ZCS – PRIVACY POLICY

          This Privacy Policy, hereinafter referred to as the Policy, applies to the processing of personal data that the Limited Liability Company “PLANT OF CONVEYOR SYSTEMS” can receive 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 01.06. 2010 No. 2297-VI (hereinafter – the Law), as well as the General Data Protection Regulation (EU) 2016/679 of 04/27/2016 (EU General Data Protection Regulation, hereinafter – GDPR) and other applicable European legislation on protection data, collectively referred to hereinafter as the 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 share 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 referred to 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 for the provision of services to you;
• such processing is required by the laws of the countries in which you are located.

We really take the security of the personal data of our clients, potential clients and others who contact us seriously, therefore we strive to protect the confidentiality of your personal data. The administration undertakes to take all necessary measures to prevent the abuse of your personal data that becomes known to us. We will process your personal data in strict accordance with the requirements of applicable Laws and only if there are legal grounds for such processing.

You are not required to provide us with personal data, but without certain information about you, we may not be able to provide you with some of our services. In the event that we control the ways in which your personal data is collected and determine the purposes for which this personal data is used, the Administration is the “controller of personal data” for the purposes of the GDPR and other applicable European data protection legislation, as well as the “owner of personal data” in the sense Law.

1. Terms and definitions

Personal data – information or a set of information about an individual who is identified or can be specifically identified (User);

Special categories of personal data are so-called “sensitive” personal data that may cause harm to the data subject at work, in an educational institution, in the environment of residence, or may lead to discrimination in society. For example, this is personal data that contains information about racial origin, political or religious views, trade union membership, health status, sexual life, biometric or genetic data. In the terminology of Ukrainian legislation, these are such personal data, the processing of which carries a special risk for personal data subjects;

The subject of personal data is a natural person to whom personal data relates and who can be identified by these personal data, or who has already been identified;

Administration site (Administration, as well as further in the text we, us, us, us) – Limited Liability Company “PLANT OF CONVEYOR SYSTEMS”, legal address: 49127, Ukraine, Dnipro, st. Gavanskaya, 16; registration date: 09/17/2020, record number: 1002241020000095508;

Processing of personal data – any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, restoration, use and distribution (distribution, sale, transfer), depersonalization, destruction of personal data, including using information ( automated) systems;

Distribution of personal data – actions to transfer information about an individual with the consent of the subject of personal data;

Use of personal data – any actions of the Administration for the processing of these data, actions to protect them, as well as actions to grant partial or full rights to process personal data to other subjects of relations related to personal data, performed with the consent of the subjects of personal data or in accordance with the legislation of Ukraine ;

Depersonalization of personal data – the withdrawal of information that allows you to directly or indirectly identify a person;

User – the subject of personal data, any capable individual who has joined this Policy in his own interests to receive confidential information, who has registered on the website https://zcs.com.ua using the Internet;

Registration – the User’s actions to fill out and send the registration form posted on the site.

Policy – this Privacy Policy located at https://zcs.com.ua/politika-konfidenczialnosti/

The controller of personal data is the natural or legal person who determines the purposes and means for the processing of personal data and is primarily responsible for their processing. The personal data controller is the “owner of personal data” in the terminology of Ukrainian legislation. Within the framework of this Policy, the Controller of personal data is the Limited Liability Company “Plant of Conveyor Systems”;

Personal data processor is a natural or legal person who, on the basis of instructions (instructions, orders), the controller processes personal data for the controller. The processor of personal data is the “manager of personal data” in the terminology of Ukrainian legislation;

2. General provisions

2.1. The Policy applies to all of Your personal data that We may receive in the course of Your use of the online service. This Policy applies to personal data received both before and after the entry into force of this Policy.

2.2. The purpose of the Policy is to provide you with the necessary information that allows you to evaluate what personal data and for what purposes are processed by us, the methods of their processing and security.

2.3. When using the online service, by informing the Administration of your personal data, including through third parties, you acknowledge your consent to the processing of your personal data in accordance with this Policy.

2.4. If you disagree with the terms of this Policy, you must stop using the online service.

2.5. Consent to the processing of personal data may be withdrawn by the subject of personal data. If 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 accuracy of the personal data provided by the User, does not have the ability to assess his legal capacity. However, the Administration assumes that the User acts in good faith, prudently, provides reliable and sufficient personal data and makes every effort to keep such data up to date, 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 collecting personal data, you are notified of the persons to whom personal data is transferred, the content and purposes of collecting personal data. You confirm (guarantee) that the personal data that is transferred to us for processing is 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 assume the obligation to inform the subjects (their representatives), whose personal data has been transferred to it, about the start of processing personal data, since the obligation to carry out appropriate information when concluding an agreement with the subject of personal data and / or when obtaining consent to such a transfer, is borne by the User who transferred personal data.

