This Privacy Policy, hereinafter - the Policy, applies to the processing of personal data that may be received by the Limited Liability Company "Kablex Ukraine" from individuals (subjects of personal data) on the basis of the Constitution of Ukraine and the Law of Ukraine "On the protection of personal data" dated June 1, 2010. No. 2297-VI (hereinafter - the Law), as well as the General Data Protection Regulation (EU) 2016/679 dated 04.27.2016. (EU General Data Protection Regulation, hereinafter - GDPR) and other applicable European legislation on data protection, Collectively hereinafter - Legislation.
This Privacy Policy is designed to tell you:
what is personal data;
what personal data we collect about you;
how and why we use them;
to whom we transfer your personal data;
how we protect the privacy of your personal data;
how to contact us and who to contact if you have any questions regarding the processing of your personal data.
We process your personal data only if one of the conditions specified in Article 6 of the GDPR is met, including but not limited to:
- You have consented to the processing of your personal data;
- processing is necessary to provide you with services;
- such processing is required by the legislation of the country where you are located.
We take seriously the security of personal data of our customers, potential customers and other persons who have contacted us, therefore we strive to protect the privacy of your personal data. The administration undertakes to take all necessary measures to prevent misuse of your personal data that become known to us. We will process your personal data in strict accordance with the requirements of the applicable legislation and only if there are legal grounds for such processing.
You are not obliged to provide us with personal data, but without certain information about you, we will not be able to provide you with some of our services. In the event that we control the methods of collecting your personal data and determine the purposes for which this personal data is used, The Administration is a “controller of personal data” for the purposes of GDPR and other applicable European legislation on data protection, as well as “owner of personal data” within the meaning of the Law.
1. Terms and definitions
Personal data — information or a set of information about a natural person who is identified or can be specifically identified (User);
Special categories of personal data — this is the so-called "sensitive" personal data, which may cause harm to the data subject at work, in an educational institution, in the place of residence, or may lead to his discrimination in society. For example, this is personal data that contains information about racial origin, political or religious views, trade union membership, health status, sex life, biometric or genetic data. In the terminology of Ukrainian legislation, this is such personal data, the processing of which carries a special risk for the subjects of personal data;
Subject of personal data — is a natural person to whom the personal data belong, and who can be identified by these personal data, or who has already been identified;
Site administration (Administration, as well as further on in the text we, us, us, us) — Kablex Ukraine Limited Liability Company, legal address: 65000, Ukraine, m. Odesa, ave. Heavenly Hundred, 101/1 {correct if different}; physical address and mailing address: {required};
Processing of personal data — any action or set of actions, such as: collection, registration, accumulation, storage, adaptation, change, restoration, use and distribution (dissemination, implementation, transfer), depersonalization, destruction of personal data, including using information (automated ) systems;
Distribution of personal data — actions regarding the transfer of information about a natural person with the consent of the subject of personal data;
Use of personal data — any actions of the Administration on the processing of this data, actions on their protection, as well as actions on granting partial or full right to process personal data to other subjects of relations related to personal data, carried out with the consent of the subjects of personal data or in accordance with the legislation of Ukraine;
Зnon-identification of personal data — extraction of information that allows direct or indirect identification of a person;
User — subject of personal data, any legally capable natural person who has joined this Policy in their own interests to obtain information on the pages of a web resource (site) or to receive advice in online format on the sitehttps://kablex.ua using the Internet;
Web resource (сайт) — a set of data, electronic (digital) information, other objects of copyright and/or related rights, interconnected and structured within the website address and/or account of a person who has Intellectual Property rights (hereinafter - IP) to the site. These objects are accessed through an Internet address, which may consist of a domain name, directory or call records, and/or a numeric Internet Protocol address. The web resource belonging to the Administration is located at the web address https://kablex.ua;
Policy — this Privacy Policy, which is located on the page of the web resource at the address https://kablex.ua/polityka-konfidentsiynosti;
Personal data controller — it is a natural or legal person who determines the purposes and means for processing personal data and bears the main responsibility for their processing. The controller of personal data is the "owner of personal data" in the terminology of Ukrainian legislation. Within the framework of this Policy, the Controller of personal data is Kablex Ukraine Limited Liability Company;
Personal data processor — this is a natural or legal person who processes personal data for the controller on the basis of instructions (instructions, orders) of the controller. A personal data processor is a "personal data administrator" in the terminology of Ukrainian legislation;
2. General provisions
2.1. The policy applies to all of your personal data that may be obtained by Us in the process of using the web resource. This Policy applies to personal data collected both before and after the implementation of this Policy.
