Version: 1.0
Effective date: 20.08.2026
Last updated: 20.08.2026
1. Who We Are
MAXPRIMACY LLC is a company established under the laws of Ukraine.
Legal name: LIMITED LIABILITY COMPANY “MAXPRIMACY” / ТОВАРИСТВО З ОБМЕЖЕНОЮ ВІДПОВІДАЛЬНІСТЮ «МАКСПРАЙМЕСІ»
Registration number: 46371303
Registered office: 08141, Ukraine, region Kyivska, district Buchanskyi, village Sviatopetrivske, street Hryhoriia Skovorody, build 5, fl 9
Website: https://maxprimacy.com/
Privacy contact: [privacy@maxprimacy.com]
For the personal data covered by this Privacy Notice, MAXPRIMACY generally acts as the data controller, meaning that we determine why and how personal data is processed.
Where MAXPRIMACY processes personal data solely on behalf of a client and according to that client’s instructions, MAXPRIMACY may instead act as a processor. Such processing is governed by the applicable client agreement and, where required, a Data Processing Addendum rather than solely by this Privacy Notice.
2. Scope of This Privacy Notice
This Privacy Notice explains how MAXPRIMACY collects, uses, stores, shares and protects personal data in connection with:
- our website;
- business inquiries and consultation requests;
- qualification of potential client engagements;
- business development and professional outreach;
- newsletters, research and MAXPRIMACY Insights;
- client and prospect relationships;
- meetings, events and professional communications;
- contracts, billing and administration;
- suppliers, contractors and business partners;
- other legitimate business activities in which MAXPRIMACY determines the purposes and means of processing personal data.
This Notice applies to personal data relating to individuals. Information relating solely to a legal entity is not personal data unless it identifies or relates to an identifiable individual.
3. Who This Notice Applies To
This Notice may apply to:
- visitors to our website;
- individuals who contact MAXPRIMACY;
- founders, directors, executives and employees of prospective clients;
- representatives and employees of existing clients;
- professional contacts and prospects;
- subscribers to our research, insights or communications;
- event participants;
- suppliers, contractors and professional advisers;
- representatives of our commercial partners;
- other individuals whose personal data we lawfully process in connection with our business.
4. Personal Data We May Collect
Depending on how you interact with MAXPRIMACY, we may process the following categories of personal data.
4.1 Identity and professional information
This may include:
- name and surname;
- job title;
- employer or organisation;
- professional role;
- department;
- professional profile information;
- country or general business location.
4.2 Contact information
This may include:
- business email address;
- business telephone number;
- professional social media profile;
- company address;
- preferred communication channel.
4.3 Business inquiry and qualification information
Where you contact us about a potential engagement, we may collect information such as:
- company website;
- business challenge;
- commercial objectives;
- current market situation;
- information about previous actions or approaches;
- expected outcomes;
- approximate project timing;
- readiness to implement changes;
- information submitted through qualification or consultation forms.
Please do not submit confidential, privileged, special-category personal data or commercially restricted information through a general website form unless we specifically request it through an appropriate secure process.
4.4 Communications
We may process:
- emails;
- messages;
- meeting notes;
- correspondence history;
- records of requests;
- documents or attachments you provide;
- information discussed during calls or meetings.
Where a meeting is recorded or transcribed, we will apply the transparency or consent requirements required by applicable law.
4.5 Contractual and administrative information
This may include:
- client representatives;
- authorised signatories;
- billing contacts;
- contractual correspondence;
- signatures and electronic signature audit information;
- invoice and payment administration information;
- records relating to delivery, acceptance and project administration.
We generally do not need to collect payment card information directly because payments are handled through banks or authorised payment providers.
4.6 Website and technical information
When you use our website, certain technical information may be processed automatically, including:
- IP address;
- browser and device information;
- operating system;
- requested pages;
- timestamps;
- referral information;
- security and server logs;
- cookie and similar technology identifiers, where applicable.
For information about cookies and similar technologies, please see our Cookie Policy.
4.7 Marketing and subscription information
Where you subscribe to MAXPRIMACY communications, we may process:
- name;
- email address;
- organisation;
- subscription source;
- communication preferences;
- consent records, where consent is the legal basis;
- unsubscribe or objection records;
- engagement information where permitted by applicable law.
