PRIVACY POLICY

Effective Date: September 16, 2026
Last Updated: September 16, 2026

Dobriansky Group LLC, ("Dobriansky Group," "Company," "we," "us," or "our"), respects your privacy and is committed to handling personal information responsibly.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit www.igordobrianskyi.com (the "Site"), submit an inquiry, request advisory or consulting services, communicate with us, or otherwise interact with Dobriansky Group LLC.

The Site presents the professional activities, background, experience, and advisory services of Igor Dobrianskyi. Any consulting or advisory engagement offered through or in connection with the Site is provided through Dobriansky Group LLC unless expressly stated otherwise in a written agreement.

For purposes of applicable privacy and data protection laws, Dobriansky Group LLC may act as the "controller," "business," or similar responsible entity with respect to personal information covered by this Privacy Policy.

This Privacy Policy is intended to apply to visitors and clients in the United States and internationally. Additional rights may apply depending on your location.

1. Scope

This Privacy Policy applies to personal information collected through or in connection with:

• this Site;

• contact, inquiry, or advisory request forms;

• email communications;

• meeting and scheduling services;

• consulting and advisory inquiries;

• prospective and existing client relationships;

• website analytics and similar technologies;

• professional and business communications; and

• other interactions in which this Privacy Policy is referenced.

This Privacy Policy does not govern websites, platforms, applications, or services operated independently by third parties.

2. Personal Information We May Collect

The information we collect depends on how you interact with us.

A. Contact Information

We may collect information such as:

• name;

• email address;

• telephone number;

• company or organization name;

• job title;

• professional role; and

• other contact information you voluntarily provide.

B. Business and Professional Information

If you inquire about advisory or consulting services, we may collect information such as:

• company information;

• industry;

• business model;

• company size or stage;

• professional background;

• business objectives;

• geographic markets;

• growth plans;

• business challenges;

• sales or partnership information;

• fundraising-related business information;

• project details;

• requested services; and

• other business information you choose to provide.

C. Communications

We may collect information contained in:

• emails;

• inquiry forms;

• meeting requests;

• messages;

• attachments;

• questionnaires;

• proposals;

• feedback; and

• other communications with us.

D. Client and Engagement Information

If you enter into a consulting or advisory relationship with Dobriansky Group LLC, we may maintain:

• contracts;

• statements of work;

• proposals;

• engagement details;

• invoices;

• payment records;

• project materials;

• meeting notes;

• deliverables; and

• other records reasonably related to the engagement.

E. Payment Information

We do not currently process payments directly through the Site.

If you enter into a paid engagement with Dobriansky Group LLC, payments may be requested and processed separately through invoices, banks, payment processors, or other third-party financial service providers.

We generally do not intend to collect or store complete payment card numbers, online banking passwords, or similar financial credentials ourselves.

Third-party payment providers process information according to their own terms and privacy policies.

F. Device and Technical Information

When you access the Site, we or service providers supporting the Site may automatically receive information such as:

• IP address;

• browser type;

• device type;

• operating system;

• approximate geographic location derived from IP address;

• language settings;

• referring website or URL;

• pages visited;

• time and date of visits;

• interactions with the Site;

• traffic information;

• cookie identifiers; and

• other technical or usage information.

G. Information From Other Sources

We may receive professional or business information from lawful sources, including:

• publicly available websites;

• professional networking platforms;

• company websites;

• public business directories;

• referrals;

• conferences and events;

• business partners; and

• professional contacts.

Where required by applicable law, we will provide any additional notice required when personal information is obtained from sources other than directly from the individual.

3. Sensitive Personal Information

We do not intentionally request sensitive personal information through the Site unless reasonably necessary for a specific lawful purpose.

Please do not submit Social Security numbers, passport numbers, government identification numbers, complete financial account credentials, medical information, biometric information, precise geolocation data, information concerning children, or other highly sensitive information unless we specifically request it and it is reasonably necessary.

If sensitive information is voluntarily provided to us, we will process it only as reasonably necessary for the purpose for which it was provided, as permitted by law, or with consent where required.

4. How We Collect Information

We may collect personal information:

• directly from you;

• automatically when you use the Site;

• through communications with you;

• through service providers acting on our behalf;

• from publicly available sources;

• from professional referrals or contacts; and

• from other lawful sources.

5. How We Use Personal Information

We may use personal information to:

• operate and maintain the Site;

• respond to inquiries;

• communicate with you;

• evaluate consulting or advisory requests;

• schedule meetings;

• determine whether a potential engagement is appropriate;

• prepare proposals and agreements;

• provide consulting and advisory services;

• manage current and prospective client relationships;

• create and deliver project materials;

• administer invoices and payment records;

• maintain business and accounting records;

• improve our Site, services, and communications;

• understand website usage and performance;

• maintain security;

• detect and prevent fraud, abuse, or unlawful activity;

• protect our legal rights;

• enforce agreements;

• resolve disputes;

• establish, exercise, or defend legal claims;

• comply with legal, tax, accounting, contractual, or regulatory requirements; and

• carry out another purpose disclosed when the information is collected.

