Last Updated: December 27, 2024
1. General Provisions
Revolution REA LLC (LIMITED LIABILITY COMPANY "REAL ESTATE AGENCY 'REVOLUTION'") (hereinafter referred to as "Company", "we", "our" or "us") respects users' right to privacy and is committed to protecting personal data.
This Privacy Policy defines the procedure for collecting, using, storing and protecting information processed when using our website, CRM system, software products and related services (hereinafter referred to as "Service").
By using the Service, you confirm your consent to this Policy.
2. What Information We Collect
2.1. Information Collected Automatically When Visiting the Website
When visiting the website, we may automatically receive technical information, including:
- IP address
- browser type and operating system
- date and time of access
- pages visited
- server log files data
This information is used to ensure stable operation of the website, analytics and security enhancement.
2.2. Cookies and Similar Technologies
Our website uses cookies and similar technologies for:
- proper website operation
- saving user preferences
- website usage analytics
- improving user experience
Users can restrict or disable the use of cookies in their browser settings. In this case, some website functions may not work correctly.
2.3. Data Provided by Users
We may process information that users provide voluntarily, including:
- registration data (name, email address, password)
- profile data
- information entered or uploaded to the CRM
- customer support inquiries
2.4. Data from Facebook and Instagram
When connecting Facebook Pages or Instagram Business accounts to the Service, we receive and process the following data through Facebook Graph API:
Facebook Messenger:
- PSID (Page-Scoped ID) of the sender
- Text of messages
- Attachments (images, documents, audio, video)
- Time of message receipt and sending
- Read status
- Message metadata
Instagram Direct:
- Instagram User ID (IGSID)
- Text of messages
- Media files (photos, videos)
- Time of receipt and sending
- Message metadata
Facebook Platform Permissions Used by the Application:
- pages_messaging (for processing page messages)
- pages_manage_metadata (for managing page settings)
- instagram_basic (for basic Instagram access)
- instagram_manage_messages (for managing Instagram messages)
Processing Purpose: This data is processed exclusively for synchronizing business correspondence with the CRM, centralized management of customer communications, and providing technical support to Service users.
Retention Period: Data from Facebook and Instagram is stored during active use of the integration plus 30 calendar days after disconnecting the integration to ensure technical deletion from all systems.
2.5. Data Obtained via Google APIs
If a user connects their Google account to the Service, we may access and process data via Google APIs in accordance with the Google API Services User Data Policy.
Depending on the permissions granted by the user, the Service may access the following data:
Google Calendar:
- calendar events (title, date, time, participants)
- event metadata
- calendar identifiers
Google Gmail (if applicable):
- email metadata (sender, subject, date)
- email content or parts of email messages, only when explicitly initiated by the user
Purpose of processing:
Google data is used exclusively to synchronize calendar events and/or email data with the CRM system, automate workflows, schedule tasks and reminders, and improve the functionality of the Service.
Limitations on use:
We do not use Google API data for advertising, profiling, or any purpose unrelated to the core functionality of the Service.
Data retention:
Google data is stored for the duration of the active integration and for up to 30 calendar days after the integration is disconnected, after which the data is deleted or anonymized.
3. Purpose of Information Processing
We use the collected information for:
- ensuring website and Service operation
- user authentication
- synchronizing Facebook and Instagram messages with CRM
- Synchronization of Google Calendar and/or Gmail data with CRM
- centralized management of customer communications
- technical support
- analyzing website and service usage
- ensuring security and preventing abuse
- complying with legal requirements
Important Note: We do not sell or use personal data or message content for advertising targeting, third-party profiling, or any purposes not directly related to the Service functionality.
4. Transfer of Information to Third Parties
We may transfer information only in the following cases:
To Technical Service Providers:
- Hosting provider: Amazon Web Services (AWS)
- Server location: Belgium or Germany
- Transfer purpose: ensuring Service operation
- Security level: compliant with international security standards (ISO 27001)
Upon Legal Request:
- Authorized government agencies upon official request
- To protect the rights and security of the Company or users
- When executing court decisions
Guarantees: We do not sell, transfer free of charge, or lease personal data or user messages to third parties for their commercial purposes.
