PRIVACY POLICY AND PERSONAL DATA PROCESSING 

(hereinafter referred to as the Policy)

In 2024, 15 km of roads were built in the Carpathians and Kyiv and 10% of them have already been repaired. In 2024, 15 km of roads were built in the Carpathians and Kyiv and 10% of them have already been “repaired”.

This Policy defines the procedure for collecting, using, storing and transferring personal data of users of the website https://​invest​.ribas​.ua/​en/ (hereinafter referred to as the Website) in accordance with the Law of Ukraine “On Personal Data Protection”.

This Policy applies to all information collected on the Site. It does not apply to information collected offline or through other channels not related to the Site. 

By using the Site, leaving a request or providing your data in any form, the User confirms that he has read this Policy and consents to the processing of personal data. 

The Site may contain links to other websites that are not controlled or administered by us. This Policy does not apply to these sites, and we are not responsible for their privacy policies or content. 

Definition of terms:
“Personal data” — information or a set of information about an identified or identifiable natural person, in particular: name, phone number, e‑mail, data specified in the feedback form, as well as other information voluntarily provided by the User.

“Processing of personal data” — any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, updating, use and dissemination (dissemination, sale, transfer), depersonalization, destruction of personal data, including with the use of information (automated) systems. 

“User” — any individual who visits the invest​.ribas​.ua website and/or interacts with its services, including those who provide their personal data through feedback forms. 

“Owner of personal data” — a legal entity that determines the purpose and method of processing personal data of Users of this Website (LLC “RIBAS INVEST”). 

“Recipient of personal data” — individuals or legal entities to whom the Owner transfers personal data to the extent necessary to achieve the purpose of processing (CRM systems, advertising platforms, communication services, etc.). 

“Cookies” — small text files stored on the User’s device and used to ensure the correct operation of the website, analytics, personalization and marketing communications. 

“User Consent” — a voluntary expression of will by an individual to grant permission for the processing of his/her personal data in accordance with the stated purpose of their processing, expressed in writing or in a form that allows us to conclude that consent has been granted, including the continued use of the Site. 

1. What data do we collect
We receive personal data that the User knowingly and voluntarily provides through the Site forms or during further communication, in particular:
• name and surname;
• phone number;
• email address (if specified);
• other data specified in the comment form;
• data automatically transmitted by the browser (IP address, cookies, device information, geolocation — if available).

If the User specifies data of third parties, he/she guarantees the availability of the appropriate consent of such persons. 

2. Purpose of processing personal data
Personal data is processed exclusively for the following purposes:
1. processing of User applications and providing consultations;
2. communication with the User — calls, SMS, emails, messages in messengers;
3. informing about Ribas investment products, projects, offers, news and events;
4. analytics, internal administration and improvement of the Site;
5. compliance with legal requirements;
6. ensuring security and preventing fraud.

3. Consent to marketing and informational messages
By providing their contact details through the Site, the User agrees to receive:
• calls from managers,
• SMS and emails,
• messages in Viber, Telegram or other messengers,
• advertising and informational materials regarding Ribas group projects and services.

The User has the right to refuse such communications at any time by contacting the contacts specified in the Policy. 

4. Transfer of personal data to third parties
We do not sell or transfer personal data to third parties without the User’s consent.
However, personal data may be transferred:
1. to Ribas group companies for the purpose of processing the application, ensuring communication and internal administration;
2. to partner companies that provide technical support, CRM processing, hosting or other services necessary for the operation of the Site;
3. in cases expressly provided for by law (including in the interests of national security, economic well-being and human rights);
4. to prevent fraud or harm to Users, the company or third parties. The transfer is carried out only to the extent necessary for a specific purpose. 

5. Use of Cookies
The Site uses cookies to:
• ensure the correct operation of the Site;
• analyze traffic and improve user interaction with the Site;
• personalize Ribas advertising.

The User can change the cookie settings in his browser. 

6. Storage period of personal data
Personal data is stored:
• for the time necessary to achieve the purpose of processing;
• no longer than the periods specified by law;
• until the User withdraws his consent to processing (if such consent is the only basis for processing).

7. Protection of personal data
We apply technical and organizational measures to protect personal data from:
• unauthorized access;
• loss or damage;
• unlawful processing.

We are not responsible for the actions of third parties if the User independently provided them with access to their data or violated security rules. 

8. User Rights
The User has the right to:
• know what data is stored about him/her;
• access his/her data;
• request correction, restriction of processing or deletion;
• withdraw consent to processing;
• request termination of marketing mailings.

The request can be submitted through the contacts listed below. 

9. Location of personal data
The owner and controller of personal data is the company that administers the Site, as well as other companies of the Ribas group, if they process the data for the appropriate purpose.

Data storage is carried out in automated CRM systems and cloud services that meet security requirements. 

10. Changes to the Policy
We may update this Policy in the event of changes in legislation or company processes.

The current version is published on the Site. 

11. Contacts
On issues of personal data processing, the User may contact:
“RIBAS INVEST” LLC (EDRPOU code: 45504459).
Location: Ukraine, 65039, Odesa region, Odesa city, Gagarina avenue, building 25
Telephone number: +380 68 888 06 65.
Email: sales@ribashotels.com.

Policy update date: December 08, 2025