1. Scope and Our Role

This Policy applies to website visitors, prospective clients, business contacts, newsletter subscribers, donors, payors, partners, and other individuals who interact with Sohodny through the Site. For purposes of applicable data protection laws, Sohodny LLC is generally the business or controller responsible for the personal information described in this Policy.

The Site is intended primarily for business and organizational users. If you provide information about another person, you represent that you are authorized to do so and that you have given that person any notice required by applicable law.

2. Personal Information We Collect

The personal information we collect depends on how you use the Site and which features are enabled.

2.1 Information You Provide

• Contact and inquiry information. Your name, email address, telephone number, company or organization, job title, country, and the contents of your message when you submit a form, request information, or contact us.
• Business and professional information. Information about your organization, industry, business needs, proposed project, partnership interests, investment or reconstruction opportunities, and other information relevant to a potential engagement.
• Newsletter information. Your name, email address, communication preferences, subscription status, and information about your interaction with our emails, such as opens and link clicks, where permitted.
• Payment or donation information. Information connected to a payment or donation, such as your name, email address, amount, date, transaction status, billing country, and any message you submit. Complete payment-card or bank-account information is generally collected and processed directly by the payment provider, not by Sohodny.
• Other information. Any information you choose to provide in a message, form, document, or other communication. Please do not submit sensitive personal information unless it is necessary and we specifically request it.

2.2 Information Collected Automatically

When you visit the Site, Sohodny and its service providers may automatically collect information through cookies, pixels, tags, server logs, and similar technologies, including:

• Internet Protocol (IP) address and approximate location derived from it;
• browser type, device type, operating system, language, screen resolution, and device identifiers;
• pages viewed, links clicked, referral and exit pages, date and time of access, and time spent on the Site;
• interactions with forms, newsletters, and other Site features; and
• cookie identifiers, advertising identifiers, and information used to measure traffic, performance, and engagement.

We may combine automatically collected information with information you provide, where permitted by law.

2.3 Information From Other Sources

We may receive personal information from payment processors, analytics and email-service providers, referral partners, professional advisers, public sources, and business contacts. The information received depends on the source and your interaction with that source.

3. Cookies and Similar Technologies

The Site uses cookies and similar technologies to operate, measure, improve, and, where enabled, promote the Site. Cookies are small files stored on or accessed from your device. They may be set by Sohodny (first-party cookies) or by service providers (third-party cookies).

• Essential technologies. Support basic Site functions, security, network management, fraud prevention, and user-requested services. These technologies may operate without consent where permitted by law.
• Analytics technologies. Help us understand visits, traffic sources, page performance, and how users interact with the Site. Depending on the Site’s configuration, these services may include Google Analytics or comparable tools.
• Preference technologies. Remember choices such as language, region, or cookie settings.
• Advertising or tracking technologies. May measure campaigns, limit repeated advertisements, or associate activity across websites or services when those features are enabled.

You can manage non-essential cookies through the Site’s cookie banner or cookie settings, if available, and through your browser settings. Blocking cookies may affect Site functionality. Where required by law, we request consent before placing non-essential cookies and honor applicable opt-out preference signals that we are legally required and technically able to recognize.

For information about how Google handles data, see the Google Privacy Policy. The specific providers and cookie durations in use may also be identified through the Site’s cookie settings.

4. How We Use Personal Information

We may use personal information to:

• operate, maintain, secure, troubleshoot, and improve the Site;
• respond to inquiries, schedule conversations, and communicate about Sohodny’s consulting, market-entry, reconstruction, and business-development services;
• evaluate potential clients, projects, partnerships, investments, and other business opportunities;
• process and document payments or donations, provide confirmations, and maintain accounting and tax records;
• send newsletters, economic updates, announcements, invitations, and other communications you request or that are otherwise permitted by law;
• measure Site and email performance, understand audiences, and improve content and outreach;
• detect, investigate, and prevent fraud, abuse, security incidents, and other harmful activity;
• enforce agreements, establish or defend legal claims, and protect Sohodny, our users, and others; and
• comply with legal, regulatory, accounting, reporting, and recordkeeping obligations.

We may use information that has been aggregated or deidentified so that it cannot reasonably identify you, and we may use and disclose such information for lawful purposes.

5. Legal Bases for Processing

Where the law requires a legal basis for processing, we rely on one or more of the following, as appropriate:

• Consent, such as when you accept non-essential cookies or subscribe to marketing communications. You may withdraw consent at any time, although withdrawal does not affect earlier lawful processing.
• Contractual necessity, when processing is needed to take steps at your request before entering an agreement or to perform an agreement with you.
• Legitimate interests, including operating and improving the Site, responding to business inquiries, protecting security, and developing Sohodny’s services, provided those interests are not overridden by your rights and interests.
• Legal obligations, when processing is necessary to comply with applicable law, lawful requests, accounting rules, or regulatory requirements.

6. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients for the purposes described in this Policy:

• Service providers. Companies that provide website hosting, security, analytics, email delivery, customer relationship management, data storage, professional support, and payment processing. They may process information only as authorized by their agreements and applicable law.
• Payment processors. Third-party processors, such as PayPal or another provider displayed at checkout, process payment credentials under their own terms and privacy notices. Sohodny may receive transaction records and limited payer or donor details needed for confirmation, accounting, fraud prevention, and compliance.
• Business and project partners. With your direction or as reasonably necessary to evaluate or perform a requested service, we may share relevant information with advisers, local partners, contractors, or other parties involved in a potential engagement. We will not disclose confidential project information for unrelated purposes.
• Professional advisers. Lawyers, accountants, auditors, insurers, banks, and consultants where reasonably necessary for their professional services.
• Legal and safety recipients. Government authorities, courts, law enforcement, regulators, or other parties when we believe disclosure is required by law or reasonably necessary to protect rights, safety, security, or property; investigate wrongdoing; or respond to a lawful request.
• Corporate transaction recipients. Actual or prospective parties and advisers involved in a merger, financing, reorganization, sale of assets, acquisition, bankruptcy, or similar transaction, subject to appropriate confidentiality protections where practicable.

