Privacy Policy
Version dated 22 June 2026
1. Who Is the Personal Data Controller
1.1. The personal data controller is Sole Proprietor Oleksandr Pavlovych Sytnik, operating under the trade name Dbayemo.
Provider: Sole Proprietor Oleksandr Pavlovych Sytnik
Trade name: Dbayemo
EDRPOU / RNOKPP code: 3729302899
Registered address / location: Ukraine, Odesa oblast, Odesa, Heroiv Zmiinoho St.
IBAN: UA373348510000000026005362093
Bank: JSC PUMB
Email for customer enquiries: info@dbayemo.com.ua
Phone: +380 97 4275986
Website: https://dbayemo.com.ua
1.2. For matters concerning personal data, contact: info@dbayemo.com.ua.
2. What Data We Collect
the Customer's contact details: first name, last name, phone, email, messenger, country/city of residence;
order data: city, cemetery, sector, row, plot number, landmarks, work preferences, history of orders and payments;
data on the burial site: the full name of the buried person, years of life, photos/videos of the burial site, the condition of the monument, fence, and area;
payment data: amount, date, payment status, transaction identifier; we do not store full bank card details, they are processed by the payment system;
communications: messages, enquiries, claims, records of agreements within the scope of service;
technical website data: IP address, cookies, browser type, device, pages viewed, referral source.
2.2. Information about a deceased person is not in itself always personal data within the meaning of the legislation, but we process it confidentially, as it may relate to the private and family life of the Customer and their family.
3. Why We Use the Data
accepting, clarifying, and performing the order;
locating the burial site based on the provided landmarks;
preparing and sending the photo/video report;
accepting payment, refunds, accounting and tax records;
communicating with the Customer, support, handling enquiries and claims;
managing the subscription, reminders about scheduled visits and debits;
protecting the rights and interests of the parties, preventing fraud;
marketing communications only with consent or another lawful basis.
4. Legal Bases for Processing
4.1. We process personal data on the following bases: the consent of the personal data subject; the conclusion and performance of the agreement or actions preceding its conclusion; compliance with statutory requirements regarding accounting, tax, and payment records; protection of the legitimate interests of the Provider or third parties, where the rights of the data subject do not override such interests.
5. To Whom the Data May Be Disclosed
payment systems, banks, and other payment service providers;
contractors, employees, or partners who directly perform the order at the cemetery;
providers of hosting, CRM, email/SMS/messenger services, analytics, and technical support;
accountants, lawyers, auditors, consultants within the scope of their professional duties;
government authorities, courts, law enforcement agencies — only in cases provided by law.
5.2. Contractors are provided only with the minimum amount of information necessary to perform the specific order.
6. International Data Transfer
6.1. If the Customer communicates with us through international messengers, email services, or if we use technical services with infrastructure outside Ukraine, data may be transferred or stored outside Ukraine. We take reasonable measures to ensure the confidentiality and protection of such data.
7. Photo and Video Reports
7.1. Photos and videos of the burial site are created to confirm the performance of the Services and are sent to the Customer.
7.2. We do not publish photos/videos of the burial site, the full name of the buried person, or other family information in advertising, social media, portfolios, or public materials without the Customer's separate consent.
8. Retention Periods
8.1. Order data, payments, correspondence, and reporting materials are stored for the period necessary to perform the order, service the subscription, maintain accounting/tax records, settle disputes, and protect the rights of the parties.
8.2. Photo/video reports may be stored in the Customer's personal account or archive for the duration of the subscription and an additional period necessary for support, unless otherwise agreed by the parties.
9. Rights of the Personal Data Subject
9.1. The Customer has the right to know about the sources of collection and the location of their personal data, the purpose of its processing, to receive information about the conditions of access to personal data, to demand the clarification, blocking, or destruction of data in cases provided by law, to withdraw consent, to file objections to processing, and to apply to the Ukrainian Parliament Commissioner for Human Rights or a court.
9.2. To exercise your rights, contact info@dbayemo.com.ua. We may ask you to confirm the applicant's identity so as not to disclose data to an unauthorised person.
10. Cookies and Analytics
10.1. The website may use cookies and similar technologies for proper operation, analytics, saving settings, improving the service, and marketing, where permitted by law and the user's settings.
10.2. The user may restrict or delete cookies in their browser settings, but some website functions may not work correctly.
11. Data Protection
11.1. We apply organisational and technical measures to protect data from unlawful access, loss, alteration, disclosure, or destruction. Access to data is granted only to persons who need it to perform their official or contractual duties.
12. Changes to the Policy
12.1. We may update this Policy. The new version takes effect from the moment of publication on the website, unless otherwise stated in the Policy itself.
13. Contacts
Email: info@dbayemo.com.ua
Phone: +380 97 4275986