PRIVACY POLICY

Last update: __ September 2022

Ukrpol Publishing House, LLC (“we”, “Company”) cares for your privacy and therefore provides you with the information hereunder. On this page, you can learn what information about you we collect while you interact with the Company, what for and how it is used, stored, disclosed etc., as well as how we process personal data you provide us with.

This Privacy Notice (“Notice”) describes how we handle the data you provide us with through the website https://ukrpol.ua/ (“Website”). It’s based on the current data protection laws and clarifies how we work to protect your rights and your integrity. Such treatment may include, but is not limited to, the following:

  • collection;
  • recording;
  • organization;
  • storage;
  • structuring;
  • use;
  • disclosure by transmission;
  • dissemination or otherwise making available;
  • restriction;
  • erasure or destruction.

We act as a data controller in relation to the personal data you provide us.

When you use our Website, you become our user. As a user, you may belong to a category:

  • Visitor — when you are surfing through the Website;
  • Client — when you submit your personal data via our forms on the Website;
  • Candidate — You are our potential employee and are applying for the position.

We may process personal data on the following lawful basis:

  • performance of the contract — the processing of personal data is necessary for the conclusion and performance of a contract;
  • legitimate interest — for processing that is reasonable for the user and necessary for the development of our services;
  • consent — for additional processing for certain purposes.

You may contact us using the following details:

Data Collection

We use the personal data you provided us with or requested us to collect only for the purposes listed in this Notice. We may share your personal data with third parties solely for purposes listed herein.

We do not sell your data. We DO NOT use automated decision-making and profiling that entail any legal effects or other similarly significant effects.

Company knowingly does not collect sensitive categories of personal data (data regarding racial or ethnic origin, political or religious beliefs, memberships in political parties and trade unions, criminal convictions, as well as data on health, sexual life, biometrics or genetic data). Please refrain from providing us with your personal data that falls into the sensitive category mentioned above. If the Company still receives sensitive personal data, we process it in accordance with all the requirements of applicable personal data protection legislation.

Personal Data We Collect

The data we collect and process through the Website and the forms are divided into categories:

  • automatically collected data (Visitors data);
  • the data provided to us by the Client;
  • the data provided to us by the Candidate;
  • data obtained from third parties.
Automatically collected data (Visitors data)
Data category
Description
Purpose
Lawful basis
Technical data
IP address, browser type, operating system; language settings, access time, address of the requested page, information about the user's browser (or another program through which the Website is accessed)
Correct operation of the Website
Legitimate interest
Necessary cookies
Information necessary for the operation of the Website.
Improving your experience using the Website
Legitimate interest
Statistical cookies
Statistical information generated when using our Website.
Statistics and analytics
Consent
Storage limitation
Data that are processed based on a legitimate interest
Stored for up to 2 years from the last use of the Website
Data that are processed based on consent
Stored for up to 2 years from the last use of the Website or until the withdrawal of consent

The data provided to us by the Client.
Data category
Description
Purpose
Lawful basis
Order form data
Name Phone number Company name
Ordering
Performance of the contract
IMPORTANT: upon processing of payments using the Services of a payment processor, the such payment provider may collect your e-mail address, phone number, billing address, credit card details and expiry date and other personal data it considers as necessary for the provision of services. Such collection of personal data is regulated under the rules and policies of payment processors. We are not responsible and hold no liability regarding your personal data collected by third-party websites. We advise you to access the payment providers’ websites carefully and always check their policies and rules regarding the collection of your personal data.
Storage limitation
Data that are processed based on the performance of the contract
Stored while using our service + 3 years

The data provided to us by the Candidate.
Data category
Description
Purpose
Lawful basis
Application data
Name Phone number CV
Recruitment
Performance of the contract
Storage limitation
Data that are processed based on the performance of the contract
Stored for 1 year after application

Data obtained from third parties

In addition, we may collect some data from third-party services. This helps us:

  • develop and improve our Website;
  • manage internal processes;
  • answer your questions and communicate with you.

The scope of the data collected, the purpose and the basis of the processing are determined by the respective privacy documents of these parties:

Category of third parties
Purpose
Marketing and analytical tools
We use different analytics tools to promote ourselves. Contact us for a full list of marketing and analytics tools.
Messengers
We use various messengers to communicate with you in ways that are convenient for you. Contact us for a complete list of messengers.
Payment providers
We use payment service providers to arrange secure financial transfers. Contact us for a full list of payment providers.
Social media
We use various social media to communicate with you and promote ourselves. Contact us for a complete list of social media.
Job search services
We use various job search services for recruitment. Contact us for a complete list of job search services.

