This Privacy and Personal Data Protection Policy (hereinafter referred to as the “Policy”) establishes the procedure for collecting and processing by Limited Liability Company “RAZOM COMMUNICATIONS” (hereinafter referred to as “LLC ‘RAZOM COMMUNICATIONS’”) of personal data, the types of personal data collected, the purpose of using such personal data, interaction with third parties, security measures to protect personal data, conditions for access to personal data, as well as contact information for the user regarding access, modification, blocking, or deletion of their personal data and addressing any questions that may arise concerning the storage and protection of personal data. This Policy applies to all information and data that LLC “RAZOM COMMUNICATIONS” may obtain about an individual (hereinafter — the User) while using the website https://rzm.com.ua (hereinafter — the Website) of LLC “RAZOM COMMUNICATIONS.”
1. This Policy sets the terms of access to and use of the Website and does not apply to third-party websites that the User may access via links available on the Website.
The User’s use of the Website signifies their unconditional agreement with this Policy and the terms specified herein. If the User disagrees with these terms, they must refrain from using the Website.
2. Consent to the Processing of Personal Data
2.1. By filling out forms on the Website, the User, as the subject of personal data, provides the Limited Liability Company “RAZOM COMMUNICATIONS” (Identification code 41172691, registered address: 4 Harmatna St., Kyiv, 03067) (hereinafter referred to as the “Data Controller”) with their consent to the processing of their personal data provided by the User when filling out such forms, as well as data obtained by the Data Controller in any other manner during the User’s use of the Website, in a personal data database for the purpose of fulfilling obligations assumed by the Data Controller, for the maintenance of relations in the fields of tax, accounting, and statistical reporting, as well as for maintaining relations in the fields of advertising and business communications, sending (dispatching) to the User’s address special offers, service information, and other information about the Data Controller, and for the performance by the Data Controller of its obligations towards the User or the entity represented by/employing the User (hereinafter referred to as the “User’s Company”).
2.2. Personal data of Users collected and processed by the Data Controller under this Policy include:
2.2.1. Personal data that the User provides about themselves when filling out forms on the Website, or that the Data Controller receives by other means, including such personal data of the User as:
- email address
- surname, first name, and patronymic
- phone number
- information provided by the User in the “Message Text” field in the feedback form on the Website
2.2.2. Information from the computer/mobile device. Any information about the computer system or other technological device used by the User to access the Website (IP address, type of operating system, type and version of web browser, unique mobile device identifier, advertising identifier, geographic location, etc.).
2.2.3. Website visit statistics data, which may include information about connection, traffic, user browser, as well as the date, time, duration of Internet use, and duration of visits to the Website.
2.2.4. Any other personal data and information voluntarily provided by the User to the Data Controller, as well as data that may be required by the Data Controller in connection with achieving the purpose of personal data processing.
3. Purposes of Collection and Processing of Users’ Personal Data
3.1. The Data Controller collects and stores personal data that is necessary for the provision of services to the User or the User’s Company, which is processed for the purposes and by the means specified in this Policy, except in cases where the legislation of Ukraine provides for the mandatory storage of personal information for a period determined by the laws of Ukraine.
3.2. The Data Controller processes the User’s personal data, including collection, receipt, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, and destruction — both by automated means and without the use of such means, as well as by mixed processing — for the following purposes:
- identification of the User as a representative/employee of the User’s Company;
- establishing feedback with the User, including the sending of messages and inquiries related to the use of the Website, processing of requests and applications from the User;
- confirmation of the authenticity and completeness of the personal data provided by the User;
- provision of effective customer support to the User or the User’s Company in the course of using the services provided by the Data Controller;
- technical support for the User in the event of issues related to the use of the Website;
- monitoring of Website usage;
- sending advertising messages to the User, offering the User additional opportunities to use the services provided by the Data Controller;
- improving the user experience and service quality, developing new services;
- analysis of data intended for the User, conducting statistical and other studies of the User’s (or User’s Company’s) interaction with the Data Controller.
4. Conditions for Processing of Users’ Personal Data and Their Transfer to Third Parties
4.1. The processing of Users’ personal data is carried out in accordance with the Law of Ukraine “On Personal Data Protection.”
4.2. All of the User’s personal data is kept confidential and protected.
4.3. The Data Controller has the right to transfer the User’s personal data and/or assign its processing to third parties in the following cases:
4.3.1. the transfer of data is necessary for the User’s use of the Website;
4.3.2. for the purpose of ensuring the possibility of protecting the rights and lawful interests of the Data Controller, including for legal proceedings;
4.3.3. if required by applicable legislation;
4.3.4. in response to a request from a competent law enforcement authority;
4.3.5. the transfer of the User’s data to the Data Controller’s legal successors in the event that the Data Controller or its assets are acquired or merged with another company, including as a result of bankruptcy.
