Security policy

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

1. 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 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 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, which approves the purpose of processing personal data in this database, establishes the composition of this data and the procedures for their processing, unless otherwise specified by law ;

consent of the subject of personal data - a voluntary expression of the will of an individual (subject to his knowledge) to grant permission to process his personal data in accordance with the stated purpose of their processing, expressed in writing or in a form that allows us to conclude that consent has been granted;

depersonalization 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 the 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 collection of information about an individual who is identified or can be specifically identified, and may include the recording of one or more cookies or anonymous identifiers, also cookies and anonymous identifiers, when the subject of personal data interacts with the services offered by our partners as advertising services, for example, which may appear on other websites that have been explicitly made public by the personal data subjectThe person who is entrusted by the owner and / or manager of the personal data base to carry out technical work with the personal data base without access to the content of personal data is not the manager of the personal data base;

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

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 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 worldview beliefs, membership in political parties and trade unions, as well as data relating to health or sexual 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:

counterparty personal data base.

3. 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, 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”, and other obligations imposed 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 the creation and implementation of bonus programs, loyalty programs, sending messages in the form of emails, messages in Viber, SMS messages, notifications in a mobile application, web browser notifications, including for the purpose of sending commercial offers, with in order to improve the quality of services, generate ratings, analyze activity, search by keywords, send information and marketing mailings (news, company promotions, information about promotions, promotional codes and discounts, personal recommendations, personal discounts and offers), which contain information about goods and/or services, advertising and commercial offers for such goods and/or services, etc.

4. The procedure for processing personal data. Obtaining consent, notification of rights and actions with personal data of the subject of personal data.

4.1.The processing of personal data used to fulfill the purpose of processing provided for in clause 3.2 of this Regulation is carried out on the basis of Article 11 of the Law of Ukraine "On the Protection of Personal Data".

4.2. The processing of personal data used to fulfill 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 fulfillment of offers accepted by the subject of personal data, including the execution of subscriptions.

4.2.1. 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 formulated purpose of their processing. The consent of the subject of personal data can be provided in the following forms:

a document on paper with details that allows you to identify this document and an individual;

an electronic document that must contain mandatory details that allow identifying this document and an individual. It is advisable to certify the voluntary will of an individual to grant permission for the processing of his personal data with an electronic signature of the subject of personal data.

mark on the electronic page of a document or in an electronic file, which is processed in the information system on the basis of documented software and hardware solutions.

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 persons to whom his personal data is transferred, is carried out when registering civil law relations in accordance with applicable law .

4.4. The processing of personal data on racial or ethnic origin, political, religious or philosophical 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 this Regulation are located at the address of the seller.

6. Terms of disclosure of information about personal data to third parties.

6.1. The procedure for access to personal data of third parties is determined by the terms of the consent of the subject of personal data provided to the owner of the personal data base for the processing of these data in order to fulfill their obligations to the subject of personal 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 said person refuses to assume 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

surname, name, patronymic, place of residence (location) and details of the document certifying the individual who submits the request (for an individual applicant);

name, location of the legal entity submitting the request, position, surname, name, patronymic of the person certifying the request; confirmation that the content of the request corresponds to the powers of the legal entity (for the legal entity - the applicant);

surname, name, patronymic, as well as other information that allows 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, or information about the owner or manager of this database;

list of requested personal data;

request target.

6.5. The term for studying the 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 informs the person submitting the request that the request will be satisfied or the relevant personal data will not 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 required to comply with confidentiality requirements regarding personal data and information on securities accounts and securities turnover.

6.7.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 time for resolving the issues raised in the request cannot exceed forty-five calendar days.

6.8. A notice of postponement shall be communicated to the third person who submitted the request in writing, explaining the procedure for appealing such a decision.

6.9. The postponement notice states:

surname, name, patronymic of the official;

the date the message was sent;

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 rejection message states:

surname, name, patronymic of the official who refuses access;

the date the message was sent;

rejection reason.

6.12. The decision to postpone 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 governments, whose powers include the protection of personal data, or in 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, software and hardware and communication tools 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 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 data base.

The duties 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 must:

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 labor 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 for the processing and protection of personal data in personal data bases;

develop a procedure (procedure) for internal control over compliance with the requirements of Ukrainian legislation in the field of personal data protection and external