We will not use personal information for materially incompatible purposes where applicable law requires additional notice or consent.

6. Legal Bases for Processing

Where the General Data Protection Regulation, UK GDPR, or another law requires a lawful basis for processing, we may rely on one or more of the following:

Contract and Pre-Contractual Steps

Processing may be necessary to:

• respond to your request;

• evaluate a proposed engagement;

• prepare an agreement;

• enter into a contract; or

• perform services.

Legitimate Interests

We may process information where reasonably necessary for legitimate interests including:

• operating our business;

• communicating with professional contacts;

• responding to inquiries;

• managing business relationships;

• improving our Site and services;

• maintaining network and information security;

• preventing misuse;

• protecting legal rights; and

• establishing or defending claims.

We consider applicable individual rights when relying on legitimate interests.

Consent

We may rely on consent where required, including for certain cookies, marketing activities, or other processing.

Where processing is based on consent, consent may generally be withdrawn at any time.

Withdrawal does not affect processing that lawfully occurred before withdrawal.

Legal Obligations

We may process information where necessary to comply with law, regulation, legal process, tax obligations, court orders, or lawful governmental requests.

Protection of Rights and Interests

Where permitted by applicable law, we may process personal information where necessary to protect legal rights, security, property, or the vital interests of an individual.

7. Google Sites, Cookies, and Similar Technologies

The Site is hosted using Google Sites.

Google and other service providers supporting the Site may use cookies and similar technologies to provide functionality, maintain security, remember preferences, analyze traffic, and measure website usage.

Such technologies may process information including:

• IP address;

• browser information;

• device information;

• cookie identifiers;

• approximate location;

• page activity; and

• interaction information.

Where required by applicable law, non-essential cookies or similar technologies subject to our control will be used only after the applicable consent requirements have been satisfied.

Visitors may also be able to manage cookies through browser settings or consent controls provided by Google or other applicable service providers.

Rejecting or disabling certain cookies may affect Site functionality or the accuracy of analytics information.

Google's collection and processing of information is also subject to Google's applicable privacy policies, terms, and data processing practices.

8. Analytics

We may use Google Analytics or comparable analytics services to understand how visitors use the Site.

Depending on configuration and user consent, analytics information may include:

• visits;

• page views;

• session information;

• approximate geographic location;

• device and browser information;

• traffic sources; and

• interactions with Site content.

We may use this information to:

• measure Site performance;

• understand visitor behavior;

• identify technical issues;

• improve content; and

• improve user experience.

Where applicable law requires consent before analytics technologies are activated, we intend to follow the applicable consent requirement.

9. Service Providers and Third Parties

We may use third parties to assist with business operations, including providers of:

• website hosting;

• cloud services;

• analytics;

• email;

• communications;

• scheduling;

• forms;

• document management;

• accounting;

• invoicing;

• payment processing;

• cybersecurity;

• professional services; and

• other business support services.

Such providers may process information on our behalf or, in certain circumstances, as independent controllers under their own privacy policies.

10. Disclosure of Personal Information

We may disclose personal information in the following circumstances.

Service Providers

We may provide information to service providers where reasonably necessary for them to perform services for us.

Professional Advisors

We may provide information to:

• attorneys;

• accountants;

• auditors;

• insurers;

• tax professionals;

• consultants; or

• other professional advisors.

Legal and Safety Requirements

We may disclose information if reasonably necessary to:

• comply with law;

• respond to legal process;

• comply with lawful governmental requests;

• enforce contracts;

• investigate fraud or security incidents;

• protect our rights or property;

• protect another person's safety or rights; or

• establish, exercise, or defend legal claims.

Business Transactions

Information may be transferred or disclosed in connection with a:

• merger;

• acquisition;

• financing;

• restructuring;

• asset sale;

• corporate reorganization;

• change of control;

• bankruptcy; or

• similar transaction.

At Your Direction

We may disclose information when you direct or authorize us to do so.

11. Sale, Sharing, and Targeted Advertising

Dobriansky Group LLC does not currently sell personal information for monetary consideration.

We do not currently use personal information collected directly through the Site for our own cross-context behavioral advertising or targeted advertising programs.

Third-party website infrastructure or analytics providers may independently process technical information as described in this Privacy Policy and under their own applicable terms.

