Privacy policy
Last updated: July 14, 2026
Privacy Policy
This Privacy Policy (hereinafter – the “Policy”) provides you with information on how UGEARS USA, CORP. and LIMITED LIABILITY COMPANY “UKRAINIAN GEARS” (hereinafter - “we”, “us” and “our”) process (collect, store, use, share, transfer disclose by transmission, disseminate or otherwise make available, align or combine, restrict, erase or destruct etc.) personal data (personal information) collected via ugearsflowers.com (hereinafter - the “Webpage”).
This Policy applies only to the processing of personal data collected/received by us. If you provide your personal data to a third party, the processing of your personal data will be subject to the policies and business practices of the respective third party. Joint data controllers are not responsible for such third party’s compliance with the legislation regulating processing of personal data.
Personal data processed, purposes and legal basis for processing
We will process the following types of your personal data: your e-mail addresses.
This data is processed for the following purposes:
a) to enable your participation in the Secret Super Early Bird;
b) to provide you with digital access and materials about the 2026 UGEARS Kickstarter project;
c) to enable the discount on your 2026 UGEARS Kickstarter pledge/reward and the bonus;
d) to contact you and to communicate with you concerning/related to your participation in the in the Secret Super Early Bird, the 2026 UGEARS Kickstarter project or your digital access/digital materials/pledge/reward/bonus;
e) to include/add you to VIP-group on Facebook;
f) to send you your 2026 UGEARS Kickstarter pledge/reward and the bonus;
g) to receive non-refundable participation fee for your participation in the Secret Super Early Bird and enabling the discount on your 2026 UGEARS Kickstarter pledge/reward and the bonus.
We process your personal data based on your consent.
We do not collect special categories of personal data envisaged by Article 9 of the General Data Protection Regulation (hereinafter – the “GDPR”).
Since the Webpage uses Shopify services, your personal data is also processed by the Shopify which is processing your personal data on our behalf (please check the Shopify’s policy for detailed information on such processing, https://www.shopify.com/legal/privacy and https://www.shopify.com/legal/dpa).
How personal data is collected and used
You provide your personal data when you enter your email on the Webpage and subscribe and/or pay and/or consent to one or more purposes for processing from the “Personal data processed, purposes and legal basis for processing” section.
We do not use automated decision-making systems including profiling while processing your personal data. Please take into account that Shopify may use automated decision-making techniques in the course of their processing of your personal data (please check “Our use of Machine Learning” section at https://www.shopify.com/legal/privacy).
You may send a notice/request at any time that you object to the processing of your personal data or that you no longer wish joint data controllers to continue processing your personal or that you wish to withdraw your consent to the processing of your personal data or that you wish to restrict the processing of your personal data (to opt out from certain use of your personal data) by contacting us at privacy@ugearsmodels.com. Please be aware that we may request additional information necessary to identify you and satisfy your notice/request.
Sharing personal data with third parties
Your personal data may be shared with social networks and/or third parties services providers we engaged to assist us with the activity specified in clauses “a” - “g” of “Personal data processed, purposes and legal basis for processing” section of this Policy. This may involve sharing personal data with or importing personal data to systems of such service providers and subsequent sharing of personal data with companies that help third parties service providers to promote, provide, or support the corresponding service.
It is recommended to read the privacy policies of payment systems: https://stripe.com/privacy and https://www.paypal.com/legalhub/privacy-full.
The sharing may result in transferring your personal data out of the EEA. Any transfer of personal data subject to GDPR out of the EEA shall take place if the EU Commission has decided that the corresponding country ensures an adequate level of protection of personal data or if such transfer is subject to appropriate safeguards for the protection of personal data provided by, for instance, the standard data protection clauses adopted by the EU Commission or binding corporate rules. You may contact us to obtain a copy of such safeguards.
