Privacy Policy – UA Product Team

Last updated: March 2026

UA Product Team (operated by PE Nabatova A. M., Ukraine) (“we,” “us,” or “our”) is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect information when you visit our website or engage our services.

1. Who We Are

Data Controller:
PE Nabatova A. M., operating as UA Product Team
Ukraine
Contact: privacy@uaproduct.team

If you are located in the European Economic Area (EEA) or UK, we act as the data controller for you personal data under the General Data Protection Regulation (GDPR).

2. What Data We Collect

2.1 Website Visitors

When you browse our website, we may collect:

Usage data: pages visited, time spent, browser type, device type, IP address
Cookie data: analytics and preference cookies (see Section 8)
Contact form submissions: name, email address, company name, message content

2.2 Clients and Prospective Clients

When you engage or inquire about our services, we collect:

Name, job title, company name
Business email address and phone number
Project details and requirements shared during discovery calls or onboarding
Billing and invoicing information (name, company, address)
Communications (emails, meeting notes, feedback)

2.3 Data You Provide for Service Delivery

In the course of delivering consulting services, clients may share:

User research data (interview recordings, survey responses, personas)
Business strategy information, market data, and product documentation
Any other materials provided for project purposes

This data is handled under your signed Professional Services Agreement, which takes precedence for client engagements.

3. Legal Basis for Processing (GDPR)

If you are in the EEA or UK, we process your data on the following legal grounds:

Purpose	Legal Basis
Responding to inquiries	Legitimate interest / Performance of a contract
Delivering contracted services	Performance of a contract
Sending service-related communications	Performance of a contract
Analytics and website improvement	Legitimate interest
Marketing communications (if opted in)	Consent
Compliance with legal obligations	Legal obligation

4. How We Use Your Data

We use your data to:

Respond to inquiries and communicate about services
Deliver and manage consulting engagements
Issue invoices and process payments
Improve our website and services
Comply with legal and regulatory obligations
Send marketing updates, only where you have given explicit consent

We do not sell your personal data to third parties. We do not use your data for automated decision-making or profiling.

5. How We Share Your Data

We may share your data with:

Service providers who support our operations, bound by data processing agreements
Professional advisors (accountants, lawyers) under strict confidentiality obligations
Payment processors for invoicing purposes
Authorities, if required by law

Current sub-processors include:

Google Workspace (Google LLC, USA) — email, document storage, video conferencing
Notion (Notion Labs Inc., USA) — project and knowledge management
(additional tools as applicable)

All sub-processors are bound by their respective Data Processing Agreements and Standard Contractual Clauses where required. A current list of sub-processors is available upon request.

All third-party processors are required to handle your data in compliance with applicable law, including GDPR where applicable.

6. International Data Transfers

UA Product Team is based in Ukraine. Where we transfer data to countries outside the EEA, we ensure appropriate safeguards are in place, such as:

Standard Contractual Clauses (SCCs) approved by the European Commission
Transfers to countries with an adequacy decision

For US-based clients: by engaging our services, you acknowledge that your data may be processed in Ukraine and other countries where our service providers operate.

7. Data Retention

We retain your data only as long as necessary:

Data Type	Retention Period
Inquiry / contact form data	12 months from last contact
Client project data	Duration of engagement + 3 years
Invoicing and financial records	7 years (legal/tax obligation)
Website analytics data	12 months (rolling)
Marketing consent records	Until consent is withdrawn + 6 months

After the retention period, data is securely deleted or anonymized.

8. Cookies

Our website uses cookies to:

Ensure basic functionality (strictly necessary)
Analyze website traffic and usage (analytics)

Strictly necessary cookies are always active. Analytics cookies require your consent and can be declined via our cookie banner.

You can manage cookies at any time through your browser settings or our cookie preferences panel.

9. Your Rights

Depending on your location, you have the following rights regarding your personal data:

All users:

Right to know what data we hold about you
Right to correct inaccurate data
Right to request deletion of your data (“right to be forgotten”)
Right to withdraw consent at any time (where processing is consent-based)

EEA/UK users (GDPR):

Right of access (Article 15)
Right to rectification (Article 16)
Right to erasure (Article 17)
Right to restriction of processing (Article 18)
Right to data portability (Article 20)
Right to object to processing (Article 21)
Right to lodge a complaint with your national Data Protection Authority

California residents (CCPA):

Right to know and access personal information collected
Right to delete personal information
Right to opt out of sale of personal information (we do not sell data)
Right to non-discrimination for exercising your rights

To exercise any of these rights, contact us at: privacy@uaproduct.teamWe will respond within 30 days (GDPR) or 45 days (CCPA).

10. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

Encrypted data transmission (HTTPS/TLS)
Access controls and authentication for internal systems
Restricted access to personal data on a need-to-know basis
Confidentiality obligations for team members and contractors

In the event of a data breach affecting your rights and freedoms, we will notify relevant authorities and affected individuals in accordance with applicable law.

11. Children’s Privacy

Our website and services are not directed to individuals under the age of 16. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected such data, please contact us immediately.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified by updating the “Last updated” date at the top and, where appropriate, by direct notification to active clients.

13. Contact Us

For any privacy-related questions, requests, or complaints:

UA Product Team

Email: privacy@uaproduct.team

Website: https://uaproduct.team/

If you are in the EU/EEA and are not satisfied with our response, you have the right to contact your local Data Protection Authority (DPA).