Privacy Policy
21.09.2026
1. Data Controller and Contact Details
The controller of personal data processed in connection with this website and contact-form submissions is CONSORTIUM “INFRACITY” (Ukrainian: КОНСОРЦІУМ «ІНФРАСІТІ»), EDRPOU code 46248890, registered address: 61004, м. Харків, бульвар Нетіченський, 23А.
For questions about personal data processing or protection, or to exercise your rights, contact us at office@infracity.com.ua.
2. Personal Data We Process
When you submit the contact form, we process information you provide voluntarily: your name, a phone number or email address, your message, and any other information you include in it. Please do not include special-category or confidential data unless necessary. Without contact details we may be unable to reply.
Limited technical request data is processed to operate and secure the website. Cloudflare infrastructure may process the IP address, technical characteristics of the request, browser and connection, and other data needed to detect automated or malicious requests.
Our server does not persist the IP address for contact-form purposes. Rate limiting uses a cryptographic identifier generated with a random process salt and held only in volatile memory.
Cloudflare Turnstile protects the form by analysing technical and security signals from the browser and network connection. We do not use Turnstile for advertising profiling or marketing tracking, and we do not use web analytics or marketing trackers.
3. Purposes and Legal Bases
We process data to respond to inquiries; provide information and consultations; prepare proposals and pre-contractual steps; maintain necessary business correspondence; and protect the site and form from spam, automated requests, abuse and network threats.
Article 11(1)(3) of the Law of Ukraine ‘On Personal Data Protection’ may apply where processing is necessary to take steps at the data subject’s request before entering into a transaction.
For other inquiries and website security, Article 11(1)(6) may apply where processing protects legitimate interests of the controller or a third party and the data subject’s fundamental rights and freedoms do not override them. These interests include replies, necessary business communication, reliable operation and prevention of misuse.
If Regulation (EU) 2016/679 (GDPR) applies to particular processing under Article 3, the bases may be Article 6(1)(b), for pre-contractual steps requested by the data subject, and Article 6(1)(f), for legitimate interests in business communication and website security.
Contact details are not used for advertising or marketing messages without a separate appropriate legal basis.
4. Recipients of Personal Data
Inquiries are accessible only to persons duly authorised by CONSORTIUM “INFRACITY”, and only as necessary for their duties.
Data may be processed by Cloudflare for network protection, website delivery, Turnstile, server-side form processing and technical message transmission, and by Google (Gmail) for receiving and storing consortium email.
Only where necessary, information may be shared with authorised representatives of consortium members: Kherson Construction Alliance LLC, VAIT LLC, Zavod Spiroplast LLC, Tekhex Infra LLC and Arma Kavach Ukraine LLC.
We may disclose data where required by law. We do not sell or provide personal data to advertising agencies, networks or data brokers for their own marketing purposes.
5. International Data Transfers
Cloudflare and Google use international technical infrastructure, so personal and technical data may be processed outside Ukraine.
Transfers follow Article 29 of the Law of Ukraine ‘On Personal Data Protection’ and other applicable requirements. If the GDPR applies, transfers use GDPR mechanisms and contractual or other safeguards applied by the relevant providers.
You may request information about applicable safeguards at office@infracity.com.ua.
6. Retention
If an inquiry does not result in a contract or other contractual relationship, related correspondence is generally kept for no longer than 12 months after the last substantive contact and then deleted under the applicable retention procedure.
If a legal relationship arises, data may be kept for its duration and afterwards as needed for legal or accounting duties or to establish, exercise or defend legal claims.
The in-memory cryptographic IP identifier is removed no later than one hour after the last relevant request. Provider logs, service records or backups may be retained under provider rules.
We do not maintain a separate persistent database of contact-form submissions on the public web server.
7. Data Subject Rights
Article 8 of the Law of Ukraine ‘On Personal Data Protection’ provides rights including information about sources, location and purposes; access; correction, alteration or destruction where provided by law; objection; and recourse to the Ukrainian Parliament Commissioner for Human Rights or a court.
If the GDPR applies, Articles 15–22 also provide rights including access, rectification, erasure and restriction and, where applicable, objection and portability.
To exercise your rights, contact office@infracity.com.ua. We may request information to verify your identity. Requests are handled within applicable statutory periods. If the GDPR applies, we respond without undue delay and generally within one month; this may be extended where permitted, with notice.
You may complain to the Ukrainian Parliament Commissioner for Human Rights at 21/8 Instytutska Street, Kyiv 01008, Ukraine; hotline@ombudsman.gov.ua. If the GDPR applies, you may also complain to a competent supervisory authority under Article 77 GDPR.
8. Personal Data Security
We use appropriate technical and organisational measures against accidental loss, destruction, unauthorised access, disclosure or other unlawful processing, including HTTPS/TLS, rate limiting, automated-abuse protection, restricted correspondence access and minimised persistent storage.
No transmission or storage method guarantees absolute security, but our measures are proportionate to the nature of the data and processing risks.
9. Cookies and Other Technical Means
We do not use cookies or similar technologies for advertising profiling, marketing or web analytics.
Cloudflare security services may use technically necessary identifiers or cookies to validate requests, protect against automated attacks and maintain website security. We do not use them for advertising.
The contact form is protected by Cloudflare Turnstile. More information is available in the Cloudflare Turnstile Privacy Addendum.
If optional tracking technologies are introduced, this Policy and, where necessary, the consent mechanism will be updated before they are used.
Cloudflare Turnstile Privacy Addendum10. Automated Decision-Making
We do not use contact-form data for automated decision-making or profiling that produces legal effects or otherwise significantly affects a person.
11. Changes to this Policy
This Policy may be updated when laws, processing activities or technical services change. The current version is published here with its latest update date.
If changes materially affect purposes, legal bases or other essential terms, we will take additional steps to inform data subjects where required by law.