Personal data processing policy
1. General provisions
The actual personal data processing policy was drawn up in accordance with the requirements of the Law of Ukraine dated June 1, 2010 No. 2297-VI "On the Protection of Personal Data" (hereinafter referred to as the "Law") and defines the procedure for processing personal data and measures to ensure the security of personal data used by the Company with limited liability "Innovative technological solutions" (hereinafter - the Operator).
1.1. The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This policy of the Operator on the processing of personal data (hereinafter - the Policy) applies to all information that the Operator can obtain about visitors to the website https://itsodessa.com.
2. Basic concepts used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer equipment.
2.2. Blocking of personal data – temporary suspension of processing of personal data (unless processing requires clarification of personal data).
2.3. The website is a collection of graphic and informational materials, as well as computer programs and databases, which ensure their availability on the Internet at the network address https://itsodessa.com.
2.4. The information system of personal data is a set of personal data contained in databases, and their processing is ensured by information technologies and technical means.
2.5. Depersonalization of personal data — actions in which it is impossible to determine without the use of additional information the ownership of personal data to a specific User or other subject of personal data.
2.6. Processing of personal data – any action (operation) or set of actions (operations) carried out with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing) , extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state body, municipal body, legal entity or natural person that independently or jointly with other persons organizes and (or) carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, actions (operations) , which are carried out with personal data.
2.8. Personal data - any information relating directly or indirectly to a specific or User-defined website https://itsodessa.com.
2.9. Personal data authorized by the subject of personal data for distribution - personal data, access to an unlimited range of persons to whom the subject of personal data has been granted by giving consent to the processing of personal data, authorized by the subject of personal data for distribution in the manner prescribed by the Law on personal data (hereinafter referred to as personal data data permitted to be distributed).
2.10. User is any visitor to https://itsodessa.com.
2.11. Provision of personal data – actions created to disclose personal data to a certain person or a certain circle of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an unspecified number of persons (transfer of personal data) or to familiarization with personal data of an unlimited number of persons, including publication of personal data in mass media, placement in information and telecommunication networks or provision of access to personal data in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to a foreign authority, a foreign natural person or a foreign legal entity.
2.14. Destruction of personal data - any actions, as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) material carriers of personal data are destroyed.
3. Basic rights and obligations of the Operator
3.1. The operator has the right to:
– to receive reliable information and/or documents containing personal data from the subject of personal data;
– in the event that the subject of personal data withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Law on Personal Data;
- Independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The operator is obliged to:
- to provide the subject of personal data at his request with information regarding the processing of his personal data;
- to organize the processing of personal data in accordance with the procedure established by the current legislation of Ukraine;
- respond to appeals and requests of personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
- to notify the authorized body for the protection of the rights of personal data subjects at the request of this body, the necessary information within 30 days from the date of receipt of such a request;
- publish or otherwise provide unrestricted access to this Policy on the processing of personal data;
– take legal, organizational and technical measures to protect personal data from illegal or accidental access to them, destruction, changes, blocking, copying, provision, distribution of personal data, as well as from other illegal actions regarding personal data;
- stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Law on Personal Data;
- Perform other duties stipulated by the Law on Personal Data.
4. Basic rights and obligations of subjects of personal data
4.1. Subjects of personal data have the right to:
- To receive information related to the processing of his personal data, except for cases provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data belonging to other subjects of personal data, except when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
– to demand from the operator clarification of his personal data, their blocking or destruction in the event that personal data are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as take legal measures to protect his rights;
- to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- to withdraw consent to the processing of personal data;
- appeal to the authorized body for the protection of the rights of personal data subjects or in a court of law against the illegal actions or inaction of the Operator during the processing of his personal data;
- to exercise other rights provided for by the legislation of Ukraine
4.2. Subjects of personal data are obliged to:
- provide the Operator with reliable data about yourself;
- notify the Operator about clarification (update, change) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another subject of personal data without the latter's consent, are responsible in accordance with the legislation of Ukraine.
5. The Operator may process such personal data of the User
5.1. Full Name.
5.2. E-mail address.
5.3. Phone numbers.
5.4. The site also collects and processes depersonalized data about visitors (including cookie files) using Internet statistics services (Google Analytics and others).
5.5. Data according to the text of the Policy are united by the general concept of Personal data.
5.6. Processing of special categories of personal data related to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.
5.7. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data, is allowed if the prohibitions and conditions stipulated by Art. 10.1 of the Personal Data Act.
5.8. The User's consent to the processing of personal data permitted for distribution is issued separately from other consents to the processing of personal data. At the same time, the conditions stipulated, in particular, in Art. 10.1 of the Personal Data Act. The requirements for the content of such consent are established by the authorized body for the protection of the rights of the subjects of personal data.
5.8.1 Consent to the processing of personal data permitted for distribution is given by the User directly to the Operator.
5.8.2 The Operator is obliged, no later than three working days from the moment of receiving the User's consent, to publish information about the conditions of processing, the presence of prohibitions and conditions for the processing of personal data authorized for distribution by an unlimited number of persons.
5.8.3 Transfer (distribution, provision, access) of personal data authorized by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This requirement should include the surname, first name, patronymic (if available), contact information (phone number, email address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this requirement can be processed only by the Operator to whom it was sent.
5.8.4 Consent to the processing of personal data permitted for distribution ceases to be effective from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.
6. Principles of personal data processing
6.1. Processing of personal data is carried out on a legal and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined and legal goals. Processing of personal data incompatible with the purpose of collecting personal data is not allowed.
