How Kolo, a product of LimTC, collects, uses, shares and protects personal data across the Kolo website and platform, and your rights under GDPR and Ukrainian data protection law.
Last updated: 14 July 2026
This Privacy Policy explains how personal data is collected, used, shared and protected in connection with the Kolo website at kolohr.com and the Kolo platform at app.kolohr.com (together, the “Service”). Kolo is operated by LimTC, a company registered in Ukraine [full legal entity name, EDRPOU registration number and registered address to be completed] (“LimTC”, “we”, “us”). Please read it alongside our Terms of Service.
Our responsibilities depend on how you use Kolo:
If your employer uses Kolo and you have questions about how your personal data is handled, please contact your employer in the first instance, as they control that data.
Payments are processed by our payment provider, LiqPay (operated by JSC CB PrivatBank). We do not collect or store full card numbers; we receive only limited transaction confirmation data needed to manage subscriptions.
We use essential cookies to operate the Service and analytics cookies to understand how the website is used. Website analytics are provided by Google Analytics (GA4). You can control or block cookies through your browser settings and, where presented, through our cookie preferences. Blocking some cookies may affect how the website works.
Where we act as controller, we rely on the following legal bases under the EU General Data Protection Regulation (GDPR) and applicable Ukrainian law:
Where we act as processor, the legal basis for processing customer content is determined by the customer as controller, and we process it only on their instructions.
We do not sell personal data. We share it only as needed to run Kolo, comply with law, or protect our rights. We use the following trusted subprocessors:
We may also disclose data to comply with legal obligations, enforce our agreements, or as part of a merger, acquisition or sale of assets, in each case with appropriate safeguards. A current list of subprocessors is available on request.
Some of our subprocessors may process data outside Ukraine or the European Economic Area. Where they do, we rely on appropriate safeguards, such as the European Commission’s Standard Contractual Clauses and equivalent legal mechanisms, to protect your data.
We retain account and customer data while an account is active. Following cancellation or termination, data is kept for a limited grace period during which the customer may export it, after which it is permanently deleted, unless a longer period is required to meet legal, tax or regulatory obligations. Website and analytics data are retained in line with our analytics configuration.
We apply technical and organisational measures designed to protect personal data, including encryption in transit, access controls, logical isolation of each customer’s data, least-privilege access for our team, and secure hosting infrastructure. No method of transmission or storage is completely secure, but we work to protect data and will notify affected parties and authorities of a personal data breach where required by law.
Subject to applicable law, you may have the right to access, correct, delete, restrict or object to the processing of your personal data, to data portability, and to withdraw consent at any time. You also have the right to lodge a complaint with a supervisory authority — in Ukraine, the Ukrainian Parliament Commissioner for Human Rights (the Ombudsman), and in the EU, your local Data Protection Authority.
To exercise rights over data we hold as controller, contact us at hello@limtc.com. If your employer is the controller of your data, please direct your request to your employer.
Kolo’s wellbeing and mood check-ins, and certain HR records, may involve sensitive information. Where a customer enables and uses these features, the customer, as controller, is responsible for establishing a lawful basis and obtaining any consents required. We process such data only as instructed by the customer.
Kolo is a workplace product and is not directed to children. We do not knowingly collect personal data from anyone under 16, except where such data is provided by a customer about an employee and its processing is lawful.
We may update this Privacy Policy from time to time. We will post the updated version with a new “Last updated” date and, for material changes, take reasonable steps to notify you.
LimTC, [registered address], Ukraine. For any questions about this policy or your personal data, email hello@limtc.com.