2.9. The processing of your personal data is carried out in accordance with the requirements of the Law. The processing of personal data of persons located in the EU or who are EU citizens is regulated, in particular, by the EU General Data Protection Regulation 2016/679 (hereinafter referred to as the “GDPR”). Also, the legislation of other countries may establish additional requirements.

2.10. This Policy applies to all information that the Administration can receive about the User when using the online service, as well as during the implementation 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 liability for the consequences that occurred in connection with the processing of personal data by him, if he is not responsible for the event that led to the occurrence of 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 messages, only if the purpose of their processing does not change and only in cases provided for in this Privacy Policy and/or Ukrainian legislation.

No one under the age of 18 should provide us with personal information through the Online Service. We do not knowingly collect personal information from persons under the age of 18. Parents and guardians should constantly supervise the related activities of their children.

3. Composition of personal data

3.1. The Administration, in order to carry out its activities and fulfill its obligations, processes the User’s personal data provided by him during registration on the site https://zcs.com.ua

3.2. The User’s personal data includes: last name, first name, patronymic, e-mail address, mobile / landline phone number, country of residence, place of work, position, date of birth.

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 us with additional personal data, we will also be able to process them with the necessary level of protection.

3.3. The Administration has the right to establish requirements for the composition of personal data, which must be provided when using the online service. If certain information is not marked by the Administration as mandatory, its provision or disclosure is carried out by the User at his own discretion.

3.4. Data that is automatically transmitted to the Administration when using the online service 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, hardware and software specifications, date and time of access to the online service.

4. Grounds and purpose of personal data processing

4.1. The grounds for the processing of personal data are:

1) the consent of the subject of personal data to the processing of his personal data by the Administration;

2) the conclusion and execution of an agreement, one of the parties to which is the subject of personal data or which is concluded in favor 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 provided for 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 the GDPR;

⦁ collection, storage and processing of personal data received in the online service within the framework of the Law and the GDPR;

⦁ to send the User commercial (marketing) notifications containing additional information about the services, current promotions and special offers related to the services provided by the Administration using the online service.

⦁ identification of the subject of personal data when using the online service;

⦁ 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 online service, its ease of use, developing new functionality and improving the quality of service;

⦁ improving the professional skills and qualifications of the User;

⦁ conducting statistical and other studies based on anonymized data;

⦁ fulfillment by the Administration of contractual and other obligations to the User on transactions concluded between the Administration and the User or third parties in the interests 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. The legality of the purposes and methods of processing personal data;

5.1.2. The integrity of the Administration, as the owner of personal data, is achieved by complying with the requirements of the legislation of Ukraine regarding the processing of personal data;

5.1.3. Achievement of specific, predetermined purposes of personal data processing;

5.1.4. Compliance of the purposes of processing personal data with the purposes predetermined and declared when collecting personal data;

5.1.5. Compliance of the list and volume of processed personal data, as well as the methods of processing personal data with the stated purposes of processing;

5.1.6. Reliability of personal data, their sufficiency for the purposes of processing, inadmissibility of processing personal data that is excessive in relation to the purposes of processing personal data;

5.1.7. Ensuring, when processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data.

5.1.8. The inadmissibility of combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other;

5.1.9. Storage of personal data in a form that allows to identify the subject of personal data, no longer than required by the purposes of their processing.

5.1.10. The processed personal data is subject to destruction or depersonalization upon achievement of the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided 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 in order to comply with our legal obligations to you or regulatory authorities.

5.1.12. We may minimize the personal data we use about you over time, or we may even make your data anonymous so that it can no longer be associated with 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 processing of personal data is carried out by the Administration for statistical or other research purposes, subject to the mandatory depersonalization of personal data.

5.3. The administration does not process personal data related to racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties and trade unions, criminal convictions, as well as data related to health, sexual life, biometric and genetic data.

5.4. The processing of personal data is carried out in compliance with the conditions determined by the legislation of Ukraine and the GDPR.