4.8 Information obtained from other sources
We may obtain professional contact information from lawful sources including:
- corporate websites;
- professional networking platforms;
- public professional profiles;
- public business registers;
- professional directories;
- conferences, exhibitions and business events;
- referrals and introductions;
- commercial business-information providers, where their collection and use of data is lawful;
- existing business relationships;
- other publicly available professional sources.
Where required by applicable data protection law, we will tell you the source or category of source from which your personal data was obtained.
5. Special Categories of Personal Data
MAXPRIMACY does not generally require special-category or highly sensitive personal data in order to provide its services.
Please do not provide information concerning matters such as health, biometric data, political opinions, religious beliefs, trade union membership, sexual life or similar sensitive matters unless it is genuinely necessary, lawful and specifically requested through an appropriate process.
If we receive such data unintentionally and have no lawful reason to retain it, we may delete or restrict it.
6. Why We Process Personal Data and Our Legal Bases
The legal basis depends on the purpose and applicable law.
6.1 Responding to inquiries and evaluating potential engagements
We process relevant information to:
- respond to your inquiry;
- understand the business challenge you describe;
- determine whether MAXPRIMACY may be an appropriate fit;
- arrange meetings;
- prepare proposals or Statements of Work;
- take appropriate pre-contractual steps.
Depending on the circumstances, we may rely on steps taken at your request before entering into a contract or on our legitimate interests in managing prospective business relationships.
Where you act on behalf of a company rather than in your personal capacity, our legitimate interests in communicating with your organisation may be the more appropriate legal basis.
6.2 Providing services and managing client relationships
We process personal data to:
- administer engagements;
- communicate with client representatives;
- manage projects;
- provide agreed services;
- administer Statements of Work and Change Orders;
- issue invoices;
- document delivery and acceptance;
- manage contractual rights and obligations.
The legal basis may include contractual necessity, steps connected with a contract, our legitimate interests in managing a client relationship, and compliance with legal obligations.
6.3 Business development and professional outreach
We may use relevant professional contact information to identify and communicate with organisations and individuals who may reasonably have an interest in MAXPRIMACY’s work.
Where permitted by applicable law, this may be based on our legitimate interests in developing our business and communicating with relevant professional audiences.
We assess legitimate interests against the rights, interests and reasonable expectations of the individual.
Data protection law is not the only law that may regulate direct marketing. Email, telephone, SMS and other outreach may also be subject to electronic communications and direct-marketing rules in the recipient’s jurisdiction. We apply those requirements where they are applicable.
You may object to direct marketing at any time.
6.4 MAXPRIMACY Insights, newsletters and marketing communications
Where applicable law requires consent, we send optional marketing communications on the basis of your consent.
Where another lawful basis is available, we may rely on that basis as permitted by applicable law.
You can unsubscribe or object at any time using the mechanism provided in the communication or by contacting us.
6.5 Website operation, security and fraud prevention
We may process technical data to:
- operate and maintain our website;
- maintain network and information security;
- prevent misuse;
- detect technical incidents;
- troubleshoot problems;
- maintain logs necessary for security and reliability.
We generally rely on our legitimate interests in operating and securing our digital infrastructure and, where relevant, compliance with legal obligations.
6.6 Analytics and optional technologies
Where consent is required for analytics, advertising cookies or similar non-essential technologies, we use them only after the required consent has been obtained.
You may manage your preferences through our cookie management tool.
6.7 Compliance with legal and regulatory obligations
We may process and retain information where necessary to comply with:
- accounting requirements;
- tax requirements;
- corporate requirements;
- regulatory obligations;
- lawful requests from public authorities;
- applicable record-keeping obligations.
6.8 Establishing, exercising or defending legal claims
Where necessary, we may retain or process relevant information to:
- establish contractual rights;
- enforce agreements;
- respond to disputes;
- defend legal claims;
- prevent or investigate misconduct.
7. Personal Data We Did Not Obtain Directly From You
Where we obtain personal data from another source, such as a public professional profile, corporate website, professional directory, referral or lawful business-information provider, we apply the transparency requirements required by applicable law.
Where the GDPR applies, this information will generally be provided no later than the first communication with you or within the applicable statutory period, unless a lawful exception applies.
