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This Privacy Policy (hereinafter – the Policy) applies to the use of our website: https://spacelab.ua/ and defines what data is collected during your visit to our Website and when you accept offers posted on our Website, as well as determines how your personal data is processed and used.
1.1. “Administration” – the authorized owner of the Website represented by LLC “AVADA MEDIA”, which, acting on behalf of the Website, processes personal data and determines the purpose(s) of processing personal data, the composition of personal data subject to processing, and the actions (operations) performed using personal data.
1.2. “Website/Site” – the online platform under the domain: https://spacelab.ua/
1.3. “Website User” (hereinafter – the User) – a person who has access to the Website via the Internet or other networks and interacts with or uses the Website.
1.4. “Services/Service” – the goods/works/services placed on the Website that may be received and used by Users.
1.5. “Order” – an offer consisting of the User’s (Customer’s) intent to receive and use the Service.
1.6. “Personal data” – information or a set of information about an individual who is identified or can be identified through such information.
1.7. “Data subject” – an identified individual or an individual who can be identified, with respect to whom personal data is processed.
1.8. “Identifiable individual” – a person who can be directly or indirectly identified.
1.9. “User’s consent” – complete, unconditional, and voluntary, informed and unambiguous, specific, and free acceptance, in the manner provided by this Privacy Policy, of the terms of this Privacy Policy and its annexes.
1.10. “Processing of personal data” – any action (operation) or set of actions (operations) with personal data performed with or without the use of automation tools, including collection, registration, recording, archiving, systematization, organization, structuring, arrangement, combination, clarification (updating, modification), retrieval, use, transfer/disclosure (distribution, provision, access, or other means of provision), depersonalization, blocking, storage, adaptation, modification, restriction, deletion, or destruction of personal data.
1.11. “Operator” – an individual or legal entity, or a state body, that processes personal data on behalf of the Administration.
1.12. “Partners” – any business entities related to the Administration by contractual relations that are granted limited access rights (including but not limited to licensees) to the Website for the purpose of providing services, goods, performing works, distributing and/or providing information about their services and/or goods and/or works (including informational materials and messages published on their behalf or in their interests), as well as receiving requests from Users.
1.13. “Third party” – a natural or legal person, public authority, agency, or body other than the data subject, owner, controller, operator, and/or persons authorized to process personal data under the direct supervision of the owner, controller, or operator.
1.14. “Recipient” – a natural or legal person, public authority, agency, or other body to whom personal data is disclosed, whether or not it is a third party. Processing of such data by public authorities must comply with applicable data protection laws according to the purposes of processing.
1.15. “Confidentiality of personal data” – the requirement to prevent and prohibit the dissemination of personal data without the consent of the data subject or the presence of a legal or contractual provision (requirement).
1.16. “Cookies” – small text files that store information directly on the user’s computer, mobile phone, or other device.
1.17. “Pixels” – small digital images that are part of the code on web pages, allowing another server to measure page views and often used in combination with cookies.
1.18. “IP address” – a unique network address of a node in a computer network built using the IP protocol.
Other terms used in this Privacy Policy are defined by the current legislation of Ukraine.
2.1. The processing of personal data is necessary to achieve the purposes set forth in this Privacy Policy, to fulfill a contract to which the data subject is a party or intends to become a party, to comply with a legal obligation of the Administration, to protect the vital interests of the data subject, or for the purposes of the legitimate interests of the Administration or a third party, except in cases provided for by applicable law.
2.2. The personal data of Users is processed by the Administration, registered under the laws of Ukraine, located at: 65023, Ukraine, Odesa, 7 Dvoryanska St.
2.3. The Administration collects information (personal data) in the manner and by the means defined by this Privacy Policy and applicable law, both directly and/or indirectly.
2.4. Direct collection of personal data includes, for example, obtaining data that the User submits/provides through the Website and/or in the course of communication with the Administration via web forms (chats), email, telephone, letters, social networks, messengers, etc.
2.5. Indirect collection of personal data includes, for example, obtaining User data from third parties, including but not limited to business partners, subcontractors in technical, payment, and other services, or from publicly available external sources.
2.6. The processing of personal data and, in particular, the making of decisions based on such processing may be carried out in automated and/or non-automated forms.