To who and when access to your personal data is provided
Access to your personal data (disclosure by transmission, dissemination or otherwise making your personal data available) may be provided to regulatory, law enforcement and/or other agencies:
- on the basis of a request provided that there are sufficient grounds to believe that it is necessary according to the applicable law;
- if there is a reason to believe that providing access to your personal data is necessary to track, prevent, or investigate fraud, unauthorized use of the account or payment credentials, other harmful or illegal acts;
- if granting access to your personal data is necessary for the protection of joint data controllers’ rights and/or compliance with our obligation arising out of an investigation or trial.
Storage period
The personal data storage period is determined based on the applicable regulations (for example, those governing the storage period for tax and/or accounting purposes or establishing limitation periods).
At the end of the respective period, the relevant data will be systematically deleted, provided it is no longer required for the fulfillment of contractual obligations, protection of legal interests, compliance with the request lodged by a supervisory or law enforcement agency or an obligation arising in connection with the investigation or trial.
Security
The employees engaged in processing of your personal data are obliged to adhere to the security principles and current provisions on personal data protection.
Reasonable and appropriate measures are taken to protect your personal data, including against the risks of unintentional or unlawful destruction, manipulation, damage, alteration, or unauthorized disclosure or access.
Your rights
You have the following rights:
- the right to obtain confirmation as to whether or not your personal data are being processed, and, where that is the case, to access to such personal data and information;
- the right to obtain the rectification (correction) of your inaccurate personal data including the right to have your incomplete personal data completed;
- the right to obtain the erasure of your personal data;
- the right to obtain restriction of processing (the right to opt out from certain use of your personal data, including but not limited to from direct marketing/personalized advertising);
- the right to request information on the recipients of your personal data;
- the right to receive your personal data that you have provided, in a structured, commonly used and machine-readable format and the right to transmit such data to another controller (data portability);
- the right to object at any time to processing of your personal data;
- the right not to be a subject to a decision based solely on automated processing, including profiling;
- the right to withdraw consent to the processing of your personal data at any time, without affecting the lawfulness of processing based on consent before the withdrawal;
- the right to lodge a complaint with the competent supervisory authority or court;
- other rights provided by applicable laws.
If you have any questions about your rights or would like to exercise your rights, you may send a message to: privacy@ugearsmodels.com. Please be aware of our necessity to perform unambiguous identification of your person.
Age restrictions
We do not knowingly process personal data of children.
By using the Webpage, you confirm that you have reached the majority age in accordance with the laws applicable in your place of residence.
Please contact us at privacy@ugearsmodels.com if you have provided us with any personal data about children so we will be able to erase the data. Please be aware that we may request additional information necessary to identify your information and satisfy your request.
Confidentiality notice
By using the Webpage and/or consenting to the processing of your personal data, you confirm that your personal data is not classified as confidential.
Date of entry into force and change to this Policy
This Policy becomes effective upon posting at the URL accessible via Webpage.
Joint data controllers reserve the right to change this Policy at any time. Changes to the Policy take effect immediately after their posting new policy as specified herein and apply to those who have consented to the processing of personal data after such changes have been posted as specified herein.
To avoid misunderstandings, please revise this Policy each time you use the Webpage.
Contact details:
Joint data controllers:
UGEARS USA, CORP.
USA, 33702, FL, St. Petersburg, 7901 4th St N STE 5981
(role, responsibility and liability of this joint controller for compliance with obligations under GDPR, in particular as regards the exercising of your rights and duties to provide information envisaged by the GDPR: please consult clauses “a”-“g” of “Personal data processed, purposes and legal basis for processing” section of this Policy)
LLC “UKRAINIAN GEARS”
Ukraine, 08105, Kyiv region, Buchansky district, Horenka village, Pryozerna street, building 9
(role, responsibility and liability of this joint controller for compliance with obligations under GDPR, in particular as regards the exercising of your rights and duties to provide information envisaged by the GDPR: please consult clauses “a”-“f” of “Personal data processed, purposes and legal basis for processing” section of this Policy)
Joint controllers agreed to work in close cooperation to secure the most efficient exercise of your rights.
