Website: https://custom.mavistep.com/ (hereinafter referred to as the "Site")

Last Updated: May 28, 2025

1. General Provisions

1.1. This Privacy Policy (hereinafter referred to as the "Policy") describes how the Administration of the site custom.mavistep.com (hereinafter referred to as "We", "Us", "Our") collects, uses, discloses, and protects the information you provide when using our Site. Our Site operates on the Horoshop e-commerce platform (LLC "Horoshop").

1.2. We are committed to protecting your privacy and respecting your rights regarding your personal data. This Policy has been developed in accordance with the Law of Ukraine "On Personal Data Protection" and, where applicable, the General Data Protection Regulation (GDPR) and other relevant data protection laws.

1.3. By using our Site, you agree to the terms of this Policy and consent to the processing of your personal data in accordance with the terms described herein. If you do not agree with the terms of this Policy, please do not use the Site.

1.4. For data processed directly by the Horoshop platform as the Owner and Processor for the functioning of online stores on its basis, the Privacy Policy of LLC "Horoshop" applies, available at: https://horoshop.ua/privacy-policy/. This Policy supplements the platform's policy regarding the data processing that we control as the Site Administration.

2. What Personal Data We Collect

We, as the Administration of the site custom.mavistep.com, may collect and process the following categories of personal data through the functionality provided by the Horoshop platform, as well as through services additionally integrated by us:

2.1. Information You Provide Directly to Us:

  • Contact and Order Data: Name, surname, email address, phone number, delivery address (if you provide them when placing an order, registering, using contact forms, subscribing to newsletters).
  • Payment Information: Data necessary for processing payments (we do not store full payment card details; they are processed by the respective payment services).
  • Any other information you voluntarily provide to us.

2.2. Information Collected Automatically (Technical Information and Usage Data):

  • Device and Connection Data: IP address, browser type and version, device type, operating system, time zone, unique device identifiers. This data may be collected by both the Horoshop platform and analytical systems connected by us.
  • Site Usage Data: Information about how you use our Site, including the pages you visited, products viewed, time spent on pages, links you clicked, date and time of visits, and page interaction data.
  • Cookies and Similar Tracking Technologies: We and the Horoshop platform use cookies and other tracking technologies. More details on this can be found in the "Use of Cookies and Tracking Technologies" section.

2.3. Information from Third Parties:

  • We may receive information about you from third parties if you have given them consent to share such information with us, or if such third parties have a legal basis to transfer your data to us (e.g., analytics services, advertising partners we connect).

3. Purposes of Collecting and Processing Personal Data

We collect and process your personal data for the following purposes:

3.1. Ensuring Site Operation and Order Fulfillment: To administer and operate the Site, process your orders, deliver goods, and ensure security and availability.

3.2. Communication with You: To respond to your inquiries, provide support, send service messages regarding orders, and inform you of changes.

3.3. Improving the Site and Services: To analyze Site usage, identify trends, improve user experience, and develop new features and services.

3.4. Marketing and Advertising (with Your Consent):

  • To send you marketing materials, news, and special offers (only with your prior consent).
  • To display personalized advertising on our Site and on third-party sites (e.g., through services like Microsoft Advertising, Google Ads, which we may connect). This includes collecting data to measure ad effectiveness and for retargeting.

3.5. Compliance with Legal Obligations: To comply with applicable laws, court orders, or government requests.

3.6. Fraud Prevention and Security.

4. Legal Basis for Processing Personal Data

We process your personal data on the following legal bases:

4.1. Consent: If you have given us explicit consent to process your personal data for one or more specific purposes.

4.2. Performance of a Contract: If processing is necessary for the performance of a contract to which you are a party (e.g., a contract for the sale of goods).

4.3. Legitimate Interests: If processing is necessary for the purposes of our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms.

4.4. Legal Obligation: If processing is necessary for compliance with a legal obligation to which we are subject.

5. Use of Cookies and Tracking Technologies

5.1. Our Site uses cookies and similar technologies. Cookies are small text files stored on your device.

5.2. Horoshop Platform Cookies: The Horoshop platform uses certain cookies necessary for the functioning of online stores on its basis (e.g., PHPSESSID for session identification). A detailed list and description of cookies that may be used by the Horoshop platform and its integrated services (e.g., Intercom) are provided in the Privacy Policy of LLC "Horoshop" (https://horoshop.ua/privacy-policy/), particularly in the "Cookies" section.

