Privacy Policy

Website: lnz.com.ua
Legal entity: LNZ GROUP
Effective date: April 10, 2026
Last updated: April 10, 2026

GDPRCCPAUkraine LawMicrosoft ClarityGoogle AnalyticsMeta Pixel

1. Who We Are

LNZ GROUP is a Ukrainian agroholding company operating in the agricultural sector, including seed production, crop growing, and related agri-business services. Our corporate website is located at https://lnz.com.ua (the "Website" or "Site").

We are committed to protecting the privacy and security of the personal data of our website visitors, partners, clients, and users. This Privacy Policy describes our practices in accordance with the applicable data protection laws of Ukraine, the European Union, and the United States of America.

2. Data Controller & Responsible Person

The Data Controller determines the purposes and means of processing personal data collected through this Website. For questions relating to the use of your data, tracking technologies, or exercising your rights, please contact the responsible person listed above.

3. What Data We Collect

3.1 Data You Provide Directly

• Name, surname
• Email address
• Phone number
• Company name and position
• Message content (contact forms, inquiries)
• Any other information you voluntarily submit

3.2 Data Collected Automatically

• IP address (anonymized where possible)
• Browser type, version, and language
• Operating system and device type
• Pages visited, time on page, scroll depth
• Referring URL and exit page
• Date, time, and duration of visit
• Clickstream data (which links and elements you click)
• Session recordings and heatmaps (via Microsoft Clarity)
• Cookie identifiers and tracking pixels
• Geographic location (country/city level, derived from IP)

3.3 Data from Third Parties

• Aggregated audience data from Google and Meta advertising platforms
• Social media interaction data (likes, shares of our content)
• Data from business partners with your consent

4. How We Use Your Data

5. Legal Basis for Processing (GDPR)

For visitors from the European Union and European Economic Area (EEA), we process personal data on the following legal bases under Article 6 of the GDPR (Regulation (EU) 2016/679):

• Article 6(1)(a) — Consent: For marketing communications, advertising cookies, behavioral tracking (Clarity, Meta Pixel, Google Ads remarketing). You may withdraw consent at any time.
• Article 6(1)(b) — Contract: When processing is necessary to respond to your inquiry or perform a contractual obligation.
• Article 6(1)(c) — Legal obligation: When we are required by applicable law to process your data.
• Article 6(1)(f) — Legitimate interests: For website security, fraud prevention, basic analytics, and improving user experience, provided our interests do not override your fundamental rights and freedoms.

For special categories of personal data (sensitive data as defined in Article 9 GDPR), we rely on explicit consent under Article 9(2)(a) GDPR, or other applicable exceptions.

6. Cookies & Tracking Technologies

We improve our products and advertising by using tracking technologies to see how you use our website. By using our site, you agree that we and our technology partners can collect and use this data. More details are provided in the sections below.

6.1 What Are Cookies

Cookies are small text files placed on your device by websites you visit. They are widely used to make websites work efficiently, provide analytics, enable personalization, and deliver relevant advertising.

6.2 Types of Cookies We Use

6.3 Managing Cookies

You can manage, disable, or delete cookies through your browser settings. Note that disabling certain cookies may affect the functionality of this website. You can also opt out of behavioral advertising through:

• Digital Advertising Alliance (DAA) Opt-Out
• Your Online Choices (EU)
• Network Advertising Initiative (NAI) Opt-Out

7. Microsoft Clarity

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products and services.

Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising.

What Clarity captures:

• Mouse movements and clicks
• Scroll behavior and depth
• Session recordings (anonymized video replay of your visit)
• Heatmap data (aggregate view of where users click and scroll)
• Device type, browser, and operating system
• Geographic location (country/city level)

Site Disclosure: We improve our products and advertising by using Microsoft Clarity to see how you use our website. By using our site, you agree that we and Microsoft can collect and use this data. Our privacy policy (this document) has more details.

For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

To opt out of Microsoft Clarity data collection, visit: clarity.microsoft.com/opt-out

8. Google Analytics & Google Ads

8.1 Google Analytics 4 (GA4)

We use Google Analytics 4, a web analytics service provided by Google LLC ("Google"), 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.

Google Analytics uses cookies and similar technologies to collect and analyze information about your use of this website. This information includes:

• Pages viewed and user interactions
• Session duration and bounce rate
• Traffic source and medium
• Demographic and interest data (aggregated)
• Conversion events

We have enabled IP anonymization (IP masking) in Google Analytics, so your full IP address is never stored. Data is processed in accordance with Google's data processing agreement.

