Privacy Policy

Regulations on the processing and protection of personal data in personal data databases owned by the seller

Contents

General concepts and scope
List of personal data databases
Purpose of personal data processing
Procedure for processing personal data: obtaining consent, notification of rights and actions with personal data of the personal data subject
Location of the personal data database
Conditions for disclosing information about personal data to third parties
Protection of personal data: methods of protection, responsible person, employees who directly process and/or have access to personal data in connection with the performance of their official duties, storage period of personal data
Rights of the personal data subject
Procedure for working with requests from the personal data subject
Additional methods of tracking personal data
State registration of the personal data database

1. General concepts and scope

1.1. Definition of terms:

personal database - a named set of organized personal data in electronic form and/or in the form of personal data files;

responsible person - a designated person who organizes work related to the protection of personal data during their processing, in accordance with the law;

personal database owner - a natural or legal person who is granted the right to process these data by law or with the consent of the personal data subject, who approves the purpose of processing personal data in this database, establishes the composition of these data and the procedure for their processing, unless otherwise specified by law;

State Register of Personal Databases - a single state information system for collecting, accumulating and processing information on registered personal database;

publicly available sources of personal data - directories, address books, registers, lists, catalogs, other systematized collections of open information that contain personal data, posted and published with the consent of the personal data subject. Social networks and Internet resources in which the personal data subject leaves their personal data are not considered publicly available sources of personal data (except for cases when the personal data subject explicitly states that the personal data is posted for the purpose of their free distribution and use);

consent of the personal data subject - any documented, voluntary expression of will of an individual to grant permission for the processing of his personal data in accordance with the formulated purpose of their processing;

depersonalization of personal data - removal of information that allows identifying a person;

personal data processing - any action or set of actions performed in whole or in part in an information (automated) system and/or in personal data filing systems, which are related to the collection, registration, accumulation, storage, adaptation, modification, updating, use and dissemination (dissemination, sale, transfer), depersonalization, destruction of information about an individual;

personal data - information or a set of information about an individual who is identified or can be specifically identified;

personal data database administrator - an individual or legal entity who is granted the right to process this data by the owner of the personal data database or by law. A person who is entrusted by the owner and/or the owner of the personal data database to carry out technical work with the personal data database without access to the content of the personal data is not a personal data database administrator;

personal data subject - a natural person whose personal data is processed in accordance with the law;

third party - any person, except for the personal data subject, the owner or manager of the personal data base and the authorized state body for personal data protection, to whom the owner or manager of the personal data base transfers personal data in accordance with the law;

special categories of data - personal data about racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties and trade unions, as well as data concerning health or sex life.

1.2. This Regulation is mandatory for application by the responsible person and employees of the seller who directly process and/or have access to personal data in connection with the performance of their official duties.

2. List of personal data bases

2.1. The Seller is the owner of the following personal data bases:

personal data base of counterparties.

3. Purpose of processing personal data

3.1. The purpose of processing personal data in the system is to ensure the implementation of civil legal relations, the provision, receipt and payment for purchased goods and services in accordance with the Tax Code of Ukraine, the Law of Ukraine "On Accounting and Financial Reporting in Ukraine".

4. Procedure for processing personal data: obtaining consent, notification of on the rights and actions with the personal data of the subject of personal data

4.1. The consent of the subject of personal data must be a voluntary expression of the will of an individual to grant permission for the processing of his personal data in accordance with the formulated purpose of their processing.

4.2. The consent of the subject of personal data may be provided in the following forms:

a document on a paper medium with details that allow to identify this document and the individual;
an electronic document that must contain mandatory details that allow to identify this document and the individual. The voluntary expression of the will of an individual to grant permission for the processing of his personal data should be certified by an electronic signature of the subject of personal data;
a mark on an electronic page of a document or in an electronic file that is processed in an information system based on documented software and technical solutions.

4.3. The consent of the personal data subject is provided during the registration of civil legal relations in accordance with current legislation.

4.4. Notification of the personal data subject about the inclusion of his personal data in the personal data base, the rights defined by the Law of Ukraine "On Personal Data Protection", the purpose of data collection and the persons to whom his personal data is transferred is carried out during the registration of civil legal relations in accordance with current legislation.

