Security policy
Provisions on the processing and protection of personal data in personal databases owned by the seller
- General concepts and scope of application.
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 certain person who organizes work related to the protection of personal data during their processing in accordance with the law;
the owner of the personal database is a natural or legal person who is granted the right to process this data by law or with the consent of the subject of personal data, who approves the purpose of processing personal data in this database, establishes the composition of this data and the procedures for its processing unless otherwise determined by law;
consent of the subject of personal data - a voluntary expression of the will of a natural person (provided that he is informed) to grant permission for the processing of his personal data in accordance with the formulated purpose of their processing, expressed in writing or in a form that allows drawing a conclusion about the granting of consent;
depersonalization of personal data - removal of information that allows identification of a person;
processing of personal data - any action or set of actions, performed in whole or in part in the information (automated) system and/or in personal data files, related to the collection, registration, accumulation, storage, adaptation, change, update, use and distribution (distribution, sale, transfer), depersonalization, 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 and may include the recording of one or more cookies or anonymous identifiers, as well as cookies and anonymous identifiers when the subject of personal data interacts with the services offered by our partners, such as advertising services, for example, which may appear on other sites that have been explicitly made public by the subject of personal data. A person who is entrusted by the owner and/or manager of the personal database to carry out technical work with the personal data base is not the manager of the personal database. without access to the content of personal data;
the subject of personal data - a natural person whose personal data is processed in accordance with the law;
third party - any person, with the exception of 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 database 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 sexual life.
1.2. This Regulation is mandatory for the responsible person and employees of the seller who directly processes and/or have access to personal data in connection with the performance of their official duties.
- List of personal databases.
2.1. The seller is the owner of the following personal databases:
the basis of the counterparty's personal data.
- Purpose of personal data processing.
3.1. The purpose of processing personal data in the system is the storage and maintenance of counterparty data in accordance with Articles 6 and 7 of the Law of Ukraine "On the Protection of Personal Data".
3.2. The purpose of personal data processing is to ensure the implementation of civil legal relations, provision/receipt and settlement of purchased goods/services in accordance with the Tax Code of Ukraine, the Law of Ukraine "On Accounting and Financial Reporting in Ukraine" and other duties assigned by law on the owner of personal data, to protect the legitimate interests of the owner of personal data or a third party to whom personal data is transferred.
3.3. The purpose of processing personal data is to create and implement bonus programs, and loyalty programs, sending messages in the form of e-mails, Viber messages, SMS messages, messages in the mobile application, and web browser messages, including for the purpose of sending commercial offers, with in order to improve the quality of services, form ratings, analyze activity, perform keyword searches, send informational and marketing newsletters (news, company promotions, information about promotions, promotional codes and discounts, personal recommendations, personal values and offers), which contain information about goods and/or services, advertising and commercial offers regarding such goods and/or services, etc.
- The procedure for processing personal data. Obtaining consent, notification of rights and actions with personal data of the subject of personal data.
4.1. Processing of personal data used to fulfil the purpose of processing provided for in clause 3.2 of this Regulation shall be carried out
4.2. Processing of personal data used to fulfil the purpose of processing provided for in clause 3.3 of this Regulation is carried out on the basis of the consent of the subject of personal data or for the execution of offers accepted by the subject of personal data, including registration of subscriptions.
4.2.1. The consent of the subject of personal data must be a voluntary expression of the individual's will to grant permission for the processing of his personal data in accordance with the formulated purpose of their processing. The consent of the subject of personal data can be given in the following forms:
a document on a paper medium with details that allows identification of this document and a natural person;
an electronic document, which must contain mandatory details that allow identification of this document and a natural person. It is expedient to certify a natural person's voluntary declaration of consent to the processing of his personal data with an electronic signature of the subject of personal data.
mark on an electronic page of a document or an electronic file, which is processed in the information system on the basis of documented software and technical solutions.
4.3. The notification of the subject of personal data about the inclusion of his personal data in the personal database, the rights defined by the Law of Ukraine "On the Protection of Personal Data", 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 the 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 sexual life (special categories of data) is prohibited.
- Location of the personal database.
5.1. The personal database specified in section 2 of this Regulation is located at the address of the seller.
- Terms of disclosure of personal data to third parties.
6.1. The procedure for accessing the personal data of third parties is determined by the terms of the consent of the subject of personal data, given to the owner of the personal database for the processing of this data, for the purpose of fulfilling obligations to the subject of personal data or in accordance with the requirements of the law.
6.2. Access to personal data is not granted to a third party if the specified person refuses to undertake obligations to ensure the fulfilment of the requirements of the Law of Ukraine "On the Protection of Personal Data" or is unable to ensure them.
6.3. The subject of relations related to personal data submits a request for access (hereinafter - a request) to personal data to the owner of the personal database.
6.4. The request specifies:
surname, first name, patronymic, place of residence (location) and details of the document certifying the natural person submitting the request (for a natural person - the applicant);
name, location of the legal entity submitting the request, position, surname, first name, patronymic of the person certifying the request; confirmation that the content of the request corresponds to the authority of the legal entity (for the legal entity – the applicant);
surname, first name, patronymic, as well as other information that allows identification of the natural person, regarding whom the request is made;
information about the staff base
6.5. The term for examining a request for its satisfaction cannot exceed ten working days from the date of receipt.
During this period, the owner of the personal database informs the person who submits the request that the request will be satisfied or that the relevant personal data are not subject to the provision, indicating the grounds specified in the relevant regulatory legal act.
The request is satisfied within thirty calendar days from the date of receipt unless otherwise provided by law.
6.6. All employees of the owner of the personal database are obliged to comply with confidentiality requirements regarding personal data and information on accounts in securities and securities circulation.
6.7. Delaying access to the 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 solving the issues raised in the request cannot exceed forty-five calendar days.
6.8. The notice of postponement is brought to the attention of the third person who submitted the request in writing with an explanation of the procedure for appealing such a decision.
6.9. The notice of postponement states:
- surname, first name, patronymic of the official;
- the date of sending the message;
- the reason for the delay;
- the period during which the request will be granted.
6.10. Denial of access to personal data is permitted if access to it is prohibited by law.
6.11. The notice of refusal shall indicate:
- last name, first name, patronymic of the official denying access;
- the date of sending the message;
- reason for refusal.
6.12. The decision to delay or deny access to personal data may be appealed to the authorized state body for the protection of personal data, other state authorities and local self-government bodies, whose powers include protecting personal data, or in court.
- Protection of personal data: methods of protection, the responsible person, employees who directly process and/or have access to personal data in connection with the performance of their official duties, and the period of storage of personal data.
7.1. The owner of the personal database is equipped with the system and software-technical means and means of communication that prevent the loss, theft, unauthorized destruction, distortion, forgery, and copying of information and meet the requirements of international and national standards.
7.2. The responsible person organizes the 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 duties 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 the personal data of employees in accordance with their professional or official or labour duties;
to ensure compliance by the employees of the Personal Data Base Owner with the requirements of Ukrainian legislation in the field of personal data protection and internal documents regulating the activities of the Personal Data Base Owner regarding the processing and protection of personal data in personal databases;
to develop an order (procedure) of internal control over compliance with the requirements of Ukrainian legislation in the field of personal data protection and