2.2. The purpose of the Policy is to provide you with the necessary information that allows you to assess what personal data and for what purposes we process it, the methods of their processing and ensuring security.
2.3. When using the site, you, having notified the Administration of your personal data, including with the help of third parties, acknowledge your consent to the processing of your personal data in accordance with this Policy.
2.4. In case of disagreement with the terms of this Policy, you must stop using the web resource.
2.5. Consent to the processing of personal data may be withdrawn by the subject of personal data. In the event that the subject of personal data withdraws consent to the processing of personal data, the Administration has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the legislation.
2.6. The site administration does not verify the authenticity of the personal data provided by the User, and is unable to assess its validity. However, the Administration assumes that the User acts in good faith, carefully, provides reliable and sufficient personal data and makes all necessary efforts to maintain such data in an up-to-date state and does not violate the rights of third parties.
2.7. By agreeing to the terms of this Policy, you confirm that at the time of personal data collection, you are informed about the persons to whom personal data is transferred, the content and purposes of personal data collection. You confirm (guarantee) that the personal data transferred to Us for processing are transferred with the consent of the owners of personal data and within the framework of the Legislation.
2.8. The Administration, having received personal data from the User, does not undertake the obligation to inform the subjects (their representatives), the personal data transferred to it, about the start of processing of personal data, since the obligation to provide the relevant information during the conclusion of the contract with the subject of personal data and/or upon obtaining consent for such transfer shall be borne by the User who transferred personal data.
2.9. Processing of your personal data is carried out in accordance with the requirements of the Law. The processing of personal data of persons residing in the EU or who are EU citizens is regulated, in particular, by the EU General Data Protection Regulation 2016/679 (hereinafter - "GDPR"). Also, the legislation of other countries may set additional requirements.
2.10. This Policy applies to all information that the Administration can obtain about the User during his use of the web resource, as well as during the execution by the Administration of any agreements and contracts with the User.
2.11. This Policy is an internal document of the Administration.
2.12. The controller of personal data is released from responsibility for the consequences arising from his processing of personal data, if he is not responsible for the event that caused such consequences.
You also agree that the Owner of personal data has the right to provide access and transfer your personal data to third parties without any additional notice, only if the purpose of their processing does not change and only in the cases provided for in this Privacy Policy and/or legislation of Ukraine.
No one under the age of 18 should provide us with personal information through the web resource. We do not purposefully collect personal information of persons under the age of 18. Parents and guardians must constantly monitor their children's related activities.
3. Composition of personal data
3.1. In order to carry out its activities and fulfill its obligations, the Administration processes the User's personal data provided to them when visiting the site https://kablex.ua and stores on the Administration server.
3.2. The User's personal data include: last name, first name, patronymic, e-mail address, mobile/landline phone number, country of residence, place of work, position, date of birth, as well as other data entered by the User in the feedback form connection or application for cooperation/partnership, or when completing a resume application.
We ask you to provide only those personal data that are necessary to provide the service you have chosen, receive newsletters or respond to your special request/claim. At the same time, if you decide to provide additional personal data, we will also be able to process it with the necessary level of protection.
3.3. The administration has the right to set requirements for the composition of personal data, which must be provided when using the web resource. If certain information is not specified by the Administration as mandatory, its provision or disclosure is carried out by the User at his own discretion.
3.4. Data that are automatically transmitted to the Administration when using the web resource by the User using the software installed on the device: IP address, information about the browser and the type of operating system of the device, technical characteristics of the equipment and software, date and time of access to the web resource.
4. Basis and purpose of personal data processing
4.1.The grounds for processing personal data are::
1) consent of the subject of personal data to the processing of his personal data by the Administration;
2) conclusion and execution of a contract, one of the parties of which is the subject of personal data or which is concluded for the benefit of the subject of personal data, or for the implementation of measures preceding the conclusion of the contract at the request of the subject of personal data;
3) the need for the Administration to fulfill the requirements stipulated by the Legislation.
