法律文件

PRIVACY POLICY

版本 1.0 权威版本最后更新：2026年7月1日

1. GENERAL PROVISIONS

KYLYVNYK CLUB is an international private membership platform operated by Kylyvnyk Consulting LLC, registered in the state of Florida, United States of America.

This Privacy Policy applies to all users of the KYLYVNYK CLUB platform, regardless of country of residence, citizenship, location or place of business.

This Privacy Policy describes the procedure for collecting, receiving, storing, using, transferring, disclosing, protecting and otherwise processing personal data of platform users.

This Policy applies to all services, products, features, digital club cards, business profiles, subscriptions, Business Introductions, websites, pages, applications and other services provided by KYLYVNYK CLUB.

The Platform may not collect all categories of data listed in this Policy. The actual amount of data collected depends on the features used, account type, membership category, subscription status, presence of a business profile, user location and other circumstances.

The use of the platform is also governed by the Terms of Use, Cookie Policy, Refund Policy, Club Rules, Partner Rules, Business Implementation Rules, Disclaimer and other official platform documents.

By using the platform, the user confirms that he has read this Privacy Policy and agrees to its terms.

2. DATA OPERATOR

For the purposes of this Policy, the personal data operator is:

Kylyvnyk Consulting LLC

6 Pauline Pl

Palm Coast, FL 32164-7535

United States

Email:

kylyvnykclub@gmail.com

Kylyvnyk Consulting LLC determines the purposes, methods and basic principles of processing personal data of platform users.

Depending on the nature of the processing, individual service providers, payment providers, hosting providers, analytics services, security services, email services, cloud services and other third parties may act as Data Processors, Service Providers or independent data processors in accordance with applicable law.

The Platform may use contractors and technology partners located both in the United States of America and in other countries around the world as necessary to provide platform services, security, payment processing, analytics, technical support, or compliance with laws.

3. SCOPE OF THE POLICY

This Policy applies to:

official website of KYLYVNYK CLUB;
mobile versions of the site;
personal accounts of users;
registration forms;
digital club cards;
business profiles;
directory of partners;
special conditions of partners;
Business Introductions;
subscriptions and paid services;
feedback forms;
electronic correspondence with users;
contacting support;
marketing and information mailings;
analytical and technical tools of the platform;
social networking platforms;
platform mobile applications (if available);
other services and functions provided by KYLYVNYK CLUB.

This Policy does not apply to websites, applications, services, payment pages, social networks and other resources of third parties, even if links to them are posted on the platform.

Your use of third party services is subject to the privacy policies and terms and conditions of the applicable third parties.

KYLYVNYK CLUB does not control the activities of third parties and is not responsible for the processing of data by such parties.

4. CATEGORIES OF DATA COLLECTED

Depending on the functions used, the platform can collect, receive, store and process the following categories of data:

account details;
contact details;
identification data;
digital club card data;
subscription data;
payment and transaction data;
business profile data;
data on licenses, permits and professional activities;
information about the company and business activities;
identification documents;
documents confirming the address of residence or business;
photographs, images, logos, documents and other downloadable materials;
geolocation data;
technical data of devices;
browser data;
data from cookies and similar technologies;
data on the use of the platform;
data of correspondence and requests;
data required for security checks;
data necessary to verify the user’s identity (Know Your Customer / KYC);
data necessary for business verification;
data necessary to comply with legislation;
data voluntarily provided by the user.

The listing of a certain category of data in this Policy does not mean that the platform necessarily collects such data from each user.

KYLYVNYK CLUB may only collect data that is necessary or reasonably useful to provide relevant functionality, verify users, verify business profiles, prevent fraud, ensure platform security, comply with laws and develop platform services.

The platform has the right to expand or reduce the list of data actually collected as services develop, new functions are introduced, legislation changes, or the platform’s business model changes.

5. ACCOUNT DETAILS

When registering, using the platform or interacting with KYLYVNYK CLUB services, the platform may collect and process the following user data:

name;
last name;
middle name, if the user voluntarily indicates it;
pseudonym;
profile photo;
email address;
telephone number;
Telegram username;
WhatsApp number;
links to social networks;
links to professional profiles and directories;
date of birth;
country of residence;
city of residence;
postal address;
language of communication;
account ID;
digital club card number;
type of membership;
participant status;
subscription status;
date of registration;
account login history;
account settings;
history of account changes;
data voluntarily added by the user to the profile.

The user is responsible for the accuracy, relevance and completeness of the data provided when registering and using the platform.

