, please contact us at the email address provided in this Privacy Policy. 

The Company will provide you with information on the actions taken following your request for the exercise of your rights without undue delay, but not later than within one (1) month of receipt of your request. Depending on the complexity of the request and the number of requests received, this deadline may be extended by a further 2 (two) months. In this case, we will inform you within one (1) month of receipt of the request of such extension and the reasons thereof. The Company will only refuse to implement your rights in cases provided for by law. 


       17.1.        The right to access your personal data 

We want you to fully understand how we use your personal data so that you do not experience any inconvenience. You can contact us at any time to enquire whether we process any of your personal data. If we store or use your personal data in any way, you have the right to access them. To do so, please submit a written request to us at the email address set out in this Privacy Policy, provide us with proof of your identity, and observe the principles of fairness and reasonableness when making such a request. 


        17.2.        The right to withdraw the consent 

If you have given us your explicit consent to the processing of your data, you can withdraw it at any time. 


        17.3.        Additional rights 

The following information sets out the additional rights that you may have, which you can exercise by following the procedures described below. 

  1. You have the right to ask us to rectify any inaccuracies in the data we hold. In this case, we may ask you to confirm the rectified information. 
  2. You have the right to ask us to delete your personal data. This right will be ensured in the cases provided for in Article 17 of the General Data Protection Regulation (EU) 2016/679. 
  3. You have the right to ask us to restrict or refrain from processing your personal data: 
    1. for the period necessary to verify the accuracy of your personal data in the event of a data accuracy complaint. 
    2. where our collection, storage or use of your personal data is unlawful, but you choose not to request erasure. 
    3. where we no longer need your personal data, but you need them to establish, exercise or defend a legal claim. 
    4. for the period necessary to determine whether we have overriding legitimate grounds to continue processing your personal data if you have exercised your right to object to the processing of personal data. 
  4. You have the right to the transfer of data processed by automated means, where the data have been obtained from you with your consent or for the purpose of concluding a contract. If you exercise this right, we will transfer a copy of the data you have provided at your request. 
  5. You have the right to object to our use of your personal data in accordance with Article 21 of the GDPR. You have the right to object when your personal data are processed on the grounds of legitimate interest (for each of the processing purposes listed above, it is indicated on which grounds the data are processed) or for direct marketing purposes. 

       17.4. The right to request more information 

We hope you will understand that it is very difficult to discuss all possible ways in which data can be collected and used. We endeavour to provide as clear and complete information as possible and we undertake to update this Privacy Policy as and when we change the way we use personal data. However, if you have any questions about our use of your personal data, we will be happy to answer them or provide you with any additional information we may disclose. If you have any specific questions or if you do not understand the information provided, please contact us. 


  1. Complaints

If you believe that your rights as a Data Subject have been and/or may be violated, please contact us immediately at the email address specified in this Privacy Policy. We ensure that once we have received your complaint, we will contact you within a reasonable period to inform you of the progress of the investigation and, subsequently, of the outcome. 

If you are not satisfied with the results of the investigation, you may lodge a complaint with the supervisory authority – State Data Protection Inspectorate ( 


  1. Liability

You are responsible for maintaining the confidentiality of the data you provide to us and for ensuring that the data you provide to us are accurate, correct and complete. If the data you have provided change, you must inform us immediately by email. In no event shall we be liable for the damages incurred by you due to incorrect or incomplete personal data provided by you or your failure to inform us of changes thereto. 


  1. Changes to the Privacy Policy

We may update or change this Privacy Policy at any time. If you would like to receive an updated version of the Privacy Policy, please notify us at the email address specified in Section 2. 


  1. Contacts

Pontic Trading

Address: Kolcevaja str. 4, Proliski, Kyiv region, Ukraine

Telephone: +380504157770 ,+37061670993