Certain U.S. state privacy laws define terms such as "sale," "sharing," or "targeted advertising" more broadly than their ordinary meanings.

If any activity conducted through the Site is considered a sale, sharing, or targeted advertising activity under applicable law, eligible individuals may exercise any legally available opt-out rights.

We do not knowingly sell or share the personal information of individuals under the age threshold established by applicable law.

12. Global Privacy Control and Do Not Track

Some jurisdictions recognize browser-based or device-based privacy preference signals.

Where applicable law requires us to recognize a valid universal opt-out mechanism, including Global Privacy Control ("GPC"), we will honor the signal for processing activities to which the applicable law applies.

Traditional browser "Do Not Track" or "DNT" signals do not currently operate under a single uniform legal or technical standard.

Accordingly, except where applicable law requires otherwise, the Site may not respond to traditional DNT signals.

13. Data Retention

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected or as otherwise permitted or required by law.

Retention periods may depend on:

• the nature of the information;

• the purpose for which it was collected;

• whether a business relationship exists;

• contractual obligations;

• accounting requirements;

• tax requirements;

• insurance requirements;

• legal claims;

• applicable limitation periods;

• security needs; and

• regulatory or recordkeeping requirements.

General inquiries that do not result in an engagement may be deleted or anonymized when no longer reasonably necessary.

Client records may be maintained during an engagement and for an appropriate period afterward to satisfy legal, accounting, contractual, insurance, security, and recordkeeping requirements.

When information is no longer reasonably required, we may delete, anonymize, aggregate, or securely dispose of it, subject to applicable law and ordinary backup processes.

14. Information Security

We use reasonable administrative, technical, and organizational safeguards appropriate to the nature of the information we process.

These measures are intended to protect information against:

• unauthorized access;

• unauthorized disclosure;

• misuse;

• alteration;

• destruction; and

• accidental loss.

However, no Internet transmission, email system, website, cloud platform, or electronic storage system can be guaranteed to be completely secure.

Accordingly, we cannot guarantee absolute security.

15. International Data Transfers

Dobriansky Group LLC is based in the United States.

Personal information may therefore be processed or stored in the United States or in other countries where our service providers operate.

Privacy and data protection laws in those jurisdictions may differ from laws in your country.

Where applicable law requires specific safeguards for an international data transfer, we will use an appropriate lawful transfer mechanism where required, which may include:

• adequacy decisions;

• Standard Contractual Clauses;

• applicable UK transfer mechanisms;

• contractual protections; or

• another legally recognized transfer mechanism.

16. Your Privacy Rights

Depending on where you live and the law that applies, you may have rights including the right to:

• know whether we process personal information about you;

• access personal information;

• obtain information regarding categories of information collected;

• request correction of inaccurate information;

• request deletion;

• obtain a portable copy of certain information;

• object to certain processing;

• restrict certain processing;

• opt out of certain sales of personal information;

• opt out of certain sharing;

• opt out of targeted advertising;

• opt out of certain profiling or automated decision-making;

• limit certain uses of sensitive personal information;

• withdraw consent;

• obtain information regarding recipients of personal information;

• appeal certain privacy request decisions; and

• exercise privacy rights without unlawful discrimination or retaliation.

These rights are not absolute.

Applicable law may allow or require us to deny or limit a request in certain circumstances.

17. Exercising Your Privacy Rights

Privacy requests may be submitted to:

dobrianskygroup@gmail.com

Please describe your request with enough detail for us to understand and process it.

We may request information reasonably necessary to verify:

• your identity;

• the information to which the request relates; or

• an authorized agent's authority to act for you.

Verification information will be used only as reasonably necessary to process the request.

Where applicable law permits an authorized agent to submit a request, we may require appropriate evidence of authorization.

We will respond within the period required by the applicable law.

Where applicable law provides a right to appeal a decision concerning a privacy request, an appeal may be submitted to the same email address with the word "Appeal" in the subject line.

18. U.S. State Privacy Rights

Residents of certain U.S. states may have privacy rights under applicable state consumer privacy laws.

Depending on the state, the law, applicable thresholds, and the nature of our activities, those rights may include:

• access;

• confirmation;

• correction;

• deletion;

• portability;

• opt-out rights;

• sensitive data rights;

• profiling rights;

• targeted advertising rights;

• authorized agent rights; and

• appeal rights.

Not every U.S. state privacy statute applies to every company.

Where a state privacy law applies to Dobriansky Group LLC, we intend to honor the rights required by that law.

Nothing in this Privacy Policy is intended to waive any non-waivable consumer right.

19. California Privacy Disclosures

This section supplements the remainder of this Privacy Policy for California residents where applicable.