IMPORTANT: we may receive data from third parties, but we won't necessarily receive it. It all depends on your settings and the features you use. For example, we may receive data if you communicate with us via messengers.

Data Security, Integrity and Retention

To ensure the integrity and confidentiality of your data, our office has a security service at the entrance. Our office is accessible only through turnstiles and with special passes. Also, all guests of the office are accompanied by an employee of the Company to ensure compliance with all the requirements of the Company's internal policies and rules.

The company uses Secure Sockets Layer (SSL) encryption for user requests. URL encryption is also used, including with regard to the path and name of the resource (page), query parameters, headers, and cookies, which often contain user personal data. The database administrator access password is also encrypted.

You can exercise your right to erasure. In this case, we will delete your data from our servers within 30 days of your request. You can exercise your rights by sending us a request to the email: ukrpol@ukrpol.ua

Data Sharing and Disclosure
General

We may transfer your data with our employees and partners for contractual purposes. We transfer your data on the following basis:

  1. Consent. We transfer your personal data based on your explicit consent.
  2. Compliance with the law. We will disclose your personal data to third parties to the extent that it is necessary:
    • to comply with a government request, court order, or applicable law;
    • prevent the illegal use of our Website or violation of our policies;
    • to protect against claims of third parties;
    • to help prevent or investigate fraud.
  3. Transfer to third parties: we contractually transfer your personal data to third parties for processing on our behalf, subject to technical and organisational measures to protect your personal data. We may transfer data to certain companies, consultants and contractors hired to provide certain services on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service and marketing assistance.

IMPORTANT: we will ask for your consent if the transfer of data is not part of the contract.

Data transfer outside the European Economic Area

We may transfer your personal data to different countries, including the EU countries, the UK, Ukraine, and other countries that are not determined to offer an adequate level of data protection on the basis of article 45 of General Data Protection Regulation (adequacy decision) with appropriate safeguards as determined under the General Data Protection Regulation (“GDPR”).

We only transfer your personal data to third parties within requirements under the GDPR. We always enter into Data Processing Agreements (“DPA”) with them and treat personal data transfer seriously. Where the Processor has an appropriate DPA in place, the Company may adjoin such DPA.

Data Subject Age

The Company does not knowingly collect personal data from persons under the age of 16.

By entering into the contract with the Company, you acknowledge that you have reached the age of 16 and under the laws of your country of residence you have all rights to provide us with your personal data for processing.

The use of cookies

We use cookies that are necessary for the Website to function. By using cookies, we receive automatically collected data. You can read more in our Cookie Policy.

If you want to disable cookies, you can find instructions for managing your browser settings at these links:


Your Rights

You may exercise the following rights by submitting your request at ukrpol@ukrpol.ua.

We comply with global best practices for data protection (“GDPR”) and represent the rights provided there.

You, as data subjects, have the following rights:

Right
Description
Right to access
You can request an explanation of the processing of your personal data.
Right to rectification
You can change the data if it is inaccurate or incomplete.
Right to erasure
You can send us a request to delete your personal data from our systems. We will remove them unless otherwise provided by law.
Right to restriction the processing
You may partially or completely prohibit us from processing your personal data.
Right to object
You may object to the processing of your personal data.
Right to withdraw consent
You can withdraw your consent at any time.
Right to file a complaint
If your request was not satisfied, you can file a complaint to the regulatory body.

Data Protection Authority

You may submit the complaint to the supervisory authority of your place of residence within the EU, Ukraine.

We kindly invite you to share your concerns with us in the first place regarding any issue related to your personal data processing. You may use the following channels to address your inquiries: ukrpol@ukrpol.ua.

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. The list of EU data protection authorities you may find here.

Changes to the Privacy Notice

This Notice may be changed from time to time due to the implementation of new technologies, laws’ requirements or for other purposes. We will send notice to you if these changes are dramatic and where required by applicable laws, we will obtain your consent. Also, we encourage you to regularly review this Notice to check for any changes.

Such notification may be provided via an announcement on the Website and/or by other means consistent with applicable law.

Contact us

If you have any issues concerning the usage of our Website, please do not hesitate to contact us through:

Email address:: ukrpol@ukrpol.ua

Phone number: +38 (03245) 7-21-47

Address for postal letters: Ukraine, 82400, Lviv region, Stryi city, Promyslova st. 2А

Representative office in Poland: ____________, Obrzezna st. 5/712.

mykola.kovalchuk@ukrpol.ua

+48 737 465 733