Last updated: 14 September 2026

1. General

This Privacy Policy explains what personal data LLC HUDVIL TEKHNIKAL UKRAINA (referred to below as GoodWill Tech, we) collects when you use the good-will-tech.com website and when we provide our services, why we process it, and what rights you have in relation to your data.

The data controller is:

• Name: LLC HUDVIL TEKHNIKAL UKRAINA
• Registration code: 43625113
• Address: 6 Mykoly Shepelieva Street, Kyiv, Ukraine
• Email: super@good-will.biz

We process personal data in accordance with the Law of Ukraine On Personal Data Protection and, for data subjects in the European Union, with the General Data Protection Regulation (GDPR).

2. Data we collect through the website

When you fill in a form, subscribe to our newsletter or book a demonstration, we collect your first and last name, email address, phone number, company name and job title, and the content of your enquiry.

Automatically, while you browse the site, we and our providers receive your IP address and approximate location, browser type and version, operating system and device type, the pages you viewed and the referring source, and cookie identifiers.

We do not collect special categories of data through the website, and we do not knowingly collect data of people under 16.

3. Purposes and legal bases

Responding to your enquiry, consulting you and preparing a commercial proposal — steps taken at the request of the data subject prior to entering into a contract. Sending informational and marketing materials — your consent, which you may withdraw at any time through the Unsubscribe link in any email. Website analytics and improvement — legitimate interest. Serving and measuring advertising — your consent. Meeting statutory requirements — compliance with a legal obligation.

4. Data we process when providing our Threads presence service

GoodWill Tech operates a managed social media presence service for client businesses on Threads. When a client engages this service, the client authorises our application to access their own Threads account through Meta's official authorisation flow. In relation to that data GoodWill Tech acts as a processor on the client's behalf, and the client is the controller.

Through the Threads API our application accesses:

• the client's own posts and the replies to them;
• public Threads posts matching the professional keywords agreed with the client, so that we can identify relevant industry discussions;
• mentions of the client's brand;
• metrics for the client's account and for individual published posts.

The application also publishes replies and posts on the client's behalf. Every published item is reviewed and approved by a person before it is sent.

We do not access private messages, contact lists, follower lists or any data beyond the scope described above.

Access tokens and retrieved content are stored encrypted on infrastructure operated by GoodWill Tech and are used solely to provide the service to the client who granted access. We do not sell this data, do not share it with other clients, do not combine it into cross-client datasets, and do not use it to train general-purpose models.

A client may revoke our access at any time in their Threads account settings or by writing to super@good-will.biz. Upon revocation, or upon termination of the contract, we stop processing immediately and delete the client's data within 30 days unless a longer retention period is required by law.

Public posts by third parties that our system retrieves in order to find relevant discussions are retained only for as long as is necessary to prepare and publish a reply, and in any case no longer than 90 days.

5. Who we share data with

We do not sell your personal data. To operate the website and communicate with you we engage providers who process data on our instructions: HubSpot Inc. (CRM, forms, mailings, analytics), Meta Platforms Inc. (serving and measuring advertising on Facebook and Instagram, and the Threads API), Google LLC (web analytics). We may also disclose data at the request of public authorities where required by law.

6. International transfers

Our providers are located in the United States and other countries outside Ukraine and the EEA. Transfers are made on the basis of the Standard Contractual Clauses approved by the European Commission, or other safeguards provided for by law.

7. Retention

Data from contact forms — up to 3 years from the last interaction. Newsletter subscriber data — until consent is withdrawn. Data processed as part of the Threads presence service — as described in section 4. Data required to meet statutory obligations — for the periods set by law. Once the period ends, data is deleted or anonymised.

8. Your rights

You have the right to be told what data of yours we process and to receive a copy of it; to have inaccurate or incomplete data corrected; to request erasure; to restrict or object to processing; to withdraw consent at any time; to receive your data in a structured format; and to lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or with the supervisory authority where you live in the EU. To exercise any of these rights, write to super@good-will.biz. We respond within 30 calendar days.

9. Cookies

The site uses cookies — small text files stored in your browser. Necessary cookies keep the site working. Analytics cookies help us understand how visitors use the site. Marketing cookies are used to serve relevant advertising and measure its effectiveness. You can manage cookies in your browser settings or decline optional categories in the consent banner.

10. Security

We apply organisational and technical safeguards: encrypted connections (HTTPS), encryption of stored access credentials, role-based access control, activity logging, and regular software updates. Only employees who need it for their duties have access to personal data.

11. Changes to this Policy

We may update this Policy. The current version is always available at this address and the date of the last update is shown at the top of the page.

12. Contact

For any questions about the processing of personal data, contact us: LLC HUDVIL TEKHNIKAL UKRAINA, 6 Mykoly Shepelieva Street, Kyiv, Ukraine. Email: super@good-will.biz.