EN

PRIVACY POLICY

Last updated: 15 June 2024

PRINTING COMPANY “UKRPOL”, LLC (“we”, “us”, “our”)is a Ukrainian company that operates this Websitehttps://ukrpol.ua/ (“Website”).

We care about your privacy and would like to explain how we collect, process, and use your personal data in this Privacy Policy (“Policy”).

When interacting with us, you can be considered a website visitor, a potential customer, a customer or a job applicant:

  • You are a website visitor when you merely browse this Website and provide us with your data via cookies or other tracking technologies;
  • You are a potential customer when you contact us via email, phone, our social media accounts (Instagram, Facebook, LinkedIn) or messengers, fill out online forms on this Website or subscribe to newsletters, contact us in person, by mail, or other available means of communication.
  • You are a customer when you make a purchase of our products or services, and contact us via available options for assistance.
  • You are a job applicant when you apply for a job via a form on our Website and contact us via available options regarding our vacancies.

We use the following definitions in this Privacy Policy:

  • “GDPR” means the European Union’s General Data Protection Regulation.
  • “data subject” is an identified or identifiable natural person about whom we hold personal data.
  • “personal data” means any information relating to you and helping identify you (directly or indirectly), such as a name, email, address, etc.
  • “controller” means the natural or legal person who (either alone or jointly with others) determines the purposes and means of the processing of personal data.
  • “processor” means a natural or legal person who processes personal data on behalf of the controller.
  • “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

We act as a controller under the GDPR when we process your data under this Privacy Policy.

PRINTING COMPANY “UKRPOL”, LLC is a Ukrainian company with the EDRPOU code 32802333.

We may collect your personal data when you:

  • visit our Website;
  • contact us via email, phone, our social media accounts or messengers;
  • fill out online forms on the Website;
  • subscribe to newsletters;
  • contact us in person or by mail;
  • make a purchase of our products or services and sign the contract with us;
  • contact us about job applications and the recruitment process, and send us your job application via our Website;
  • voluntarily provide your data, including where you knowingly choose to share your personal data on our Website in any other scenarios.

Providing your contact details for payment and transaction information is necessary to enter into or perform a contract with you in the meaning of the GDPR.

We collect website visitor data, potential customer data, customer data, and job applicant data:

Website visitor data
Type of data
Description
Collected personal data
(a) Cookies Information
We use cookies on our Website for analytics and marketing activities, remembering your preferences, ensuring the Website functionality and for other purposes.

We can collect usage information (pages you have viewed on our Website, search terms and search results, and other information regarding your use of the Website) for analytics purposes. We also use necessary, preferences and targeting cookies. To learn more about our use of cookies, please read our Cookies Policy.

(b) Automatically Collected Information
We may automatically collect some information about you and your device when you access our Website.
This information may include the domain name and IP address of your device, the type of browser you are using, technical information, geographical location, and information about your visit to our Website (length of visit, products you viewed, page response time, navigation paths, as well as information about the timing, frequency, and pattern of your service use, etc.).
Potential customer data
(c) Potential Customer Information
When you contact us via email, phone, our social media accounts (Instagram, Facebook or LinkedIn), messengers, fill out online forms on the Website or subscribe to newsletters, contact us in person or by mail, we may collect some information about you. We may process this information to promote our products and services and communicate with potential customers.
It may include your name, email, phone number, your company name, and any other information in communications between you and us.
Customer data
(d) Customer Information
We may process your contact information relating to our customer relationships and other information you provide us with, in particular, when signing the contract with us. We may process this information to manage our relationships with customers and communicate with them, keep records of those communications, and promote our services.
It may include your name, contact details (email address, phone number, fax), your company name, legal data needed for signing the contract and information contained in communications between you and us.
(e) Transactions and Payment Information
We will process some financial details or banking information to obtain payment from you.
It includes your contact details, your company details and transaction details so that the order can be fulfilled.
Job applicant data
(f) Job Applicant Information
We will process the information relating to your job application for our recruitment processes.
It may include your name, place of residence, contact details (phone, email), data about your previous employment(s), education, and other information relevant to recruitment purposes.

When we act as a data controller:

  • we DO NOT collect or process your sensitive data;
  • we DO NOT use automated decision-making, including profiling, which produces legal effects concerning a data subject or similarly significantly affects a data subject;
  • we DO NOT sell your data.

We process your personal data in accordance with the GDPR, which provides an exhaustive list of lawful bases for processing. We rely on four of them:

Article 6.1(a): consent

We process your personal data to protect our legitimate interests, such as:

  • preventing fraud;
  • for the recruitment process;
  • ensuring the security and functionality of our Website.

We only collect and use the data necessary to achieve these purposes and do not override your fundamental rights and freedoms.

Article 6.1(b): performance of a contract

When you provide us with personal data to purchase our products or services, this can be considered as a request to form a contract or to perform a contract between you and us.

Article 6.1(c): legal obligation

We process your personal data to fulfil our legal obligations, such as complying with tax or regulatory requirements.