4.5. Processing of personal data about racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, as well as data relating to health or sexual life (special categories of data) is prohibited.

5. Location of the personal data base

5.1. The personal data bases specified in Section 2 of these Regulations are located at the address of the seller.

6. Conditions for disclosing information about personal data to third parties

6.1. The procedure for accessing personal data of third parties is determined by the terms of the consent of the personal data subject provided to the personal data controller for the processing of these data, or in accordance with the requirements of the law.

6.2. Access to personal data is not provided to a third party if the specified person refuses to assume obligations to ensure compliance with the requirements of the Law of Ukraine "On Personal Data Protection" or is unable to provide them.

6.3. The subject of relations related to personal data submits a request for access (hereinafter referred to as the request) to personal data to the personal data controller.

6.4. The request shall specify:

surname, first name and patronymic, place of residence (place of stay) and details of the document certifying the individual submitting the request (for an individual - the applicant);

name, location of the legal entity submitting the request, position, surname, first name and patronymic of the person certifying the request; confirmation that the content of the request corresponds to the powers of the legal entity (for a legal entity - the applicant);
surname, first name and patronymic, as well as other information that allows identifying the individual in respect of whom the request is made;
information about the personal data base in respect of which the request is submitted, or information about the owner or administrator of this personal data base;
list of personal data requested;
purpose and/or legal grounds for the request.

6.5. The term for examining the request for the purpose of its satisfaction may not exceed ten working days from the date of its receipt. During this period, the owner of the personal data base shall notify the person submitting the request that the request will be satisfied or that the relevant personal data shall not be provided, indicating the grounds specified in the relevant regulatory legal act. The request shall be satisfied within thirty calendar days from the date of its receipt, unless otherwise provided by law.

6.6. Postponement of access to personal data of third parties is allowed if the necessary data cannot be provided within thirty calendar days from the date of receipt of the request. In this case, the total term for resolving the issues raised in the request may not exceed forty-five calendar days.

6.7. The notification of the postponement shall be notified to the third party who submitted the request in writing with an explanation of the procedure for appealing such a decision.

6.8. The notification of the postponement shall indicate:

the last name, first name and patronymic of the official;

date of sending the notification;
reason for the postponement;
period within which the request will be satisfied.

6.9. Refusal of access to personal data is allowed if access to them is prohibited by law.

6.10. The notification of refusal shall indicate:

surname, first name, patronymic of the official who refuses access;
date of sending the notification;
reason for the refusal.

6.11. The decision to postpone or refuse access to personal data may be appealed to the court.

7. Protection of personal data: methods of protection, responsible person, employees who directly process and/or have access to personal data in connection with the performance of their official duties, the period of storage of personal data

7.1. The owner of the personal database is equipped with system and software and hardware and communication means that prevent loss, theft, unauthorized destruction, distortion, forgery, copying of information and meet the requirements of international and national standards.

7.2. The responsible person organizes work related to the protection of personal data during their processing, in accordance with the law. The responsible person is determined by the order of the owner of the personal database.

The responsibilities of the responsible person regarding the organization of work related to the protection of personal data during their processing are specified in the job description.

7.3. The responsible person is obliged to:

know the legislation of Ukraine in the field of personal data protection;

develop procedures for access to personal data of employees in accordance with their professional or official or labor duties;
ensure that the employees of the Owner of the personal database comply with the requirements of the legislation of Ukraine in the field of personal data protection and internal documents regulating the activities of the Owner of the personal database regarding the processing and protection of personal data in personal database databases;
develop a procedure for internal control over compliance with the requirements of the legislation of Ukraine in the field of personal data protection and internal documents regulating the activities of the Owner of the personal database regarding the processing and protection of personal data in personal database databases, which, in particular, must contain norms regarding the frequency of such control;
notify the Owner of the personal database of the facts of violations by employees of the requirements of the legislation of Ukraine in the field of personal data protection and internal documents regulating the activities of the Owner of the personal database regarding the processing and protection of personal data in personal database databases no later than one working day from the moment such violations are detected;
ensure the storage of documents confirming the provision by the subject of personal data of consent to the processing of their personal data and notification of the specified subject of his rights.

