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PRIVACY POLICY  

 

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

Content

1. General concepts and scope.

2. List of personal data bases.

3. Purpose of processing personal data.

4. The procedure for processing personal data: obtaining consent, reporting rights and actions with personal data of the subject of personal data.

5. Location of the personal data base.

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

7. Protection of personal data: methods of protection, the person in charge, 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.

8. Rights of the subject of personal data.

9. Procedure for handling requests of the subject of personal data.

10. State registration of the personal data base.

11. General concepts and scope.

1.1. Definition of terms:

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

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

the owner of the personal data base is an individual or legal entity who is granted the right to process this data by law or with the consent of the subject of personal data, approves the purpose of processing personal data in this database, establishes the composition of this data and procedures for their processing, unless otherwise specified by law;

State register of personal data bases - a unified state information system for collecting, accumulating and processing information about registered personal data bases;

publicly available sources of personal data - directories, address books, registers, lists, catalogs, other systematized collections of open information containing personal data posted and published with the consent of the subject of personal data.

Social networks and Internet resources in which the subject of personal data leave their personal data are not considered publicly available sources of personal data (unless the subject of personal data explicitly states that personal data is posted for the purpose of their free distribution and use);

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

anonymization of personal data - the seizure of information that allows you to identify a person;

processing of personal data - any action or set of actions performed in whole or in part in an information (automated) system and / or in personal data files related to the collection, registration, accumulation, storage, adaptation, modification, updating, use and distribution (distribution, 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;

manager of the personal data base - a natural or legal person who is granted the right to process this data by the owner of the personal data base or by law.

The owner and / or manager of the personal data base is not the manager of the personal data base;

subject of personal data - an individual in respect of whom, in accordance with the law, his personal data is processed;

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

special categories of data - personal data on racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, as well as data related to health or sex life.

1.2. This Regulation is mandatory for application by the responsible person and the seller's employees 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:

• database of personal data of counterparties.

 

3. Purpose of processing personal data.

3.1. The purpose of processing personal data in the system is to store and maintain data of contractors in accordance with Articles 6, 7 of the Law of Ukraine "On the Protection of Personal Data":.

3.2. The purpose of processing personal data is to ensure the implementation of civil law relations, the provision / receipt and implementation of payments for purchased goods / services in accordance with the Tax Code of Ukraine, the Law of Ukraine "On accounting and financial reporting in Ukraine."

4. The procedure for processing personal data: obtaining consent, reporting rights and actions with 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 to process his personal data in accordance with the stated purpose of their processing. The consent of the subject of personal data can be provided​​ in the following forms:

• a paper document with details, allows you to identify this document and an individual;

• an electronic document, which must contain mandatory details to identify this document and an individual. It is advisable to certify the voluntary expression of the will of an individual to grant permission for the processing of his personal data with the electronic signature of the subject of personal data.

• mark on the electronic page of the document or in the electronic file processed in the information system on the basis of documented software and hardware solutions.

4.2. The consent of the subject of personal data is provided when registering civil law relations in accordance with applicable law.

4.3. Notification of the subject of personal data about the inclusion of his personal data in the personal data base, the rights defined by the Law of Ukraine "On the Protection of Personal Data", the purpose of collecting data and the persons to whom his personal data is transferred is carried out when formalizing civil law relations in accordance with current legislation.

4.4. The processing of personal data on racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, as well as data related to health or sexuality (special categories of data) is prohibited.

5. Location of the personal data base.

5.1. The personal data bases specified in section 2 of this Regulation are located at the seller's address.

 

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 consent of the subject of personal data provided to the owner of the personal data base for the processing of this data, or in accordance with the requirements of the law.

6.2. Access to personal data to a third party is not provided if the specified person refuses to undertake obligations to ensure compliance with the requirements of the Law of Ukraine "On the Protection of Personal Data" or cannot 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 owner of the personal data base.

6.4. The request specifies:

• last name, first name and patronymic, place of residence (location) 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 complies with the powers of the legal entity (for the legal entity - the applicant);

• surname, first name and patronymic, as well as other information that allows you to identify the individual in respect of whom the request is made;

• information about the personal data base in respect of which the request is submitted, information about the owner or manager of this database;

list of personal data requested;

• the purpose of the request.

6.5. The term for studying a request for its satisfaction cannot exceed ten working days from the date of its receipt.

During this period, the owner of the personal data base notifies the person making the request that the request will be sufficient or the corresponding personal data cannot be provided, indicating the grounds specified in the relevant regulatory legal act.

The request is satisfied within thirty calendar days from the date of its receipt, unless otherwise provided by law.

6.6. All employees of the owner of the personal data base are obliged to comply with the confidentiality requirements with respect to personal data and information on securities and securities accounts.

