version 1.1.

effective date: 17.06.2022


The CLUST team values ​​and respects everyone, so the privacy of the personal data of everyone who visits the website and clear and transparent rules for using the website are our priority. This Privacy Policy, Cookies and Terms of Use (hereinafter referred to as the “Website Policy” and/or “Policy”) provide information on how we collect information and how you may use the Web Portal, and explain the purpose and methods of processing of personal data provided by users.

The website policy is developed, approved and applies exclusively to the website The CLUST team makes no warranties or representations regarding the information collected and used on third party websites. We do not verify the accuracy of the users’ information we receive or do not control the legal personality of users.

For easy mastering of the Policy

we use the following TERMS AND DEFINITIONS:

Website (hereinafter referred to as Site) – an information resource on the Internet, located at and containing textual, graphical and other information that is perceived as a whole and is supported by a set of system software.

User means any individual who has ever accessed the Site and reached the age, when they are permitted to accept the User Agreement posted on the Site and this Policy.

User Information– an information array of the User in the form of a story about themselves, their achievements, links to their profiles in social networks/communities, provided by the User for viewing by the Site team. User Information may contain Personal Data.

Personal data – an information or a set of information about the User, which is specifically identified or can be specifically identified.

Services (Site Services) – any services offered on the Site that include, but are not limited to, the provision of information content about the CLUST team and products, interaction with potential job applicants, direct brand promotion, advertising, etc.


1.1. Use of the Site does not require registration and/or authorization and direct provision of personal data that can identify the User, except for the cases expressly provided in the terms of the Policy.

1.2. Users provide all the Information exclusively on a voluntary basis, expressing the will of each individual User.

1.3. We receive User Information in order to process the User’s request to us.

1.4. When using the Site, automatic collection of technical information related to the use of the Site by the User is possible.

1.5. We may collect, store and use the following types of User Information:

• information about visits to and use of this Site, including the source of referrals, duration of visits, page views and navigation routes on the Site;

• information about the computer, including IP address, geographical location, type and version of browser, operating system;

• name and e-mail address that the User, which the enters to subscribe for e-mails and/or newsletters of the Site;

• information that the User enters when using the Services on the Site;

• information contained in the messages that the User sends us by e-mail or through the Site, including its content/files/links and metadata;

• any other Personal data that the User sends us.

1.6. Before disclosing us another person’s Personal data, in accordance with this Policy and applicable law the User must obtain that person’s consent to both the disclosure and processing of that Personal data.

1.7. When a User visits the Site, a connection is established, data on the Site is accessed and a log file is created. It may contain:

– date and time of access to the Site;

– IP-address from which the Site was accessed;

– data or name of the file, which the User accessed on the Site;

– time spent on the Site;

– name and version of the web browser, operating system;

– name of the website, where the User came to the Site from.

This information is used to improve the performance of the Site, for security reasons, to ensure the stability of the Site, as well as to protect the Site from possible external attacks. In addition, we can perform statistical analysis of these data. The data stored in the log file does not allow us to identify the User. The log-file data is used only for the purpose specified herein and is not passed to third parties, except as expressly provided by the terms of the Policy and applicable law.

1.8. We collect only the Personal data knowingly and voluntarily provided by the User as a Subject of Personal data for using the Services of the Site. In accordance with the requirements of current legislation of Ukraine, it constitutes the consent of the Subject of Personal data to processing of their personal data in accordance with the purpose specified herein.

1.9. We guarantee that we will not sell or rent out our Users’ Personal data to third parties, except when the disclosure of the Personal data is necessary to comply with current legislation of Ukraine.

1.10. We do not collect or process information regarding racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, criminal convictions, as well as data relating to health, sexual life, biometric or genetic data (in accordance with Article 7 of the Law of Ukraine “On Personal Data Protection”).


2.1. Personal data is processed and stored in data centers, where the equipment ensuring the Services of the Site is allocated. The Personal data provided are processed and can be stored in the Personal Data base or in a separate table of the Site Database.

Personal data are processed and stored at the address: 35V Borychiv Tik str., Kyiv 04071.


