Cookie Policy

Version of

1. Who we are

This site belongs to , trading under the Web Sphere brand (“we”). Address: . Email for data questions: .

We are the controller of the data collected through cookies on this site.

2. What cookies are

Cookies are small text files that a site stores in your browser. In this policy we also use “cookies” for similar technologies: browser local storage (localStorage, sessionStorage) and tracking pixels.

3. Which cookies we use

Necessary. Keep the site working and remember your cookie choice. They don’t require consent and can’t be switched off.

Analytics. Help us understand how visitors use the site: which pages they view, where they come from, where they run into difficulties. For this we use Google Analytics 4, Microsoft Clarity and Hotjar. Clarity and Hotjar may record sessions (cursor movements, clicks, scrolling), but anything you type into form fields is masked. They work only with your consent.

Marketing. Help measure ad effectiveness and show you relevant ads on other sites. These are Google Ads and Meta Pixel, as well as embedded YouTube and Vimeo videos. They work only with your consent.

Full list of cookies:

4. What happens before you consent

Until you give consent, no analytics or marketing cookies are set. However, for the site to work your browser contacts two external services, and they receive your IP address:

• Cloudflare (cdnjs.cloudflare.com) — delivers the library for the phone number field in forms.
• Google Tag Manager (googletagmanager.com) — loads the tag container. We use Google Consent Mode v2: until you consent, Google tags run in “consent not granted” mode and don’t write cookies. Google may still receive anonymized cookieless signals, which it uses for statistical modeling.

5. Legal grounds

• Necessary cookies — our legitimate interest in keeping the site running (Art. 6(1)(f) GDPR, Art. 11 of the Law of Ukraine “On Personal Data Protection”).
• Analytics and marketing cookies — your consent (Art. 6(1)(a) GDPR, Art. 11 of the Law of Ukraine “On Personal Data Protection”).

6. How long cookies are kept

The retention period of each cookie is listed in the table above. We keep your cookie choice for 6 months, after which we’ll ask you to confirm it again. We’ll also ask for consent again if this policy changes significantly.

7. International data transfers

Google, Microsoft and Meta are US companies. Hotjar is an EU company (Malta). Data is transferred to the US on the basis of the EU–US Data Privacy Framework, in which these companies participate, as well as the standard contractual clauses approved by the European Commission.

8. How to manage cookies

You can change or withdraw your consent at any time: click “Cookie settings” at the bottom of any page or the button below. Withdrawing consent is as easy as giving it. After withdrawal we delete our cookies of the relevant category; reload the page for the changes to take full effect.

You can also delete or block cookies in your browser settings. Declining analytics and marketing cookies doesn’t limit your access to the site.

9. Your rights

You have the right to:

• get information about what data of yours we process;
• have your data corrected or deleted;
• restrict or object to processing;
• receive your data in a convenient format (portability);
• withdraw your consent at any time. This doesn’t affect the lawfulness of processing carried out before the withdrawal.

To exercise your rights, write to us at . We’ll respond within 30 days.

You can also lodge a complaint with the data protection supervisory authority in the EU country where you live, and in Ukraine — with the Ukrainian Parliament Commissioner for Human Rights.

10. Changes to this policy

We may update this policy. The date of the current version is shown at the top of the page. We’ll announce significant changes by asking for your consent again.

11. Contacts