5. Data Storage
Personal and technical data is stored according to the following terms:
- Account data: during active use of the Service + 90 days after account deletion
- Facebook/Instagram data: during active integration + 30 days after disconnection
- Server logs: 12 months
- Customer support data: 24 months after the last inquiry
Exceptions: In cases provided by law (accounting documents, tax reporting), data may be stored longer in accordance with legal requirements.
After the retention period expires, data is deleted or anonymized without the possibility of recovery.
6. Information Protection
We apply technical and organizational security measures, including:
- data encryption during transmission (SSL/TLS protocols)
- data encryption at rest
- multi-factor authentication for CRM access
- role-based access control
- restriction of employee access to personal data (need-to-know principle)
- regular security system and patch updates
- monitoring of unauthorized access
- regular security audits
7. User Rights
In accordance with applicable law, users have the right to:
- Right of access: obtain information about their personal data being processed
- Right to rectification: request correction of inaccurate data
- Right to erasure: request deletion of their personal data (see Section 12)
- Right to restriction of processing: restrict processing in certain cases
- Right to withdraw consent: withdraw consent to processing at any time
- Right to data portability: receive their data in a structured format
- Right to object: object to data processing
To exercise your rights, contact us using the information provided in Section 14.
8. Use of third-party API platforms
8. Use of Facebook Platform API
Our application uses Facebook Graph API and complies with:
Usage Restrictions: We use Facebook and Instagram data exclusively for providing Service functionality and do not transfer this data to third-party advertising or analytics platforms.
8.2. Use of Google API Services
Our Service complies with the Google API Services User Data Policy, including the Limited Use requirements.
9. Third-Party Services
The Service integrates with Meta Platforms, Inc. (Facebook, Instagram) platforms in accordance with their privacy policies:
We are not responsible for the privacy policies and practices of third-party platforms. We recommend reviewing their policies separately.
10. Children's Privacy
The Service is not intended for persons under 13 years of age (or under 16 years of age for users from the EU). We do not knowingly collect or process personal data of children.
If you become aware that a child has provided us with personal data without parental consent, please contact us and we will immediately delete such information.
11. International Data Transfer
If your data is transferred outside Ukraine or the EU, we ensure:
- Use of servers in jurisdictions with adequate data protection levels
- Application of EU Standard Contractual Clauses
- Compliance with GDPR requirements for international transfers
12. Deletion of data
For Facebook and Instagram Users:
You can delete all data obtained through Facebook Platform using one of the following methods:
Via Email: Send a request to info@revolution.kyiv.ua with the subject "Facebook Data Deletion", specifying:
- Your name
- Email associated with the account
- Facebook Page ID or Instagram account ID
Через онлайн-форму: Заповніть форму за посиланням: https://revolution.kyiv.ua/contactus
Execution Time: Your data will be completely deleted within 30 calendar days from the receipt of the request. You will receive a confirmation email after the deletion process is completed.
What Will Be Deleted:
- All messages from Facebook Messenger and Instagram Direct
- Message metadata
- Media files and attachments
12.2. Deleting Google data
Users may delete all data obtained via Google APIs at any time by:
- revoking access to their Google account through Google Account security settings, or
- sending a deletion request to info@revolution.kyiv.ua with the subject line "Google Data Deletion" info@revolution.kyiv.ua з темою "Видалення даних Google"
Upon receiving such a request, all Google API data associated with the user will be permanently deleted within 30 calendar days.
13. Changes to the Policy
We may update this Privacy Policy from time to time. When making significant changes, we will notify you using one of the following methods:
- Email notification
- Notification in the Service
- Updating the date at the beginning of this document
The current version is always available at: https://revolution.kyiv.ua/privacy-policy
We recommend periodically reviewing this Policy to stay informed about how we protect your information.
14. Contact Information
For privacy-related inquiries, contact:
Company: Revolution REA LLC — LIMITED LIABILITY COMPANY "REAL ESTATE AGENCY 'REVOLUTION'"
Legal Address: 17/4 Mykilsko-Botanichna Street, Kyiv, Ukraine, 01032
Email for Privacy Inquiries: info@revolution.kyiv.ua
General Phone: +380 68 231 1100
Support Hours: Mon-Fri, 9:00 AM - 6:00 PM (Kyiv time)
Privacy Inquiry Response Time: up to 30 calendar days
Thank you for trusting us with your data. We take its protection seriously.