2.7. The administrator, controller, and owner of the personal data database provided by the User is the Administration.
2.8. The Users’ personal data is processed on secure servers.
2.9. The Administration keeps records of the personal data processed by it and falling under its responsibility.
2.10. The Administration may delegate the processing of personal data to Operators. When delegating authority to process personal data to Operators, the Administration performs all actions required by law.
2.11. The Administration processes Users’ personal data only in the presence of the User’s (data subject’s) “Consent”.
2.12. This Policy and its annexes are considered accepted by the data subjects without any reservations or exceptions upon performing any voluntary, informed, and unambiguous, specific, and freely given expression of intent, whereby a natural person, through a clear affirmative action (confirming act) or other affirmative actions, including but not limited to submitting an application and/or Order, contacting the Administration/Operator through the contact details provided on the Website and/or using the Website in other available ways as defined by the Website and/or this Policy, agrees to the terms of this Privacy Policy and provides (confirms) their consent to the Administration to: process their personal data specified in the Policy; make automated individual decisions (based on automated processing of personal data); transfer their personal data to third parties, including cross-border transfers to any third country, for the purpose of receiving services/works/goods from such third parties; and perform other actions provided for by this Policy, applicable law, and necessary to achieve the purposes of personal data processing under this Policy.
2.13. Acceptance of this Policy in the manner prescribed herein indicates that the User consents to receiving system and other informational messages from the Administration by posting information on the Website, via email newsletters, phone calls, or other available means, and also confirms that the User has read, understands, agrees with, and undertakes to comply with the terms of this Policy and its annexes.
2.14. The User guarantees that they possess the necessary legal capacity, rights, and authority required and sufficient to conclude and perform the terms of this Policy as a personal data processing agreement.
2.15. The User’s consent is voluntary and direct.
2.16. By granting consent to the processing of personal data, a contract for the processing of personal data is deemed concluded between the data subject (User) and the Administration, the terms of which are set forth in this Policy.
2.17. The Administration is not obliged to verify the User’s compliance with the requirements of the Policy and is not liable in the event of the User’s non-compliance with these requirements.
2.18. To ensure proper and lawful processing of the data subject’s personal data, the Administration reserves the right to additionally verify the accuracy and authenticity of the personal data provided by the User and, in particular, to identify the data subject by a method chosen by the Administration, including requesting from the User information and documents to confirm their identity and the information provided, other personal data of the User, and other necessary data.
2.19. Identification of the data subject includes digital identification of the data subject, for example, through an authentication mechanism such as identical credentials used by the data subject to contact the Administration or access the Services.
2.20. In the event of an unsuccessful attempt to verify the User’s personal data or identity, the Administration may suspend, limit, or block the User’s access to the Website/Services.
2.21. When the User–data subject provides consent for personal data processing within the Website/Services to the Administration or to other persons, including those located abroad, in accordance with this Policy, they are considered notified of such transfer of their personal data.
2.22. The User’s consent to the acceptance of this Policy shall constitute sufficient notification of the inclusion of their personal data in the User database and the processing of their personal data.
2.23. Users should be aware that when following certain links posted on the Website, they may be redirected to websites (including applications, etc.) of other companies outside the Website’s hosting environment, where information about Users is collected beyond the direct control of the Administration. In such cases, the privacy policies of those third-party websites and/or applications shall govern the processing of information obtained from Users by those third parties.
