Who runs the service
The site crm.serjuga.com and the SC CRM service ("SC", "we").
Data controller: Фізична особа-підприємець Васильєв Сергій Володимирович (Unified State Register record No. 2010350000000980461 of 01.03.2026), Ukraine, Kyiv.
The full registered address is provided on request at the address below.
Requests about your data: privacy@serjuga.com
What this policy covers
The public site (its pages, the survey, the "Try SC" request) and the SC CRM service itself, where stores and their teams work. The data of a store's own customers follows separate rules — see "Organizations' data in SC CRM".
The "Try SC" request (/access)
If you sent a request we keep what you entered: the reason, your name, phone and/or email, the store name and comment, the page and language it was sent from, the address of the site you came from (no path) and the link's UTM tags (source, medium, campaign, content, term). We use this to handle the request and contact you about it. A notice of the new request is sent to our internal address.
Basis: the steps needed to answer your own request (under the GDPR, Article 6(1)(b)). This does not extend to mailings or advertising — those, should they ever appear, would need a separate basis and your separate decision.
The survey on the main page
Your answer (the text, if you wrote one) and the directions you chose; the page language, the address of the site you came from and the UTM tags. If you left a contact on the second step — an email and, optionally, a phone; a letter about the public launch only if you ticked that box separately. Answers without a contact stay in the statistics; for 30 days a pseudonymous technical address identifier is kept with the answer, then it is cleared.
Visit analytics
We count visits ourselves, on our own server, without cookies and without a visitor identifier: the event name (a page view, a button click, a form opened or sent), the page, the language, the source site's address, the device class (phone, tablet, desktop) and the UTM tags. The full page address and typed text are not stored. Such records are kept for up to 400 days. Basis: our legitimate interest in understanding how the site is used; you may object by writing to us. To protect the server from overload, a pseudonymous address identifier is held briefly in the server's memory while an event is received; it is not stored with the statistics records.
In the current configuration no third-party analytics or advertising technologies are used.
If the configuration changes, we will update this policy before connecting such a service and, where the law requires it, ask for your consent.
Cookies and browser storage
In the current configuration the public site sets no cookies. In your browser's storage (localStorage / sessionStorage) the site keeps only functional values:
sc-site-lang— the site language you chosesc-site-survey-receipt— a receipt that you voted in the survey (to show the results; not linked to your answer)sc-site-first-touch— the source site and the UTM tags of your first visit — for the visit, so a request knows where you came fromsc-site-entered— a mark that the site is already open in this tab — so an entry is not counted twicesc-analytics-optout— an opt-out mark from visit counting, if setsc-analytics-consent— your consent to third-party analytics — used only if we ever connect itsc-ga4-lead-at— a technical mark for third-party analytics — unused until it is connectedsc-crm-session— the SC CRM sign-in session (service users only)
These values stay in your browser and disappear when you clear the site's data (sessionStorage — when you close the tab).
Who is responsible for what
The public site, access requests, SC CRM user accounts, support, security and our own visit statistics: we decide the purposes of this processing and, within the applicable law, we are the controller of this data.
Data a client organization enters into SC CRM (orders, buyers' contacts, conversations, documents, files) or receives through the services it connected (Prom, Rozetka, Nova Poshta and others): the organization decides the purposes of its processing. Where we process such data on its instructions under the relevant agreement, the organization is the controller and we are the processor. We do not use this data for advertising, marketing or any other purpose of our own beyond operating the service.
Organizations' data in SC CRM
An organization's data is available to its users by the permissions the organization set. SC staff may access it to support and operate the service; such actions are recorded in a log.
If you are a customer of a store that uses SC CRM, a request about your data should go to that store: it makes the decisions, and we assist it within our contractual duties.
Files and attachments
Files organizations upload into SC CRM are stored on the same server as the database and are available to that organization's users by its permissions. The organization deletes them itself.
SC CRM users
To sign in, the service keeps an email, a name, a password hash (the password itself is not stored), sign-in sessions and a log of actions in the service — so the organization can see who changed what. This data is kept while the account exists.
Technical logs and security
The application does not store your raw IP address. To limit the number of requests and answers from one address, a pseudonymous technical identifier is derived; it is cleared after 30 days.
The server's technical log holds only the request method and path — no parameters and no IP address — and is kept for up to 30 days. The web server keeps no visit log.
Database backups are made to recover from a failure and are kept for a limited time on a rotation cycle. Data deleted from the service may remain in a backup until the end of that cycle.
Hosting and third-party services
The site and the data are hosted with the hosting provider Hetzner Online GmbH (Germany).
Letters (request notices, access letters, subscription mailings) are sent through the mail service Brevo, which processes recipients' addresses for that purpose. Letters you send to our address pass through the mail service in the same way, and we process them in order to reply.
The services an organization connects to SC CRM (marketplaces, carriers, messengers) process data under their own rules; the organization chooses them itself.
How long we keep it
The terms below are enforced automatically in the service's current configuration.
| Data | Purpose | Term or criterion |
|---|---|---|
| Access request | handle the request and contact you | 365 days after the last action on the request, then deleted |
| Contact left in the survey | send the results; a launch letter only if you ticked it | 365 days or until you unsubscribe |
| Survey answer without a contact | statistics | stays in the statistics; the technical address identifier is cleared after 30 days |
| Technical address identifier | limit on requests and answers | cleared after 30 days |
| Our own visit statistics records | understand how the site is used | up to 400 days |
| Server technical log | security and operations | up to 30 days |
| SC CRM user account | sign-in and the action log | while the account exists |
| An organization's data in SC CRM | the organization's work in the service | as set out in the agreement with the organization |
Your rights
For the data we are responsible for (the site, requests, accounts, our own statistics) you may ask for access to your data, its correction or deletion, and object to processing based on our legitimate interest. You can unsubscribe from letters by the link in every letter.
For data a client organization keeps in SC CRM, address your request to that organization: it decides, and we assist it within our contractual duties.
Send requests to . We reply within the time the applicable law provides.privacy@serjuga.com
You also have the right to complain to a supervisory authority: in Ukraine the Ukrainian Parliament Commissioner for Human Rights, in the EU your country's data protection authority.
Changes to this policy
A new edition is published on this page with a new version number and date; the version you read is stored with your request or contact.