4.2. The purpose of personal data processing is:
⦁ implementation of the functions assigned to the Administration in accordance with the legislation of Ukraine and GDPR;
⦁ collection, storage and processing of personal data obtained from the web resource within the framework of the Law and GDPR;
⦁ to send the User commercial (marketing) messages containing additional information about services, current promotions and special offers, product catalogs related to services provided by the Administration through the site.
⦁ identification of the subject of personal data when using the site;
⦁ communication with the subject of personal data if necessary, including sending offers, information materials, messages, information and requests, advertising, as well as processing requests from the subject of personal data;
⦁ improving the quality of the web resource, its ease of use, developing new functionalities and improving the quality of service;
⦁ improving the User's professional skills and qualifications;
⦁ conducting statistical and other research based on depersonalized data;
⦁ fulfillment by the Administration of contractual and other obligations to the User under agreements concluded between the Administration and the User or third parties in favor of the User.
5. Basic principles of personal data processing
5.1. The processing of personal data by the Administration is carried out on the basis of the principles:
5.1.1. Lawfulness of the purposes and methods of processing personal data;
5.1.2. The good faith of the Administration, as the owner of personal data, is achieved by fulfilling the requirements of the legislation of Ukraine regarding the processing of personal data.;
5.1.3. Achieving specific, predetermined purposes of processing personal data;
5.1.4. Compliance of the purposes of processing personal data with the purposes previously determined and stated when collecting personal data;
5.1.5. Compliance of the list and scope of processed personal data, as well as the methods of processing personal data, with the stated purposes of processing;
5.1.6. Accuracy of personal data, their sufficiency for the purpose of processing, inadmissibility of processing personal data that is excessive in relation to the purposes of processing personal data;
5.1.7. Ensuring the accuracy of personal data, their adequacy, and, where necessary, relevance to the purposes of personal data processing when processing personal data.
5.1.8. Inadmissibility of combining databases containing personal data processed for incompatible purposes;
5.1.9. Storage of personal data in a form that allows identification of the subject of personal data for no longer than is required for the purpose of their processing.
5.1.10. Personal data being processed shall be destroyed or depersonalized upon achievement of the purposes of processing or in the event of loss of necessity for achieving these purposes, unless otherwise provided for by the legislation of Ukraine and the GDPR.
5.1.11. We must also take into account the periods for which we may need to retain your personal data to comply with our legal obligations to you or to regulatory authorities..
5.1.12. We may over time minimize the personal data we use about you, or we may even anonymize your data so that it cannot be linked to you personally. In this case, we may use this information for statistical or other purposes without further notice to you, as such information ceases to be personal data.
5.2. The Administration processes personal data for statistical or other research purposes, subject to mandatory anonymization of personal data.
5.3. The Administration does not process personal data relating to racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties and trade unions, criminal convictions, as well as data concerning health, sex life, biometric and genetic data.
5.4. Personal data is processed in compliance with the conditions specified by the legislation of Ukraine and the GDPR.
6. Personal data processing terms
6.1. The terms of processing personal data are determined based on the purposes of processing, but not longer than specified by the Legislation.
6.2. Personal data whose processing (storage) period has expired must be destroyed or depersonalized, unless otherwise provided by Law. Personal data shall be stored in a form that permits identification of the subject of personal data for no longer than is required for the purpose of processing personal data, unless the storage period for personal data is not established by Law. Personal data processed shall be destroyed or depersonalized after the purposes of processing have been achieved or when the need to achieve these purposes has ceased, unless otherwise provided by Law. We must also take into account the periods for which we may need to retain your personal data to comply with our legal obligations to you or to supervisory authorities (in accordance with EU Regulation 261/2004).
6.3. We may over time minimize the personal data we use about you, or we may even anonymize your data so that it cannot be linked to you personally. In this case, we may use this information without further notice to you.
7. The circle of persons allowed to process personal data by the Administration
7.1. To achieve the goals of this Policy, only those employees of the Administration who are assigned such a duty in accordance with their official (labor) duties are allowed to process personal data. Access to other employees may be granted only in cases provided for by Law. The Administration guarantees that its employees will maintain the confidentiality and security of personal data during their processing.
7.2. The administration has the right to transfer personal data to third parties in the following cases::
- the personal data subject has expressed his/her consent to such actions in writing;
- the transfer is provided for by Ukrainian or other relevant legislation within the framework of the procedure established by law. In this case, 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 or cannot ensure them.
