Privacy Policy

1. Introduction

PE Modern Technologies (“we”, “our”, or “us”) values your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains how we collect, use, store, disclose, and safeguard personal data when you visit mobilunity-bpo.com, contact us, request information about our services, or otherwise interact with our business.

We process personal data in accordance with applicable privacy and data protection laws and strive to ensure that all personal information is handled fairly, lawfully, and transparently.

Depending on your location, this may include compliance with:

• the General Data Protection Regulation (EU) 2016/679 (“GDPR”);
• the UK General Data Protection Regulation (“UK GDPR”);
• the UK Data Protection Act 2018;
• the Law of Ukraine “On Personal Data Protection”;
• and any other applicable data protection legislation.

Please read this Privacy Policy carefully to understand how we process personal data and the rights available to you.

2. Who We Are

PE Modern Technologies provides business process outsourcing (BPO) services to organizations worldwide. Our services include customer support, back-office support, business development and marketing support, web accessibility consulting, data annotation, AI training data services, and other business process outsourcing solutions.

Depending on the nature of the services provided, PE Modern Technologies may act either as:

• a Data Controller, where we determine why and how personal data is processed for our own business activities, such as website administration, customer relationship management, business communications, and marketing; or
• a Data Processor, where we process personal data solely on behalf of our clients while delivering outsourced business services, data annotation, AI training data services, or other contracted services, in accordance with their documented instructions.

If you have any questions regarding this Privacy Policy or our handling of personal data, you may contact us using the details provided at the end of this document.

3. Scope of this Privacy Policy

This Privacy Policy applies to personal data collected through:

• our website;
• contact forms and online enquiries;
• email, telephone, and other business communications;
• customer relationship management systems;
• business development activities;
• marketing campaigns;
• webinars, conferences, and business events;
• contractual relationships with clients, suppliers, and service providers;
• data annotation and AI training projects;
• any other interactions related to our business operations.

This Privacy Policy applies to:

• website visitors;
• prospective and existing clients;
• business contacts;
• suppliers and service providers;
• event participants;
• newsletter subscribers; 
• and individuals who communicate with us regarding our services.

This Privacy Policy does not apply where PE Modern Technologies processes personal data exclusively on behalf of a client while acting as a Data Processor. In such cases, the client remains responsible for determining the purposes and legal basis for processing personal data, while we process such information only in accordance with contractual obligations and documented instructions.

4. Personal Data We Collect

The categories of personal data we collect depend on how you interact with our website and services.

4.1 Information You Provide Directly

You may provide personal information when you:

• submit an enquiry through our website;
• request information about our services;
• schedule a meeting or consultation;
• communicate with our representatives;
• enter into a contractual relationship with us.

Depending on the circumstances, we may collect information such as:

• full name;
• company name;
• job title;
• business email address;
• telephone number;
• country and city;
• information about your business or project;
• meeting requests;
• communication preferences;
• correspondence exchanged with our team.

We collect only the information that is reasonably necessary to respond to your enquiry, provide our services, maintain business relationships, or comply with legal obligations.

4.2 Information Collected Automatically

When you use our website, certain technical information may be collected automatically, including:

• IP address;
• browser type and version;
• operating system;
• device information;
• language preferences;
• referring website;
• pages visited;
• time spent on our website;
• interactions with website content;
• cookies and similar technologies;
• diagnostic information; and
• analytics data.

This information helps us maintain the security of our website, improve performance, understand visitor behaviour, and enhance the overall user experience.

4.3 Information Obtained from Third Parties

Where permitted by applicable law, we may receive limited business-related information from third-party sources, including:

• professional networking platforms;
• publicly available business directories;
• company websites;
• business partners;
• marketing and event partners;
• and other publicly available professional sources.

Such information is used solely for legitimate business purposes, including business development, communication with prospective clients, and maintaining professional relationships.

4.4 Sensitive Personal Data

We do not seek or collect sensitive personal information through our website. This includes information that may reveal an individual’s ethnic or racial background, political or religious views, philosophical beliefs, trade union affiliation, health status, biometric or genetic information, or details concerning a person’s sex life or sexual orientation, unless such processing is specifically permitted or required under applicable law.

If sensitive personal data is voluntarily provided, it will be processed only where permitted by applicable legislation and only to the extent necessary for the relevant purpose.

5. Purposes of Processing and Legal Bases

We process personal data only where there is a valid legal basis under applicable data protection legislation.

Depending on the circumstances, we may rely on one or more of the following legal grounds:

• your consent;
• the performance of a contract or steps taken before entering into a contract;
• compliance with legal obligations; 
• our legitimate business interests, provided those interests do not override your fundamental rights and freedoms.

The table below summarises the primary purposes for which we process personal data.