In case you send us a request to exercise your rights under the GDPR, we may ask you for some personal data we already have to identify you and achieve compliance with the applicable law.

When acting as a data controller, we use your personal data for the purposes listed in this table, where we also detail the type of personal data processed and the legal bases we rely on to do so.

Purpose of processing
Type of personal data
Legal grounds
Third parties recipients
Source
Provision of services
(d) Customer Information
Performance of a contract (Article 6(1)(b))
IT Enterprise ASystem ClickUp
customer
Processing of payments
(e) Transactions and Payment Information
Performance of a contract (Article 6(1)(b))
BAS IT Enterprise
customer
Communication with customers and potential customers (including responding to queries and requests, customer support, investigating complaints and assisting with product or service selection)
(c) Potential Customer Information (d) Customer Information
Performance of a contract (Article 6(1)(b))
Facebook Mailchimp
potential customer customer
Recruitment
(f) Job Applicant Information
Our legitimate interest (Article 6(1)(f))
BAS IT Enterprise ClickUp
job applicant
Analytics & Developing & Maintenance of the Website
(a) Cookies Information (b) Automatically Collected Information
Your consent (Article 6(1)(a)) Our legitimate interest (Article 6(1)(f))
Google Analytics Webmill Web-Production
website visitor
Marketing activities
(a) Cookies Information (b) Automatically Collected Information (d) Customer Information (c) Potential Customer Information
Your consent (Article 6(1)(a))
Google Analytics Google Ads Facebook Mailchimp
website visitor сustomer potential customer
Security and fraud prevention
(a) Cookies Information (b) Automatically Collected Information
Our legitimate interest (Article 6(1)(f))
Google Analytics Webmill Web-Production
website visitor
Complying with the law or legal process
(a) Cookies Information (b) Automatically Collected Information (c) Potential Customer Information (d) Customer Information (e) Transactions and Payment Information (f) Job Applicant Information
Legal obligation (Article 6(1)(c))
BAS ASystem IT Enterprise ClickUp
website visitor сustomer potential customer job applicant

We may share your personal data as a data controller with joint controllers, other controllers, and data processors. When we act as a joint controller for a particular processing of personal data, data subjects may exercise their rights under the GDPR in respect of and against both joint controllers.

We act as the joint controller while cooperating with Facebook (Meta Platforms Ireland Limited). With respect to this case of personal data processing, we are the party to the Facebook Controller Addendum.

We act as independent controllers with Google LLC across Google LLC’s digital marketing services, such as Google Ads. To learn more, please read our Cookies Policy.

We may share your personal data with data processors who act on our behalf according to our instructions (“service providers”) to effectively manage risks, seek professional advice, and deliver services. We may share your data with our representatives in other countries (e.g., “PRINTING COMPANY “UKRPOL” Sp. z o.o. in Poland).

Also, we may share and disclose your personal data to other service providers:

  • Facebook (Meta Platforms Ireland Ltd., Ireland): for Facebook targeting and communication. You may read its privacy policy here;
  • IT Enterprise (Research and Production Enterprise “Information Technologies”, LLC, Ukraine): for automating our internal management. You may read its privacy policy here.
  • ClickUp (Mango Technologies, Inc, USA): for automating our internal management. You may read its privacy policy here.
  • Webmil Web-Production (Webmil Web-Production, LLC, Ukraine): for website development. You may read its privacy policy here.
  • BAS (Business automation software for document management; CORP, “NetHelp Jarocki Piotr”, Poland): automation of accounting.
  • Mailchimp (The Rocket Science Group, LLC, USA): for marketing communications. You may read its privacy policy here;
  • Google Analytics (Google Ireland Limited, Ireland): for analytics purposes. You may read its privacy policy here;
  • Google Ads (Google Ireland Limited, Ireland): for advertising. You may read its privacy policy here.

This Privacy Policy applies only to this Website. We strongly recommend you review the privacy documents of any websites you may reach by following the hyperlinks presented on our Website. We have no control over the content and data practices of other websites and are not responsible for their actions.

We manage our official pages on different social media, particularly LinkedIn, Facebook, and Instagram. We may also use messengers to communicate with you.

Please note that we are not responsible for social media or messengers’ data practices and advise checking their privacy documents regarding the collection of your personal data on their side.

We may transfer your personal data to countries outside the European Union (EU) and the European Economic Area (EEA) that are not deemed to provide an adequate level of data protection under Article 45 of the GDPR (adequacy decision).

In such cases, we will ensure that appropriate safeguards are implemented in accordance with the GDPR to protect your personal data, in particular, the standard contractual clauses adopted by the European Commission. Where possible, we always enter into Data Processing Agreements (DPAs) and Non-Disclosure Agreements (NDAs) with these third parties to ensure that your personal data is adequately protected.

As a data controller, we store and process your personal data collected via the Website for the period of three years unless a longer retention period is required or expressly permitted by law. We may not delete or anonymize your data if we are required to retain it to comply with the law or legal process.

To exercise your right to erasure, you may contact us at ukrpol@ukrpol.ua or in any other convenient way.