KYLYVNYK CLUB has the right to request additional information if it is necessary to verify the account, prevent fraud, comply with the law, protect the platform, or consider the user's request.

KYLYVNYK CLUB has the right to request user identification documents, company documents, licenses, permits, proof of address, confirmation of the right to conduct relevant activities, as well as other documents that may be reasonably necessary to verify the user’s identity (Know Your Customer / KYC), prevent fraud, ensure the security of the platform, comply with the law, or protect the legitimate interests of KYLYVNYK CLUB and other users of the platform.

6. BUSINESS PROFILE DATA

If a user creates, posts or applies for a business profile, KYLYVNYK CLUB may collect and process the following data:

company name;
company name;
trade name;
name of the owner or representative of the business;
position of representative;
company registration numbers;
tax numbers, if necessary;
licenses;
permissions;
certificates;
documents confirming the right to conduct the relevant activities;
documents confirming the right to represent the relevant business, organization or entrepreneur;
office addresses;
addresses of branches;
service areas;
business contact information;
business email;
business telephone;
business website;
links to social networks;
logos;
business photographs;
promotional materials;
description of goods and services;
prices, if the user specifies them;
special conditions;
discounts;
bonuses;
validity periods of offers;
restrictions on offers;
requirements for pre-registration;
minimum order amounts;
opening hours;
information about employees or representatives, if they are voluntarily specified by the user;
other information necessary for posting, checking, publishing, refusing to publish, updating, hiding or deleting a business profile.

The user posting a business profile confirms that he has the right to provide the relevant information, that such information is reliable, current and not misleading to other users, and that the posting of such information does not violate the rights of third parties, the user's contractual obligations or the requirements of applicable law.

KYLYVNYK CLUB has the right to use business profile data to verify the accuracy of information, assess business compliance with platform requirements, prevent fraud, protect users, display the business in the partner directory, administer special conditions for partners and comply with legal requirements.

KYLYVNYK CLUB has the right to use automated and non-automated methods to verify information posted in business profiles, including analysis of publicly available information, official registers, licenses, permits, websites, social networks, public databases, documents provided by the user, as well as other legal sources of information available to the platform.

The use of such verification methods does not imply that the platform undertakes to continually monitor, control or guarantee the accuracy of all information posted by users and business partners.

The user understands and agrees that the information he places in his business profile for publication on the platform may be publicly available to other users of the platform, site visitors, search engines and other persons, depending on the platform settings, the selected platform functions and the nature of the published information.

7. SUBSCRIPTION AND PAYMENT DETAILS

When using paid functions, VIP Membership, Business Profiles or other paid services, KYLYVNYK CLUB may collect and process information about:

subscription type;
subscription status;
date of subscription;
subscription renewal date;
date of subscription cancellation;
payment amount;
payment currency;
transaction status;
payment history;
return history;
payment method;
transaction ID;
payment provider;
tax information if required by law;
accounts;
receipts;
payment confirmations.

KYLYVNYK CLUB does not store complete data of users' bank cards.

Payment data may be processed by independent payment providers, including Stripe and other payment service providers used by the platform.

Payment providers may independently collect, store and process user payment information in accordance with their terms of service, privacy policies, security rules and legal requirements.

KYLYVNYK CLUB may receive limited information from payment providers necessary to confirm payment, manage subscriptions, process refunds, prevent fraud, maintain accounting, tax accounting and comply with laws.

8. GEOLOCATION DATA

KYLYVNYK CLUB may collect and process information about the location of the user or business.

Such information may include:

country;
region;
staff;
canton;
region;
city;
postal code;
approximate location;
IP geolocation;
address specified by the user;
business address;
territory of service provision;
GPS data;
mobile device data;
location information voluntarily provided by the user.

Precise GPS geolocation data may only be collected if appropriate user permission is granted through device, application, browser, or operating system settings.

Geolocation data can be used to:

determining the user's country or region;
display of local offers;
displaying partners by country, region, city or service area;
checking the accuracy of business profiles;
identifying discrepancies between the declared and actual territory of activity of the user or business partner;
identifying false, inaccurate or misleading information about the location of the user, business or territory where services are provided;
checking compliance of the declared territory of activity with the requirements of applicable legislation, licensing and other regulatory requirements;
checking the compliance of the declared service area with actual data;
fraud prevention;
preventing misleading information;
protection of platform users;
compliance with legal requirements;
compliance with sanctions, export and other applicable regulatory restrictions;
ensuring account security;
improving the quality of platform services;
analytics and development of new functions.