6. Terms of personal data processing

6.1. The terms for processing personal data are determined based on the purposes of processing, but no longer than it is determined by the Legislation.

6.2. Personal data, the period of processing (storage) of which has expired, must be destroyed or anonymized, unless otherwise provided by the Law. The storage of personal data is carried out in a form that allows to determine the subject of personal data, no longer than required by the purposes of processing personal data, if the period of storage of personal data is not established by the Law. The processed personal data is subject to destruction or depersonalization upon achievement of the purposes of processing or in case of loss of the need to achieve these purposes, unless otherwise provided by the Law. We must also take into account the periods for which we may need to retain your personal data in order to comply with our legal obligations to you or to regulatory authorities (in accordance with EU Regulation 261/2004).

6.3. We may minimize the personal data we use about you over time, or we may even make your data anonymous so that it can no longer be associated with you personally. In this case, we may use this information without informing you further.

7. The circle of persons admitted to the processing of personal data by the Administration

7.1. To achieve the goals of this Policy, only those employees of the Administration who are entrusted with such an obligation 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 confidentiality and security of personal data during their processing from its employees.

7.2. The administration has the right to transfer personal data to third parties in the following cases:

– the subject of personal data has expressed his 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. At the same time, 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 provide them.

7.3. The Administration has the right to entrust the processing of personal data to a third party with the consent of the subject of personal data, unless otherwise provided by the legislation of Ukraine, on the basis of an agreement concluded with a third party, the condition of which is confidentiality and non-disclosure of personal data.

7.4. Representatives of state authorities (including regulatory, supervisory, law enforcement and other bodies) get access to personal data processed by the Administration in the amount and in the manner prescribed by the Legislation.

 

8. Implementation of personal data protection

8.1. The activities of the Administration for the processing of personal data in information systems are inextricably linked with the protection by the Administration of the confidentiality of the information received, if this does not contradict the 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 activities with the advent of new technologies, if necessary.

8.3. The exchange of personal data during their processing in information systems is carried out through communication channels protected by technical means of information protection.

8.4. When processing personal data in information systems, the Administration provides:

⦁ 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 facts of unauthorized access to personal data;

⦁ avoiding the impact on technical means of automated processing of personal data, as a result of which their functioning may be disrupted;

⦁ the possibility of immediate recovery of personal data modified and destroyed due to unauthorized access to them;

⦁ constant monitoring of the level of protection of personal data.

8.5. With regard to personal information, confidentiality is maintained, except when the technology of the online service or the settings of the software used by the User provide for an open exchange of information with other Users of the online service or with any Internet users.

8.6. The administration implements the following requirements of Ukrainian legislation in the field of personal data:

⦁ requirements for the confidentiality of personal data;

⦁ requirements to ensure the exercise by the subject of personal data of their rights;

⦁ requirements to ensure the accuracy of personal data, and, if necessary, relevance in relation to the purposes of processing personal data (with the adoption (ensuring the adoption) 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 from other illegal actions in relation to 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 the obligations stipulated by the legislation in the field of personal data from unauthorized or illegal processing and from unintentional loss, destruction or damage.

The administration adheres to the principle of minimizing personal data. We process only the information about you that we need, or the information that you consent to provide more than the limits of necessary processing. In addition, we have configured all interfaces of the Online Service and application to provide services so that the highest possible confidentiality is respected, the settings of which can be adjusted at your discretion. When transferring personal data to government authorities, we always use the most secure and proven methods for 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. Thus, the site will temporarily remember your benefits and actions that you have performed, including so that you do not need to re-enter this data. Our cookies by themselves do not identify an individual user, but only the computer or mobile device you are using.

Cookies and other tracking technologies in our online service can be used in a variety of ways, such as for the operation of the online service, traffic analysis or advertising purposes. We use cookies and other tracking technologies, among other things, to improve the quality and efficiency of our services.

For more information on what cookies are, how they work, how to manage them or how to delete them, please go to www.allaboutcookies.org .

We would like to inform you that in the settings of some Internet browsers you can set the prohibition of cookies and other tracking technologies. However, you should understand that if you disable some cookies, the functionality of the online service may be limited and you will not be able to use all its advantages, and some pages may not work correctly.

9. Rights of the subject of personal data

9.1. The rights of subjects of personal data in accordance with the legislation of Ukraine:

9.1.1. Know about the sources of collection, the location of their personal data, the purpose of their processing, the location of the processor of personal data or give an appropriate instruction to obtain this information to authorized persons, except as otherwise established by the Law.