We use Google Analytics with the following settings compliant with GDPR:

• Data retention: 14 months (configurable)
• Google Signals: enabled (aggregate reporting only)
• User-ID: not used without explicit consent

Opt-out: You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.

For more information, see Google's Privacy Policy and Google Analytics data safeguarding.

8.2 Google Ads & Remarketing

We use Google Ads conversion tracking and remarketing features. These technologies allow us to:

• Measure the effectiveness of our advertising campaigns
• Show relevant ads to users who have previously visited our website
• Create and target custom audiences

Google Ads uses cookies such as _gcl_au to track conversions and enable remarketing. This data is governed by Google's advertising policies, including the Google Advertising Policies and the EU User Consent Policy.

Opt-out: Manage personalized Google ads at Google Ad Settings.

8.3 Google Consent Mode

Our website implements Google Consent Mode v2 to ensure that Google tags respect user consent choices. When consent is not granted, Google will only use cookieless pings and will not use personal data for advertising purposes.

9. Meta Pixel (Facebook & Instagram)

We use the Meta Pixel (formerly Facebook Pixel), a tracking technology provided by Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA, and its EU subsidiary Meta Platforms Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland.

The Meta Pixel allows us to:

• Measure the effectiveness of Facebook and Instagram advertising campaigns
• Build custom audiences for advertising (including Lookalike Audiences)
• Run retargeting campaigns to users who visited our website
• Track conversion events (form submissions, page views, etc.)

When the Meta Pixel is active, Meta may collect and process:

• Browser type, operating system, and device identifiers
• IP address
• Cookie data (including _fbp and _fbc)
• URL of the page you are visiting
• Events you trigger on our website

We have implemented the Meta Pixel in compliance with Meta's Privacy Policy and Cookie Policy. We have entered into a Data Processing Agreement with Meta as required under GDPR.

If you have a Facebook or Instagram account, Meta may link the data collected through our pixel to your profile. Meta acts as an independent data controller for data processed through its own platforms.

Legal basis: Consent (Article 6(1)(a) GDPR) for EU users; Legitimate interest for other jurisdictions where applicable.

Opt-out: Manage your Facebook ad preferences at Facebook Ad Preferences. You can also opt out via the Your Online Choices platform.

10. Third-Party Services

All third-party service providers are contractually required to process your data only in accordance with our instructions and applicable law, and to implement appropriate technical and organizational security measures.

11. Data Sharing & Disclosure

We do not sell, rent, or trade your personal data to third parties for their independent marketing purposes. We may share your data in the following circumstances:

• Service providers: Technology partners and vendors who process data on our behalf (listed in Section 10) under strict data processing agreements.
• Legal compliance: When required by applicable law, court order, or governmental authority in Ukraine, the EU, or other jurisdictions.
• Business transfers: In the event of a merger, acquisition, or sale of assets, personal data may be transferred as part of that transaction, subject to equivalent privacy protections.
• Protection of rights: When necessary to detect, prevent, or address fraud, security vulnerabilities, or protect the rights and safety of LNZ GROUP, our users, or the public.
• With your consent: For any other purpose with your explicit consent.

12. International Data Transfers

Our service providers (Google, Microsoft, Meta) are based in the United States. As a result, your data may be transferred to, and processed in, the United States and other countries outside the European Economic Area (EEA) and Ukraine that may have different data protection standards.

For transfers from the EU/EEA, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses (SCCs) approved by the European Commission (Decision 2021/914)
• EU-U.S. Data Privacy Framework (where applicable for U.S. recipients)
• Adequacy decisions by the European Commission (where applicable)

For transfers from Ukraine, we comply with the requirements of the Law of Ukraine "On Personal Data Protection" (No. 2297-VI, as amended) regarding cross-border data transfers, including ensuring that the receiving country provides an adequate level of data protection.

13. Data Retention

We review and securely delete personal data that is no longer necessary for the purposes for which it was collected, unless we are required to retain it by law.

14. Your Rights — EU / EEA Users (GDPR)

If you are located in the European Union or European Economic Area, under the General Data Protection Regulation (GDPR — Regulation (EU) 2016/679), you have the following rights:

• Right of Access (Art. 15): Request a copy of the personal data we hold about you.
• Right to Rectification (Art. 16): Request correction of inaccurate or incomplete personal data.
• Right to Erasure / "Right to be Forgotten" (Art. 17): Request deletion of your personal data where processing is no longer necessary or lawful.
• Right to Restriction of Processing (Art. 18): Request that we restrict how we use your data in certain circumstances.
• Right to Data Portability (Art. 20): Receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object (Art. 21): Object to processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent (Art. 7(3)): Withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.
• Right not to be subject to automated decision-making (Art. 22): Not to be subject to solely automated decisions, including profiling, that significantly affect you.
• Right to lodge a complaint: You have the right to lodge a complaint with your national supervisory authority. For EU residents, you may contact the supervisory authority in your Member State. The European Data Protection Board maintains a list at edpb.europa.eu.

