Privacy policy
By visiting the site romankoff.com, social networks, communicating using the means of communication, you agree to the Privacy Policy and give your consent to the collection, processing, storage and transfer of personal data.
The privacy policy ("Policy") describes the rules and principles of collection and processing of Personal data of Users, Clients, Consultants of "Romankoff Development".
References to the words "we", "our" or "us" or words of similar meaning shall mean "Romankoff Development" and Affiliates of "Romankoff Development", depending on the context of the Policy.
References to the words "you", "your" or "your" or words of similar meaning mean Users, Clients and Consultants of "Romankoff Development".
We are committed to protecting the privacy and security of the Personal Data you provide to us, and we will only collect, use and share the data in the ways described in this Policy.
1. Terms
We enter and mark some terms with a capital letter, their use in the text of the Policy means that they have a special meaning that is defined in the description of such a term. Section 1 of the Privacy Policy defines some of these terms.
1.1. Affiliate is any entity that directly or indirectly controls, is controlled by, or is under joint control with Romankoff Development.
1.2. Questionnaire — a list of questions drawn up in a document or web form for collecting personal data of Users, Clients and Consultants.
1.3. External resources — Romankoff Development company pages on LinkedIn, X, Facebook, Instagram and other social networks.
1.4. Personal data is information that identifies you as a specific person or can be identified to interact with you.
1.5. User is an identified natural person who interacts with the Website or External Resources.
1.6. Visitor is an unidentified natural person who interacts with the Website or External Resources.
1.7. The client is a natural or legal person who receives Services from "Romankoff Development" and provides access to Personal Data on the basis of a contract.
1.8. Third parties are individuals and legal entities that provide or receive services from Clients on the basis of an employment, partnership or service contract.
1.9. Consultants are individuals and legal entities providing services to "Romankoff Development" on the basis of a contract.
1.10. The website is informational pages on the Internet hosted under the domain name romankoff.com. The domain name is registered and owned by "Romankoff Development". The content of the Website is protected by copyright, trademark, intellectual property and unfair competition laws.
1.11. Means of communication - e-mail, mobile communication, IP telephony, corporate and mobile messengers Telegram, WhatsApp, Slack, conference communication tools Google Meet, Zoom, Microsoft Teams, etc.
1.12. Advertising and analytics services - Google ADS, Google Analytics, Facebook ADS, Facebook Analytics, LinkedIn and other internal and external software solutions in the field of Internet marketing.
1.13. Services — activities in the field of web development provided by the company "Romankoff Development" and Consultants.
1.14. EDPB (European Data Protection Board) — European data protection board.
1.15. CCPA (California Consumer Privacy Act) is a statute of the state of California designed to enhance privacy and consumer protection rights for residents of California and the United States.
1.16. Cookies are small text files that store information about your previous actions on the website.
1.17. GDPR is the General Data Protection Regulation (GDPR), which applies to regulate the processing of personal data from May 25, 2018.
2. Methods of collecting personal data
2.1. We collect Personal Data of Users, Clients, Consultants in the following ways:
- 2.1.1. When filling out forms on the Website.
- 2.1.2. When communicating by means of communication.
- 2.1.3. When interacting with external resources.
- 2.1.4. When completing Questionnaires and accessing data.
- 2.1.5. When filling in details in the contract.
- 2.1.6. In the process of using advertising and analytics services.
- 2.1.7. When participating in offline and online events by scanning QR codes and online business cards.
- 2.1.8. In the process of collecting and processing data from public resources: forums, aggregators, classifieds, catalogs.
3. Personal data that we collect
3.1. Personal data collected voluntarily at the initiative of Users. "Romankoff Development" collects Personal data of Users, Clients, Consultants for contacting by means of communication and/or providing Services, including:
- 3.1.1. first name (login, nickname), last name, address,
- 3.1.2. phone number/email address;
- 3.1.3. nickname in the Telegram/Whatsapp messenger and/or nickname in the Facebook/LinkedIn social network;
- 3.1.4. type of activity, professional experience and areas of activity;
- 3.1.5. information about nationality, language.
3.2. Personal data is collected automatically. The User consents to the automatic collection of data from a computer or mobile device when interacting with the Website, for example: User-Agent, IP address, time zone, device data and browser type, URL of the page from which you visited the Website, and the third-party web resources you go through to leave the Website.
3.3. Non-identifying personal data of visitors. We may collect zip code, demographic and statistical information about Users and Visitors for analytics and marketing research. We transform Personal Data into a form of non-identifying information in software code, which is not considered Personal Data under the GDPR because it does not reveal your identity.
