Privacy & Cookie Policy

Last updated: 1 May 2025

1. Introduction

Gaisteris Matchmaking (the trading name of the personal professional practice of Mrs. Okunyeva Olga Kharisivna, Individual Entrepreneur, Identification Number 3113816961, registered at Beresteyskyi av., 208, Kyiv, Ukraine — hereinafter “the Agency”, “we”, “us”, or “our”) is committed to protecting the privacy of all individuals whose personal data we process.

This Privacy and Cookie Policy (the “Policy”) explains what personal data we collect, on what legal basis we process it, how we use and protect it, with whom we may share it, how long we retain it, and what rights you have in relation to your data. It applies to:

• visitors to our website at www.gaisteris.com (“Website”);
• Clients — individuals who have signed a Matchmaking Services Agreement with the Agency; and
• Database Members — individuals who have signed a Database Membership Agreement and consented to inclusion of their Profile in the Agency’s candidate database free of charge.

We process personal data in compliance with the Law of Ukraine on Personal Data Protection and, where applicable, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable data protection legislation.

2. What Personal Data We Collect

The categories of personal data we collect depend on your relationship with the Agency.

2.1 Website Visitors

• Usage data automatically collected via cookies and similar technologies: IP address, browser type, device type, pages visited, time spent on page, and referring URL.
• Contact data you voluntarily submit via our contact form or newsletter sign-up: name, email address, and the content of your message.

2.2 Clients (Matchmaking Services Agreement)

• Identity and contact data: full name, date of birth, nationality, residential address, email address, telephone number, and copies of government-issued identification.
• Profile data: physical description, lifestyle information, relationship history, personal values, interests, professional background, and partner preferences, as provided during the intake interview and questionnaire.
• Photographs: a minimum of four recent photographs, as required under the Matchmaking Services Agreement.
• Financial data: payment details for the purpose of processing fees. No full card numbers are stored by the Agency; payment processing is handled by third-party processors subject to PCI-DSS standards.
• Communications: content of emails, messages, and session notes exchanged in the course of service delivery.
• Coaching session content: notes and summaries prepared in connection with dating coaching sessions.

2.3 Database Members (Database Membership Agreement)

• Identity and contact data: full name, date of birth, nationality, city of residence, email address, telephone number, and languages spoken.
• Profile data: physical description, marital status, family situation, lifestyle, values, interests, and partner preferences, as provided during the intake interview and questionnaire.
• Photographs: a minimum of four recent photographs, as required under the Database Membership Agreement.
• Feedback: notes and observations arising from introductions and meetings provided by the Database Member to the Agency.

3. Legal Basis for Processing

We rely on the following legal bases to process personal data:

• Performance of a contract (Art. 6(1)(b) GDPR): we process Client and Database Member data to the extent necessary to deliver the services agreed under the applicable signed agreement — including identifying potential matches, facilitating introductions, and delivering coaching sessions.
• Legitimate interests (Art. 6(1)(f) GDPR): we process website usage data and certain analytical data to maintain and improve our website, protect against fraud, and develop our service offering, where our interests are not overridden by your rights.
• Consent (Art. 6(1)(a) GDPR): we process data for purposes beyond contractual necessity — such as sharing your Profile with partner agencies or closed professional networks, or sending marketing communications — only where you have given us your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Legal obligation (Art. 6(1)(c) GDPR): we may process personal data where required to comply with applicable Ukrainian law or to respond to a request from a competent authority.

4. How We Use Your Personal Data

We use personal data strictly for the following purposes and do not process it in any manner incompatible with them:

• Service delivery: conducting intake interviews; compiling and maintaining Profiles; identifying potential Matches; facilitating video introductions and in-person meetings; delivering dating coaching sessions.
• Communication: scheduling appointments; sending session reminders and service updates; responding to enquiries submitted via the Website contact form.
• Payment processing: invoicing and managing payments for matchmaking and coaching services.
• Service improvement: analysing aggregated, anonymised data to refine our matching methodology and improve service quality. No individual Client or Database Member is identifiable in this analysis.
• Professional community engagement: sharing anonymised and de-identified experiences within professional matchmaking communities, strictly with your prior written consent.
• Marketing: sending newsletters or service updates via email only where you have subscribed or consented. You may unsubscribe at any time via the link in any marketing email or by writing to info@gaisteris.com.
• Website analytics: understanding how visitors interact with our Website in order to improve its content and performance.
• Legal compliance and security: protecting the Agency and our clients from fraud and complying with applicable legal obligations.

5. Use of Artificial Intelligence Tools

The Agency uses artificial intelligence (AI) tools to support certain aspects of service delivery. AI is used as an analytical aid under human supervision and does not replace the professional judgement of our matchmakers and coaches.

AI tools may be applied in the following areas:

• candidate research and Profile analysis — reviewing and organising candidate information to identify compatibility indicators;
• drafting Profile descriptions and introductory correspondence — all AI-generated content is reviewed and approved by a human team member before it is shared with any party;
• summarising intake interview notes and preparing session briefings; and
• appointment scheduling and routine administrative communications.

No decision that materially affects you — including the selection of candidates presented to you — is made solely on the basis of automated processing. All such decisions are made or confirmed by qualified human professionals.

Third-party AI service providers engaged by the Agency are contractually prohibited from using your personal data to train or fine-tune their AI models. Data shared with such providers is limited to the minimum strictly necessary for the specific task. You may at any time request information about whether AI was used in a specific step of your service, or request that a specific task be performed without AI assistance, by contacting us at info@gaisteris.com.

6. With Whom We Share Your Data

We do not sell, trade, or otherwise disclose your personal data to third parties for marketing or commercial purposes. We may share personal data only in the following circumstances.

6.1 Service Delivery Partners

We engage third-party service providers who assist in delivering our services, including payment processors, online video conferencing platforms (such as Zoom), and IT infrastructure providers. These providers process your data only on our instructions and are contractually required to maintain confidentiality. They may not use it for their own purposes.

6.2 Partner Matchmaking Agencies, Networks, and Databases

With your prior written consent, we may share your approved Profile — including a description and photographs, but without direct contact information — with partner matchmaking agencies, closed professional matchmaking networks, or vetted partner databases. This includes sharing via private professional correspondence or within closed professional communities (including, where applicable, closed groups on social media platforms such as Facebook), solely for the purpose of identifying suitable Matches for you. Any recipient of your Profile is subject to equivalent confidentiality obligations.

We will not share your Profile with any partner agency or network without first obtaining your express consent. You may withdraw this consent at any time.

6.3 Legal Requirements

We may disclose personal data where required by applicable Ukrainian law or in response to a valid request from a competent governmental or regulatory authority.

6.4 Anonymous Professional Sharing

With your prior written consent, we may share an anonymised account of your experience with our services — containing no identifying details — within professional matchmaking communities for educational or illustrative purposes.

7. How Long We Retain Your Data

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:

• Client data: retained for the duration of the Matchmaking Services Agreement plus three (3) years thereafter, unless a longer period is required by applicable law.
• Database Member data: retained for the duration of the Database Membership Agreement plus three (3) years thereafter. Upon a removal request, the Profile is removed within seven (7) calendar days, subject to the narrow exception described in the Database Membership Agreement.
• Website usage data and cookies: retained for up to 12 months from the date of collection, unless you clear your cookies earlier.
• Contact form and newsletter enquiries: retained for up to 24 months from last contact, or until you request deletion.

At the end of the applicable retention period, personal data is securely deleted or anonymised.

8. Your Rights

Subject to applicable law, you have the following rights in relation to your personal data:

• Right of access: request confirmation of whether we hold personal data about you and, if so, a copy of that data and information about how it is processed.
• Right to rectification: request correction of any inaccurate or incomplete personal data we hold.
• Right to erasure: request deletion of your personal data in certain circumstances, including where it is no longer necessary for the purposes for which it was collected.
• Right to restriction of processing: request that we restrict the processing of your data in certain circumstances, for example while its accuracy is contested.
• Right to data portability: where processing is based on your consent or a contract, receive your personal data in a structured, commonly used, and machine-readable format.
• Right to object: object to processing based on our legitimate interests; we will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: withdraw consent at any time where processing is consent-based, without affecting the lawfulness of prior processing.
• Right not to be subject to solely automated decisions: you have the right not to be subject to a decision based solely on automated processing that produces significant effects. We do not make such decisions.

To exercise any of the rights above, please contact us at info@gaisteris.com. We will respond within thirty (30) days. We may ask you to verify your identity before acting on your request.

9. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, alteration, or disclosure. These include:

• encryption of data in transit (TLS/HTTPS) and, where appropriate, at rest;
• access controls limiting personal data to personnel who require it for the performance of their duties;
• secure servers and firewall protection;
• regular personnel training on data privacy and social engineering threats; and
• contractual data protection obligations imposed on all third-party service providers.

No method of electronic transmission or storage is completely secure. While we take all reasonable steps to protect your data, we cannot guarantee absolute security. In the event of a personal data breach likely to result in a risk to your rights and freedoms, we will notify you and, where required, the relevant supervisory authority, in accordance with applicable law.

10. Cookies and Tracking Technologies

Cookies are small text files placed on your device when you visit our Website. We use the following categories:

• Strictly necessary cookies: essential for the operation of the Website. These cannot be disabled without affecting core functionality and do not collect information used for marketing.
• Analytical / performance cookies: used to collect information about how visitors interact with our Website (for example via Google Analytics). Data is aggregated and anonymised.
• Functional cookies: used to remember your preferences and settings during and between visits.

When you first visit our Website, we will ask for your consent to place non-essential cookies. You may withdraw consent at any time by adjusting your browser settings. Disabling certain cookies may affect Website functionality.

11. International Data Transfers

The Agency is based in Ukraine. Where personal data is transferred outside Ukraine — for example, when sharing a Profile with a partner agency in another country — we ensure that appropriate safeguards are in place to protect your data.

12. Changes to This Policy

We may update this Policy from time to time to reflect changes in our services, our data practices, or applicable law. The current version is always available at www.gaisteris.com/privacy-policy.

Where a change is material, we will notify you by email prior to the change taking effect, where we hold your contact details. Your continued use of our Website or services following the effective date of a material change constitutes acceptance of the updated Policy.

13. Contact Us

If you have any questions, concerns, or requests relating to this Policy or the processing of your personal data, please contact us:

Name	Mrs. Okunyeva Olga Kharisivna, Individual Entrepreneur
Email	info@gaisteris.com
Website	www.gaisteris.com
Address	Beresteyskyi av., 208, Kyiv, Ukraine

We aim to respond to all data rights requests within thirty (30) days. If you are not satisfied with our response, you have the right to lodge a complaint with the competent data protection supervisory authority in your country.