To exercise any of these rights, please contact us at privacy@lnz.com.ua. We will respond within 30 days (extendable by 60 additional days for complex requests) as required by GDPR Article 12.

15. Your Rights — California Users (CCPA / CPRA)

If you are a resident of California, USA, you have rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

• Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the third parties with whom we share it.
• Right to Delete: Request deletion of your personal information, subject to certain exceptions.
• Right to Correct: Request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing: We do not sell personal information. However, we share certain data with advertising partners (Google, Meta) which may be considered "sharing" under CCPA. You may opt out by contacting us or using the opt-out tools provided in Section 6.3.
• Right to Limit Use of Sensitive Personal Information: We do not intentionally collect sensitive personal information as defined under CPRA.
• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

California Privacy Notice: In the preceding 12 months, LNZ GROUP has collected the following categories of personal information: identifiers (name, email, IP address), internet or other electronic network activity information (browsing history, click data), and geolocation data (country/city level). This information was collected for the business purposes described in Section 4 of this policy.

To submit a verifiable consumer request under CCPA, contact us at privacy@lnz.com.ua. We will respond within 45 days as required by CCPA.

16. Your Rights — Ukrainian Users

For users located in Ukraine, the processing of your personal data is governed by the Law of Ukraine "On Personal Data Protection" (Закон України «Про захист персональних даних», No. 2297-VI of June 1, 2010, as amended).

Under Ukrainian law, you have the right to:

• Know about the sources of collection, the location of your personal data, the purpose of processing, and the location of the data controller;
• Access your personal data held by us;
• Receive information about the conditions of providing access to your personal data, including to third parties;
• Object to the processing of your personal data;
• Demand rectification, destruction, or blocking of incomplete, inaccurate, or outdated personal data;
• Demand deletion of your personal data if it is processed unlawfully;
• Withdraw consent to the processing of personal data at any time;
• Lodge a complaint with the Commissioner of the Verkhovna Rada of Ukraine for Human Rights (Уповноважений Верховної Ради України з прав людини) — the supervisory authority for personal data protection in Ukraine, at ombudsman.gov.ua.

We process personal data in compliance with the principles of legality, fairness, proportionality, and purpose limitation as required under Article 6 of the Law of Ukraine "On Personal Data Protection."

The personal data database of LNZ GROUP is registered in accordance with applicable Ukrainian law requirements.

17. Children's Privacy

Our website is not directed to children under the age of 16 years (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal data from children. If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately at privacy@lnz.com.ua, and we will take steps to delete such information.

This is consistent with:

• Article 8 GDPR (age of consent for information society services — 16 years, or lower if Member State law provides otherwise, but not below 13)
• Children's Online Privacy Protection Act (COPPA) — 13 years minimum in the USA
• Ukrainian Law on Personal Data Protection

18. Data Security

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, destruction, or loss. These measures include:

• HTTPS / SSL/TLS encryption for all data transmissions
• Access controls and authentication measures limiting access to personal data to authorized personnel only
• Regular security assessments and updates
• Secure server infrastructure
• Vendor due diligence ensuring third-party processors maintain adequate security
• Staff training on data protection best practices

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours as required by GDPR Article 33, and will notify affected individuals without undue delay where required by Article 34.

Despite our best efforts, no method of transmission over the Internet or electronic storage is 100% secure. If you have concerns about the security of your personal data, please contact us.

19. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will indicate the date of the most recent update at the top of this page.

For material changes, we will provide more prominent notice, which may include:

• A notice on our website homepage
• An email notification (if we have your email address)
• A pop-up or banner on the website

Your continued use of our website after any changes to this Privacy Policy constitutes your acceptance of the updated policy. We encourage you to review this policy periodically.

Version history:

20. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:

We are committed to working with you to achieve a fair resolution of any privacy concerns. If you are not satisfied with our response, you have the right to lodge a complaint with the relevant data protection supervisory authority in your jurisdiction (see Sections 14, 15, and 16).

Disclaimer: This Privacy Policy was prepared for informational purposes. LNZ GROUP recommends consulting with a qualified legal professional to ensure full compliance with all applicable local and international data protection regulations for your specific circumstances.

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