Privacy Policy

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

1. General concepts and scope of application

1.1. Definitions of terms:

personal data database — a named set of ordered personal data in electronic form and/or in the form of personal data card files;

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

owner of the personal data database — a natural or legal person who, by law or with the consent of the personal data subject, has been granted the right to process such data, who approves the purpose of processing personal data in this database, establishes the composition of such data and the procedures for processing them, unless otherwise provided by law;

State Register of Personal Data Databases — a unified state information system for the collection, accumulation and processing of information about registered personal data databases;

publicly available sources of personal data — directories, address books, registers, lists, catalogues, and other systematised collections of open information containing personal data placed and published with the knowledge 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 where the personal data subject has expressly indicated that the personal data are placed for the purpose of their free distribution and use);

consent of the personal data subject — any documented, voluntary expression of the will of a natural person to grant permission to process their personal data in accordance with the stated purpose of such processing;

depersonalisation of personal data — removal of information that makes it possible to identify a person;

processing of personal data — any action or set of actions carried out in whole or in part in an information (automated) system and/or in personal data card files that relate to the collection, registration, accumulation, storage, adaptation, alteration, updating, use and dissemination (distribution, sale, transfer), depersonalisation, and destruction of information about a natural person;

personal data — information or a set of information about a natural person who is identified or can be specifically identified;

administrator of the personal data database — a natural or legal person to whom the owner of the personal data database or the law has granted the right to process such data. A person entrusted by the owner and/or administrator of the personal data database with performing technical work with the personal data database without access to the content of the personal data is not an administrator of the personal data database;

personal data subject — a natural person whose personal data are processed in accordance with the law;

third party — any person, except the personal data subject, the owner or administrator of the personal data database and the authorised state body on personal data protection, to whom personal data are transferred by the owner or administrator of the personal data database 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 relating to health or sexual life.

1.2. These Regulations are mandatory for 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:

personal data base of counterparties.

3. Purpose of personal data processing

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

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

4.1. The consent of the personal data subject must be a voluntary expression of the will of a natural person to grant permission to process their personal data in accordance with the stated purpose of such processing.

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

a paper document with details that make it possible to identify this document and the natural person;
an electronic document, which must contain mandatory details that make it possible to identify this document and the natural person. It is advisable for the voluntary expression of the natural person's will to grant permission to process their personal data to be certified by the electronic signature of the personal data subject;
a mark on the electronic page of a document or in an electronic file processed in an information system on the basis of documented software and hardware solutions.

4.3. The consent of the personal data subject is given during the execution of civil-law relations in accordance with applicable law.

4.4. Notification of the personal data subject about the inclusion of their 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 their personal data is transferred, is carried out during the execution of civil-law relations in accordance with applicable law.

4.5. 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 concerning 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 seller's address.

6. Conditions for disclosure of personal data to third parties

6.1. The procedure for third parties' access to personal data is determined by the terms of the consent given by the personal data subject to the owner of the personal data for the processing of such data, or in accordance with the requirements of the law.

6.2. Access to personal data is not granted to a third party if that party refuses to undertake obligations to ensure compliance with the requirements of the Law of Ukraine "On Personal Data Protection" or is unable to ensure such compliance.

6.3. A subject of relations related to personal data submits a request for access (hereinafter — the request) to personal data to the owner of the personal data.

6.4. The request shall specify:

surname, first name and patronymic, place of residence (place of stay) and details of the identity document of the natural person submitting the request (for a natural person — the applicant);
the name and location of the legal entity submitting the request, the 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 makes it possible to identify the natural person 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;
the list of personal data requested;
the purpose and/or legal grounds for the request.

6.5. The period for reviewing a request for the purpose of granting it may not exceed ten working days from the date of its receipt. Within this period, the owner of the personal data base shall inform the person submitting the request that the request will be granted or that the relevant personal data is not subject to disclosure, stating the grounds set out in the relevant regulatory legal act. The request is granted within thirty calendar days from the date of its receipt, unless otherwise provided by law.

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

6.7. Notice of postponement shall be provided to the third party that submitted the request in writing, with an explanation of the procedure for appealing such a decision.

6.8. The notice of postponement shall specify:

the surname, first name and patronymic of the official;
the date the notice was sent;
the reason for the postponement;
the period within which the request will be granted.

6.9. Refusal of access to personal data is permitted if access to it is prohibited by law.

6.10. The notice of refusal shall specify:

the surname, first name and patronymic of the official refusing access;
the date the notice was sent;
the reason for refusal.