6.7. The 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. At the same time, the total period for resolving the issues raised in the request cannot exceed forty-five calendar days.

6.8. The postponement notice is brought to the notice of the third party who submitted the request, in writing, with an explanation of the procedure for appealing such a decision.

6.9. The postponement message indicates:

• surname, name and patronymic of the official;

• date of sending the message;

• the reason for the delay;

• the period during which the request will be satisfied.

6.10. Denial of access to personal data is allowed if access to them is prohibited by law.

6.11. The refusal message indicates:

• surname, name, patronymic of the official who denies access;

• date of sending the message;

• rejection reason.

6.12. The decision to postpone or refuse access to personal data can be appealed to the authorized state body for the protection of personal data, other state authorities and local authorities, whose powers include the protection of personal data, or in court.

 

7. Protection of personal data: methods of protection, the person in charge, 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 data base is equipped with system and software and hardware and communication facilities 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 person in charge is determined by the order of the owner of the personal data base.

The responsibilities of the responsible person for organizing work related to the protection of personal data during their processing are indicated in the job description.

7.3. The responsible person is obliged:

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

• develop procedures for accessing personal data of employees in accordance with their professional or official or job duties;

• ensure that the employees of the owner of the personal data base 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 data base on the processing and protection of personal data in personal data bases;

• develop a procedure (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 data base on the processing and protection of personal data in personal data bases, which, in particular, should contain norms on the frequency of implementation such control;

• inform the owner of the personal data base about the facts of violations by employees of the requirements of the legislation of Ukraine in the field of personal data protection and internal documents governing the activities of the owner of the personal data base on the processing and protection of personal data in personal data bases 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 his personal data and messages of the specified subject about his rights.

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

• 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 received documents, including copies of files, any records stored in local computer networks and autonomous computer systems;

• to participate in the discussion of the duties performed by him in organizing work related to the protection of personal data during their processing;

• submit for consideration proposals for improving activities and improving working methods, submit comments and options for eliminating identified deficiencies in the process of processing personal data;

• receive explanations on the implementation of the processing of personal data;

• sign and endorse documents within their 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, on the processing and protection of personal data in personal data bases.

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

7.7. Individuals who have access to personal data, including those who process them, if they violate the requirements of the Law of Ukraine "On the Protection of Personal Data", are liable in accordance with the legislation of Ukraine.

7.8. Personal data should not be stored longer than is necessary for the purpose for which such data are stored, but in any case no longer than the storage period of the data determined by the consent of the subject of personal data to the processing of this data.

 

8. Rights of the subject of personal data.

8.1. The personal data subject has the right:

• 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 manager of this database, or give an appropriate order to receive this information to persons authorized by him, except in cases established by law;

• receive information about the conditions for providing access to personal data, including information about third parties to whom his personal data contained in the relevant personal data base are transferred;

• to access your personal data contained in the relevant personal data base;

• receive, no later than thirty calendar days from the date of receipt of the request, except as otherwise provided by law, an answer about whether his personal data is stored in the corresponding database of personal data, as well as receive the content of his personal data that are stored;

present a reasoned demand with an objection to the processing of their personal data by state authorities, local authorities in the exercise of powers provided for by law;

• submit a reasoned demand to change or destroy your personal data by any owner and manager of this database, if these data are processed illegally or are unreliable;

to protect their personal data from illegal processing and accidental loss, destruction, damage due to deliberate concealment, failure to provide or untimely provision of them, as well as to protect against the provision of information that is inaccurate or defaming the honor, dignity and business reputation of an individual;

• apply for the protection of your personal data rights to state authorities, local authorities, whose powers include the implementation of the protection of personal data;

• apply remedies in case of violation of legislation on the protection of personal data.

9. Procedure for handling requests of the subject of personal data.

9.1. The subject of personal data has the right to receive any information about himself from any subject of relations related to personal data, without specifying the purpose of the request, except as otherwise provided by law.

9.2. Access of the subject of personal data to data about himself is free of charge.

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

The request specifies:

• last name, first name and patronymic, place of residence (location) and details of the identity document of the subject of personal data;

• other information that allows you to identify the identity of the subject of personal data;

• information about the personal data base in respect of which the request is submitted, information about the owner or manager of this database;

• a list of personal data requested.

9.4. The term for studying a request for its satisfaction cannot exceed ten working days from the date of its receipt.

9.5. During this period, the owner of the personal data base notifies the subject of personal data, the request will be sufficient or the corresponding personal data cannot be provided, indicating the grounds specified in the relevant regulatory legal act.

9.6. The request is satisfied within thirty calendar days from the date of its receipt, unless otherwise provided by law.

 

10. State registration of the personal data base.

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

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