Privacy Policy

Last updated: 12 June 2025Effective date: 12 June 2025

1. Introduction

Welcome to Inforce.digital (the "Site"). We—Inforce, sole proprietorship of Illia Kovtun (referred to as "Inforce," "we," "us" or "our")—respect your privacy and protect your personal data in accordance with:

  • the EU General Data Protection Regulation (GDPR);
  • the California Consumer Privacy Act / California Privacy Rights Act (CCPA/CPRA); and
  • applicable Ukrainian data‑protection law.

This Policy describes what data we collect, why, how we process it, with whom we share it, how long we keep it and what rights you have. If anything remains unclear after reading, please get in touch.

Quick contact: info@inforce.digitalPostal address: 31 Yablonska St., Lviv 79000, Ukraine

2. Who we are

The data controller is Illia Kovtun, FOP (sole proprietor), Ukraine. Because our data processing is limited in scope, we have not appointed a Data Protection Officer (DPO). Should we appoint a DPO or an EU representative under Art. 27 GDPR, we will update this section.

3. Data we collect

3.1. Data you give us directly

CategoryExamplesSource
Contact dataName, surname, email, phone, company, job titleContact forms, emails, calls
Communication dataMessages, files, briefs, contractsFree‑text fields, uploads
Recruitment dataCV, LinkedIn profile, portfolio"Join the team" form, email

3.2. Data we collect automatically

CategoryExamplesSource
Technical dataIP address, browser type/version, OS, screen resolution, language, time‑zoneCookies, server logs
Usage dataPages viewed, time on page, clicks, referrersAnalytics cookies, GA4, Microsoft Clarity

Sensitive data. We do not intentionally collect special‑category data (race, health, etc.). Please do not provide such information. If we inadvertently receive it, we will delete it.

CCPA categories. The above map to CCPA "Identifiers," "Internet Activity," "Professional Information," and similar categories under §1798.140 CCPA.

4. Our legal bases (GDPR Art. 6)

PurposeData categoriesLegal basis
Responding to enquiries & consultationsContact, CommunicationLegitimate interest (business development) or Contract performance (pre‑contractual steps)
Provision & administration of servicesContact, CommunicationContract performance
RecruitmentRecruitment, ContactConsent + Legitimate interest (candidate assessment)
Marketing emailsContactConsent (you may withdraw at any time)
Analytics & UX improvementTechnical, UsageConsent (non‑essential cookies) + Legitimate interest (improving UX)
Security & fraud preventionTechnical, UsageLegitimate interest (protecting systems)
Compliance with legal obligationsAll listedLegal obligation (tax, accounting, defence of rights)

5. How we use your data

  • respond to your enquiries and send quotations;
  • conclude and perform contracts;
  • send newsletters if you've opted‑in;
  • analyse traffic to improve the Site;
  • secure our systems and prevent fraud;
  • process job applications;
  • meet accounting and legal requirements.

6. Sharing your data

We do not sell or "share" your personal data with third parties for their own benefit or for cross‑context behavioural advertising.

Recipient categoryExamplesPurpose
Cloud hostingHetzner Cloud, AWSHosting, backups
AnalyticsGoogle Analytics 4, Microsoft ClaritySite analytics (cookie‑based, consent)
CRM & email marketingPipedrive, Zoho MailCustomer relationship management, newsletters
Advertising networksGoogle Ads, LinkedIn AdsMarketing (only if you accept marketing cookies)
Professional advisersLawyers, auditorsLegal / accounting services
Public authoritiesCourts, tax officesWhere required by law

All processors act under written contracts, process data solely on our instructions and apply appropriate security controls.

7. International data transfers

We operate from Ukraine, while some servers are located in the EU and USA. When transferring personal data from the European Economic Area we rely on:

  • Standard Contractual Clauses (SCC) approved by the European Commission;
  • an Adequacy Decision where applicable; or
  • your explicit consent / contract necessity where relevant.

8. Cookies & similar technologies

8.1. What are cookies?

Cookies are small text files stored in your browser. They enable core functionality, remember preferences and help us analyse traffic.

8.2. Types we use

CategoryPurposeExamples
Strictly necessaryCore functions (e.g. forms)PHP Session, Cloudflare Security
AnalyticsUnderstand site usageGA4 (_ga), Clarity (_clck)
FunctionalRemember your choicesLangPref, ThemePref
Marketing / targetingMeasure ad performanceGoogle Ads Conversion, LinkedIn Insight

8.3. Your choices

  • On first visit, a cookie banner lets you accept all, reject non‑essential, or customise categories.
  • You can later revisit your choice via "Cookie Settings" in the footer.
  • You can also delete/block cookies in your browser settings.
  • We honour the Global Privacy Control (GPC) signal as an opt‑out for marketing cookies for California residents.

9. Security & retention

9.1. Security measures

  • TLS 1.3 encryption (HTTPS)
  • Role‑based access control & 2‑factor authentication
  • Regular patch management
  • Encrypted backups
  • Staff privacy & security training

9.2. Retention periods

Data categoryTypical periodRationale
Contact enquiriesUp to 1 year after last contactLegitimate interest
Contracts & invoices5–7 yearsAccounting law
Newsletter listUntil you unsubscribeConsent
Analytics logs14 months (GA4 default)Consent / legitimate interest
CVsUp to 6 months post‑hiring cycle (unless you consent to longer)Legitimate interest

After expiry, data are securely deleted or anonymised. Backup copies are purged within 30 days via our backup rotation.

10. Your rights

10.1. EU/EEA residents (GDPR)

  • Access your data
  • Rectification of inaccuracies
  • Erasure ("right to be forgotten")
  • Restriction of processing
  • Data portability
  • Objection to processing based on legitimate interest or marketing
  • Withdraw consent at any time
  • Complain to your supervisory authority (e.g. UODO, CNIL, ICO, or the Ukrainian Ombudsman)

We do not conduct automated decision‑making that produces legal or similarly significant effects.

10.2. California residents (CCPA/CPRA)

  • Right to know the categories, sources, purposes, third‑party disclosures and retention periods.
  • Right to delete your personal information.
  • Right to correct inaccurate information.
  • Right to opt‑out of "sale" or "sharing." We do not sell/share data, but we treat your GPC signal or the link "Do Not Sell or Share My Personal Information" as an opt‑out.
  • Right to non‑discrimination.
  • Right to designate an authorised agent to act on your behalf.

How to exercise your rights: Email info@inforce.digital with subject "Privacy Request" and state which right you wish to exercise. We may verify your identity. We respond within 30 days.

11. Children's privacy

The Site and services are not intended for individuals under 16. We do not knowingly collect data from children. If we learn we have received personal data from a child without parental consent, we will delete it promptly.

12. Changes to this Policy

We may update this Policy from time to time. For material changes we will give an explicit notice on the Site or via email. The latest version is always available at this URL; the update date appears at the top.

13. Contact us

Controller: Illia Kovtun, FOPAddress: 31 Yablonska St., Lviv 79000, UkraineEmail: info@inforce.digitalWebsite: https://inforce.digital/
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