Publication Date: “05” May 2026

This Privacy Policy defines the policy of COMEL LLC, identification code: 24083083, registered address: Ukraine, Kyiv, 67 Beresteiskyi Ave. (hereinafter referred to as “We”, “Owner”), regarding the processing of your personal data (hereinafter – “PD”) when you use our website https://vinga.ua (hereinafter – the “Website”).

You, as the personal data subject (hereinafter – the “Subject”), by filling out any forms on this Website that require the provision of PD, voluntarily grant consent to the Owner for their processing. The Subject undertakes to provide accurate and truthful information about themselves, as well as to promptly notify the Owner of any changes related to the provided information.

We are the Controller of the database containing your PD and store it on secure servers of DigitalOcean, LLC.

1. GENERAL PROVISIONS

• Personal data is processed in accordance with the Law of Ukraine “On Personal Data Protection” No. 2297-XII.
• This Policy applies to all pages of the Website vinga.ua.
• By accessing the Website, you agree to the collection and use of your data. If you do not agree, please discontinue using the Website.
• We may amend this Policy without prior notice. The current version is always available on this page.

2. INFORMATION WE COLLECT

We process the following categories of data:

• Personal identification: Last name, first name, patronymic, date of birth.
• Contact details: Email address, phone number, delivery address.
• Social networks: Data provided when signing in via Facebook, Instagram, AppleID (to the extent permitted by these services).
• Technical information: IP address, browser type, language, request date/time, cookies.
• User messages: Content of support requests or chats for service improvement purposes.

3. PURPOSE OF DATA USAGE

Your PD is used for:

• Concluding and fulfilling purchase and sale agreements for Vinga equipment and accessories.
• Creating and managing the Customer Electronic Account.
• Processing orders, payments, and logistics (delivery).
• Providing warranty service and processing feedback.
• Marketing activities and newsletters (with your consent).
• Protecting the Website from fraud and resolving technical issues.

4. TRANSFER OF DATA TO THIRD PARTIES

We do not sell your data. Data transfer is possible only for:

• Fulfilling your order (courier services, payment systems).
• Legal procedures and compliance with the laws of Ukraine.
• Website traffic analytics and advertising effectiveness analysis.
• Fraud prevention. We require our partners to maintain confidentiality and use data only for specified purposes.

5. DATA STORAGE

• PD is stored for the duration of your account activity and for 5 years after the last order or account deletion.
• Certain information may be retained longer for reporting purposes (in accordance with the Tax Code of Ukraine) or to protect the legitimate interests of the Owner.

6. USE OF COOKIES

Cookies help us adapt the Website to your needs. You may disable or delete Cookies in your browser settings; however, this may limit the Website’s functionality.

7. YOUR RIGHTS (under Article 8 of the Law of Ukraine “On Personal Data Protection”)

You have the right to:

1. Know the sources of collection and the location of your data.
2. Access your PD and obtain information about the conditions for providing it to third parties.
3. Request modification or deletion of data if it is inaccurate or processed unlawfully.
4. Withdraw consent to the processing of PD.
5. File complaints with the Ukrainian Parliament Commissioner for Human Rights or with the court.

8. SECURITY

We take reasonable measures to protect your data from loss or theft. However, the transmission of data over the Internet cannot be guaranteed to be 100% secure, therefore you share information at your own risk.

9. REQUESTS AND CONTACTS

To withdraw consent, modify your data, or obtain information regarding your PD, please contact us:

• Email: info@vinga.ua
• Contact page: https://vinga.ua/ua/contacts/ (or a similar contacts page on the Website).

Note: Withdrawal of consent to data processing may result in the inability to fulfill your orders or provide access to the functionality of the Electronic Account.