7.3. The Administration has the right to entrust the processing of personal data to a third party with the consent of the personal data subject, unless otherwise provided for by the legislation of Ukraine, on the basis of an agreement concluded with a third party, the condition of which is compliance with the confidentiality and non-disclosure of personal data..
7.4. Representatives of state authorities (including regulatory, supervisory, law enforcement and other bodies) receive access to personal data processed by the Administration, to the extent and in accordance with the procedure specified by the Legislation.
8. Implementing personal data protection
8.1. The Administration's activities in processing personal data in information systems are inextricably linked to the Administration's protection of the confidentiality of the information received, unless this contradicts current legislation..
8.2. The personal data protection system includes organizational and (or) technical measures determined taking into account current threats to the security of personal data and information technologies used in information systems. The administration updates these measures with the emergence of new technologies if necessary.
8.3. The exchange of personal data during their processing in information systems is carried out via communication channels protected by technical means of information protection..
8.4. When processing personal data in information systems, the Administration ensures::
⦁ taking measures aimed at preventing unauthorized access to personal data and (or) their transfer to persons who do not have the right to access such information;
⦁ timely detection of unauthorized access to personal data;
⦁ preventing influence on technical means of automated processing of personal data, as a result of which their functioning may be disrupted;
⦁ the ability to immediately restore personal data modified and destroyed as a result of unauthorized access to them;
⦁ constant monitoring of personal data security.
8.5. Confidentiality is maintained with regard to personal information, except in cases where the technology of the web resource or the settings of the software used by the User provide for the open exchange of information with other Users of the sites or with any users of the Internet..
8.6. The administration implements the following requirements of the legislation of Ukraine in the field of personal data::
⦁ personal data confidentiality requirements;
⦁ requirements for ensuring the exercise of personal data subjects' rights;
⦁ requirements for ensuring the accuracy of personal data, and where necessary, relevance in relation to the purposes of processing personal data (with the taking (ensuring the taking) of measures to delete or clarify incomplete or inaccurate data);
⦁ requirements for the protection of personal data from unauthorized or accidental access to them, destruction, distortion, blocking, copying, provision, distribution of personal data, as well as other unlawful actions regarding personal data;
⦁ other requirements of the Law.
8.7. In accordance with the Law, the Administration independently determines the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the legislation in the field of personal data from unauthorized or unlawful processing and from unintentional loss, destruction or damage.
The Administration adheres to the principle of minimization of personal data. We process only the information about you that we need, or information that you provide with your consent, in excess of the necessary processing. In addition, we have configured all interfaces of the Web resource and programs for providing services in such a way that the maximum possible confidentiality is observed. When transferring personal data to state bodies, we always use the most secure and proven ways of transferring such data.
8.8. Cookies and other tracking technologies.
Cookies are small text files that websites store on your computer or mobile device when you start using them. This allows the website to remember your preferences and actions you have taken for a while, including so that you do not have to re-enter this information. Our cookies do not identify you as an individual, but only the computer or mobile device you are using..
Cookies and other tracking technologies on our website may be used in various ways, for example, for the purpose of operating the website, analyzing traffic or for advertising purposes. We use cookies and other tracking technologies, in particular, to improve the quality and efficiency of our services..
For more information about what cookies are, how they work, how to manage them or how to delete them, go to www.allaboutcookies.org.
Please note that you can disable cookies and other tracking technologies in the settings of some Internet browsers. However, you should understand that if you disable some cookies, the functionality of the site may be limited and you will not be able to use all its benefits, and some pages may not work correctly..
8.9. You can find more detailed information about the cookie policy on our website on the page https://kablex.ua/polityka-cookie.
9. Rights of the personal data subject
9.1. Rights of personal data subjects in accordance with the legislation of Ukraine:
9.1.1. To know about the sources of collection, the location of their personal data, the purpose of their processing, the location of the personal data controller or to give an appropriate instruction to obtain this information to authorized persons, except for cases established by Law.
9.1.2. Receive information about the conditions for providing access to personal data, including information about third parties to whom his personal data is transferred.
9.1.3. Access to your personal data.
9.1.4. Receive no later than thirty calendar days from the date of receipt of the request, except in cases provided for by the Law, a response on whether his personal data is being processed and what data is being processed.