6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for mutually incompatible purposes.
6.4. Only personal data that correspond to the purposes of their processing shall be processed.
6.5. The content and scope of processed personal data correspond to the stated purposes of processing. Redundancy of processed personal data in relation to the declared purposes of their processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, in necessary cases, relevance in relation to the purposes of personal data processing is ensured. The operator takes the necessary measures and/or ensures their adoption regarding the deletion or clarification of incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form that allows identification of the subject of personal data, no longer than the purpose of processing personal data requires, if the term of storage of personal data is not established by federal law, a contract to which the beneficiary or guarantor is a party object of personal data. The processed personal data is destroyed or depersonalized after the goals of the processing have been achieved or in the event of the loss of the need to achieve these goals, unless otherwise provided by federal law.
7. Purposes of personal data processing
7.1. The purpose of processing the User's personal data:
– informing the User by sending e-mails;
- conclusion, execution and termination of civil law contracts;
- providing the User with access to services, information and/or materials contained on the website https://itsodessa.com.
7.2. The Operator also has the right to send messages to the User about new products and services, special offers and various events. The User can always refuse to receive information messages by sending a letter to the Operator at the e-mail address firstname.lastname@example.org marked "Rejection of notifications about new products and services and special offers".
7.3. Depersonalized data of Users, which are collected with the help of Internet statistics services, serve to collect information about the actions of Users on the site, to improve the quality of the site and its content.
8. Legal bases of personal data processing
8.1. The legal grounds for processing personal data by the Operator are:
– Law of Ukraine dated June 1, 2010 No. 2297-VI "On Protection of Personal Data" (hereinafter referred to as "the Law");
- Federal laws, other legal acts in the field of personal data protection;
– consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution.
8.2. The Operator processes the User's personal data only if they are filled in and/or sent by the User independently through special forms located on the website https://itsodessa.com or sent to the Operator by e-mail. By filling out the appropriate forms and/or sending personal data to the Operator, the User expresses his agreement with this Policy.
8.4. The subject of personal data independently decides on the provision of his personal data and gives consent freely, of his own free will and in his own interest.
9. Terms of personal data processing
9.1. Processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
9.2. The processing of personal data is necessary to achieve the goals stipulated by the international treaty of Ukraine or the law, to implement the functions, powers and duties assigned to the operator by the legislation of Ukraine.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a court act, an act of another body or official, which are subject to execution in accordance with the legislation of Ukraine on executive proceedings.
9.4. The processing of personal data is necessary for the performance of a contract to which the party of the beneficiary or guarantor is the subject of personal data, as well as for the conclusion of a contract at the initiative of the subject of personal data or the contract under which the subject of personal data will be the beneficiary or guarantor
9.5. The processing of personal data is necessary for the realization of the right and legitimate interests of the operator or third parties or for the achievement of socially significant goals, provided that the legal rights and freedoms of the subject of personal data are not violated.
9.6. Processing of personal data is carried out, access of an unlimited number of persons to whom the subject of personal data has been provided or at his request (hereinafter - publicly available personal data).
9.7. Personal data subject to publication or mandatory disclosure in accordance with federal law is processed. 10. The procedure for collecting, storing, transferring and other types of personal data processing
The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary for the full implementation of the requirements of current legislation in the field of personal data protection.
10.1. The operator ensures the preservation of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.
10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except for cases related to the implementation of applicable legislation or in the case that the subject of personal data has given consent to the Operator for the transfer of data to a third party for the fulfillment of civil obligations - a legal contract.
10.3. If inaccuracies in personal data are detected, the User can update them independently by sending a message to the Operator at the Operator's e-mail address email@example.com marked "Update personal data".
10.4. The term of personal data processing is determined by the achievement of the purposes for which personal data were collected, unless another term is provided by the contract or current legislation.
The User may withdraw his consent to the processing of personal data at any time by sending a message to the Operator via e-mail to the Operator's e-mail address firstname.lastname@example.org with the mark "Revocation of consent to the processing of personal data".
10.6. The prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing of personal data in the state, public and other public interests, defined by the legislation of UKRAINE.
10.7. During the processing of personal data, the operator ensures the confidentiality of personal data.
10.8. The operator stores personal data in a form that allows identification of the subject of personal data, no longer than the purpose of processing personal data requires, if the term of storage of personal data is not established by federal law, a contract to which the beneficiary is a party or a guarantor for which the subject is object of personal data.
10.9. The condition for the termination of personal data processing may be the achievement of the goals of personal data processing, the expiration of the consent period of the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the detection of improper processing of personal data.
11. List of actions carried out by the Operator with the received personal data
11.1. The operator collects, records, systematizes, accumulates, stores, specifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, and destroys personal data.
11.2. The operator carries out automated processing of personal data with the receipt and/or transmission of the received information via information and telecommunication networks
12. Cross-border transfer of personal data
12.1. At the beginning of the cross-border transfer of personal data, the operator is obliged to make sure that the foreign country, whose territory is intended to transfer personal data, ensures reliable protection of the rights of the subjects of personal data.
12.2. Cross-border transfer of personal data on the territory of foreign countries that do not meet the above-mentioned requirements can be carried out only in the case of the consent in writing of the subject of personal data to the cross-border transfer of his personal data and/or the performance of a contract to which the subject of personal data is a party .
13. Confidentiality of personal data
The operator and other persons who received access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
14. Final provisions
14.1. The User can get any clarifications on issues related to the processing of his personal data by contacting the Operator via e-mail email@example.com