5.3. Cookies Used by Us (Administration of custom.mavistep.com): In addition to platform cookies, we may use our own or third-party cookies through services integrated by us (e.g., via Google Tag Manager) for the following purposes:

  • Analytical/Performance Cookies: To collect anonymous statistics on Site usage (e.g., Google Analytics).
  • Advertising/Targeting Cookies: To display relevant advertising and measure its effectiveness (e.g., Microsoft Universal Event Tracking (UET), Google Ads, Facebook Pixel).

5.4. Managing Cookies and Consent Mode:

  • Upon your first visit to the Site, we request your consent for the use of non-essential cookies via a consent banner (e.g., provided by the Clickio platform). You can configure your cookie preferences through this banner.
  • Most web browsers allow you to control cookies through their settings.
  • We aim to use Google Consent Mode (via our CMP, e.g., Clickio) to communicate your consent preferences for cookies and data processing to services like Google Analytics, Google Ads, and Microsoft Advertising, enabling these services to adapt their behavior according to your choices.

6. Disclosure of Personal Data to Third Parties

We may disclose your personal data to third parties only in the following cases:

6.1. To the Horoshop Platform (LLC "Horoshop"). As our Site operates on the Horoshop platform, LLC "Horoshop" acts as a data processor, processing data on our behalf to ensure the functioning of the online store, fulfill orders, etc., in accordance with their Privacy Policy.

6.2. To Service Providers Integrated by Us: We may engage third-party companies to provide certain services on our behalf, such as:

  • Payment systems for processing payments.
  • Delivery services for order fulfillment.
  • Analytics service providers (e.g., Google Analytics).
  • Advertising partners (e.g., Microsoft Advertising, Google Ads).
  • Consent Management Platforms (CMPs) (e.g., Clickio).

These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

6.3. As Required by Law. To comply with legal obligations, court orders, or lawful government requests.

6.4. To Protect Our Rights. To protect and defend our rights, property, or safety, or that of our users or others.

7. Data Retention

7.1. Your personal data is stored on servers used by the Horoshop platform. According to their policy, the place of storage and processing of personal data may be located at: OVH, Roubaix, France, 2 Rue Kellermann, 59100.

7.2. We and the Horoshop platform retain your personal data for no longer than is necessary for the purposes for which it was collected and in accordance with legal requirements.

8. Data Security

8.1. We, in conjunction with the Horoshop platform, take appropriate technical and organizational security measures to protect your personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data.

8.2. However, no method of transmission over the Internet or method of electronic storage is 100% secure.

9. International Data Transfers

9.1. As stated above, data may be processed and stored on servers in France (via the Horoshop platform). Also, if we use third-party services (e.g., Google, Microsoft) whose servers may be located in other countries (e.g., USA, EU countries), your data may be transferred to these countries.

9.2. We will take steps to ensure that any such international transfer of information is managed to ensure your rights are protected and that your data is treated securely and in accordance with this Policy. This may include using Standard Contractual Clauses approved by the European Commission (or the UK equivalent) or relying on adequacy decisions.

10. Your Rights Regarding Personal Data

Depending on your location and applicable law (such as GDPR for EU/UK residents, or specific US state laws), you may have the following rights regarding your personal data:

  • The right to be informed: about how your personal data is being used.
  • The right of access: to your personal data.
  • The right to rectification: if your personal data is inaccurate or incomplete.
  • The right to erasure (right to be forgotten): to have your personal data deleted or removed where there is no compelling reason for its continued processing.
  • The right to restrict processing: to block or suppress processing of your personal data.
  • The right to data portability: to obtain and reuse your personal data for your own purposes across different services.
  • The right to object: to the processing of your personal data in certain circumstances (e.g., for direct marketing).
  • Rights related to automated decision-making and profiling.
  • The right to withdraw consent: at any time, where processing is based on consent.
  • The right to lodge a complaint: with a supervisory authority (e.g., the Information Commissioner's Office (ICO) in the UK, or a Data Protection Authority in an EU country).

To exercise your rights, you can contact us using the contact details provided in Section 14 of this Policy. To exercise rights regarding data processed by LLC "Horoshop" as the data controller, you should contact LLC "Horoshop" directly.

11. Children's Privacy

Our Site is not intended for use by individuals under the age of 16 ("Children"). We do not knowingly collect personal data from Children. If you are a parent or guardian and you are aware that your Child has provided us with personal data, please contact us.

12. Links to Other Websites

Our Site may contain links to other websites. We are not responsible for the privacy practices of these other sites.

13. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

14. Contact Information

If you have any questions about this Privacy Policy or the processing of your personal data by the Administration of the site custom.mavistep.com, please contact us:
Email: custom@mavistep.com