3.1. The personal data of Users, as provided to the Administration, will be used for the purposes defined in this Policy. In particular, the Administration may process personal data for the following purposes:
3.1.1. displaying advertising, sponsorship, and other informational materials;
3.1.2. providing, selling, promoting, and improving the Services;
3.1.3. conducting surveys on behalf of the Administration/Partners or third parties and evaluating the effectiveness of advertising or other informational materials for statistical purposes, improving the Services and/or the Website;
3.1.4. providing user (customer) support, resolving technical issues, and ensuring access to various features of the Website and Services;
3.1.5. providing information offered on the Website;
3.1.6. providing additional information about the Services;
3.1.7. using information stored on the Website to create personalized offers that may appear on other platforms or websites, as well as on social media pages. These may include offers that the User can find directly on platforms or third-party products and offers that may be of interest to the User;
3.1.8. adapting offers and user experience, including advertising, within its own services or third-party services;
3.1.9. monitoring overall and individual User activity, such as keyword searches, order placements, contract execution, and Service selection, as well as managing traffic on the Website;
3.1.10. communicating with Users, including for Service-related issues, customer support, or authorized marketing communications via any available communication channels;
3.1.11. conducting research and analytical activities aimed at improving the Website;
3.1.12. ensuring compliance with Website user agreements, including combating fraud and abuse;
3.1.13. assessing certain factors of personal information, including analyzing and predicting personal preferences, interests, behavior, and location;
3.1.14. maintaining records;
3.1.15. supporting general organizational purposes;
3.1.16. reporting on the impact and effectiveness of the provided Services;
3.1.17. launching and/or administering the Website;
3.1.18. processing User applications/orders and/or roles;
3.1.19. training and/or quality control;
3.1.20. fulfilling legal obligations binding upon the Administration in accordance with applicable law, including requirements from regulatory, governmental, and/or law enforcement authorities (for example, tax compliance obligations);
3.1.21. identifying the client as a Website User, processing payments, conducting financial transactions, maintaining reporting, accounting, and management records, creating and implementing loyalty programs, user protection programs, sending postal and email communications, including commercial offers, promotional notifications, and other updates;
3.1.22. fulfilling contractual obligations concluded with Users (clients);
3.1.23. ensuring that Users receive services/works/goods from third parties;
3.1.24. fulfilling the legitimate interests of the Administration, which include, in particular:
3.2. Performing other purposes for which the User has provided consent.
4.1. Orders, agreements: Within the operation of the Website, the Administration may process information, including personal and contact details, necessary for executing an agreement between the User and the seller/provider/performer of the Services, in particular information about: geographic location, first name, patronymic and last name, date of birth and gender, credit card and other financial account information, transaction data, including Services offered, viewed or purchased on the Website, phone number and related information, including photos, education, occupation and work experience, time for providing services, performing work and receiving goods, language proficiency level, IP address, audio/video recordings if the User contacts the seller/provider/performer of the Services via video/audio call, user-generated content (e.g., messages, reviews, etc.), skills, completed tests, test results, other information provided by the User on or through the Website, or otherwise provided to the Administration/Third Parties/Partners.
4.2. Customer service for Users: When Users contact the Administration or Third Parties, the Administration, if necessary, may collect personal information required to fulfill the User’s request and provide feedback, including audio/video recordings if the User contacts the Administration/Third Parties/Partners via audio/video call, information about the Services used by the User or those that, in the Administration’s view, may interest the User. The Administration may also contact the User using the existing contact details provided for this purpose, including those obtained as a result of using the Services (executed agreements). The Administration may also collect other information about communications with Users, such as any support requests submitted by Users or any feedback provided by them, including in the form of reviews left by Users. Correspondence data may include the content of the communication and metadata associated with the communication. The Website will generate metadata associated with messages made through the Website’s contact forms.
4.3. Website and mobile data, User actions on the Website, information from Cookies: The Administration may automatically receive, record, and otherwise process on its servers unique device and application identifiers, browsing history, or other usage data of the Website, information from the User’s browser or any device, including IP address, User’s geolocation, software and hardware attributes, pages requested by the User, URL or advertisement that referred the person to the Website, search terms entered by the User in a search engine that led to the Website, parts of the Website visited by the User, hyperlinks clicked, pages or content viewed and for how long, data stored in the browser databases, including SQL databases, mobile identifiers (including mobile device identifiers such as Google Advertisement ID, IFA or IFV), information about app usage, and/or information about other used devices or system-level data, other similar information and statistics regarding the User’s interaction with the Website, such as content response time, loading errors, and duration of visits to specific Website pages, and others, within the purpose of personal data processing in accordance with this Policy. This may occur on the Website or on third-party services. Additional information about the collection and processing of Cookies, as well as how Users can control and/or block such collection of information, can be found in the Cookie Policy.
4.4. Information obtained through surveys: The Administration may process information obtained through surveys conducted by the Administration or contractors engaged by the Administration — third parties — specifically, information regarding gender, age, marital status, personal preferences, etc.