8. Cookies and Similar Technologies
Our website may use cookies and similar technologies for purposes such as:
- essential website functionality;
- security;
- preference management;
- analytics;
- measuring website performance;
- marketing or advertising, where enabled.
Non-essential technologies that require consent are not intended to be activated before the relevant consent has been provided.
Our current cookie inventory, purposes and available controls are described in our Cookie Policy at:
/legal/cookies/
You can also change your cookie preferences through the cookie settings available on our website.
9. Who We May Share Personal Data With
We do not disclose personal data indiscriminately.
Where reasonably necessary for the purposes described in this Notice, personal data may be made available to:
- authorised MAXPRIMACY personnel;
- contractors working under appropriate confidentiality and data-protection obligations;
- website hosting and infrastructure providers;
- corporate email providers;
- CRM providers;
- scheduling and communication platforms;
- video conferencing providers;
- cloud storage and collaboration providers;
- analytics and security providers;
- electronic signature providers;
- accounting, banking and payment providers;
- lawyers, auditors and professional advisers;
- public authorities where disclosure is required by law;
- other service providers necessary to operate our business.
Access should be limited according to business need.
Where a service provider processes personal data on our behalf, we seek to use appropriate contractual and organisational safeguards.
We do not disclose personal data to third parties simply because they wish to use it for their own unrelated marketing purposes.
10. International Data Transfers
MAXPRIMACY operates from Ukraine and may use service providers located in different countries.
As a result, personal data may be processed or stored outside the country in which you are located.
Where applicable law requires safeguards for an international transfer, we use an appropriate transfer mechanism. Depending on the circumstances, this may include:
- an adequacy decision;
- Standard Contractual Clauses;
- contractual safeguards;
- another mechanism permitted under applicable law.
Where the GDPR applies to a transfer requiring additional safeguards, we will assess and apply the appropriate mechanism before carrying out the relevant processing.
International transfers of personal data subject to Ukrainian law are also handled in accordance with applicable Ukrainian requirements.
11. Data Processed on Behalf of Clients
Some MAXPRIMACY engagements may involve analysing personal data controlled by our clients, for example:
- CRM information;
- lead databases;
- customer records;
- marketing data;
- customer research;
- identifiable sales information.
Where MAXPRIMACY processes such personal data solely according to a client’s documented instructions, the client generally remains the controller and MAXPRIMACY acts as processor.
In those cases:
- the relevant client determines the purposes of processing;
- MAXPRIMACY processes the data only within the agreed scope;
- the applicable Master Services Agreement, Statement of Work and Data Processing Addendum govern the processing;
- approved subprocessors may be used subject to the applicable contractual framework;
- the client’s privacy notice may be the primary notice governing the relationship with the affected individuals.
Requests relating to data we process solely on behalf of a client may need to be referred to that client.
12. Artificial Intelligence and Automated Processing
MAXPRIMACY may use approved AI-assisted or automated tools to support activities such as:
- research;
- analysis;
- summarisation;
- drafting;
- classification;
- workflow assistance;
- internal quality control.
Use of such tools does not remove MAXPRIMACY’s responsibility for appropriate data protection and confidentiality controls.
Where an AI or automated service receives personal data, we assess the relevant service, purpose, contractual terms and data-protection safeguards as appropriate to the processing.
We do not intentionally upload confidential client personal data to unrestricted consumer AI services where doing so would be inconsistent with our contractual or data-protection obligations.
MAXPRIMACY does not intend to make decisions about individuals based solely on automated processing where those decisions produce legal effects or similarly significant effects, unless such processing is lawful and the required information and safeguards are provided.
Automated tools may assist with lead analysis or workflow prioritisation, but material decisions about whether MAXPRIMACY enters into a client engagement should involve human judgment.
13. How Long We Keep Personal Data
We retain personal data only for as long as reasonably necessary for the purpose for which it was collected and for any applicable legal, accounting, contractual or dispute-resolution requirements.
Retention periods may differ depending on the category of data.
