Effective Date: July 13, 2026

Privacy Policy

General Cherry ("Company", "we", "us", or "our") is a Ukrainian defence technology company committed to responsible innovation and the protection of individual rights. This Privacy Policy explains how we collect, use, disclose, and safeguard personal data obtained through our website at https://gencherry.com (the "Site"), as well as through any related services, communications, or business interactions.

By accessing or using our Site, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with its terms, please discontinue use of the Site.

Data Controller

The data controller responsible for your personal data is:

General Cherry
Legal entity: CENTER OF UNMANNED TECHNOLOGIES
Legal address: Ukraine, 08132, Vyshneve town, 37 Kyivska Street
Website: https://gencherry.com/en
Contact: privacy@gencherry.com

Information We Collect

We may collect the following categories of personal data:

Information You Provide Directly

Full name and professional title
Business or personal email address
Organization or company name
Country of residence or operation
Content of messages sent via contact forms or email

Information Collected Automatically

IP address and approximate geographic location
Browser type, version, and operating system
Pages visited and time spent on the Site
Referring URLs and navigation paths
Device identifiers and screen resolution

Information from Third Parties

In limited circumstances, we may receive data from publicly available sources, partner organizations, or background-screening services where required for security or compliance purposes.

Legal Basis and Purposes of Processing

We process your personal data on the following legal bases and for the following purposes:

Legitimate interest: Operating and improving the Site; responding to enquiries; conducting market research and business development activities.
Contractual necessity: Fulfilling obligations arising from agreements with clients, partners, and suppliers.
Legal obligation: Compliance with applicable Ukrainian law, export control regulations, anti-money laundering requirements, and international sanctions regimes.
Consent: Sending marketing communications or newsletters, where you have opted in. You may withdraw consent at any time.
Vital interests / public interest: Where processing is necessary to protect security interests relevant to national defence or critical infrastructure, in accordance with applicable law.

How We Share Your Data

We do not sell personal data. We may share data in the following circumstances:

Service providers and processors acting on our behalf (e.g., hosting, analytics, CRM), bound by data processing agreements. Before engaging any processor, we conduct due diligence and enter into a Data Processing Agreement (DPA) in accordance with Article 28 of the GDPR.
Government authorities, regulators, or law enforcement where we are legally required to do so, including under Ukrainian national security legislation.
Verified defence and government partners where data sharing is necessary for programme delivery and subject to appropriate safeguards.
Professional advisors (lawyers, auditors) under obligations of confidentiality.
Successors in interest in the event of a merger, acquisition, or asset transfer.

International Data Transfers

As a company operating in the defence sector with international partners, data may be transferred to and processed in countries outside Ukraine. Where such transfers occur, we ensure appropriate safeguards are in place — such as standard contractual clauses, adequacy decisions, or equivalent mechanisms — consistent with the requirements of Ukrainian personal data protection law and, where applicable, the EU General Data Protection Regulation (GDPR).

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes set out in this Policy, or as required by applicable law. Enquiry data is typically retained for up to three (3) years. Data processed under legal or regulatory obligations may be retained for longer periods as prescribed by law.

Cookies and Tracking Technologies

Our Site may use cookies and similar technologies for the following purposes:

Essential cookies: required for the Site to function correctly.
Analytics cookies: to understand how visitors use the Site and improve its performance.
Preference cookies: to remember your settings and language preferences.

You may control cookie settings through your browser. Disabling certain cookies may affect site functionality. For full details, please refer to our separate Cookie Policy.

Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

Right of access – to obtain a copy of your personal data.
Right to rectification – to correct inaccurate or incomplete data.
Right to erasure – to request deletion, subject to applicable legal obligations.
Right to restriction – to limit how we process your data in certain circumstances.
Right to data portability – to receive your data in a structured, machine-readable format.
Right to object – to processing based on legitimate interests or for direct marketing.
Right to withdraw consent – at any time, where processing is consent-based.

To exercise any of these rights, please contact us at privacy@gencherry.com. We will respond within 90 days. Please note that certain rights may be restricted where processing is necessary for national security, defence, or law enforcement purposes.

You also have the right to lodge a complaint with the Ukrainian Commissioner for Human Rights (Уповноважений Верховної Ради України з прав людини) or another competent supervisory authority in your country of residence.

Security

We implement technical and organisational measures appropriate to the sensitivity of the data we handle and the threat environment in which we operate. These include encryption in transit and at rest, access controls, audit logging, and regular security assessments. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

Children's Privacy

Our Site is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected such data, please contact us immediately and we will take steps to delete it.

Third-Party Links

Our Site may contain links to external websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies independently.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in law, our operations, or data practices. Material changes will be notified on this page with an updated effective date. We encourage you to review this Policy periodically.

For any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact:

Data Protection Contact: General Cherry
Email: privacy@gencherry.com
Website: https://gencherry.com/en