For PayPal’s practices, see the PayPal Privacy Statement. Other payment providers displayed on the Site govern their own collection and use of payment credentials.

7. Sale, Sharing, and Targeted Advertising

Sohodny does not sell personal information for money. Some analytics or advertising technologies may disclose identifiers and Internet or network activity to third parties in a manner that certain U.S. state laws define as a “sale,” “sharing,” or processing for “targeted advertising,” even when no money is exchanged.

Where applicable, you may opt out through a “Your Privacy Choices,” “Do Not Sell or Share My Personal Information,” or similar link in the Site footer or cookie settings, or by contacting us as described in Section 15. We do not knowingly sell or share the personal information of individuals under 16.

8. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to provide requested services, maintain business and transaction records, comply with legal and accounting obligations, resolve disputes, enforce agreements, and protect security.

Retention periods vary based on the type of information, the nature of our relationship, legal requirements, relevant limitation periods, and technical considerations. For example, inquiry records may be retained while a business opportunity remains active and for a reasonable period afterward; newsletter information is retained until you unsubscribe or the subscription becomes inactive, subject to maintaining a suppression record; and transaction records may be retained for tax, accounting, anti-fraud, and legal compliance. When information is no longer needed, we take reasonable steps to delete, deidentify, or securely dispose of it.

9. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against accidental or unlawful loss, misuse, alteration, disclosure, or access. However, no website, transmission method, or storage system is completely secure, and we cannot guarantee absolute security. You should use care when sending confidential or sensitive information through ordinary email or general website forms.

10. International Data Transfers

Sohodny is based in the United States and works in an international business environment, including matters involving the United States and Ukraine. Personal information may be processed in the United States and other countries where Sohodny’s service providers or partners operate. Those countries may have data protection laws that differ from the laws where you live.

Where required, we use recognized safeguards for international transfers, such as contractual protections, adequacy mechanisms, or other lawful transfer methods. You may contact us for additional information about safeguards applicable to your personal information.

11. Your Privacy Rights and Choices

11.1 Marketing Communications

You may unsubscribe from marketing emails at any time by selecting the unsubscribe link in an email or contacting us. We may continue to send non-marketing communications, such as responses to your requests, transaction confirmations, security notices, or communications necessary for an existing business relationship.

11.2 Cookie and Tracking Choices

You may adjust cookie choices through the Site’s cookie settings and your browser controls. Clearing cookies may reset your preferences. Device and browser controls do not necessarily affect information already collected, and some essential technologies cannot be disabled through the Site.

11.3 Rights Under Applicable Privacy Laws

Depending on where you live and subject to legal exceptions, you may have the right to:

• know whether we process your personal information and obtain access to or a copy of it;
• correct inaccurate personal information;
• request deletion of personal information;
• request restriction of or object to certain processing;
• receive certain information in a portable format;
• withdraw consent where processing is based on consent;
• opt out of the sale or sharing of personal information, targeted advertising, or certain profiling;
• limit certain uses or disclosures of sensitive personal information, where applicable;
• appeal a decision concerning a privacy request, where applicable; and
• receive equal service and not be discriminated against for exercising a privacy right.

Sohodny does not currently use personal information to make decisions based solely on automated processing that produce legal or similarly significant effects.

11.4 EEA, United Kingdom, and Switzerland

If applicable law in the European Economic Area, United Kingdom, or Switzerland covers our processing of your personal information, you may have rights of access, correction, erasure, restriction, portability, and objection, as well as the right to withdraw consent and lodge a complaint with the data protection authority in your country. You have an absolute right to object to processing for direct marketing.

11.5 Submitting a Request

To exercise a privacy right, contact us using the information in Section 15 and include “Privacy Request” in the subject line. Please describe your request and identify the state or country where you live. We may ask for information reasonably necessary to verify your identity and authority. Authorized agents may submit requests where permitted by law, but we may require proof of authorization and direct verification with the individual.

We will respond within the period required by applicable law. Some rights are subject to exceptions, and we may deny or limit a request where permitted. If we deny an appealable request, our response will explain how to appeal. You may also have the right to contact your state attorney general or local data protection authority.

12. Children’s Privacy

The Site is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided personal information to us, please contact us so we can take appropriate action. If local law provides a higher minimum age for consent to online data processing, we will follow that requirement where applicable.

13. Third-Party Websites and Services

The Site may contain links to third-party websites, social media pages, embedded tools, and services. Sohodny does not control and is not responsible for the privacy, security, or content practices of third parties. Review the privacy notices of any third-party service before providing personal information.

14. Changes to This Privacy Policy

We may update this Policy from time to time to reflect changes in our practices, technology, services, or legal obligations. We will post the revised Policy on the Site and update the effective date above. If required by law, we will provide additional notice or obtain consent for material changes.

15. Contact Us

Questions, requests, or concerns about this Privacy Policy or Sohodny’s handling of personal information may be directed to:

If you contact us about a privacy request, please do not include sensitive identifiers, passwords, complete payment-card numbers, or other information that is not necessary for us to understand and verify your request.