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Privacy Notice

e-Residency Ukraine

Last update date: 19/12/23

At e-Residency Ukraine, we care about the privacy of your data and are committed to protecting it. This Privacy Notice (“Notice”) is here to help you understand how your personal data is processed when: 

  • you use our website located at e-resident.diia.gov.ua (“Website”) or the "E-Resident" mobile application (App), which are components of the "E-Resident" information system;
  • apply for e-resident status by completing the appropriate in the "E-Resident" information system;
  • register as an individual entrepreneur;
  • apply to open a bank account in a Ukrainian bank and to close such an account; 
  • contact us via our support email.

1. Who is responsible for processing your data in the "E-Resident" information system?

The data controller in the "E-Resident" information system is the Ministry of Digital Transformation of Ukraine (ID number 43220851), registered at 24, Dilova Street, Kyiv, 03150. In this document, we will call ourselves “Mindigital”, "we" or "ours".

The data processor in the "E-Resident" information system is the state enterprise Diia (ID number 43395033), registered at: 24, Dilova Street, Kyiv, 03150.

If you have any questions about your personal data, you can contact us at  privacy.e-resident@e-resident.diia.gov.ua.

2. How do we collect and use the data in the "E-Resident" information system?

You can view our Website without providing us with your personal data. However, we will automatically receive certain technical data when you enter our Website or App for the "E-Resident" information system.

2.1. Automatically collected data.

We automatically collect certain data to operate, maintain, and improve our Website or App. Such data includes: 

  • Browser and device information: we receive information about the device that you are using (type, model, online identifiers such as IP address, MAC address, etc.) also receive information about your browser (type, version, language, etc.)
  • Usage information: we collect the information relating to the usage of the Website or App, including your actions;
  • Cookies and similar technologies. We use cookies for analytical purposes and to provide you with the features of our Website and App. You may disable cookies in your browser settings at any time. Find out more about our use of cookies in Section 4 of this Notice. 

2.2. Data you give us.

If you have applied for e-residency, we process the personal data you have provided in the Application form on our Website or App. Such data includes:

  • biographical data: given name, surname, patronymic (if available), date of birth, country of birth, settlement of birth, registration number of the taxpayer's registration card (RNTRC) - after receiving information from the State Tax Service;
  • graphic data: a scanned copy of your travel document;
  • demographic data: gender;
  • travel document details: document number, issuing authority, date of issue, date of expiry, issuing country;
  • contact data: country of citizenship, country of residence, settlement, postal code, street name, house number, email address, mobile phone number; 
  • additional data:  information on existing business,  tax number in the country of citizenship, criminal background.

 

We transfer your personal data to the Ministry of Internal Affairs and the Security Service of Ukraine in order to verify information regarding your criminal liability, the absence or presence of a criminal record, or restrictions on the acquisition of e-resident status.

The following personal data are transferred to the Ministry of Internal Affairs for the specified purpose:

  • biographical data: given name, surname, patronymic (if available), date of birth, country of birth, settlement of birth;
  • demographic data: gender;
  • contact data: country of  citizenship, country of residence, settlement, street name, house number.

The following personal data are transferred to the Security Service of Ukraine for the specified purpose:

  • biographical data: given name, surname, patronymic (if available), date of birth, country of birth, settlement of birth;
  • graphic data: a scanned copy of your travel document;
  • demographic data: gender;
  • travel document details: document number, issuing authority, date of issue, date of expiry, issuing country;
  • contact data: country of  citizenship, country of residence, settlement, street name, house number, email address, mobile phone number. 

2.3. Calling for support. 

We collect and process your personal data when you contact us with a support request via our email address. Such data includes:

  • name;
  • contact data: email address, social media account information;
  • data you provide us during communication;
  • automatically collected data in accordance with clause 2.1 of this notice.

2.4. Information you provide us for registration as an individual entrepreneur.

We collect and process your personal data, provided for in clause 3.3 of this notice when you contact us with a request for registration as an individual entrepreneur.

2.5. Information you provide us to open a bank account. 

We collect and process your personal data under clause 3.4 of this Notice when you contact us with a request to open a bank account.