3.1. The Information provided by the User, which may include Personal data, may be used for the following purposes:

• conducting an interview with the User for possible future cooperation/interaction with the CLUST team;

• Site administration;

• personalization of the Site for the User;

• for sending non-marketing communications;

• sending e-mail notifications in case the User has ordered it. The User may at any time refuse to receive such notifications by making appropriate action on the Site and/or by sending a corresponding e-mail;

• to consider and resolve Users’ complaints related to the use of the Site;

• to keep the Site safe and prevent fraud;

• other types of using of the Site.

3.2. We guarantee that we will not provide the User’s Personal data to any third parties for their direct marketing or other purposes without the direct consent of the User, except as provided by current legislation of Ukraine.


4.1. Personal data is stored for no longer than it is necessary in accordance with the purpose of processing.

4.2. After the User has requested the deletion of the User Information from the Site and/or from the Personal Data base, Personal data of such User are deleted permanently.


5.1. When using the Services, the pages of the Site may contain other Internet resources and third parties’ code, which results in such Internet resources and third parties receiving the Users’ data. These resources may receive and process information that the User has visited the relevant pages, as well as other information transmitted by the browser. Such Internet resources can be:

– banner display systems (for example, DoubleClick for Publishers, Admixer, AdRiver, etc.);

– social network plugins (for example, Discus, Facebook, Twitter, Google+,).

5.2. These services are necessary for the prompt analysis of visits to the Site, internal and external assessment of the traffic, depth of views, Users activity. We do not store or process the data received from these services.

5.3. If the User for any reason does not want the services mentioned above to access their Personal data, the User may voluntarily log out of the resource and clear cookies (using their browser).


6.1. We do not transfer personal data to third parties, except when such transfer is required by an applicable law, at the request of the Subject of Personal data or in other cases provided for herein. We understand that Personal data is the value and inalienable content, including personal non-property rights of an individual, so we take all possible measures to protect the User Personal data.

6.2. Personal data may be accessed by our authorized employees who have agreed to ensure the confidentiality of the Personal data of Users, as well as third parties, who provide us with the Site support and administer services, other services related to our business activities. Our authorized employees and/or third parties undertake to comply with all the requirements of the current legislation of Ukraine regarding the protection of Personal data of Users and their confidentiality – and concluded the relevant contracts with us.

6.3. The Site may contain links to other websites (for informational purposes only). This Policy is not applied to the other websites, which the User goes to through the link. Therefore, we recommend you to read the Privacy and Personal data Policies of each website before transmitting any personal information, by which you may be identified.

6.4. The personal information that the User publishes on the Site may be available via the Internet worldwide. We cannot prevent the use and misuse of such information by third parties in other countries.


7.1. We use generally accepted standards of technological and operational protection of information and personal data against loss, misuse, alteration or destruction, but we do not guarantee absolute protection against any threats arising outside the limits of our regulation.

7.2. We ensure that all applicable confidentiality obligations, as well as technical and organizational security measures, are applied to prevent the unauthorized or unlawful disclosure or processing of such information and data, their accidental loss, destruction or damage.

7.3. We have the right to disclose personal data without the consent of the User in cases specified by applicable legislation, and only (if it is necessary) in the interests of national security, economic well-being and human rights.

7.4. If the User has provided/lost an access to their profile/e-mail, the User bears full responsibility for the actions of the new User when using the Site from their profile.


8.1. The procedure for access to personal data by third parties is determined by the terms of the User’s consent provided for the processing of such data, or by the requirements of law.

8.2. The User has the right to receive any information about themselves from any subject of relations related to Personal data, provided that the requesting person will provide their surname, name and patronymic, place of residence (stay) and details of the identification document, except for the cases established by the current legislation.

8.3. Access to Personal data is free of charge. Postponement of access to your Personal data is not allowed. Postponement of access to personal data by third parties is allowed if the data needed cannot be provided within thirty calendar days from the date of the request. In this case, the total term for resolving the issues raised in the request may not exceed forty-five calendar days.

8.4. The third party who submitted the request shall be notified of postponement in writing, explaining the procedure for appealing such a decision.