We generally apply the following criteria:
- website and security data: for the period reasonably required for security, troubleshooting and infrastructure management;
- business inquiries and unconverted prospects: for a limited business-development period after the last meaningful interaction, unless there is a reason to retain the information longer;
- active prospects: while discussions remain active and for a reasonable follow-up period;
- marketing subscriptions: until you unsubscribe, withdraw consent or otherwise object, subject to retention of limited suppression information where necessary to respect your choice;
- consent and privacy-preference records: for as long as reasonably necessary to demonstrate compliance;
- client relationship and project records: for the duration of the engagement and an appropriate period afterwards for contractual, legal and business-administration purposes;
- contracts, invoices and accounting records: for the period required under applicable tax, accounting and other legal requirements;
- client-controlled datasets processed by MAXPRIMACY as processor: according to the relevant Data Processing Addendum, Statement of Work or documented client instructions;
- legal claims and disputes: for as long as reasonably necessary to establish, exercise or defend relevant rights.
Where continued identification is no longer necessary, data may be deleted or anonymised.
MAXPRIMACY maintains or intends to maintain an internal retention schedule containing more detailed operational periods.
14. How We Protect Personal Data
We take reasonable technical and organisational measures appropriate to the nature and risk of the processing.
These may include, as appropriate:
- access controls;
- role-based access;
- secure authentication;
- password-management practices;
- multi-factor authentication;
- encryption where appropriate;
- secure backups;
- system updates and vulnerability management;
- logging and security monitoring;
- confidentiality obligations;
- restrictions on access to client data;
- service-provider assessments;
- incident-response procedures;
- staff and contractor awareness measures.
No system can guarantee absolute security. We therefore review security measures in light of the risks, technologies and types of data involved.
15. Your Privacy Rights
Your rights depend on the law applicable to the processing.
Where the GDPR applies, you may have rights including:
- the right to receive information about the processing of your personal data;
- the right of access;
- the right to rectification;
- the right to erasure in applicable circumstances;
- the right to restriction of processing;
- the right to data portability where applicable;
- the right to object to processing based on legitimate interests;
- the right to object to direct marketing at any time;
- the right to withdraw consent where processing is based on consent;
- rights relating to certain solely automated decisions;
- the right to lodge a complaint with a competent supervisory authority.
Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
Where Ukrainian personal data law applies, you also have the rights provided by applicable Ukrainian legislation.
We may need to verify your identity before responding to a privacy request in order to prevent unauthorised disclosure.
16. Direct Marketing and Your Right to Object
You can ask us to stop using your personal data for direct marketing at any time.
If you unsubscribe or object, we may retain limited information, such as your email address and the fact that you opted out, in a suppression record. This is used to ensure that your preference is respected and is not intended for further marketing.
17. Children
MAXPRIMACY provides professional B2B services and its website is not directed at children.
We do not intentionally seek to collect personal data from children through our general business-development activities.
If we become aware that personal data relating to a child has been collected without an appropriate lawful basis, we will take reasonable steps to address the situation.
18. Third-Party Websites and Services
Our website may contain links to websites or services operated by third parties.
MAXPRIMACY does not control the privacy practices of independent third parties. Their processing is governed by their own privacy notices and terms.
19. Changes to This Privacy Notice
We may update this Privacy Notice when:
- our processing activities change;
- we introduce new systems or service providers;
- legal requirements change;
- our business model or services materially change.
The current version and effective date will be displayed at the top of this page.
Where a change materially affects how we process personal data and applicable law requires additional notice or consent, we will take the appropriate steps.
20. Contact Us
For questions about this Privacy Notice or the processing of your personal data, or to exercise an applicable privacy right, contact:
MAXPRIMACY LLC
08141, Ukraine, region Kyivska, district Buchanskyi, village Sviatopetrivske, street Hryhoriia Skovorody, build 5, fl 9
Privacy email: [privacy@maxprimacy.com]
We aim to handle privacy requests without undue delay and within the period required by applicable law.
21. Complaints
If you believe that your personal data has been processed unlawfully, we encourage you to contact MAXPRIMACY first so that we can review the matter.
Depending on the law applicable to you, you may also have the right to lodge a complaint with:
- the data protection supervisory authority competent for your location or the relevant processing under the GDPR;
- the Ukrainian Parliament Commissioner for Human Rights where Ukrainian personal data law applies;
- another competent data-protection authority where applicable.
Nothing in this Notice limits any rights available to you under mandatory applicable law.