4.4. The Website may contain links to other websites (third-party websites), which are not controlled by the Data Controller, and the Data Controller is not responsible for their content, privacy policies, or actions. Therefore, the Data Controller recommends that the User review the privacy and personal data policies of each such website before providing their personal data.
5. Measures Taken to Protect the User’s Personal Data
5.1. In processing personal data, the Data Controller takes necessary legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, distortion, blocking, copying, provision, dissemination, as well as from other unlawful actions in relation to the User’s personal data in accordance with the requirements of legislation on the protection of such data.
5.2. The processing and storage of Users’ personal data is carried out on equipment that ensures the functioning of the Website services and guarantees secure storage of personal data by the Data Controller.
5.3. Users’ personal data is processed and may be stored in a personal data database or a separate table in the Website’s database.
6. Obligations of the Data Controller and the User
6.1. The User is obliged to provide the Data Controller with accurate personal information when filling out forms on the Website.
6.2. The Data Controller is obliged to:
6.2.1. use the received personal data of the User exclusively for the purposes specified in this Privacy Policy;
6.2.2. ensure the confidentiality of the User’s personal data;
6.2.3. fulfill other obligations stipulated by this Policy and the legislation of Ukraine.
7. User Rights
7.1. The User has the right to receive any information about themselves from any entity involved in personal data relations, provided they indicate their surname, first name and patronymic, place of residence (location), and details of a document identifying the individual making the request, except as provided by law. Access to personal data about themselves is granted to the User free of charge.
7.2. The User, as the subject of personal data, has the following rights provided for by the Law of Ukraine “On Personal Data Protection”:
7.2.1. to know the sources of collection, location of their personal data, the purpose of its processing, the location or place of residence (stay) of the data controller or processor of personal data, or to give an appropriate authorization to obtain this information to authorized persons, except in cases established by law;
7.2.2. to receive information on the conditions of access to personal data, including information about third parties to whom their personal data is transferred;
7.2.3. to access their personal data;
7.2.4. to receive, no later than thirty calendar days from the date of receipt of the request by the Data Controller, except as provided by law, a response on whether their personal data is being processed, and to receive the contents of such personal data;
7.2.5. to submit a reasoned demand to the data controller objecting to the processing of their personal data;
7.2.6. to submit a reasoned demand for the modification or destruction of their personal data to any data controller or processor, if this data is processed unlawfully or is inaccurate;
7.2.7. to protect their personal data from unlawful processing and accidental loss, destruction, damage due to deliberate concealment, failure to provide or untimely provision, as well as protection from the provision of information that is inaccurate or defames the honor, dignity, and business reputation of the individual;
7.2.8. to file complaints regarding the processing of their personal data with the Commissioner for Human Rights of the Verkhovna Rada of Ukraine or with the court;
7.2.9. to apply legal remedies in case of violation of the legislation on personal data protection;
7.2.10. to make reservations regarding the restriction of the right to process their personal data during the provision of consent;
7.2.11. to withdraw consent to the processing of personal data;
7.2.12. to know the mechanism of automatic processing of personal data;
7.2.13. to protection against an automated decision that has legal consequences for them.
7.3. To update, access, modify, block, or delete their personal data, or to withdraw consent to the processing of personal data provided by the User in accordance with this Policy, please contact us by email at nb@rzm.com.ua or in writing at the address: 4 Harmatna St., Kyiv, 03067.
8. Additional Provisions
8.1. The Privacy Policy is published on the Data Controller’s website at https://rzm.com.ua/.
8.2. Users’ personal data may be used by the Data Controller for the period necessary to achieve the purposes of processing such data specified above or to comply with applicable law. Personal data may be destroyed in cases provided by the current legislation of Ukraine or upon written request from the User within 30 calendar days from the date the Data Controller receives such a request.
8.3. The User accepts the terms of this Privacy Policy and acknowledges that this Privacy Policy may be amended from time to time without prior notice to the User. Any changes to the Privacy Policy will be published on the Data Controller’s website at https://rzm.com.ua/, and such changes shall come into force from the moment they are posted on the Data Controller’s website, unless otherwise specified in the new version of the Policy. The User is encouraged to review the Policy periodically to stay informed about any changes or additions.
8.4. If the User disagrees with the changes made to this Policy, they are obliged to stop using the Website. The continued use of the Website by the User after changes have been made by the Data Controller constitutes confirmation of the User’s consent to and acceptance of the relevant amendments/updated version of this Policy.
9. Location of Personal Data
9.1. The Data Controller and data processor of the personal data provided by the User through the Website is LLC “RAZOM COMMUNICATIONS”.
9.2. Personal data is stored in automated systems and on electronic media of the Data Controller.