4.5. Supplementary information: The Administration may also add information obtained lawfully from business partners or third parties to existing User data.
4.6. Information necessary for the performance of works/provision of services/goods to Users by third parties (including Partners): Within the Website’s operation, the Administration may process information, including personal and contact details, necessary for executing an agreement between the User and the seller/provider/performer of services/goods/works or other third parties whose services/works/goods the User receives and/or intends to receive, in particular information about: first name, last name, phone number, email address, date of birth (day and month), gender, User identification methods, IP address.
4.7. Non-identifying information: The Administration may process other information that does not directly identify the User, such as postal codes, demographic data, and other data depending on the purpose and goals of personal data processing.
4.8. The Administration also collects/processes any other personal data the User wishes to share with the Administration.
4.9. The User, who under the Law of Ukraine “On Personal Data Protection” acts as the owner, recipient, or controller of personal data of data subjects, undertakes to comply with the provisions of the said Law regarding personal data processing (including through information (automated) systems).
4.10. By accepting this Policy, the User guarantees that they have obtained and have all legal grounds (necessary permissions and consents) to collect, record, accumulate, store, adapt, modify, update, use, and distribute (publish, transfer), anonymize, destroy, or otherwise process personal data and other information constituting the content of personal data regarding third parties using the Services/Website, and also guarantees the full and unconditional consent of such persons to all provisions of this Privacy Policy.
4.11. The User undertakes, in the event of any changes to the personal data provided, to promptly provide the Administration with updated, accurate information (personal data) and, upon request from the Administration, originals of relevant documents for updating the provided personal data.
4.12. Information the Administration does not collect and process: The Administration does not collect or process personal data regarding racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties or trade unions or similar information, genetic data, biometric data for the purpose of uniquely identifying an individual, data relating to a person’s health condition or data on a person’s sex life or sexual orientation, personal data of children (if information about the person’s corresponding age is available).
4.12.1. The provisions of clause 4.12. do not apply if the data subject has given explicit consent to the processing of such personal data for one or more specified purposes and/or in other cases established by law.
4.13. If the Administration becomes aware that a child under the age of 18 (for data subjects located in Ukraine) has provided the Administration with personal data, the Administration must make all reasonable efforts to delete such information. If you are the child’s legal representative or a person with parental rights over the child and believe that the Administration is processing your child’s personal data, please contact us using the contact details provided in this Policy.
4.14. The Administration, considering available technical and administrative capabilities, will make reasonable efforts to verify, in the cases provided for in clause 4.13. of the Policy, that the User’s consent has been given or authorized by the child’s legal representative or a person holding parental rights over the child (holder of parental responsibility for the child).
5.1. In the course of operating the Website, the Administration may collect certain information using technologies such as cookies, pixels, local storage, and other similar technologies.
5.2. The User can learn more about the processing of cookies by reviewing the Cookie Policy.
5.3. The Cookie Policy is an appendix to this Policy and forms an integral part thereof.
6.1. The Administration will store Users’ personal data for as long as necessary to achieve the purposes for which they were collected, including for the fulfillment of any legal, accounting, or reporting requirements, as well as for the purposes of continuous fraud prevention, backup, and business continuity. Personal data shall not be stored longer than required for these purposes. The Administration stores the User’s personal data for the period necessary to provide access to the Website and related Website services, the Services, the performance of works/provision of services/goods to the User by third parties, as well as for as long as the Administration has a legitimate interest in storing such data.
6.2. Personal data shall be stored in a form that allows the identification of data subjects no longer than necessary for the purposes of processing. In any case, the Administration deletes personal data except for those that must be stored to fulfill its legal obligations (for example, mandatory retention periods).
6.3. The User’s personal data may be stored for longer periods than those specified in clauses 6.1–6.2 of this Policy, as long as they are processed exclusively for purposes of public interest, scientific or historical research, or statistical purposes, provided that appropriate technical and organizational measures are taken to guarantee the rights and freedoms of the data subject (“storage limitation”).
6.4. To ensure that personal data are not stored longer than necessary, the Administration periodically reviews the stored personal data.
6.5. Notwithstanding other provisions of this section of the Policy, the Administration may store Users’ personal data when such storage is necessary to comply with a legal obligation of the Administration or to protect the vital interests of the Users or another natural person.