7.4. In order to fulfill his duties, the responsible person has the right to:

receive the necessary documents, including orders and other administrative documents issued by the Owner of the personal data base, related to the processing of personal data;
make copies of the received documents, including copies of files, any records stored in local computer networks and autonomous computer systems;
participate in the discussion of the duties performed by him to organize work related to the protection of personal data during their processing;
submit proposals for improving activities and improving work methods, submit comments and options for eliminating identified shortcomings in the process of processing personal data;
receive explanations on issues related to the processing of personal data;
sign and endorse documents within the scope of his competence.

7.5. Employees who directly process and/or have access to personal data in connection with the performance of their official (labor) duties are obliged to comply with the requirements of the legislation of Ukraine in the field of personal data protection and internal documents regarding the processing and protection of personal data in personal data databases.

7.6. Employees who have access to personal data, including processing them, are obliged to prevent the disclosure in any way of personal data that was entrusted to them or that became known in connection with the performance of professional, official or labor duties. Such an obligation is valid after the termination of their activities related to personal data, except for cases established by law.

7.7. Persons who have access to personal data, including processing them, in case of violation of the requirements of the Law of Ukraine "On Personal Data Protection" are liable in accordance with the legislation of Ukraine.

7.8. Personal data shall not be stored for longer than is necessary for the purpose for which such data are stored, but in any case not longer than the data storage period specified in the consent of the personal data subject to the processing of such data.

8. Rights of the personal data subject

8.1. The personal data subject has the right:

to know about the location of the personal data base containing his personal data, its purpose and name, location and/or place of residence (stay) of the owner or administrator of this base or to give a corresponding instruction to obtain this information to persons authorized by him, except for cases established by law;
to receive information about the conditions for providing access to personal data, in particular information about third parties to whom his personal data contained in the relevant personal data base are transferred;
to access his personal data data contained in the relevant personal data base;
receive no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, a response on whether his personal data are stored in the relevant personal data base, as well as receive the content of his personal data that is stored;
submit a reasoned request with an objection to the processing of his personal data by state authorities, local self-government bodies in the exercise of their powers provided for by law;
submit a reasoned request to change or destroy his personal data by any owner and administrator of this base, if these data are processed illegally or are unreliable;
to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is unreliable or defamatory of the honor, dignity and business reputation of an individual;
to address issues of protection of their rights regarding personal data to state authorities, local self-government bodies, whose powers include the protection of personal data;
to apply legal remedies in case of violation of the legislation on personal data protection.

9. Procedure for working with requests from the subject of personal data

9.1. The subject of personal data has the right to receive any information about themselves from any subject of relations related to personal data, without specifying the purpose of the request, except for cases established by law.

9.2. The subject of personal data has access to data about themselves free of charge.

9.3. The personal data subject submits a request for access (hereinafter referred to as the request) to personal data to the owner of the personal data base.

The request shall specify:

the surname, first name and patronymic, place of residence (place of stay) and details of the document certifying the identity of the personal data subject;
other information that allows identifying the person of the personal data subject;
information about the personal data base in respect of which the request is submitted, or information about the owner or administrator of this base;
a list of personal data requested.

9.4. The term for examining the request for its satisfaction may not exceed ten working days from the date of its receipt. During this term, the owner of the personal data base shall notify the personal data subject that the request will be satisfied or the relevant personal data shall not be provided, indicating the grounds specified in the relevant regulatory legal act.

9.5. The request will be fulfilled within thirty calendar days from the date of its receipt, unless otherwise provided by law.

10. Additional methods of tracking personal data

10.1. We work with Microsoft Clarity and Microsoft Advertising to track how you use and interact with our website using behavioral indicators, heat maps, and session replay to improve and promote our products/services. Website usage data is collected using first-party and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. In addition, we use this information to optimize the site for the purpose of combating fraud/security and advertising. For more information about how Microsoft collects and uses your data, visit the official website of the service at the link: Microsoft Privacy Statement

11. State registration of the personal data database

11.1. State registration of personal data bases is carried out in accordance with Article 9 of the Law of Ukraine "On Personal Data Protection".