3.4. Combination of Personal Data and Non-Identifying Information: When Personal Data and Non-Identifying Information are combined, it may be converted into information that can identify you. For example, in cases where the User's name is known and the profile in social networks is available. We will treat the combined information as Personal Data subject to processing in accordance with this Policy.
3.5. Information obtained from external web resources and public sources. Romankoff Development may supplement the collected personal data with records from external web resources and public sources, including social networks, freelance exchanges or databases. We combine information we receive from third-party sources with information we collect from you. We will use such information as Personal Data in accordance with the Policy.
4. Purposes of collection and processing of personal data
4.1. We collect Personal Data of Users, Clients, Consultants to provide Services, fulfill obligations, comply with laws and requirements of state authorities. We collect Personal Data to investigate, resolve and prevent disputes and disputes. Purposes of collection, processing and transfer of Personal data of Users, Clients, Consultants:
- 4.1.1. To provide Services and fulfill obligations to Customers. We collect and store the Personal Data that Users have provided through the Website and External Resources for communication via the means of communication. We receive Personal Data during the development of business and commercial relations with Clients for project management and performance of tasks.
- 4.1.2. To measure the interest, search channels and interaction of Users with the Website. We analyze Personal Data that we collect through the User's interaction with the Website for: definition and segmentation of the target audience and client environment, improvement of functionality and correction of errors on the Website, development and adaptation of commercial and informational content, updating of offers, prices and Services.
- 4.1.3. To create advertising messages. We collect and process Personal Data to send one-time advertising messages to Users and initiate communication for the purpose of providing Services. We collect and process analytical and statistical data about Users to create contextual, targeted, online media advertising.
- 4.1.4. To create a security system in "Romankoff Development". We process and check Personal Data of Users, Clients, Consultants for authentication and verification of identity, authenticity of provided information and protection of interests of "Romankoff Development" from fraud, abuse and damage to business reputation.
- 4.1.5. To comply with laws and internal regulations governing the provision of Services. We process Personal Data of Users, Clients, and Consultants for business administration, creation and maintenance of Client accounts in CRM, project management and performance of tasks. Adherence to internal instructions and policies, fulfillment of legal obligations under contracts, provision of legal rights and protection of interests.
5. Access to personal data
5.1. Access to personal data. We strive to protect and preserve the confidentiality of the Personal Data provided, for this we have implemented appropriate rules and technical measures to protect the data under our control from unauthorized access, improper use or disclosure, modification, destruction and loss in accordance with the GDPR regulation.
5.2. By providing access to Personal Data, you consent to the processing, transfer and storage of Personal Data of Romankoff Development, affiliates and Consultants. We undertake to take all necessary measures to ensure that Personal Data is processed in compliance with security rules and in accordance with the provisions of the Policy.
5.3. Conditions of access In order to provide the Services, "Romankoff Development" may provide access to the Personal Data of the User and the Client of the Consultants. Consultants engaged by "Romankoff Development" undertake, according to the contract, to observe precautionary measures, to respect the integrity and confidentiality of data of Users and Clients. At "Romankoff Development" there is a unified system of control over the processing of Personal Data in the CRM system with the classification of access levels.
6. Transfer of personal data
6.1. If necessary, we may transfer Personal Data to Consultants engaged by Romankoff Development to provide Services. "Romankoff Development" consultants can access Personal Data of Users and Clients to the extent necessary to fulfill obligations under contracts and assigned tasks. "Romankoff Development" or consultants may transfer personal data to the Client's corporate systems.
6.2. When we transfer Personal Data to Consultants, we will follow safeguards in accordance with the GDPR regulation and the Policy. When transferring data to Consultants, we are guided by the regulation mechanisms of the GDPR, as well as conclude a Data protection agreement (hereinafter DPA) and Standard contractual clauses for international transfers (hereinafter SCC), approved by the EDPB in the EU. Clients may request access to the DPO and SCC for audit and reconciliation purposes.
6.3. Consultants may collect Personal Data and gain access to confidential information of Users, Clients, Consultants through communications, on the Website or in CRM system databases. Romankoff Development collects and transmits activity tracking on your device, including cookies and web beacons, to consultants. Consultants may access and process sensitive information about Users and Clients.
6.4. Consultants who may receive Personal Data:
- 6.4.1. Employees of the company;
- 6.4.2. Contractors and partners;
- 6.4.3. Digital agencies and service IT companies;
- 6.4.4. Content marketing and media buying agencies and contractors;
- 6.4.5. State and/or law enforcement agencies based on an official request and/or court decision;
- 6.4.6. Insurance, postal and courier companies;
- 6.4.7. Banks and payment systems.