We have implemented appropriate organizational, technical, administrative, and physical security measures to ensure the ongoing confidentiality, integrity, availability, and resiliency of systems and services that process personal information and will restore the availability and access to information in case of a physical or technical incident on time.

We do not knowingly collect personal data from persons under 16. By providing us with your personal data, you confirm that you are at least 16 years old and, according to the law of your country, you have all rights to consent to the processing of your personal data.

If you have any reason to believe that children under 16 have provided their personal data to us, please contact us at ukrpol@ukrpol.ua.

You may exercise the following rights by submitting a data subject request at ukrpol@ukrpol.ua.

Please note that we may need to confirm your identity for us to process your requests to exercise your rights under the GDPR. Thus, we may not be able to satisfy your request if you do not provide us with sufficient detail to allow us to verify your identity and respond to your request.

Right under the GDPR
Description
How to exercise it
Right to withdraw consent (Art. 7)
You can withdraw your consent for data processing at any time.
You can submit a request.
Right to be informed (Art. 13, 14)
You have the right to be informed about the collection and use of your personal data.
All information about our collection and use of your personal data is described in this Privacy Policy and the Cookies Policy.
Right of Access (Art. 15)
You have the right to confirm whether your personal data is being processed by us and access such data, along with specific information.
You can submit a request.
Right to rectification (Art. 16)
You have the right to correct inaccurate personal data about you and to have incomplete personal data completed.
You can submit a request.
Right to erasure (‘right to be forgotten’) (Art.17)

You have the right to have your personal data deleted without undue delay where one of the following grounds applies:

  • the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  • you withdraw consent to consent-based processing;
  • you object to the processing under certain rules of applicable data protection law;
  • the personal data have to be erased for compliance with a legal obligation in the European Union or an EU Member State law;
  • the personal data have been collected in relation to the offer of information society services referred to in Article 8(1);
  • the personal data have been unlawfully processed.
You can submit a request.
Right to restriction of processing (Art. 18)

You can limit the way in which we use your data where one of the following applies:

  • you contest the accuracy of the personal data;
  • processing is unlawful, but you oppose erasure;
  • we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise, or defense of legal claims;
  • you have objected to processing, pending the verification of that objection.

You can submit a request.

Where processing has been restricted on this basis, we may continue to store your personal data.

However, we will only otherwise process it:

  • with your consent;
  • for the establishment, exercise, or defense of legal claims;
  • for the protection of the rights of another natural or legal person;
  • or for reasons of important public interest.
Right to data portability (Art. 20)
You have the right to receive your personal data in a structured, commonly accepted, and machine-readable format and have the right to request that we transmit this data directly to another controller to the extent that the legal basis for our processing of your personal data is your consent or performance of a contract and the processing is carried out by automated means.
You can submit a request.
Right to object (Art. 21)
You have the right to object to our processing of your personal data at any time to the extent that the processing is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. Also, you have the right to object to our processing of your personal data for direct marketing purposes (including profiling).
You can submit a request.
Right not to be subject to a decision based solely on automated processing, including profiling (Art. 22)
This right restricts us from making solely automated decisions, including those based on profiling, which produce legal or other significant effects for data subjects.
We DO NOT use automated decision-making and profiling.
Right to lodge a complaint (Art. 77)
You have the right to lodge a complaint with the supervisory authority if you believe that the processing of your personal data violates the requirements of the GDPR.
You can submit the complaint in the EU member state of your place of habitual residence or to the data protection authority stated in this Privacy Policy.
Right to compensation (Art. 82)
Any person who has suffered material or moral damage as a result of a violation of GDPR requirements has the right to receive compensation from the controller or processor for the caused damage.
Court proceedings for exercising the right to receive compensation shall be brought before the courts competent under the law of the EU Member State referred to in Article 79(2).

We encourage you to reach out to us initially with any concerns you may have regarding the processing of your personal data. You may use the following email to address your concerns: ukrpol@ukrpol.ua

If you are not satisfied with our response to your complaint, you may have the right to appeal our decision by contacting us or lodge your complaint with your local data protection authority.

In some cases, you have the right to lodge a complaint about our use of your personal data with a data protection authority. For more information, please contact your national data protection authority. We will cooperate with the appropriate governmental authorities to resolve any privacy-related complaints that cannot be amicably resolved between you and us. You can find a full list of EU supervisory authorities through this link.

We may periodically update this Policy to reflect new updates, technologies, legal requirements, or for other reasons. Any changes will be communicated by posting a revised version of the Policy on our Website. Such changes will be effective immediately upon posting them.

We encourage you to review this Policy periodically. Your continued use of our Website after the revised Policy has become effective constitutes your acceptance of the new terms of the Policy. If the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change.

For questions regarding the processing of your personal data, please contact us:

PRINTING COMPANY “UKRPOL”, LLC

  • Our address: Promyslova Str. 2-A, 2-B, Stryi, Lviv region, Ukraine;
  • Our telephone number: +38 (03245) 7-21-47;
  • Our email: ukrpol@ukrpol.ua