Categories of Information

During the preceding 12 months, depending on the nature of the interaction, we may have collected categories of information such as:

• identifiers;

• contact information;

• customer or business records;

• commercial information;

• Internet or electronic network activity;

• approximate geolocation derived from technical information;

• professional or employment-related information;

• communications;

• business information; and

• information voluntarily submitted by an individual.

The sources, purposes, and categories of recipients are described elsewhere in this Privacy Policy.

California Consumer Rights

Where applicable, California residents may have rights to:

• know;

• access;

• correct;

• delete;

• obtain portable information;

• opt out of sale or sharing;

• limit certain uses of sensitive personal information; and

• receive non-discriminatory treatment for exercising privacy rights.

Requests may be submitted to dobrianskygroup@gmail.com.

Sale and Sharing

We do not currently sell personal information for monetary consideration.

If any activity becomes legally classified as "selling" or "sharing" under applicable California law, we will provide any mechanism required by applicable law.

Minors

We do not knowingly sell or share the personal information of individuals under 16 years of age.

Financial Incentives

We do not currently offer financial incentives or price or service differences in exchange for the collection, sale, or sharing of personal information.

California Shine the Light

We do not disclose personal information to third parties for their own direct marketing purposes in the manner contemplated by California's "Shine the Light" law.

20. European Economic Area, United Kingdom, and Switzerland

Where applicable European, UK, or Swiss privacy law applies, individuals may have rights including:

• access;

• rectification;

• erasure;

• restriction;

• data portability;

• objection;

• withdrawal of consent; and

• the right to complain to an applicable supervisory authority.

Where processing is based on consent, consent may generally be withdrawn at any time.

Where processing is based on legitimate interests, individuals may have a right to object based on their particular circumstances.

Where applicable law grants an unconditional right to object to direct marketing, we will honor that right.

Individuals may also lodge a complaint with the data protection authority responsible for the place where they live, work, or believe a violation occurred.

21. Canada, Brazil, Australia, and Other Jurisdictions

Individuals in other jurisdictions may have additional privacy rights under local law.

Depending on the applicable jurisdiction, those rights may include:

• access;

• correction;

• deletion;

• information regarding processing;

• withdrawal of consent;

• portability;

• objection;

• restriction; and

• the ability to complain to a privacy regulator.

Dobriansky Group LLC will honor such rights where applicable law requires us to do so.

22. Automated Decision-Making

We do not currently use personal information obtained through the Site to make decisions based solely on automated processing that produce legal or similarly significant effects concerning an individual.

If our practices materially change, we will provide any notice or rights required by applicable law.

23. Marketing Communications

Where permitted by law, we may communicate with you regarding:

• your inquiry;

• an existing or prospective engagement;

• requested information;

• relevant services; or

• a professional relationship.

Where consent is legally required for promotional communications, we will seek the required consent.

You may request that promotional communications stop by contacting us at dobrianskygroup@gmail.com or by using an unsubscribe function when available.

Transactional, administrative, legal, security, or engagement-related communications may continue where reasonably necessary.

24. Children's Privacy

The Site and Dobriansky Group LLC's consulting and advisory services are intended for adults and business professionals.

The Site is not directed to children under 13.

We do not knowingly collect personal information online from children under 13.

If we learn that we have collected personal information from a child in violation of applicable law, we will take reasonable steps to delete it.

If you believe a child has provided information to us, please contact us.

25. Third-Party Websites and Services

The Site may contain links to:

• social media platforms;

• scheduling tools;

• publications;

• companies;

• third-party websites;

• videos;

• external content; or

• other third-party services.

We do not control and are not responsible for the privacy, security, availability, content, or practices of independent third parties.

Your interaction with a third party is governed by that third party's terms and privacy practices.

26. Business Transfers

If Dobriansky Group LLC undergoes a merger, sale, financing, restructuring, acquisition, transfer of assets, reorganization, or similar transaction, personal information may be transferred as part of that transaction where permitted by law.

27. Changes to This Privacy Policy

We may update this Privacy Policy from time to time because of changes to:

• our business;

• the Site;

• our services;

• technology;

• service providers;

• legal requirements; or

• privacy practices.

The Last Updated date indicates when this Privacy Policy was most recently revised.

Where applicable law requires additional notice or consent for a material change, we will provide such notice or obtain such consent.

28. Contact Us

Questions, concerns, complaints, or privacy requests may be directed to:

Dobriansky Group LLC
Email: dobrianskygroup@gmail.com
Website: www.igordobrianskyi.com

29. No Expansion of Legal Rights

This Privacy Policy describes our privacy practices and is not intended to create contractual rights beyond those provided by applicable law.

Nothing in this Privacy Policy is intended to waive, restrict, or limit any right or obligation that cannot lawfully be waived, restricted, or limited.