7. Storage of personal data
7.1. "Romankoff Development" implements measures to store personal data in accordance with GDPR and CCPA requirements. Because no method of storing information on the Internet is completely secure, Romankoff Development does not fully guarantee the security of any information you transmit to us.
7.2. We implement measures for the security of Personal Data storage, in accordance with Article 32 GDPR, such as: ensuring confidentiality, integrity, anonymization and encryption, availability and stability of processing services, timely restoration of access to data and testing the effectiveness of protective measures.
7.3. "Romankoff Development" stores Personal Data of Clients and Consultants during the term of the contract or as long as it is necessary to fulfill obligations and provide Services, resolve disputes, prevent improper use of data or until the User's request to delete them. "Romankoff Development" may store personal data for 3 years from the date of the last interaction with the Website, in accordance with the obligations provided by the laws of the United States and the European Union.
7.4. Personal data that we process and store are and remain the property of Users, Clients and Consultants.
7.5. In the event of a change in Personal Data that is necessary for the provision of Services, Users and Clients shall notify us of such changes.
8. Security of data storage and DPO
8.1. To control the storage and security of data of Users and Clients, "Romankoff Development" engages a Data Protection Officer (hereinafter DPO), who is responsible for compliance with the law on personal data protection, in accordance with Articles 37, 38 , 39 GDPR.
8.2. According to the GDPR regulation, "Romankoff Development" engages a DPO to perform the following tasks:
- 8.2.1. Informing Users and Clients during data collection and processing;
- 8.2.2. Control over compliance with the norms and requirements of the regulation on data collection and processing;
- 8.2.3. Representation in regulatory compliance bodies;
- 8.2.4. Consulting in any situation, collection, transfer and security of data;
- 8.2.5. Consideration of appeals and complaints of Users and Clients for the protection of rights.
8.3. We create measures for safe storage of collected personal data on servers and hosting, and also ensure data encryption and anonymization. Access to the Website, CRM system is encrypted using standard transport layer security technology (TLS). We also use strict HTTPS transport security.
- 8.3.1. Access control and management system. Several levels of protection are used to access sensitive data.
- 8.3.2. Transfer control. The movement of data through the internal networks of "Romankoff Development" is protected.
- 8.3.3. Data entry control. "Romankoff Development" checks the changes made or the deletion of data from the processing systems.
- 8.3.4. Availability control. Personal data is protected against accidental destruction or loss.
- 8.3.5. Data integrity control. Romankoff Development uses firewalls, anti-virus software, and conducts external and internal penetration testing.
9. Use of Cookies. Consent to use
9.1. "Romankoff Development" uses cookies to improve and simplify user interaction with the website. Cookies are necessary to save the settings you have chosen on the Website, as well as to remember your preferences. We use cookies in accordance with the requirements of the GDPR and in accordance with the guidelines and regulations presented by the EDPB. When using cookies, we rely on the legal grounds provided for in Article 6 of the GDPR:
- 9.1.1. consent of the User;
- 9.1.2. legitimate interests of Romankoff Development.
9.2. We inform the User before placing cookies on your device by means of a pop-up message on the main page, when the User first visits the Website. By continuing to use the "Romankoff Development" website, you confirm your consent to the use of cookies.
9.3. For the operation of the Website, we use basic and additional cookies, the basic files do not require your consent to their use, as they are necessary to ensure the operation of the Website, additional cookies are collected and used in if the User agrees to it.
9.4. If you do not wish to consent or withdraw your consent to the use of cookies, you must block, delete or disable cookies. Disabling, deleting, or blocking files affects the functionality of the website, and you may be limited in using some of the website's features.
9.5. To disable, delete or block cookies, you must change the cookie settings on your browser, such settings are usually found in the "Options" or "Settings" menu of your internet browser, follow the instructions, given in the following links:
- 9.5.1. Google Chrome;
- 9.5.2. Safari;
- 9.5.3. Mozilla Firefox;
- 9.5.4. Opera;
- 9.5.5. Edge.
10. Types of cookies, purpose and storage period
10.1. Basic: Cookies and other tracking technologies are necessary to use the website and comply with applicable data protection legislation. "Romankoff Development" uses cookies to provide Services, identify Users, determine the service to which you connect, check the functionality of the Website on your device, for example: whether the User's browser supports cookies, whether the User subsequently agreed to the use of cookies.</ p>
- 10.1.1. Persistent: remain on the User's device for the period of time specified in the cookie, being activated each time the User visits the Website that created that particular Cookie.
