Privacy Policy

Personal data

Personal data is all data that relates to you personally as a data subject and enables your direct or indirect identification. The data includes information such as name, address, phone number and date of birth. Information that cannot be linked to your identification, such as favorite websites or the number of users of a site, is not considered personal data.

Wellbon respects the privacy of the personal data subjects and guarantees the fullest of protection. The purpose of the Privacy Policy is to inform you on the personal data we collect, how we use it, who we can share it with, the rights you have regarding the usage of your personal data, and how you can review and change it.

Purposes of processing. Legal basis for processing.

Wellbon processes personal data only if necessary or based upon your consent. The purposes of processing and the legal grounds are the following:
3.1 For the performance of a contract or in the context of a pre-contractual relationship
For pre-contractual and contractual reasons, we need personal data to offer and provide our services and products, to comply with the obligations arising from our pre-contractual relations and contractual agreements with you or the entities you represent.

The data may be processed for communication and response to inquiries and transactions, for provision of products and services, for the administration of customer accounts, including for management and maintenance of our products and services, for corrections, improvements and updates, etc.

We use the received personal data and other data to better understand our customers and visitors on our Website and the way they interact with it. Wellbon uses the information and personal data to improve its customer experience, implement your choices, get to know you better, maintain and improve the accuracy of the information it stores about you, improve the quality and reliability of its products, services and Website, identify problems and undertake actions as well as to improve the accuracy of our records.The legal basis is usually Art. 6 (1) b) of the GDPR since the processing is required for the performance of a contract or the pre-contractual relationship initiated by you.

3.2 For fulfillment of regulatory obligations applicable to Wellbon
Wellbon has legal requirements to collect and store for certain evidence of identification of the persons with whom it enters into a relationship, as well as to store information in connection with payments made and received by contractors. In such limited cases, your personal data as representing the client will be stored until the expiration of the statutory deadlines under Ukrainian law.

The legal basis in this case is Art. 6 (1) c) of the GDPR – processing is necessary to comply with a legal obligation that applies to the administrator.

3.3 For marketing purposes
If you give consent to Wellbon to our newsletter, your personal data (name, e-mail, address) will be processed to provide you with the latest information on offers, news, products and services. Also, based on your consent, we will contact you to provide information about our events or partner events in which we participate and a profile of the event. If you are participating in a Wellbon event or a partner event, Wellbon may post a photo on our Website for publication purposes about the event.

You have the right to object at any time to the processing of personal data for marketing purposes. To exercise your right, simply contact us using the contact details above or click the link in the marketing message. You can withdraw your consent at any time. If you unsubscribe from our emails and newsletters or withdraw your consent, the relevant data will be removed or blocked from the list and will no longer be processed for these purposes unless you provide new consent for their processing for marketing purposes.If you are a regular visitor to our Website and/or seem interested in our product portfolio, you may be shown a teaser with an invitation to contact us voluntarily.If the personal data is processed based on explicit consent, including for marketing purposes, the provision of personal data is not mandatory. The legal basis for this data processing shall be the consent according to Art. 6 (1) (a) of the GDPR;

3.4 Visiting our website

Wellbon is committed to maintaining the privacy of users of our website. When you visit the website, the web servers always temporarily store for connection and setup and security purposes the connection data of the computer connecting to the site, a list of the web pages you visit within the site, the date and duration of your visit, IP the address of your device, the identification of the type of browser and operating system used, and the website through which you linked to our site. Additional personal data such as your name, address, telephone number, or email address will not be collected unless you provide this data voluntarily, e.g. while completing an online contact form, as part of a registration, survey, contract performance, or request for information.The legal basis for the processing of the above categories of data is Art. 6 (1) (a) of the European General Data Protection Regulation (GDPR). Due to the mentioned purposes, in particular to ensure security and seamless connection setup, we also have a legitimate interest in processing this data.Web tracking data will be stored for a period of 36 months and then automatically deleted. We also use cookies, tracking tools, and targeting measures. You can get more details in our cookie policy, which is on the MentorMate website.