9.1.5. Submit a reasoned request to the Administration to object to the processing of your personal data.
9.1.6. Submit a reasoned request to change or delete your personal data if the data is processed unlawfully or is inaccurate.
9.1.7. To protect your 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 providing information that is unreliable or defamatory of the dignity and business reputation of an individual.
9.1.8. Submit complaints about the processing of your personal data to the Administration, the Commissioner for Human Rights of the Verkhovna Rada of Ukraine, or to the court..
9.1.9. Apply legal remedies in case of violation of personal data protection legislation.
9.1.10. Include a reservation regarding the restriction of the right to process your personal data when providing consent.
9.1.11. Withdraw consent to the processing of personal data.
9.1.12. Get acquainted with the mechanism of automatic processing of personal data.
9.1.13. To protect against automated decision-making that has legal consequences for him/her.
9.1.14. The Administration has the right to entrust the processing of personal data to a third party with the consent of the personal data subject, unless otherwise provided for by the legislation of Ukraine, on the basis of an agreement concluded with a third party, the condition of which is compliance with the confidentiality and non-disclosure of personal data.
9.1.15. Representatives of state authorities (including regulatory, supervisory, law enforcement and other bodies) receive access to personal data processed by the Administration, to the extent and in accordance with the procedure determined by the legislation of Ukraine.
9.2. Other rights of personal data subjects under the GDPR:
In addition to Ukrainian legislation on personal data protection, the Administration is attentive to ensuring your rights established by the GDPR..
9.2.1. Right to information.
We are ready to provide data subjects with information about what personal data we process.
If you would like to know what personal data we process about you, you can request this information at any time, including by contacting the Administration. The list of data that we must provide you with can be found in Articles 13 and 14 of the GDPR. However, when contacting us, you must state your specific requirements so that we can lawfully consider your request and respond.
Please note that if we are unable to verify your identity through email or phone contact, or if we have reasonable doubts about your identity, we may ask you to provide proof of identity, including by appearing in person at the Administration's address. This is the only way we can avoid disclosing your personal data to a person who may impersonate you.
We will process requests as soon as possible, but at the same time please remember that providing a complete and legitimate response regarding personal data is a complex process that can take up to a month.
9.2.2. The right to correct data about you.
If you find that some of the personal data we process about you is incorrect or outdated, please let us know. In this case, we may ask you to provide proof of identity, including by appearing in person at the address of the Administration.
In some cases, we may not be able to change your personal data. In particular, this may be the case when your personal data has already been used in the process of performing a contract and/or they are contained in a tax document that has been issued in accordance with Tax Legislation.
9.2.3. Withdrawal of consent to the processing of personal data and the right to be forgotten
If the Administration processes your personal data on the basis of consent to the processing of personal data (in particular, for the purpose of marketing/advertising mailings), further processing can be stopped at any time. It is sufficient to withdraw consent to such processing.
You can also exercise your right to be forgotten. In the cases provided for in Article 17 of the GDPR, the Administration will destroy your personal data that it processes, with the exception of personal data that we are obliged to retain in accordance with the requirements of the law.
Also in this case, for security purposes, the Administration may ask you to provide an identification document, in particular directly at the address of the Administration's location.
10. Personal data storage location
The administration uses the cloud services of the company {specify name} to store personal data and ensure its security.
11. Privacy Policy Change
11.1. This Policy may be amended or terminated by the Administration unilaterally without prior notice to Users, including if required by law. The new version of the Policy comes into force upon its posting on the site, unless otherwise provided by the new version of the Policy. Therefore, we ask you to visit the page https://kablex.ua/polityka-konfidentsiynosti to make sure that you have up-to-date information.
12. Who can you contact to protect your personal data?
12.1. If you have any questions, comments, complaints or requests regarding the protection and processing of personal data, you can contact the Director of Kablex Ukraine LLC {Full name}, e-mail: {specify email address}, postal address: {full postal address}.
Be sure to include your name, surname, email address, as well as detailed questions, comments, complaints or requirements in all correspondence.
12.2. The administrative body for personal data protection in Ukraine is the Personal Data Protection Department of the Secretariat of the Commissioner for Human Rights of the Verkhovna Rada of Ukraine. You can contact it with complaints or suggestions if you believe that your rights have been violated in connection with the processing of personal data.