- 10.1.2. Third-party cookies are cookies that are set by a domain other than the user visiting the website. If a user visits a website and another domain sets a cookie through that website, it will be a third-party cookie.
- 10.1.3. Sessional: allow Website operators to associate the User's actions during a browser session, with the browser session beginning when the User opens a browser window and ending when the User closes the window browser. Session files are created temporarily, as soon as you close the browser, all session cookies will be deleted.
10.2. Additional:
- 10.2.1. Analytical: help us understand how Users interact with the Website, for example: which pages are visited, page loading speed. Such files collect information anonymously to avoid your identification and are used only to help us improve the Website, to understand what interests you most on the Website.
- 10.2.2. Marketing: used to display relevant advertising. With their help, we give Users the opportunity to share our content on social networks and messengers, such as Facebook, X, LinkedIn, WhatsApp, Telegram, Viber, etc.
- 10.2.3. Functional: allow you to remember the User preferences and choices you make on the Website, and allow you to provide enhanced functionality and personalization of the Website, including comments, widgets and online chat. Such files may be installed by third-party providers whose services we may add to Company Web site pages.
11. User Rights
11.1. Right of access. The Privacy Policy lists the Personal data of Users, Clients and Consultants collected and processed by "Romankoff Development". The User, Client and Consultant can obtain confirmation about the use and processing of Personal Data, as well as contact the DPO in order to request access to the Personal Data that we store, in accordance with Art. 15 of the General Data Protection Regulation.
11.2. Right to rectification. If the Personal Data stored and processed by "Romankoff Development" are inaccurate or incomplete, the User, Client and Consultant have the right to update, correct, supplement their Personal Data, provided that they do so personally, and the individual as the subject of this data can be confirmed. The User may also contact the DPO to access their Personal Data, to update, correct and/or change them in accordance with Art. 16 of the General Data Protection Regulation. If you request Romankoff Development to correct Personal Data that has already been provided to Consultants and Advertising and Analytics Services, we will notify them of the correction where such notification is possible.
11.3. The right to export. The User, Client and Consultant may request the transfer of Personal Data to third-party organizations in accordance with Art. 20 of the General Data Protection Regulation. You have the right to receive Personal Data in a structured, commonly used and machine-readable format and use it elsewhere or ask us to transfer it to a third party of your choice, provided that you do so personally and that your identity as a data subject can be confirmed The export of personal information, which we have already shared with Consultants and Advertising and Analytics Services, is carried out by these persons using a separate request.
11.4. Right to deletion. The user has the right to delete his personal data in accordance with Art. 17 of the General Data Protection Regulation. Personal data, in this case, will be deleted forever. In the case of a request for deletion, Romankoff Development will inform you of the measures taken and within 30 working days from the date of such request. If a User or Client requests deletion of Personal Data that we have already shared with Consultants and Advertising and Analytics Services, we will notify them of the deletion where such notification is possible.
11.5. The right to restrict processing. You can ask us to stop or stop processing your personal data. In the event of a request for processing restrictions, we will inform Users and Clients about the measures taken within 30 working days from the date of such request. If you request to restrict the processing of Personal Data after Romankoff Development has shared it with third parties, we will, where possible, notify them of such restriction.
11.6. The right to object. The User, Client and Consultant have the right at any time to object to the processing of Personal Data, in accordance with Art. 21 of the General Data Protection Regulation.
11.7. The right to withdraw consent to data processing. The User has the right at any time to withdraw his consent to the processing of Personal Data, which was provided by "Romankoff Development". We rely on your consent as a legal basis for processing data, in the event that the User withdraws consent to processing, some functions of our Website may not be available.
11.8. The right not to be subject to automated decision-making in individual cases, in particular profiling. The user has the right not to submit to a decision that is based solely on automated processing, including profiling, which causes its legal consequences, in accordance with Art. 22 of the General Data Protection Regulation.
11.9. The right to file a complaint with the supervisory body. If you have doubts about any aspect of Romankoff Development's privacy policy, including the way your personal data is processed, you can notify the relevant supervisory authority or contact the Romankoff Development DPO.
11.10. "Romankoff Development" may deny Users, Clients and Consultants the right to access, correction, transfer, deletion, objection, if "Romankoff Development" acts as a processor of Personal Data and is limited in powers of the data controller. In case of denial of the right to access, correction, transfer, forgetting, denial of Personal Data, we are obliged to inform you of the reasons within 30 (thirty) working days from the date of such denial.
11.11. If the identity of the User, Client and Consultant is not confirmed or cannot be confirmed, we may request additional information or refuse to provide the opportunity to change/delete/transfer/export/revoke/deny your Personal Data data.
11.12. Romankoff Development will use commercially reasonable efforts to comply with user deletion requests, but certain information will be retained on the website. In addition, the rights described above may be limited, for example, if complying with your request results in the disclosure of another person's personal data, or if you ask us to delete information that we are required to retain by law, or if we have a legitimate interest in storage, for example, to prevent fraud.
11.13. Personal data may remain in archives, and information you update or delete may be retained for our administrative purposes to the extent permitted by law. We will not delete information that you have posted publicly using or in the Software. Romankoff Development may not delete all copies of information previously shared with others.
12. Additional Privacy Notice for California Residents
12.1. This additional privacy notice for California residents applies only to California residents. This applies to personal data that we collect on the Website or through the Advertising and Analytics Services, Communications.
12.2. The CCPA requires us to disclose the categories of Personal Data we collect about consumers in California, the categories of sources from which the information was collected, and the business or commercial purposes for which it was collected information, as well as categories of parties to whom we share Personal Data of California residents.
13. Links to Other Sites
13.1. The Website may contain links to External Resources, including integrated APIs. If you click on a link to an External Resource, you will be redirected to a website that may collect and process Personal Data.
13.2. The fact that Romankoff Development links to External Resources is not an endorsement of our affiliation with it, nor is it an endorsement that their privacy policy and/or policy information security complies with our Policy.
13.3. We do not control the external resources that may be placed on the website. External resources may place their own cookies or other files on your device, collect data, or request personal information. We recommend that you familiarize yourself with the privacy policy of the External Resources you visit by following the links posted on the "Romankoff Development" Website.
13.4. Spam protection policy. All commercial emails are sent to Romankoff Development in full compliance with the US CAN-SPAM Act of 2003. We have developed Internet marketing tools and methods to include a "permission-based" policy that prohibits the use of Users' email for the purpose of mass emailing.
13.5. If you believe that Romankoff Development has sent you an unsolicited email, please let us know about your situation via our Contact Us webpage. Your application will be considered within 30 working days.
14. Changes to this Policy
14.1. We have the right to periodically amend, update and supplement the Policy to ensure the preservation of Personal Data, notification of changes in the use of Personal Data and compliance with GDPR/CCPA legislation.
14.2. In the event of significant changes regarding Personal Data, we notify Users, Clients and Consultants of such changes by posting news on the Website and/or by means of an informational e-mail newsletter. We recommend that you periodically review the Policy to receive information about how we use your personal data.
14.3. In the event that you have unsubscribed from emails in which we notify you of changes in legal documentation, Users, Clients and Consultants are still responsible for reading them.< /p>
14.4. After making changes to the Policy, we have the right to ask Users, Clients and Consultants to agree again with the updated Policy. Changes to the current policy take effect 30 days after the date of publication of the new version of the Policy.
14.5. Our electronic or otherwise stored copies of the Privacy Policy shall be deemed to be the true, complete, valid and enforceable version of this Policy in effect at the time you interact with the Website.
14.6. By continuing to interact with the Website, you confirm your agreement to the changes made to the Romankoff Development Privacy Policy.
15. Disclaimer
15.1. The content of the Website is formed and updated by "Romankoff Development" and Consultants. Any liability for damages directly or indirectly arising from the use of the Website is excluded to the extent permitted by US and EU law.
15.2. "Romankoff Development" is not responsible for the violation of your rights or the rights of third parties, if such violation occurred as a result of sending any information through contact forms or requests by e-mail or using means of communication. This limitation of liability does not apply to situations dangerous to life and/or health, which arose as a result of intentional or negligent violations of "Romankoff Development".
16. Cases and recommendations
16.1. "Romankoff Development" collects Personal data of Clients and Consultants for the publication of cases, recommendations and information about specialists in the team. Personal data of Clients and Consultants may be available for public viewing on the Website, in the "Portfolio" and "About Me" sections.
16.2. We collect feedback and recommendations of Users and Clients on the Website about the Services, for advertising and marketing promotion of "Romankoff Development". Such information is used to respond to your requests, improve the quality of Romankoff Development services, develop new products to attract new Customers.
16.3. If you wish to update or delete your review, you can contact us at:
17. Feedback
17.1. For any questions regarding the collection and processing of your data by Romankoff Development, you can contact the DPO of Romankoff Development at the email address: info@romankoff. com.
17.2. You also have the right to receive additional information about your rights regarding your personal data by sending an email to: