Legal
GDPR & Data Protection
Last revised 4 February 2026
Pure Spaces Kyiv LLC provides commercial cleaning services in Ukraine and serves clients whose staff, partners or contacts may be located in the European Union. Where we process personal data of individuals in the EU or EEA, we do so in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"). This page sets out our approach to GDPR compliance, identifies the lawful bases on which we rely, and explains how you can exercise your rights as a data subject.
For information about our overall data practices, including what data we collect and how long we retain it, please also read our Privacy Policy.
1. Data Controller
The data controller responsible for your personal data is:
- Company: Pure Spaces Kyiv LLC
- Address: 18 Velyka Zhytomyrska St, Kyiv 01025, Ukraine
- Data protection contact: privacy@purespaceskyiv.com
We do not currently have a designated Data Protection Officer (DPO) as we are not required to appoint one under applicable law. All data protection matters are handled by senior management and our data protection contact above.
2. Lawful Bases for Processing
We rely on the following lawful bases under Article 6 of the GDPR when processing personal data:
- Consent (Art. 6(1)(a)): we process your data when you have given clear, freely given, specific, informed and unambiguous consent — for example, when you submit our contact form with the consent checkbox ticked, or when you accept analytics cookies via the cookie banner. Consent can be withdrawn at any time without detriment.
- Contract (Art. 6(1)(b)): processing is necessary to perform a contract for cleaning services to which you are a party, or to take pre-contractual steps at your request (for example, providing a service quote).
- Legitimate interests (Art. 6(1)(f)): we process certain data — such as technical logs — based on our legitimate interest in operating, maintaining and improving our website and business, provided those interests are not overridden by your fundamental rights. You have the right to object to such processing (see below).
- Legal obligation (Art. 6(1)(c)): where we must process or retain data to comply with a legal obligation under Ukrainian or EU law, such as invoicing requirements or responses to lawful authority requests.
3. Your Rights as a Data Subject
Under the GDPR, if we process your personal data you have the following rights, which you can exercise free of charge:
- Right of access (Art. 15): you may request confirmation of whether we process personal data about you and, if so, obtain a copy of that data together with information about how it is used, where it comes from and to whom it is disclosed.
- Right to rectification (Art. 16): if personal data we hold about you is inaccurate or incomplete, you have the right to request correction without undue delay.
- Right to erasure (Art. 17): you may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other lawful basis applies), where you object to processing and we have no overriding legitimate grounds, or where the data has been unlawfully processed. This right is subject to certain legal exceptions.
- Right to restriction of processing (Art. 18): you may ask us to restrict processing of your personal data in circumstances such as where you contest its accuracy (during the period of verification), where processing is unlawful but you prefer restriction to erasure, or where you have objected to processing pending our assessment.
- Right to data portability (Art. 20): where processing is based on consent or contract and is carried out by automated means, you have the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format, and to transmit it to another controller without hindrance from us.
- Right to object (Art. 21): you have the right to object at any time to processing of your personal data that is based on our legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or unless the processing is necessary for the establishment, exercise or defence of legal claims.
- Right to withdraw consent (Art. 7(3)): where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal. To withdraw consent for analytics cookies, decline or clear cookies in your browser; to withdraw consent for contact-form data processing, email us at privacy@purespaceskyiv.com.
- Rights related to automated decision-making (Art. 22): Pure Spaces Kyiv does not make decisions about you based solely on automated processing, including profiling. This right is therefore not currently applicable to our processing.
4. How to Exercise Your Rights
To exercise any of the rights listed above, please submit a written request to us by email at privacy@purespaceskyiv.com or by post to: Pure Spaces Kyiv LLC, 18 Velyka Zhytomyrska St, Kyiv 01025, Ukraine.
Please include your full name, contact details and sufficient information to identify the data concerned. We may need to verify your identity before we can act on your request. We will respond within one calendar month of receiving your request, as required by Article 12 of the GDPR. If your request is complex or we receive multiple requests, we may extend this period by a further two months and will inform you accordingly.
There is no charge for most requests. However, if requests are manifestly unfounded or excessive (particularly if they are repetitive), we may charge a reasonable administrative fee or refuse to act, in which case we will explain our reasoning.
5. International Transfers of Personal Data
Pure Spaces Kyiv is based in Ukraine, which is not a member of the EU or EEA. Where we transfer personal data from the EU/EEA to Ukraine, or onward to any other country, we ensure that appropriate safeguards are in place as required by Chapter V of the GDPR. Such safeguards may include standard contractual clauses approved by the European Commission, or reliance on an adequacy decision where one has been issued for the relevant country. Details of the safeguards applicable to any specific transfer are available on request.
6. Data Retention
We retain personal data only for as long as is necessary for the purposes described in our Privacy Policy or as required by applicable law. Contact enquiry data is generally retained for up to 24 months after last contact unless a longer period is required for legal or contractual reasons. After the relevant retention period expires, data is securely deleted or anonymised.
7. Lodging a Complaint with a Supervisory Authority
If you consider that our processing of your personal data infringes the GDPR, you have the right to lodge a complaint with a supervisory authority:
- If you are in an EU member state, you may complain to the data protection authority in your country of habitual residence, place of work or the location of the alleged infringement. A list of EU supervisory authorities is available at edpb.europa.eu.
- In Ukraine, data protection oversight is provided by the Ukrainian Parliament Commissioner for Human Rights (Ombudsperson), which handles complaints relating to violations of personal data protection legislation.
We encourage you to contact us first at privacy@purespaceskyiv.com so that we can attempt to resolve your concern directly before you escalate to a supervisory authority.
8. Changes to This Page
This GDPR & Data Protection page may be updated periodically to reflect changes in applicable law or our data practices. The "last updated" date at the top indicates when it was most recently revised.
9. Contact
For any data protection enquiry, please contact: privacy@purespaceskyiv.com