9.1.2. Receive information about the conditions for granting access to personal data, including information about third parties to whom his personal data is transferred.

9.1.3. To access 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, an answer on whether his personal data is being processed, and which ones.

9.1.5. Submit a reasoned demand to the Administration for an objection to the processing of their personal data.

9.1.6. Submit a reasoned request to change or destroy your personal data if the data is processed illegally or is unreliable.

9.1.7. To protect your 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 protection from the provision of information that is unreliable or discrediting the honor, dignity and business reputation of an individual.

9.1.8. To file complaints about the processing of their personal data to the Administration to the Commissioner of the Verkhovna Rada of Ukraine for Human Rights or to the court.

9.1.9. Apply legal remedies in case of violation of the legislation on the protection of personal data.

9.1.10. Make reservations about limiting the right to process your personal data when giving consent.

9.1.11. Withdraw consent to the processing of personal data.

9.1.12. Familiarize yourself with the mechanism of automatic processing of personal data.

9.1.13. To protect against an automated decision that has legal consequences for him.

9.1.14. The Administration has the right to entrust the processing of personal data to a third party with the consent of the subject of personal data, unless otherwise provided by the legislation of Ukraine, on the basis of an agreement concluded with a third party, the condition of which is confidentiality and non-disclosure of personal data.

9.1.15. Representatives of public authorities (including regulatory, supervisory, law enforcement and other bodies) get access to personal data processed by the Administration in the amount and in the manner determined by the legislation of Ukraine.

9.2. Other rights of data subjects under the GDPR:

In addition to Ukrainian legislation on the protection of personal data, the Administration is attentive to ensuring your rights established by the GDPR.

9.2.1. The right to information.

We are prepared to provide data subjects with information about which of their personal data we process.

If you would like to know what personal data we process about you, you can make a request for this information at any time, including by contacting the Administration. The list of data that we have to provide you can be found in Articles 13 and 14 of the GDPR. At the same time, when applying, you must tell us your specific requirements so that we can legally consider your request and provide an answer.

Please note that in the event that we are unable to verify your identity through email exchanges or during your phone call, or in the event of reasonable doubt as to your identity, we may ask you to provide proof of identity, including by personal appearances at the address of the location of the Administration. Only in this way can we avoid the disclosure of 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 legal response regarding personal data is a complex process that can take up to a month.

9.2.2. The right to correct data in you.

If you find that some of the personal data we process about you is incorrect or out of date, please let us know. In this case, we may ask you to PROVIDE an identity document, including by personal appearance at the address of the location of the Administration.

If you want to correct the personal data that is being processed by us, you can make the correction yourself by logging into your personal account in the online service or by contacting the Administration.

In some cases, we will 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 executing the contract and/or they are contained in a tax document that was drawn up in accordance with the Tax legislation.

9.2.3. Withdrawal of consent to the processing of personal data and the right to be forgotten

In the event that the Administration processes your personal data on the basis of consent to the processing of personal data (in particular, for the purpose of carrying out marketing / advertising mailings), further processing can be terminated 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 will be required to keep in accordance with the requirements of the law.

Also in this case, for security purposes, the Administration may ask you to provide an identity document, including directly to the address of the location of the Administration.

10. Place of storage of personal data

The administration has a large database of personal data. To ensure their security, we use the cloud services of DigitalOcean, LLC. The data resides in data processing centers in the city of Frankfurt am Main, Germany.

11. Changing the privacy policy

11.1. This Policy may be changed or terminated by the Administration unilaterally without prior notice to Users, including if required by applicable law. The new version of the Policy comes into force from the moment it is posted on the online service, unless otherwise provided by the new version of the Policy. Therefore, we ask you to visit the site https://zcs.com.ua 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 suggestions regarding the protection and processing of personal data, you can contact the Director of PLANT OF CONVEYOR SYSTEMS Raku Evgeny Petrovich E-mail: zavodcs@gmail.com postal address: 49127, Dnipro, st. Gavanskaya, 16.

Be sure to include in all correspondence your first name, last name, e-mail address, as well as detailed questions, comments, complaints or requirements.

12.2. The administrative body for the protection of personal data in Ukraine is the Office for the Protection of Personal Data of the Secretariat of the Commissioner of the Verkhovna Rada of Ukraine for Human Rights. You can contact him with complaints or suggestions if you think that your rights have been violated in connection with the processing of personal data.