6.6. To determine the appropriate retention period, the Administration considers the volume, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of the Users’ personal data, the purposes for which the Administration processes the Users’ personal data, as well as whether the Administration can achieve those purposes by other means, and applicable legal requirements.
6.7. If the User no longer wishes to be contacted by the Administration, the Administration will retain the User’s basic information to fulfill the User’s request and to avoid sending unwanted materials to the User in the future.
6.8. In case of any questions regarding the data retention period, the User may contact the Administration using the contact details provided in this Policy.
7.1. The Administration does not share, sell, or rent Users’ personal data to third parties for marketing purposes. However, as a general rule, the Administration may disclose personal data to selected third parties to achieve the purposes defined in this Privacy Policy.
7.2. The Administration may transfer Data collected under this Policy to its Partners, between respective Websites and programs owned or operated by the Administration; however, the data collected under the Public Agreement, the Terms of Use of the Website or application, and this Policy are always protected in accordance with this Policy and the legislation of Ukraine. At the same time, Partners and third parties bear sole responsibility for compliance with legal data processing requirements.
7.3. The Administration may share the information it collects:
7.4. The Administration may use third-party service providers to supply certain components of its services. In such cases, providers are not authorized to use personal data obtained through the Website except to provide services to the Administration, and the personal data remain subject to this Privacy Policy.
7.5. The Administration reserves the right, in accordance with legal requirements, to exchange information with private individuals and public authorities for the following purposes:
7.6. The Administration may provide Users’ personal data upon requests from competent authorities made in compliance with applicable legislation and when there are grounds established by law.
7.7. In the event that the Administration’s business or part of it is sold or reorganized, and the Administration transfers all or substantially all of its assets to a new owner, Users’ personal data may be transferred to the purchaser to ensure continuity of the Website/Services/third-party services/works/goods.
7.8. The Administration may transfer certain anonymized information (data that do not allow identification of Users individually) to third-party service providers, trusted partners, or authorized researchers to better understand which advertisements or services may interest Users, to improve the overall quality and effectiveness of the Website’s services, or to contribute to scientific research that, in the Administration’s opinion, may provide significant social benefits.
7.9. The Administration may transfer information it collects to third parties providing services to the Administration, as well as to Partners, for the purpose of conducting research or providing Services to Users, while the transferred data remain subject to this Privacy Policy, and involved third parties are not entitled to use the obtained information for any purposes other than providing services to the Administration.
7.10. The Administration may transfer Users’ personal data to third parties that provide services, perform works, or supply goods to Users, or whose services/works/goods the User intends to receive, while the transferred data remain subject to this Privacy Policy, and involved third parties are not entitled to use the obtained information other than for providing services/performing works/selling goods to Users and fulfilling agreements concluded between the User and such third party.
7.11. Personal data may be transferred abroad (outside the location of data processing) in the following cases:
7.12. The transfer of personal data to foreign entities related to personal data shall be carried out only if the respective country ensures adequate protection of personal data, in cases established by applicable law.
7.13. The Administration reserves the right to disclose the User’s personal data to third parties, including for the purpose of protecting the rights, property, or safety of the Administration, its personnel/employees, Users, and other persons.
7.14. In cases of personal data transfer as provided in this section of the Policy, informing the User about the transfer of their personal data remains at the discretion of the Administration, except in cases provided by this Policy or applicable law.
7.15. The User should be aware and understand that when personal data are voluntarily disclosed by the User in public areas of the Website, this information, together with any information disclosed in the User’s message, may be collected and used by third parties and may lead to unwanted messages from such third parties. Such activity is beyond the Administration’s control, and this Policy does not apply to such information. Any materials in chats or other public areas of the Website are accepted with the understanding that they are accessible to all third parties. If the User does not want their messages/comments/reviews to be viewed by third parties, the User is advised not to make any statements.
7.16. The Administration may collect additional information about Users from external information sources for the purposes provided in this Policy.
8.1. Users may access their personal data and other information as defined by law, restrict the processing of personal data, correct, supplement, or delete the Data they have provided. The User is responsible for the accuracy of the data or messages provided on the Website. The Administration may cease processing the User’s personal data upon receiving a written notice from the User withdrawing consent to the processing of personal data.
