1. General Provisions
2. This personal data processing policy is drafted in accordance with the Law of Ukraine dated 13.02.2022 No. 2297-VI “On Personal Data Protection” and defines the procedure for processing personal data and measures to ensure its security.

1.1. The Operator considers the protection of human and civil rights and freedoms—particularly the right to privacy and personal and family confidentiality—as a top priority in its activities.
1.2. This policy (hereinafter the “Policy”) applies to all information that the Operator may receive about visitors to the website https://urbanpearl.net.

1. Key Terms Used in This Policy

2.1. Automated processing of personal data — processing using computer technology.
2.2. Blocking of personal data — temporary suspension of personal data processing (except when clarification is needed).
2.3. Website — a combination of graphic and informational content, software, and databases accessible via the internet at https://urbanpearl.net.
2.4. Personal data information system — databases containing personal data, processed using IT and technical means.
2.5. Anonymization of personal data — actions that make identifying a user impossible without additional information.
2.6. Personal data processing — any operation involving personal data (with or without automation), including collection, recording, organization, storage, updating, retrieval, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction.
2.7. Operator — a legal entity, public body, or individual who processes personal data and determines the purpose and methods of processing.
2.8. Personal data — any information that directly or indirectly relates to a specific or identifiable User of https://urbanpearl.net.
2.9. User — any visitor to the website https://urbanpearl.net.
2.10. Provision of personal data — actions that disclose personal data to a specific individual or group.
2.11. Distribution of personal data — actions aimed at making personal data publicly available or accessible to an unlimited number of people.
2.12. Cross-border transfer of personal data — transfer of personal data to a foreign country, authority, individual, or organization.
2.13. Destruction of personal data — irreversible actions resulting in the permanent deletion of personal data.

1. Types of Personal Data Processed by the Operator

3.1. Full name (first, middle, last)
3.2. Phone number
3.3. Email address
3.4. The website also collects and processes anonymized data (including cookies) through analytics services (e.g., Google Analytics, Yandex.Metrica).
3.5. All of the above is considered “Personal Data” under this Policy.

1. Purpose of Personal Data Processing

4.1. The User’s personal data is processed to conclude, fulfill, and terminate civil law contracts; provide access to services, information, or content on https://urbanpearl.net; and clarify order details.
4.2. Urban Pearl may also use the data to inform Users about new services, special offers, and events. Users can unsubscribe by sending an email to privacy@urbanpearl.net with the subject “Unsubscribe from updates and special offers.”
4.3. Anonymized data from analytics tools is used to analyze website usage and improve content.

1. Legal Grounds for Personal Data Processing

5.1. Urban Pearl processes personal data only when voluntarily submitted through forms on https://urbanpearl.net. Submission implies acceptance of this Policy.
5.2. Urban Pearl processes anonymized data when allowed by browser settings (e.g., cookies enabled).

1. Procedure for Collecting, Storing, Transferring, and Processing Personal Data

Data protection is ensured through legal, organizational, and technical measures in compliance with relevant data protection laws.
6.1. Urban Pearl ensures personal data security and takes reasonable steps to prevent unauthorized access.
6.2. Personal data will not be shared with third parties unless required by law.
6.3. Users may update their data by emailing privacy@urbanpearl.net with the subject “Update of Personal Data.”
6.4. Data will be stored for an indefinite period. Users may withdraw consent at any time by contacting privacy@urbanpearl.net with the subject “Withdrawal of Consent to Personal Data Processing.”

1. Cross-Border Transfer of Personal Data

7.1. Before transferring data abroad, Urban Pearl ensures that the recipient country offers adequate personal data protection.
7.2. If no such protection exists, transfer is only allowed with written User consent or if needed for contractual purposes.

1. Final Provisions

8.1. For any questions regarding personal data, Users may contact privacy@urbanpearl.net.
8.2. Changes to this Policy will be reflected in this document. The Policy is valid indefinitely until replaced.
8.3. The latest version of this Policy is always available at https://urbanpearl.net/privacy.