Where we rely on legitimate interests, we carefully assess whether our interests are balanced against your rights, freedoms, and reasonable expectations.

6. Business Process Outsourcing and Professional Services

PE Modern Technologies delivers business process outsourcing (BPO) services, including dedicated non-IT specialists and teams, customer support, back-office support, business development and marketing support, web accessibility consulting, data annotation, AI training data services, and other operational support solutions.

Where we process personal data solely on behalf of a client while delivering contracted services, we act as a Data Processor, and the client remains the Data Controller responsible for determining the purposes and means of processing.

In such cases, we:

• process personal data only in accordance with documented client instructions;
• implement appropriate technical and organizational safeguards;
• ensure that employees and contractors are subject to confidentiality obligations;
• restrict access to personal data to authorized personnel only; and
• assist clients in fulfilling their data protection obligations where required by applicable law or contract.

For certain internal business activities, including customer relationship management, website administration, and marketing, PE Modern Technologies acts as a Data Controller.

7. Data Annotation and AI Training Services

As part of our service offering, PE Modern Technologies provides data annotation, data labeling, classification, validation, enrichment, quality assurance, and other services supporting artificial intelligence and machine learning projects.

Some projects may involve datasets supplied by clients that contain personal data. In such situations, we process that information exclusively on behalf of our clients and strictly in accordance with contractual agreements and documented instructions.

Client data is never used to develop or train our own artificial intelligence models or for any purpose unrelated to the services agreed with the client unless explicit written authorization has been provided.

We apply contractual, organizational, and technical safeguards designed to protect confidential information processed during data annotation and AI-related projects.

8. Business Communications and Customer Relationship Management

Personal information may be used to communicate with organizations interested in our services, support ongoing relationships with existing clients, coordinate activities with service providers and contractors, and manage interactions with other commercial partners connected with our business.

Depending on the nature of the relationship, this may include processing:

• contact details;
• company information;
• communication history;
• meeting records;
• project-related information;
• contractual documentation;
• billing information;
• customer support requests; and
• marketing preferences.

This information enables us to manage enquiries, coordinate projects, maintain customer relationships, and deliver our services effectively.

Where appropriate, we may use customer relationship management (CRM) systems and third-party scheduling tools to organize meetings, manage communications, and improve the efficiency of our business operations.

Where permitted by applicable law, we may also send newsletters, service updates, invitations to webinars or events, and other business-related communications. You may opt out of marketing communications at any time by using the unsubscribe mechanism included in our emails or by contacting us directly.

9. Cookies and Similar Technologies

Our website uses cookies and similar technologies to ensure its proper operation, improve website performance, analyze visitor interactions, and support marketing activities.

Cookies are small text files stored on your device when you visit a website. They help remember your preferences, improve functionality, and provide insights into how our website is used.

The categories of cookies we may use include:

Strictly Necessary Cookies

These cookies are required for the secure operation and basic functionality of our website. Without them, certain services and features may not function correctly.

Functional Cookies

Functional cookies remember your preferences, such as language settings and other customization choices, to provide a more personalized browsing experience.

Analytics Cookies

Analytics cookies help us understand how visitors interact with our website, identify areas for improvement, and measure the effectiveness of our content and services.

Advertising and Marketing Cookies

These cookies help us evaluate marketing performance, understand visitor interests, and deliver more relevant communications and advertising.

In jurisdictions where consent is legally required, optional cookies are activated only after you choose to accept them through the cookie preference tool available on our website.

You may review or update your cookie preferences at any time through our cookie settings or by adjusting your browser settings.

Additional information is available in our Cookie Policy.

10. AI-Assisted Business Operations

To improve efficiency and support the delivery of our services, PE Modern Technologies may use artificial intelligence and other machine-assisted technologies within its internal business operations.

These technologies may assist with activities such as:

• preparing business communications;
• summarizing meetings;
• organizing documentation;
• supporting customer service activities;
• maintaining internal knowledge resources;
• drafting documentation; and
• improving operational efficiency.

AI-assisted tools are used to support human decision-making and remain subject to appropriate human oversight.

We do not make decisions based solely on automated processing where such decisions would produce legal or similarly significant effects for individuals.

Where AI-assisted technologies involve the processing of personal data, appropriate technical and organizational measures are implemented to ensure compliance with applicable data protection legislation and to protect the confidentiality of personal information.

11. Disclosure of Personal Data

We treat personal data as confidential and do not sell or rent personal information to third parties.

Personal data may be shared only where necessary to deliver our services, support our business operations, comply with legal obligations, or protect our legitimate interests.

Depending on the circumstances, we may disclose personal data to:

• clients receiving our outsourced services;
• cloud hosting and infrastructure providers;
• customer relationship management (CRM) providers;
• communication and collaboration platform providers;
• website hosting providers;
• analytics and marketing service providers;
• payment service providers;
• legal, accounting, tax, and professional advisers;
• subcontractors engaged under appropriate contractual arrangements; and
• public authorities, regulators, courts, or law enforcement agencies where disclosure is required by applicable law.