3.5 Online presence and optimization of our website

We may use tracking software to determine how many users visit our Website and how often. We do not use this software to collect individual personal data or individual IP addresses. The data is used only in an anonymous and aggregated form for statistical purposes and Website development.

The legal basis for the collection and use of personal data depends on the type of personal data and the specific context in which we collect them and the purposes for which they are used. When it is necessary to ask you to provide us with personal data to comply with legal requirements or to fulfill a contract with you, we will provide the necessary information, including whether the provision of personal data is mandatory or not (and possible consequences if you do not provide personal data). Similarly, if we collect and use personal data due to the existence of our legitimate interests (or that of a third party) we will specify at the appropriate time or upon request what these legitimate interests are. If you have any questions or need further clarification about the legal basis on which we collect and use your personal data, please contact us using the contact details provided in this Privacy Policy.

3.6 Processing to protect the legitimate interests of MentorMate or a third party

In limited cases and to protect our legitimate interests, Wellbon will process personal data. In this case, the processing shall be admissible only to the extent that the interests or fundamental rights and freedoms of the data subject which require the protection of personal data take precedence over such interests, in particular where the data subject is a child.

Principles of processing Personal data

Wellbon observes the following principles in the processing of your personal data:
- legality, good faith and transparency;l
- imitation of processing purposes;
- relevance to the purposes of processing and minimizing the collection of personal data;
- accuracy and timeliness of the data;
- limitation of storage to achieve the objectives;
- integrity and confidentiality of the processing and ensuring an appropriate level of security of personal data.

Retention periods

The personal data is stored and processed for the following term:
- for a period of 5 years – when the personal data are obtained for the performance of contracts or pre-contractual relationships. The 5 years period starts from the latter of the two dates: the date of correspondence on the possible conclusion of a contract or the date of execution of a contract;

- for the relevant statutory term – if the personal data is collected and processed based on fulfillment statutory obligation of Wellbon;

- Until the data subject has exercised the right to withdraw his or her consent – when the personal data is processed for marketing purposes, incl. information on events, training, and publications to job applicants, if they provided us with explicit consent. The withdrawal of consent can be submitted at any time and shall not affect the lawfulness of processing based on consent before its withdrawal;

- for a period of 5 (five) years – when personal data is processed to protect our legitimate interests – protection of the MentorMate website, systems and trade secrets..

Data security

Wellbon undertakes technical and organizational security measures to ensure the most comprehensive protection of personal data from unwanted access. We use an encryption procedure in some areas to prevent the misuse of third-party data in addition to the usage of secure work environment. Our data security applies the relevant current level of technology. For example, your data is stored in a secure operating environment that is not accessible to the public. In certain cases, your data is encrypted by Secure Socket Layer (SSL) technology during transmission to third parties.We make every reasonable effort to protect your personal information.

Use of the Wellbon website by children.

We do not intend our websites or online services to be used by anyone under the age of 16. If you are a parent or guardian and you think that we may have collected information about a child, please contact us at

Sharing Your Information

We may share your information as follows or as otherwise described in this Privacy Policy:

- In response to legal process;
- In order to investigate or remedy potential violations of our user agreements or policies, or to protect the rights, property and safety of Wellbon, our users or others;
- With our subsidiaries and related companies (acting as our subcontractors and/or data processors);In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; andWith your consent or at your direction.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you..

Links to Other Websites

Our Website may contain links to third party websites. These links are provided solely as a convenience to you. By linking to these websites, we do not create or have an affiliation with, or sponsor such third-party websites. The inclusion of links within our Website does not constitute any endorsement, guarantee, warranty, or recommendation of such third-party websites. Wellbon has no control over the legal documents and privacy practices of third-party websites; as such, you access any such third-party websites at your own risk.

Amendments to this Privacy Policy

We may change this Privacy Policy from time to time. If we decide to make changes to this Privacy Policy, we will update the Privacy Policy date at the top of the policy, and post the amended Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.