Privacy Policy

Version of

1. Who processes your data

The data controller is , trading under the Web Sphere brand (“we”). Address: . Email for personal data questions: .

2. What data we collect

Data you provide yourself through the forms on the site:

• name;
• phone number;
• preferred way to contact you (call, Telegram, Viber);
• the text of your message or question, if you leave one;
• answers in the quiz game: the service you’re interested in, approximate budget, game result and discount information.

Data collected automatically:

• technical data: IP address, browser and device type, referring page, ad campaign tags (UTM);
• data about how you use the site via cookies — only to the extent you have consented to. More in our Cookie Policy.

We don’t collect special categories of data (health, religious or political views, etc.) and ask you not to include them in your messages.

3. Why we use the data

• to contact you in response to your request, advise you and prepare an offer;
• to conclude and perform a contract if we start working together;
• to apply the promised discount and include it in the offer;
• to analyze how the site works and improve it — only with your consent to analytics cookies;
• to show ads and measure their effectiveness — only with your consent to marketing cookies;
• to comply with legal requirements (accounting and tax records, if a contract is concluded).

We don’t send marketing emails without your separate consent and we don’t sell your data.

4. Legal grounds

• Your request and the steps you ask us to take before entering into a contract — Art. 6(1)(b) GDPR; Art. 11 of the Law of Ukraine “On Personal Data Protection”.
• Performance of a contract — Art. 6(1)(b) GDPR.
• Your consent (analytics and marketing cookies, agreement when submitting a form) — Art. 6(1)(a) GDPR.
• Our legitimate interest in the security and operation of the site — Art. 6(1)(f) GDPR.
• Compliance with legal obligations — Art. 6(1)(c) GDPR.

5. Who has access to the data

Your data is accessible only to Web Sphere employees and contractors who need it to work on your request or project. All of them are bound by confidentiality.

We also share data with providers who help us operate:

• website hosting and the server that receives requests;
• customer relationship management system (CRM);
• analytics and advertising services (Google, Microsoft, Hotjar, Meta) — only with your consent, see our Cookie Policy.

If you chose to be contacted via Telegram or Viber, the conversation will take place in those services under their own privacy rules.

We may disclose data to public authorities only in cases expressly provided for by law.

6. International data transfers

Some of our providers are located outside Ukraine and the EU, including in the US. In such cases we rely on the EU–US Data Privacy Framework (for participating companies) or the standard contractual clauses approved by the European Commission.

7. How long data is kept

• Request data — 3 years from our last contact with you, if we didn’t start working together.
• Data of clients with a contract — for the term of the contract and afterwards for as long as tax and accounting laws require.
• Cookie data — for the periods stated in our Cookie Policy.

When these periods expire, we delete or anonymize the data.

8. Your rights

You have the right to:

• find out what data of yours we process and get a copy of it;
• have inaccurate data corrected;
• have your data deleted;
• restrict or object to processing;
• receive your data in a convenient machine-readable 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 . We’ll respond within 30 days. To protect your data, we may ask you to confirm that the request really comes from you.

You can change your cookie consent here:

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.

9. Security

We use a secure connection (HTTPS), limit access to data to the people who need it for their work, and choose providers that ensure adequate protection. No system offers one hundred percent protection, but we do everything reasonably possible to keep your data safe.

10. Children

The site is not intended for people under 16. We don’t knowingly collect their data. If you believe a child has sent us their data, write to us and we’ll delete it.

11. 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 on the site.

12. Contacts