This Privacy Policy (hereinafter referred to as the ‘Policy’) describes how Audiocasta Ltd. (hereinafter referred to as “We” or ‘the Company’) collects, uses, processes and protects the personal data of users of the Gramophone.ua website (hereinafter referred to as the ‘Website’).

Personal data is any information relating to an identified or identifiable natural person, such as, for example, your name, contact details or order information.

We follow the following principles when processing your personal data:

• we only collect personal data for specified, explicit, and legitimate purposes;
• we do not collect personal data beyond what is necessary to accomplish those purposes;
• we do not use personal data for purposes other than that for which the data was collected, except as stated herein, or with prior consent;
• we do not transfer personal data to third parties, except as stated herein, or with prior consent;
• we maintain technical and organizational measures to protect your personal data against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing;
• we do not store personal data longer than necessary to accomplish the purpose for which the data was collected or for which it is further processed, or as is required by law.

When you engage with the Company via various channels, including our websites, apps, dealers and customer support, we collect and process your personal data. The personal data that we collect and process can be categorized as follows:

• Your personal details, such as your first name (and, if you wish, your surname), email address, telephone number (if provided).
• Your invoicing information, such as your personal details as specified above, company name, your delivery information, your order information, such as product name, quantity, product name, date of purchase.
• Behavioural information collected via use of cookies and similar technologies like pixels, tags, and other identifiers in order to remember user preferences and to understand how our websites are used.

We only collect and process personal data if at least one of the below-mentioned purposes applies:

• we provide you with customized information on news, events, competitions and similar marketing content related to Audiocasta Ltd. and its partners, its products and products made in collaboration with third parties. Our processing in this regard is based on your consent;
• we provide you with links to relevant product software updates and make your future purchases easier by remembering your shipping details. Our processing is necessary for the purposes of the legitimate interests pursued by the Company, and such processing is not considered to be harmful towards you;
• we provide you with customer service, handle your requests or complaints, and provide you with product warranty support. Our processing is necessary for the performance of a contract, to which you are a party.

Should you choose not to provide us with the requested and necessary personal data in this regard, we might not be able to fully satisfy your request.

As a rule, we only store your personal data if you have given us your consent to do so. If you have subscribed to our newsletter(s), we may store your personal data in the databases of the services that provide the relevant services. If you are one of our partners, we may also store your information in our internal systems.

Our website uses the Sanity content management system. All data, including that which you leave in feedback forms, is stored on Sanity servers located outside Ukraine. By using our website, you consent to such international data transfer.

As a general principle, we collect and process data in order to facilitate or improve our products, services, or offers. We do not sell your personal data or share the said data with third parties, except to the extent stated in this privacy policy.

We may disclose your personal data to third parties to the extent required by law, court order or decision of a competent public authority, as well as to ensure compliance with Ukrainian legislation. In addition, we may share your personal data with the following third parties:

• third-party vendors carrying out services on our behalf, including billing, sales, IT support, advertising, analytics, research, customer service, product service support, shipping and purchase order fulfilment, data storage, validation, security, fraud prevention, payment processing, and legal services. Such third-party vendors have access to perform these services but are prohibited from using your personal data for other purposes;
• third parties in order to establish, exercise, or defend legal rights of the Company;
• third parties in the event of any merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of the Company's assets (including without limitation in connection with any bankruptcy or similar proceedings);
• other third parties subject to your consent.

When we disclose your personal data to a third party, we take all reasonable steps to ensure that those third parties are bound by confidentiality and privacy obligations with respect to the protection of your personal data. The disclosure is conducted in compliance with legal requirements, including entering into data processing agreements with the relevant third parties, to ensure that personal data is only processed in accordance with our instructions, applicable laws and regulations, and for the purpose specified by us and to ensure adequate security measures.

We do not keep your information longer than necessary. How long depends on the purposes for which we collect and use it.

Personal data related to our provision of direct marketing to you is kept and processed until you unsubscribe from our list.

Personal data related to one of our partnerships is kept and processed until the partnership ends.

Relevant personal information will be deleted after expiry of the above-mentioned periods, unless such data legitimately can be kept and processed for other legitimate processing purposes.

Audiocasta Ltd., Krasnyj Provulok, 8/10, 2, Odesa, Ukraine, is the operator and is responsible for processing your personal data.

9.1 Access to your personal data and data portability

You have the right to access and receive your personal data provided to the Company in a structured, commonly used and machine-readable format, and have the right to transmit this data to any third party, you should choose. If you want to access your personal data, please contact info@gramophone.ua.

9.2 Updating and/or deleting your personal data

We recommend that you update your personal data provided to the Company if it changes. To make changes to your personal data or to delete it, please contact us at info@gramophone.ua.

In order to ensure that your personal data processed by us is up-to-date, we request that you to check and, if relevant, update your personal data at least once a year.

9.3 Right to withdraw your consent

Receiving our newsletter is based on your consent. You have the right to withdraw your consent at any time. Withdrawal of your consent will not affect the lawfulness of processing conducted prior to the withdrawal.

If you withdraw your consent, the Company and third parties involved in personal data processing will cease to process your personal data, unless and to the extent the continued processing or storage is permitted or required according to the applicable personal data legislation or other applicable laws and regulations.

9.4 Right to restriction of processing and right to object

You have the right to restrict of processing of your personal data:

• if the personal data is not correct;
• if the processing is unlawful, but you oppose erasure of your personal data;
• if the Company no longer needs your personal data for the purposes of processing, but storing such data is requested by you for the establishment, exercise, or defence of legal claims; or
• if you have objected to processing, and if verification of whether Company still has legitimate interest in the given personal data is pending.

Furthermore, you have the right to object to processing of your personal data for direct marketing purposes. You can do so by unsubscribing from our marketing information by clicking on the unsubscribe link in the bottom of marketing communication from Company.

9.5 Right to complain

If you have a complaint regarding the Company’s handling of your personal information, please send your complaint to the Company via e-mail: info@gramophone.ua. We will do our best to help you as quickly as possible.

The website may contain links to third-party websites, applications and products, plugins (e.g. plugins for logging into social networks) or services (e.g. voice control function provided by Amazon or Google). Please note that the Company does not collect or process audio recordings on its own behalf, but only provides access to third-party services.

If you choose to use these websites, plug-ins or services, you may disclose your information to those third-parties. The Company is not responsible for the content or practices of those websites, plug-ins, or services. The collection, use, and disclosure of your personal data will be subject to the privacy policies of these third parties and not this privacy policy. We urge you to read the privacy and security policies of the relevant third-parties.

The Company does everything in its power to protect the security of your personal data. We use the necessary organisational, technical and administrative measures to protect your personal data under the Company's control, such as transfer, input and accessibility, as well as data separation.

If you have reason to believe that your interaction with Audiocasta Ltd. is no longer secure (for example, if you believe that the security of your data at the Company has been compromised), please notify us of the problem immediately.

The Company may modify or update this privacy policy when necessary to reflect changes in our products and services, changes in applicable legislation, regulations, or practice and to address customer feedback. Accordingly, please review it periodically. The date of the latest update is always provided at the bottom of the document.

If you have any questions regarding this Policy, please contact us by email at: info@gramophone.ua

Date of last update of the Policy: November 13, 2025.