Privalexx Ukraine 
Privacy by Default requires that the most privacy‑friendly settings apply automatically as soon as a user begins using a product. In other words, default settings should only allow processing of personal data that is strictly necessary for the specific purpose. Any data collection or processing beyond that must be actively enabled by the user — no pre‑ticked boxes, no hidden opt‑outs
Why this is particularly important for Ukrainian providers
For companies expanding into the EU, Privacy by Default is not merely good practice but part of the legal expectations under the GDPR. EU users and business partners expect products to be privacy‑sparing, transparent and controllable by default. A privacy‑friendly default configuration also reduces the complexity of legally required consent processes and thus lowers compliance risks.
Implementation in product design and operations
Privacy by Default should be embedded in UX decisions and technical defaults. During account setup this means requesting only the information that is truly necessary; optional marketing and tracking settings must be disabled and require an active opt‑in. For data storage and retention, short, documented default retention periods are advisable — automatic deletion or anonymisation processes should be implemented. With regard to third parties, Privacy by Default means: no data sharing without an explicit, informed consent or a clearly justified legal basis. Technically, Time‑to‑Live fields, retention jobs in databases and automated workflows can reliably enforce deletion requirements.
An important aspect is transparency: users must be able to easily see which data are collected and how to disable or delete them. A privacy dashboard or easily accessible privacy settings help to build trust.
Practical examples
In a mobile app, location access should be off by default; the app may operate with reduced functionality until the user explicitly grants access. Analytics tools should, by default, collect only aggregated or pseudonymised data; more detailed usage data require a clear consent. Newsletter signup forms must not be pre‑checked — users must actively agree.
UX and avoiding dark patterns
Privacy by Default also requires that the interface does not push users toward less privacy‑friendly choices. Dark patterns — such as hard‑to‑find opt‑outs, confusing language, or visually manipulative buttons — must be avoided. Interfaces should be clear and understandable and available in relevant languages (for example Ukrainian and English) so that EU users can easily understand and evaluate their options.
Adaptations for international products
While a privacy‑friendly default configuration is recommended as a global standard, country‑specific adaptations may be necessary — these must be legally justified, documented and made transparent. Where local law imposes additional requirements, these should be added without falling below the minimum necessary protection standards.
Conclusion: first steps for implementation
Review the default settings in your products, disable all non‑essential data processing by default, implement automated deletion workflows and design clear and visible opt‑in mechanisms. A privacy dashboard gives users control and builds trust. As an EU representative, we are happy to support you with UI reviews, retention concepts and embedding privacy‑friendly defaults.
“Necessary” means only the data that is strictly required to fulfil the specific purpose (e.g. for performance of a contract). Anything beyond that must be optional and legally justified (e.g. by consent).
No. Consents must be voluntary, informed and unambiguous. Pre‑filled or pre‑ticked boxes are not permissible under the GDPR.
By using retention policies in databases, TTL fields, periodic deletion jobs and workflows that trigger deletions or anonymisations. It is important to log and provide evidence that deletions have been carried out.
A privacy‑friendly default configuration is recommended as a global standard. Country‑specific adjustments are possible but must be documented and legally justified.
You will start with less detailed personal data, which increases the need for robust aggregation and pseudonymisation procedures. For more detailed, personal analyses you will need a legal basis or an informed consent.