PRIVACY POLICY

Ukrpol Publishing House, LLC (“we”, “us”, “our”, “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 Policy (“Policy”) describes how we handle the data you provide us with through the website https://ukrpol.ua/ (“Site”). 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.

Ukrpol, LLC acts as a data controller in relation to personal data you provide us with.

You can be our visitor or client (collectively “users”):

  • You are a visitor (“visitor”), when you are surfing through the Site;
  • You are a client (“client”), when you submit your or third-party personal data via our social media accounts, email, contact us for assistance regarding the provision of services.

When you submit your personal data as a client through the Site, you may be asked to consent to our processing of the personal data you provide as explained in this Policy to enable us to provide you with the information or service requested, if no other legal ground can be used.

You may contact us using the following details:

  • Our email:: ukrpol@ukrpol.ua
Definitions

We use the following definitions in this Policy:

«data controller» means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data is processed;

«data processor» means the natural or legal person who processes personal data on behalf of the data controller;

«data subject» is any living individual who is using our Site;

«personal data» means any information relating to you and helping identify you (directly or indirectly) such as your name, last name, email, location data, etc;

«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, use, disclosure by transmission, dissemination or otherwise making available, erasure or destruction;

«services» means production of flexible or cardboard packaging, advertising, book and magazine products, manufacture of other paper or paperboard products on the basis of clients’ personal data;

«joint controllers» means two or more controllers jointly determining the purposes and means of processing.

Data Collection

We act as a controller in relation to the different categories of personal data.

We collect the information through the Site, our social media accounts, email, phone calls and process it as a data controller.

We use the personal data you provided us with or requested us to collect only for the purposes listed in this Policy. 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 special 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 a special 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

When acting as a data controller, we may process the following personal data:

Purposes
Type of personal data
Legal grounds
Third Parties recipients
Source
Communication with clients (including potential clients)
  • Name
  • Phone number
  • Company name
Performance of a contract (Article 6(1)(b)).
Microsoft Outlook
Site
Considering candidates for open vacancies in the Company
  • Name
  • Phone number
  • Any other personal data you may provide us with (for example, email, country of residence)
Performance of a contract (Article 6(1)(b)).
Microsoft Outlook, Work.ua
Site
Аnalysis of user behavior on the Site
  • Identifiers: IP address, data obtained from the cookies.
  • Usage data:: language settings, access time, address of the requested page, information about the user's browser (or another program through which the Site is accessed).
Your consent (Article 6(1)(a))
Google Analytics
Site

IMPORTANT: upon processing of payments using services of a payment processor, 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 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 the third-party websites. We advise you to access the payment processors’ websites carefully and always check their policies and rules regarding the collection of your personal data.

Data Security, Integrity and Retention

We store the data you have provided us with through the Site, our social media accounts, email, phone calls for the entire period when you use our services.

We store and process your personal data until we do not need it for any of the purposes defined in this policy, unless longer storage is required or expressly permitted by law.

To ensure the integrity and confidentiality of your data, our office has the 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 the compliance with all the requirements of the Company's internal policies and rules.

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 may request to delete your personal data by sending us an email at ukrpol@ukrpol.ua.

Data Sharing and Disclosure

We may share your personal data as data controller to joint controllers and data processors in accordance with provisions specified hereafter.

Sharing personal data with data processors.

We may share and disclose your personal data to the following data processors:

  • Microsoft Outlook (Microsoft Corporation, USA): for communication with clients and between our employees. You may read its Privacy Statement here.
  • Work.ua (Work Ukraine LLC, Ukraine): to find candidates for our open vacancies. You may read its Privacy Policy here.
  • Google Analytics (Google LLC, USA): to analyze statistical data on how the visitor uses the Site in order to improve our Site’s functionality. You may read its Privacy Policy here.
Sharing personal data with joint controllers

We act as joint controller while cooperating with advertising, analytics and other platforms.

When we act as a joint controller to particular processing of personal data, a data subject may exercise his/her rights under the GDPR in respect of and against both advertising/analytics platform and us.

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

We only transfer your personal data to third parties within requirements under the GDPR. Where possible, we always enter into Data Processing Agreements (DPAs) with them and treat personal data transfer seriously. Where the Contractor has an appropriate data processing agreement in place, the Company may adjoin such data processing agreement. If so, the Company and the Contractor may regulate the transfer of the personal data to such Contractor by means of this data processing agreement.

The Company had adjoined the publicly available data processing agreements of the following Contractors:


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.

Your Rights

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

If we receive any complaint, claim or request from the data subject which shall be completed by our joint controller, we immediately notify it of such request and inform the data subject on the applied measures and further performance steps regarding serving such complaint/claim/request.

Rights under the GDPR:
  • right of access means that you may ask us to send you the copy of your personal data collected together with information regarding the nature, processing and disclosure of that personal data;
  • right to rectification means that you may ask us to update and correct the false data, missing or incomplete personal data;
  • right to erasure (to be “forgotten”) means that you may ask us to delete your personal data collected, except insofar it is prohibited by appropriate laws;
  • right to restriction of processing means that you may ask us to restrict processing where:
    1. your personal data is not correct or outdated;
    2. the processing is unlawful.
  • right to object to the processing means that you may raise objections on grounds relating to your particular situation;
  • right to data portability means that you may ask us to transfer a copy of your personal data to another organisation or to you;
  • right to withdraw the consent, when your personal data processed on a basis of your consent;
  • right to lodge a complaint with the supervisory data protection authority pertaining to the processing of your personal data.

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

Data Protection Authority

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 Policy

This Policy 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 Policy to check for any changes.

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

Contact us

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

Email address: ukrpol@ukrpol.ua

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