8.5. Denial of access to personal data is allowed, under the procedure established by the current legislation of Ukraine, if access to such a data is prohibited in accordance with the Law of Ukraine “On Personal Data Protection” and other provisions of current legislation.

8.6. The decision to postpone or deny an access to personal data may be appealed in accordance with the requirements of the applicable law.


The User (Subject of Personal data) has the right to:

– know the sources of collection, location of their personal data, purpose of processing, or give a relevant order to obtain this information to authorized persons, except for the cases provided by the Law of Ukraine “On Personal Data Protection”;

– receive information on the conditions for granting access to personal data, in particular information on third parties, whom their personal data is transferred to;

– access their Personal data;

– no later than thirty calendar days from the date of receipt of the request, except for the cases provided for by the Law of Ukraine “On Personal Data Protection”, to receive an answer as to whether their personal data are processed, as well as receive the content of such personal data;

– file a reasoned objection to the processing of their Personal data;

– file a reasoned request to change or destroy their Personal data, if the Data is processed illegally or is inaccurate;

– to be protected  from illegal processing and accidental loss, destruction, damage of their Personal due to intentional concealment, non-provision or untimely provision, as well as to be protected from provision of information that is inaccurate or discredits the honor, dignity and business reputation of the User;

– apply with complaints about the processing of their Personal data to the Commissioner for Human Rights of the Verkhovna Rada of Ukraine or to the court;

– use legal remedies in case of violation of the current legislation of Ukraine on personal data protection;

– make reservations regarding restrictions of processing of their Personal data when granting the consent;

– withdraw the consent for the processing of their Personal data;

– know the mechanism of automatic processing of their Personal data;

– to be protected against an automated decision that has legal consequences for the User.


10.1. Our Site uses cookie files. A cookie file is a file containing an identifier (a string of letters and numbers) that a web server sends to a web browser and web browser stores. The ID is then sent back to the server each time the browser requests a page from the server. Cookie files may be both “stable” cookies and “session” cookies: a stable cookie will be stored by the web browser and remain valid until the set expiration date, unless the User has deleted it before; a session cookie, on the other hand, expires at the end of the User’s session, when the web browser is closed. Cookies usually do not contain any information that identifies the User personally, but the Personal data we store about the User may be related to the information stored and received from cookies.

10.2. Names of the cookie files we use on our Site and the purposes for which we use them are set out below:

we use Google Analytics on our Site to recognize your computer when you visit us.

Most browsers allow you to opt out of cookie files – for example:

In Internet Explorer, you can block cookie files through cookie management settings by clicking Tools – Internet Options – Privacy, and then clicking the tab Advanced.

In Firefox, you can block all cookie files by clicking Tools – Settings – Privacy, selecting “Use your own settings for history” from the drop-down menu, and unchecking “Accept cookies from sites”.

In Chrome, you can block all cookie files by going to the “Configure and manage” menu, clicking Settings – Show advanced settings – Content settings, and then selecting “Block sites from setting up any data” – “Under the heading” – “Cookies”.

10.3. Blocking all cookie files will adversely affect the usability of the Site. If the User blocks the cookies, they will not be able to use all the functions of the Site.

10.4. The User can delete the cookies that are already stored on their computer. Deleting cookies will affect the usability of many websites adversely.

To delete cookies:

in Internet Explorer you need to delete cookies manually;

in Firefox, you can delete cookies by clicking Tools – Settings – Privacy, then selecting “Use custom settings for history”, clicking “Show cookies” and then “Delete all cookies”;

in Chrome, you can delete all cookies by going to the “Configure and manage” menu, clicking Settings – Show advanced settings – Clear browsing data, selecting “Delete cookies and other plug-ins” before clicking “Clear browsing data”.


11.1. The CLUST team reserves the right to publish certain privacy notices, as well as to amend and/or supplement the content of the Policy at any time in its sole discretion.

11.2. In case of significant changes to the Policy, we will post a notice on the Site and specify the effective date of these changes. If the User does not refuse to accept these changes in writing within the specified period, it will mean that the User agrees thereto.

Subscribe to our newsletter
current vacancies