6.11. A decision to postpone or refuse access to personal data may be appealed in court.

7. Protection of personal data: means of protection, responsible person, employees who directly carry out processing and/or have access to personal data in connection with the performance of their official duties, personal data retention period

7.1. The owner of the personal data database is equipped with system, software and hardware facilities and communication means that prevent loss, theft, unauthorised destruction, distortion, falsification and copying of information and comply with the requirements of international and national standards.

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

The duties of the responsible person regarding the organisation of work related to the protection of personal data during their processing are set out 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 employees' access to personal data in accordance with their professional, official or labour duties;
ensure that the employees of the owner of the personal data database comply with the requirements of the legislation of Ukraine in the field of personal data protection and with the internal documents regulating the activities of the owner of the personal data database concerning the processing and protection of personal data in personal data 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 with the internal documents regulating the activities of the owner of the personal data database concerning the processing and protection of personal data in personal data databases, which, in particular, must contain provisions on the frequency of such control;
notify the owner of the personal data database of instances of employees' violations of the requirements of the legislation of Ukraine in the field of personal data protection and of the internal documents regulating the activities of the owner of the personal data database concerning the processing and protection of personal data in personal data databases, no later than one working day from the moment such violations are detected;
ensure the storage of documents confirming that the personal data subject has given consent to the processing of their personal data and that the said subject has been informed of their rights.

7.4. In order to perform their 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 database, related to the processing of personal data;
make copies of the documents received, including copies of files and any records stored in local computer networks and stand-alone computer systems;
participate in the discussion of the duties they perform in organising the work related to the protection of personal data during their processing;
submit proposals for improving operations and refining working methods, submit comments and options for eliminating shortcomings identified in the process of personal data processing;
obtain explanations on matters concerning the processing of personal data;
sign and endorse documents within the limits of their competence.

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

7.6. Employees who have access to personal data, including those who process such data, are obliged not to disclose in any manner the personal data entrusted to them or which became known to them in connection with the performance of their professional, official or labour duties. This obligation remains in force after they cease activities related to personal data, except in cases established by law.

7.7. Persons who have access to personal data, including those who process such data, shall be liable under the legislation of Ukraine in the event of their violation of the requirements of the Law of Ukraine "On Personal Data Protection".

7.8. Personal data must not be stored longer than is necessary for the purpose for which such data are stored, but in any case no longer than the data retention period specified in the personal data subject's consent to the processing of such data.

8. Rights of the personal data subject

8.1. The personal data subject has the right to:

know the location of the personal data database containing their personal data, its purpose and name, the location and/or place of residence (stay) of the owner or administrator of this database, or to issue a corresponding instruction to persons authorised by them to obtain this information, except in cases established by law;
receive information about the conditions for granting access to personal data, in particular information about third parties to whom their personal data contained in the relevant personal data database are transferred;
access their personal data contained in the relevant personal data database;
receive, no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, a reply as to whether their personal data are stored in the relevant personal data database, and also to receive the content of their stored personal data;
submit a substantiated demand objecting to the processing of their personal data by state authorities and local self-government bodies in the exercise of their powers provided for by law;
submit a substantiated demand for the modification or destruction of their personal data by any owner and administrator of this database, if such data are processed unlawfully or are inaccurate;
protection of their personal data against unlawful processing and accidental loss, destruction or damage due to intentional concealment, failure to provide or untimely provision of such data, as well as protection against the provision of information that is inaccurate or that discredits the honour, dignity and business reputation of the natural person;
to apply to public authorities and local self-government bodies whose powers include the protection of personal data on matters concerning the protection of their rights regarding personal data;
to use legal remedies in the event of a violation of legislation on the protection of personal data.

9. Procedure for Handling Requests from the Personal Data Subject

9.1. The personal data subject has the right to obtain any information about themselves from any party to relations involving personal data, without stating the purpose of the request, except in cases established by law.

9.2. Access by the personal data subject to data about themselves is provided free of charge.

9.3. The personal data subject submits a request for access (hereinafter — the request) to personal data to the owner of the personal data database.

The request shall state:

surname, first name and patronymic, place of residence (place of stay) and the details of the document identifying the personal data subject;
other information making it possible to identify the personal data subject;
information about the personal data database to which the request relates, or information about the owner or administrator of that database;
the list of personal data being requested.

9.4. The period for reviewing a request with a view to granting it may not exceed ten working days from the date of its receipt. Within this period, the owner of the personal data database shall notify the personal data subject that the request will be granted or that the relevant personal data are not subject to disclosure, stating the grounds specified in the relevant regulatory legal act.

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

10. State Registration of the Personal Data Database

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