The user can limit the provision of certain types of geolocation data through the settings of his device, browser, application or operating system, if such a possibility is provided by the appropriate technical means.

Restricting access to geolocation data may affect the availability of certain platform features, including displaying local offers, business profile verification, partner recommendations, and other location-based features.

9. TECHNICAL AND DEVICE DATA

When using the KYLYVNYK CLUB platform, the platform can automatically collect technical information about the user, his device and interaction with platform services.

Such information may include:

IP address;
device type;
device model;
device identifiers;
cookie identifiers;
advertising identifiers;
session identifiers;
operating system;
operating system version;
browser;
browser language;
device settings;
time zone;
Internet provider;
network type;
information about failures and errors;
activity logs;
dates and times of visiting the platform;
pages and sections of the platform;
duration of visit;
user actions on the platform;
sources of transition to the platform;
platform usage analytics data;
other technical data necessary for the operation, security and development of the platform.

Such data may be used to operate the platform, analyze performance, diagnose technical problems, prevent fraud, improve security, improve user experience and develop platform services.

10. COOKIES AND SIMILAR TECHNOLOGIES

KYLYVNYK CLUB may use cookies, pixels, tags, SDKs, local browser storage and other similar technologies.

Such technologies can be used for:

ensuring the functioning of the platform;
user authorization;
saving settings;
ensuring security;
fraud prevention;
analysis of platform usage;
statistics and analytics;
content personalization;
marketing and advertising;
measuring the effectiveness of advertising campaigns;
improving platform services.

The user can manage the use of cookies through the browser or device settings.

The user can also change cookie settings at any time through the platform's cookie management tools, if such tools are provided by the platform.

Additional information about the use of cookies may be contained in the separate Cookie Policy of the platform.

11. PURPOSE OF DATA PROCESSING

KYLYVNYK CLUB may use users' personal data for the following purposes:

registration and maintenance of accounts;
provision of digital club cards;
providing access to platform functions;
subscription management;
payment processing;
provision of Business Introductions;
business profile management;
display of partners and special conditions;
checking the identity of users;
business verification;
compliance with licensing requirements;
fraud prevention;
ensuring platform security;
compliance with legislation;
fulfillment of contractual obligations;
consideration of user requests;
conducting internal audits;
conducting internal investigations;
analytics;
statistics;
improving the quality of services;
development of new functions;
marketing and information mailings;
protection of the legitimate interests of the platform;
dispute resolution;
protection of the rights and legitimate interests of the platform in judicial, administrative, arbitration and other procedures.

12. LEGAL BASIS FOR DATA PROCESSING

Depending on the circumstances, KYLYVNYK CLUB may process personal data on the following grounds:

user consent;
execution of the contract or terms of use of the platform;
fulfillment of legal duties;
establishing, exercising or defending legal claims;
protection of the legitimate interests of the platform;
fraud prevention;
ensuring security;
compliance with the requirements of government bodies;
other grounds permitted by applicable law.

If data processing requires separate consent from the user in accordance with applicable law, such consent may be obtained separately by the platform.

13. VERIFICATION OF USERS AND BUSINESS PARTNERS

KYLYVNYK CLUB has the right to carry out inspections of users and business partners for the purposes of:

identity confirmation;
checking the right to conduct business;
checking licenses and permits;
checking the right to represent a business, organization or entrepreneur;
fraud prevention;
compliance with laws;
protection of platform users;
ensuring platform security.

For such purposes, the platform may use documents provided by users, official registers, public sources of information, government databases, open Internet resources and other legitimate sources of information.

The Platform has the right to use automated and non-automated methods for verifying information.

The user’s refusal to provide the requested information may lead to the restriction of certain functions of the platform, refusal to publish a business profile, restriction of access to certain services, or termination of access to certain functions of the platform.

14. TRANSFER OF DATA TO THIRD PARTIES

KYLYVNYK CLUB may transfer data to third parties in cases provided for by this Privacy Policy or applicable law.

Such third parties may include:

payment providers;
hosting providers;
cloud services;
analytics services;
email services;
security services;
identity verification services (KYC);
business verification services;
fraud prevention services;
software suppliers;
legal consultants;
accountants;
auditors;
government bodies;
law enforcement agencies;
regulators;
other service providers necessary for the operation of the platform.

The transfer of data is carried out only to the extent reasonably necessary to achieve the relevant purposes.

15. INTERNATIONAL DATA TRANSFERS

KYLYVNYK CLUB is an international platform.

Personal data may be processed, stored and transferred between the United States of America and other countries in the world in which users, partners, contractors, service providers or the technical infrastructure of the platform are located.

By using the platform, the user understands and agrees that his data may be transferred to countries whose laws may differ from the laws of the user's country of residence.

In some cases, the level of personal data protection in such countries may differ from the level of data protection provided for by the laws of the user’s country of residence.

KYLYVNYK CLUB takes reasonable organizational, technical and administrative measures to protect data during international transfers and strives to use data protection mechanisms provided for by applicable law.

16. DATA STORAGE TERMS

KYLYVNYK CLUB stores personal data of users for the period necessary to achieve the purposes specified in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

The retention period may depend on the nature of the data, user category, account status, subscription availability, business profile, legal obligations of the platform and other circumstances.

Once the purposes of processing have been achieved, personal data may be deleted, anonymized or archived in accordance with applicable law and the internal procedures of the platform.

KYLYVNYK CLUB has the right to save individual data after deleting a user account in cases where such storage is necessary for:

compliance with laws;
fulfillment of legal obligations;
dispute resolution;
fraud prevention;
ensuring platform security;
protection of the rights and legitimate interests of the platform;
maintaining accounting, tax or corporate records.

17. USER RIGHTS

Depending on the user's country of residence and applicable law, the user may have certain rights in relation to their personal data.

Such rights may include:

right to access data;
the right to receive information about data processing;
the right to correct inaccurate data;
right to erasure of data;
the right to restrict data processing;
the right to object to data processing;
right to data portability;
the right to withdraw previously provided consent;
the right to lodge a complaint with the competent data protection authority.

These rights may be limited in cases provided for by applicable law.

To exercise their rights, the user can contact the following address:

kylyvnykclub@gmail.com

Before executing a request, the platform may take reasonable steps to verify the identity of the applicant.

18. CALIFORNIA RIGHTS (CCPA/CPRA)

If you are a resident of California, United States of America, you may have additional rights with respect to your personal data under the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA) and other applicable laws.

To the extent provided by law, the user may have the right to:

know what categories of personal data are collected;
know the purposes of using personal data;
receive information about sources of data;
obtain information about the categories of third parties to whom data may be disclosed;
request access to your personal data;
request correction of inaccurate personal data;
request deletion of personal data;
limit the use of certain categories of personal data in cases provided for by law;
not be discriminated against for exercising your privacy rights.

Requests may be sent to:

kylyvnykclub@gmail.com

Before executing a request, KYLYVNYK CLUB has the right to take reasonable measures to confirm the identity of the applicant.

Some requests may be denied in whole or in part if data retention is required by law, is necessary to prevent fraud, to ensure security, to protect the rights of the platform, or is otherwise permitted by applicable law.

19. DATA SECURITY

KYLYVNYK CLUB takes reasonable organizational, technical and administrative measures to protect users' personal data from unauthorized access, use, disclosure, modification or destruction.

Such measures may include:

restriction of access to data;
control of access of employees and contractors to data;
use of secure connections;
use of authentication means;
security monitoring;
backup;
internal security procedures;
other reasonable protective measures.

Despite the measures taken, no system for storing or transmitting data over the Internet can guarantee absolute security.

The use of the platform is carried out by the user with an understanding of these risks.

20. CHILDREN AND AGE RESTRICTIONS

The Platform is intended exclusively for persons who have reached the age of 18 years or the age of majority established by the legislation of the relevant country.

KYLYVNYK CLUB does not intentionally collect personal data from children.

If the platform becomes aware of the collection of data from a person under the appropriate age, the platform has the right to take measures to delete such data and limit access to the platform.

Parents or legal representatives can contact kylyvnykclub@gmail.com in case of questions related to the processing of data of minors.

21. CHANGES TO THE PRIVACY POLICY

KYLYVNYK CLUB has the right to change this Privacy Policy from time to time.

The updated version is published on the platform indicating the new effective date or the date of the last update.

Continued use of the platform after the changes come into force may be considered as the user’s consent to the updated version of the Policy to the extent permitted by applicable law.

If the user does not agree with the changes, he must stop using the platform.

22. CONTACT INFORMATION AND LANGUAGE OF THE DOCUMENT

For questions related to this Privacy Policy, the user can contact:

Kylyvnyk Consulting LLC

6 Pauline Pl

Palm Coast, FL 32164-7535

United States

Email:

kylyvnykclub@gmail.com

This Privacy Policy may be translated into other languages solely for the convenience of users.

In case of discrepancies between translations, the official English version of the document shall prevail.