3. Why do we use your data? 

In this section, we describe the purposes for which your data is used. 

3.1. To provide you with access to our Website and App or feedback. 

We process your personal data to provide you with access to our Website or App so that you can view its pages and see its contents. If you leave a request on our Website or in the App, we will use that data to mail you back.

3.2. To assign you the e-resident status. 

We process your personal data to conduct a preliminary check in order to subsequently assign you the e-resident status. Also in clause 2.2. in this notice we transfer some of your personal data that you provided us when applying for the e-resident status to other authorities in accordance with the resolution of the Cabinet of Ministers of Ukraine dated 05.09.2023 No. 970, "Some issues of the activities of electronic residents (e-residents) and management of the "E-resident" information system" (Resolution).

3.3. Registration by an individual entrepreneur. 

Following the the Resolution and in order for you to be able to register as an individual entrepreneur after acquiring the e-resident  status, we additionally collect and transfer your personal data to other authorities, in particular to the Ministry of Justice and the State Tax Service such your personal data:

  • given name, surname, patronymic (if available);
  • date of birth;
  • RNTRC;
  • mobile phone number; 
  • email address;
  • information on acquiring the e-resident.

3.4. Opening a bank account in Ukraine.

In order for you to be able to carry out business activities in Ukraine, you should open a bank account in one of the Ukrainian banks, which you can select in the "E-resident" information system. In this case  the bank will be able to fulfill its functions as your tax agent. For this purpose, we transfer following your personal data to the bank: 

  • given name, surname, patronymic (if available);
  • date of birth;
  • gender;
  • RNTRC;
  • mobile phone number; 
  • email address;
  • country of residence;
  • settlement, street name, house number, apartment number; 
  • country of  citizenship;
  • biometric data (digitized facial image), which we will receive after you pass identification at a foreign diplomatic institution of Ukraine;
  • travel document details: document number, issuing authority, date of issue, date of expiry, issuing country;
  • scanned copy of your travel document;
  • tax number in the country of citizenship.

3.5. To improve your interaction with our Website or App. 

We use some of your personal data to improve your interaction with our "E-Resident" information system, including: for analysis and statistics, as well as for the development of new functions on our Website and App. This kind of processing consists mainly of depersonalized data. Therefore, it does not allow you to be identified directly or indirectly.

3.6. Communications, updates, and news. 

We process your contact data in order to communicate effectively and to inform you about the issues that require your attention. If you provide us with your contact data, we will send you E-Residency reports, news, and updates. You can always withdraw your desire to receive E-Residency reports, news, and updates by clicking the link in the email. As an alternative, you may withdraw your desire to receive E-Residency reports, news and updates by emailing us via to privacy.e-resident@e-resident.diia.gov.ua. with email subject “newsletter cancellation”. 

3.7. Compliance with legal requirements. 

We process certain personal data in order to comply with legal requirements, for instance, exercising Mindigital’s powers under legislation on e-Residency.

4. Use of cookies.

A cookie is a file stored on a user’s hard disk containing user information. We use the necessary cookies to make our site work. Necessary cookies enable core functionality such as security, network management, and accessibility. You may disable these cookies by changing your browser settings, but this may affect how the website functions. The links below provide information about cookie settings for browsers:

  • Internet Explorer
  • Firefox
  • Microsoft Edge
  • Chrome
  • Safari

Also, you can opt out by visiting the Network Advertising Initiative Opt Out page. 

 

We’d also like to set optional cookies unless you enable them. The cookies collect information in a way that does not directly identify anyone. They help us improve our website by collecting and reporting information on how you use it. The basis for the processing of personal data is the consent of the subject of personal data to the processing of cookies.

5. How do we share and disclose data? 

We do not share or disclose your contact data to any third parties under this Notice, that are not provided for in this Notice or by Resolution. However, we may share your personal data under the conditions of Safety, Legal purposes, and Law enforcement. We will disclose your personal data to third parties to the extent necessary to:

  • comply with a government request, a court order or an applicable law; 
  • defend ourselves against third-party claims; 
  • assist in fraud prevention or investigation.

6. How do we process your data?

6.1. Security. 

We provide appropriate technical and organizational measures to protect the personal data we process and maintain. For example, data that we receive is available only to authorized personnel. We store data at the Data Centre De Novo, Kyiv, Ukraine.

If you have a reason to believe that your interaction with our Website is no longer secure, please immediately notify us by contacting us in writing at privacy.e-resident@e-resident.diia.gov.ua.

6.2. Retention of your personal data. 

We retain your personal data for as long as necessary to fulfill the purpose of the data processing in accordance with this notice. 

 

Personal data of foreigners who have applied for the e-resident status are stored for the period necessary to achieve the purpose of processing, but no longer than five years.

Personal data of e-residents is stored for the entire period of validity of the e-resident status and for five years after its cancellation

 

Personal data of e-residents, which were obtained for the registration of an individual entrepreneur, are stored for the entire period of validity of the individual entrepreneur and for five years after the termination. The term of storage of an individual entrepreneur’s personal data entered the Unified State Register of Legal Entities, Individual Entrepreneurs and Public Organizations, is established under the Procedure for the Processing and Protection of Personal Data, the owner of which is the Ministry of Justice of Ukraine, approved by the order of the Ministry of Justice of Ukraine dated 01.12. 2021 No. 4293/5.

The period of storage of personal data by the bank is established under the personal data processing policy of such a bank.

Personal data obtained as a result of contacting the support service is stored for the period necessary to solve the problem, but not longer than five years.

7. How can you manage your personal data? 

You have the following rights, which are inalienable and inviolable:

  • to know about the sources of collection, the location of personal data, the purpose of its processing, the location of the controller or processor of personal data, or to give an appropriate order to obtain this information to persons authorized by it, except for cases established by law;
  • to receive information about the conditions of providing access to personal data, in particular information about third parties to whom personal data is transferred;
  • to access your personal data;
  • to receive no later than thirty calendar days from the date of receipt of the request, except in cases provided by law, an answer about whether your personal data is being processed, as well as the content of such personal data;
  • submit a reasoned claim with an objection to the processing of your personal data;
  • submit a reasoned demand for the change or extraction of your personal data by any controller or processor of personal data, if these data are processed illegally or are unreliable;
  • to protect your personal data from illegal processing and accidental loss, destruction, or damage due to intentional concealment, failure to provide or untimely provision of them, as well as protection from providing information that is unreliable or disgraces the honor, dignity, and business reputation of a person;
  • file complains about the processing of your personal data with the ombudsman or the court;
  • apply legal remedies in case of violation of the legislation on the protection of personal data;
  • enter a reservation regarding the limitation of the right to process your personal data when giving consent;
  • withdraw consent to the processing of personal data;
  • know the mechanism of automatic processing of personal data;
  • to protect against an automated decision that has legal consequences.

If you would like to execute any of your personal data rights, such as access, review, update, rectify, delete, object, restrict or execute your data portability right, you can email us at privacy.e-resident@e-resident.diia.gov.ua. describing your request. In case you are unhappy with how we handle your data, you have the right to complain with a supervisory authority. In Ukraine, the role of supervisory authority is performed by the Parliament Commissioner for Human Rights.  

8. Do we transfer your data outside the European Economic Area? 

 

We do not intend to process your data anywhere but in Ukraine or other EEA countries. However, circumstances change, and we will have to transfer your data to a third country. We will inform you about such a transfer. If such a transfer won’t be necessary for the performance of a contract or the conclusion or performance of a contract concluded in your interest, we will ask for your explicit consent before transferring your personal data or inform you about legal grounds for such a transfer. 

 

9. How do we update this Notice? 

Ukrainian law and our practices may change over time. If we decide to update our Privacy Notice, we will post the changes on our Website. If we materially change the way we process your personal data, we will provide you with prior notice, or where legally required, request your consent before implementing such changes. We strongly encourage you to read our Privacy Notice and keep yourself informed of our practices.

10. Applicable law.

Processing of your personal data is carried out in accordance with the legislation of Ukraine.