Where third-party service providers process personal data on our behalf, they are required to maintain appropriate security measures and process personal data only in accordance with applicable legal requirements and contractual obligations.

12. International Transfers of Personal Data

As an international provider of business process outsourcing services, PE Modern Technologies may transfer, access, or process personal data in countries outside the jurisdiction in which the information was originally collected.

Where cross-border transfers occur, we implement appropriate safeguards to ensure that personal data receives an adequate level of protection in accordance with applicable data protection legislation.

Depending on the circumstances, these safeguards may include:

• the European Commission’s Standard Contractual Clauses (SCCs);
• the UK International Data Transfer Addendum or other approved transfer mechanisms where applicable;
• transfers to jurisdictions that benefit from an adequacy decision;
• contractual confidentiality obligations; and
• technical and organizational measures designed to protect personal data during international transfers.

We periodically review our international data transfer practices to ensure continued compliance with applicable legal requirements.

13. Data Retention

We retain personal data only for as long as it is necessary to fulfil the purposes described in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, enforce contractual rights, and protect our legitimate business interests.

The retention period depends on the type of information involved and the reason it was collected.

As a general guideline:

Where applicable law requires longer retention periods, personal data will be retained for the required period.

Once the applicable retention period expires and there is no further legitimate reason to keep the information, we take reasonable steps to permanently erase it, anonymize it, or otherwise dispose of it in a secure manner.

14. Information Security

PE Modern Technologies maintains technical and organizational measures designed to protect personal data against unauthorized access, accidental loss, misuse, alteration, disclosure, or destruction.

Depending on the nature of the processing activities, these measures may include:

• role-based access controls;
• identity verification and authentication procedures;
• encryption where appropriate;
• secure communication channels;
• network and infrastructure security controls;
• confidentiality obligations for employees and contractors;
• regular security and privacy awareness training;
• secure operational practices;
• monitoring systems for potential security threats; and
• contractual security requirements for third-party service providers.

Although we take reasonable steps to protect personal data, no method of electronic transmission or storage can be guaranteed to be completely secure.

We maintain procedures for identifying, investigating, and responding to security incidents and will provide any notifications required by applicable law.

15. Your Privacy Rights

Depending on your location and the laws that apply to the processing of your personal data, you may have certain privacy rights.

Subject to applicable legal requirements, these rights may include:

• Right of Access – to request confirmation of whether we process your personal data and obtain access to that information.
• Right to Rectification – to ask us to amend personal information that is incorrect, incomplete, or out of date.
• Right to Erasure – to request deletion of personal data where there is no legal basis for continued processing.
• Right to Restrict Processing – to request that processing be limited in circumstances permitted by law.
• Right to Data Portability – to receive personal data in a structured, commonly used, and machine-readable format where applicable.
• Right to Object – to object to processing carried out on the basis of our legitimate interests, including direct marketing.
• Right to Withdraw Consent – where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.
• Right to Lodge a Complaint – to submit a complaint to the competent supervisory authority if you believe your personal data has been processed unlawfully.

We nevertheless encourage you to contact us first so that we have an opportunity to address your concerns directly.

16. Exercising Your Rights

If you wish to exercise any of your privacy rights or have questions regarding the processing of your personal data, you may contact us using the contact details provided below.

To protect personal information, we may request additional information necessary to verify your identity before responding to your request.

We will respond to requests within the timeframes established by applicable data protection legislation.

Where permitted by law, we may refuse requests that are manifestly unfounded, excessive, or repetitive, or charge a reasonable administrative fee where appropriate.

17. Third-Party Websites

Our website may contain links to websites or online services operated by third parties.

This Privacy Policy applies only to our own website and services. We are not responsible for the privacy practices, content, or security of third-party websites.

Because third-party websites operate independently from us, we recommend reviewing their own privacy notices before submitting any personal information through those websites.

18. Changes to this Privacy Policy

From time to time, we may revise this Privacy Policy to reflect developments in our business operations, legal requirements, or the technologies we use when providing our services.

If any material revisions are introduced, we will indicate the date of the latest update and, where appropriate, notify users through our website or by other suitable means.

Your continued use of our website after the revised Privacy Policy becomes effective constitutes your acknowledgement of the updated version, to the extent permitted by applicable law.

19. Contact Information

If you have any questions about this Privacy Policy or wish to exercise your privacy rights, please contact us:

PE Modern Technologies

Dmytrivska Street, Building 92–94

Kyiv 01135

Ukraine

Email: [email protected]

We will make reasonable efforts to respond to your request promptly and in accordance with applicable data protection legislation.