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PRIVACY AND COOKIE POLICY

(Privacy and Cookie Policy)

Effective Date: 30.04.2026

  1. General Provisions

This Privacy and Cookie Policy defines the procedures for the collection, processing, use, storage, transfer, and protection of personal data of users of the atey.army website (hereinafter referred to as the “Website”), and also regulates the use of cookies and similar technologies.

By using the Website, browsing its pages, submitting information through forms, or otherwise interacting with its functionality, the user confirms that they have read this Policy, understand its contents, and agree to its terms. If the user does not agree with the terms of this Policy, they must stop using the Website.

This Policy has been developed in accordance with the legislation of Ukraine, including the Law of Ukraine “On Personal Data Protection,” and, where applicable, taking into account the principles and requirements of GDPR, including the principles of lawfulness, transparency, data minimization, purpose limitation, storage limitation, and ensuring confidentiality and integrity of data.

Considering that the Website may be connected to the activities of a military unit, information processing may include additional security measures, including restricted access to certain categories of data, logging of user actions, request verification, and other measures aimed at preventing the leakage of information that may pose a threat to national security or the safety of personnel.

2 Personal Data Controller

The controller (owner) of personal data processed through the Website is:

ATEY Special Operations Battalion, 28th Chornobyl Regiment, National Guard of Ukraine.

The controller determines the purposes and means of processing personal data, ensures its protection, and organizes processing activities in accordance with applicable law. In cases where third parties are engaged for technical maintenance of the Website, such parties act exclusively as data processors and only on the instructions of the controller.

3 Categories of Personal Data

Various categories of information may be processed depending on the nature of the user’s interaction with the Website.

Personal data voluntarily provided by the user may include first name, last name, email address, phone number, message contents, and any other information submitted through forms or communication channels.

Technical data may include IP address, approximate geolocation data, browser type, operating system, device type, interface language, access timestamps, session identifiers, access logs, and other technical characteristics.

Usage data may include information about user behavior on the Website, including viewed pages, sequence of actions, session duration, referral sources, interaction with content, clicks, scrolling activity, and other analytical indicators.

Such data is collected only to the extent necessary to achieve the defined purposes of processing.

4 Purpose of Personal Data Processing

Personal data is processed for the purpose of ensuring the stable and secure operation of the Website, providing feedback, processing user inquiries, improving Website functionality and content, and conducting analytics regarding Website usage.

A separate purpose of processing is ensuring cybersecurity, detecting and preventing unauthorized activities, automated attacks, and other threats to information infrastructure.

Due to the military nature of operations, data processing may also be carried out to prevent the leakage of information that could pose a threat to the security of the unit, the state, or allied partners.

5 Legal Basis for Processing

Personal data is processed on the basis of user consent provided through use of the Website or submission of forms, as well as on the basis of the legitimate interests of the controller, including ensuring the security, functionality, and protection of the Website.

In cases provided by law, processing may also be carried out to comply with legal obligations or upon lawful request of authorized government authorities.

6 Use of Cookies and Tracking Technologies

The Website uses cookies and similar technologies to ensure proper functionality, maintain sessions, save user preferences, conduct analytics, and improve security.

Cookies are small text files stored on the user’s device during visits to the Website and allow identification of the user’s browser, storage of preferences, and proper interaction with the resource.

The Website may use technically necessary cookies required for Website functionality, analytical cookies used to evaluate user behavior and content effectiveness, functional cookies enabling personalization of user experience, as well as third-party cookies that may be placed by external services integrated into the Website.

Cookies may be session-based, automatically deleted after the user session ends, or persistent, stored for a defined period of time.

Where required by law, non-essential cookies are used only after obtaining user consent through an appropriate interface, including a cookie banner or other consent management mechanisms.

The user has the right to manage cookie usage through browser settings, including the ability to block or delete cookies; however, doing so may limit Website functionality.

7 Transfer of Personal Data to Third Parties

Personal data is not sold or transferred to third parties for commercial purposes.

Data may be transferred only in cases necessary for ensuring the operation of the Website, including granting access to hosting providers, technical contractors, analytics services, or other service providers acting on behalf of the controller and obligated to maintain confidentiality.

Personal data may also be transferred in cases предусмотрені by law upon lawful request of governmental authorities.

8 International Data Transfers

When using external services or infrastructure located outside Ukraine, personal data may be transferred to other jurisdictions.

The controller takes necessary measures to ensure an adequate level of protection of personal data, including the use of standard contractual clauses or other mechanisms provided under international law.

9 Protection of Personal Data

The controller applies appropriate technical and organizational measures to protect personal data from unauthorized access, loss, alteration, or destruction, including encryption, access control, action logging, internal security policies, and regular monitoring.

Considering the military nature of operations, enhanced security measures may be applied, including restricted access to information, verification of requests, and increased control over data processing.

10 Data Retention Period

Personal data is stored for the period necessary to achieve the purposes of processing or to comply with legal requirements.

After the retention period expires, data is deleted or anonymized.

11 User Rights

The user has the right to access their personal data, request correction, deletion, restriction of processing, and withdraw consent to data processing.

The exercise of these rights may be limited in accordance with the legislation of Ukraine, particularly in matters related to national security and defense.

12 Military Activity Related Provisions

Due to the activities of a military unit, data processing may be subject to special restrictions related to the protection of state secrets, official information, and personnel security.

The controller reserves the right to restrict access to information or refuse user requests if necessary to ensure security or fulfill combat-related tasks.

13 External Resources

The Website may contain links to third-party resources. The controller is not responsible for the content of such resources or their privacy policies.

14 Changes to the Policy

The controller reserves the right to make changes to this Policy at any time without prior notice. The current version of the Policy is always available on the Website.

15 Contact Information

For all questions related to personal data processing and the use of cookies, users may contact:

admin@atey.army

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