8.1.1. To exercise the rights provided for in clause 8.1 of this Policy, the User must send an appropriate request addressed to the Administration using the addresses/contacts specified in this Policy.
8.1.2. In a request to correct, update, or delete information, the User must clearly specify which information they request to be corrected, updated, or deleted.
8.1.3. The Administration shall resolve the relevant User’s request no later than 30 (thirty) calendar days from the date of receiving all necessary information from the User.
8.2. Cookies: Most major desktop and mobile web browsers (such as Safari, Firefox, Internet Explorer, Chrome, Opera) provide controls that allow the User to restrict or block the installation of Cookies on their systems. Please note that disabling Cookies related to first-party domains (visited sites) and other domains (sites linked to the visited ones) may, in some cases, result in limited functionality of those websites.
8.3. Other (non-exhaustive) rights of Users in connection with the processing of their personal data by the Administration:
8.4 The legislation of Ukraine applicable to the controller, owner, or operator may, by means of a legislative instrument, limit the scope of obligations and rights provided by law, provided that such limitation preserves the essence of fundamental rights and freedoms and constitutes a necessary and proportionate measure in a democratic society to ensure compliance with legal requirements.
9.1. All information collected by the Administration is reasonably protected by technical, administrative, and physical security measures and procedures to prevent unauthorized or unlawful access to or use of personal data, as well as to prevent accidental loss, destruction, or damage to personal data, in accordance with the level of risk.
9.2. The processing of personal data is carried out in a manner that ensures the appropriate security of personal data.
9.3. Persons affiliated with the Administration, reliable partners, and independent providers of services/works/goods, as well as third parties specified in this Policy, undertake to use the information received from the Administration in accordance with security requirements and this Privacy Policy.
10.1. This Privacy Policy was last updated on September 19, 2025.
10.2. The Administration may update this Privacy Policy from time to time. The new version of the Privacy Policy comes into effect upon its posting on the Website at the address specified in this section, unless otherwise provided by the new version of the Privacy Policy.
10.3. The current version of the Privacy Policy is always available on the Website page at: https://spacelab.ua/privacy-policy/.
10.4. In the event of an update to the Privacy Policy, the User will be notified via a pop-up window when visiting the Website, and to continue using the Website and Services, the User must agree to the terms of the updated Privacy Policy in accordance with the procedure established in Section 2 of the Policy.
10.5. If the Administration makes any changes to the Privacy Policy with which the User does not agree, the User is obliged to cease using the Website and Services.
11.1. The User is liable for non-compliance with their obligations under the Privacy Policy as determined by applicable law.
11.2. The User is obliged to compensate the Administration for any damages and losses that may be directly or indirectly caused by a breach of the User’s obligations.
11.3. The User bears sole responsibility for the distribution of data for access to the Service/Website, for the distribution of personal data of third parties (including the Administration), and for the content, including its compliance with applicable legal requirements.
12.1. This Policy is mandatory for application by Operators, Partners, the Administration, third parties defined by the Policy, and other persons who directly process Personal Data and/or have access to Personal Data in connection with the performance of their official duties and/or contractual obligations regarding the confidentiality of data received from the Administration.
12.2. All suggestions or questions regarding this Privacy Policy must be submitted as feedback in accordance with Section 13 of this Privacy Policy.
12.3. As the applicable law regarding the processing and protection of Personal Data, the User agrees to the use of the legislation of Ukraine.
12.4. Regarding any matter directly or indirectly related to the Privacy Policy, the User agrees that dispute resolution shall be conducted in competent Ukrainian courts, in the manner and procedure established by the current legislation of Ukraine.
12.5. The invalidity of any part of the Privacy Policy does not result in the invalidity of other parts of the Policy as a whole. In the event of modification, cancellation by the parties, or recognition of individual provisions of the Privacy Policy as invalid, the remaining provisions shall remain valid and binding for the Parties to the Personal Data processing agreement.
12.6. In the event that certain provisions, rights, and obligations are not regulated by this Privacy Policy, they shall be governed and established by the current legislation of Ukraine.
13.1. The User can contact the Administration using the following methods: