Contents

1. General concepts and scope of application.
2. List of personal data databases.
3. Purpose of processing personal data.
4. Procedure for processing personal data: obtaining consent, notifying about rights and actions with personal data of the data subject.
5. Location of the personal data database.
6. Conditions for disclosing information about personal data to third parties.
7. Protection of personal data: methods of protection, responsible person, employees who directly process and/or have access to personal data in connection with the performance of their official duties, storage period of personal data.
8. Rights of the data subject.
9. Procedure for handling requests from the data subject.
10. State registration of the personal data database.

1. General concepts and scope of application.

1.1. Definitions:

personal data database — a named collection of organized personal data in electronic form and/or in the form of personal data card files;

responsible person — a designated individual who organizes work related to the protection of personal data during their processing, in accordance with the law;

database owner — an individual or legal entity authorized by law or with the consent of the data subject to process these data, who determines the purpose of processing personal data in this database, establishes the composition of these data and the procedures for their processing, unless otherwise provided by law;

The State Register of Personal Data Databases is a single state information system for the collection, accumulation, and processing of information about registered personal data databases;

publicly available sources of personal data — directories, address books, registers, lists, catalogs, and other systematized collections of open information that contain personal data published with the knowledge of the data subject.

Social networks and internet resources where the data subject leaves their personal data (except where the data subject explicitly states that personal data is placed for the purpose of free dissemination and use) are not considered publicly available sources of personal data;

consent of the data subject — any documented, voluntary expression of will by an individual regarding the permission to process their personal data in accordance with the specified purpose of processing;

anonymization of personal data — removal of information that allows identifying an individual;

processing of personal data — any action or set of actions performed fully or partially in an information (automated) system and/or in personal data card files related to the collection, registration, accumulation, storage, adaptation, alteration, updating, use, and dissemination (distribution, sale, transfer), anonymization, destruction of information about an individual;

personal data — information or a set of information about an identified or identifiable individual;

personal data manager — an individual or legal entity authorized by the database owner or by law to process these data.

An individual who is assigned technical work with the personal data database without access to the content of personal data is not a personal data manager;

data subject — an individual whose personal data is processed in accordance with the law;

third party — any individual other than the data subject, the owner or manager of the personal data database, and the authorized state body for personal data protection, to whom personal data is transferred by the owner or manager of the personal data database in accordance with the law;

special categories of data — personal data concerning racial or ethnic origin, political, religious, or philosophical beliefs, membership in political parties and trade unions, as well as data concerning health or sexual life.

1.2. This Regulation is mandatory for application by the responsible person and employees of the seller who directly process and/or have access to personal data in connection with the performance of their official duties.

2. List of personal data databases.

2.1. The seller is the owner of the following personal data databases:

• personal data database of contractors.

3. Purpose of processing personal data.

3.1. The purpose of processing personal data in the system is to store and service contractor data, in accordance with Articles 6, 7 of the Law of Ukraine "On Personal Data Protection":

3.2. The purpose of processing personal data is to ensure the implementation of civil legal relations, providing/receiving and carrying out settlements for purchased goods/services in accordance with the Tax Code of Ukraine, the Law of Ukraine "On Accounting and Financial Reporting in Ukraine".

4. Procedure for processing personal data: obtaining consent, notifying about rights and actions with personal data of the data subject.

4.1. The consent of the data subject must be a voluntary expression of will by an individual regarding permission to process their personal data in accordance with the specified purpose of processing. The consent of the data subject may be provided in the following forms:

• document on paper with details allowing to identify this document and the individual;
• electronic document that must contain mandatory details allowing to identify this document and the individual. The voluntary expression of will by an individual regarding permission to process their personal data is advisable to be certified by the electronic signature of the data subject.
• mark on the electronic page of the document or in the electronic file being processed in the information system based on documented software and technical solutions.

4.2. The consent of the data subject is given during the registration of civil legal relations in accordance with current legislation.

4.3. The notification of the data subject about the inclusion of their personal data in the personal data database, the rights defined by the Law of Ukraine "On Personal Data Protection", the purpose of data collection, and the persons to whom their personal data is transferred is carried out during the registration of civil legal relations in accordance with current legislation.

4.4. Processing of personal data concerning racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties and trade unions, as well as data concerning health or sexual life (special categories of data) is prohibited.

5. Location of the personal data database.

5.1. The personal data databases specified in section 2 of this Regulation are located at the seller's address.

6. Conditions for disclosing information about personal data to third parties.

6.1. The procedure for access to personal data by third parties is determined by the conditions of consent of the data subject provided to the owner of the personal data database for processing these data, or in accordance with the requirements of the law.

6.2. Access to personal data by a third party is not granted if that person refuses to assume obligations to ensure compliance with the requirements of the Law of Ukraine "On Personal Data Protection" or is unable to ensure them.

6.3. The subject of relations related to personal data submits a request for access (hereinafter referred to as the request) to the owner of the personal data database.

6.4. The request must include:

• surname, name, and patronymic, place of residence (place of stay) and details of the document certifying the individual submitting the request (for an individual applicant);
• name, location of the legal entity submitting the request, position, surname, name, and patronymic of the person certifying the request; confirmation that the content of the request corresponds to the authority of the legal entity (for a legal entity applicant);
• surname, name, and patronymic, as well as other information allowing to identify the individual in relation to whom the request is made;
• information about the personal data database in relation to which the request is submitted, or information about the owner or manager of this database;
• list of personal data being requested;
• purpose of the request.

6.5. The time for studying the request for satisfaction may not exceed ten working days from the date of its receipt.

During this period, the owner of the personal data database informs the individual submitting the request whether the request will be satisfied or the relevant personal data is not subject to provision, indicating the basis defined in the relevant regulatory act.

The request is satisfied within thirty calendar days from the date of its receipt, unless otherwise provided by law.

6.6. All employees of the personal data database owner are obliged to comply with confidentiality requirements regarding personal data and information regarding accounts in securities and the circulation of securities.

6.7. Postponement of access to personal data by third parties is allowed if the necessary data cannot be provided within thirty calendar days from the date of receipt of the request. In this case, the total time for resolving the issues raised in the request may not exceed forty-five calendar days.

6.8. Notification of postponement is communicated to the third party that submitted the request in writing with clarification of the procedure for appealing such a decision.

6.9. The notification of postponement must include:

• surname, name, and patronymic of the official;
• date of sending the notification;
• reason for the postponement;
• time during which the request will be satisfied.

6.10. Refusal to access personal data is allowed if access to them is prohibited by law.

6.11. The notification of refusal must include:

• surname, name, patronymic of the official who refuses access;
• date of sending the notification;
• reason for refusal.

6.12. Decisions on postponement or refusal of access to personal data may be appealed to the authorized state body for personal data protection, other state authorities, and local self-government bodies responsible for personal data protection, or to the court.

7. Protection of personal data: methods of protection, responsible person, employees who directly process and/or have access to personal data in connection with the performance of their official duties, storage period of personal data.

7.1. The owner of the personal data database is equipped with system and software-technical means and means of communication that prevent losses, theft, unauthorized destruction, distortion, forgery, copying of information and meet the requirements of international and national standards.

7.2. The responsible person organizes work related to the protection of personal data during their processing, in accordance with the law. The responsible person is appointed by the order of the owner of the personal data database.

The responsibilities of the responsible person regarding the organization of work related to the protection of personal data during their processing are specified in the job description.

7.3. The responsible person is obliged to:

• know the legislation of Ukraine in the field of personal data protection;
• develop procedures for access to personal data for employees according to their professional or official or labor duties;
• ensure compliance by employees of the personal data database owner with the requirements of Ukrainian legislation in the field of personal data protection and internal documents regulating the activities of the personal data database owner regarding the processing and protection of personal data in personal data databases;
• develop a procedure for internal control over compliance with the requirements of Ukrainian legislation in the field of personal data protection and internal documents regulating the activities of the personal data database owner regarding the processing and protection of personal data, which, in particular, should contain norms regarding the frequency of such control;
• inform the owner of the personal data database about violations by employees of the requirements of Ukrainian legislation in the field of personal data protection and internal documents regulating the activities of the personal data database owner regarding the processing and protection of personal data in personal data databases within no later than one working day from the moment of detection of such violations;
• ensure the storage of documents confirming the consent of the data subject to the processing of their personal data and the notification of the specified subject about their rights.

7.4. In order to fulfill their duties, the responsible person has the right to:

• obtain necessary documents, including orders and other regulatory documents issued by the owner of the personal data database related to the processing of personal data;
• make copies of received documents, including copies of files, any records stored in local computing networks and autonomous computer systems;
• participate in discussions regarding the fulfillment of their duties in organizing work related to the protection of personal data during its processing;
• submit proposals for improving activities and enhancing methods of work, submit comments and options for eliminating identified deficiencies in the processing of personal data;
• obtain explanations on issues related to the processing of personal data;
• sign and endorse documents within their authority.

7.5. Employees who directly process and/or have access to personal data in connection with the performance of their official (labor) duties are obliged to comply with the requirements of Ukrainian legislation in the field of personal data protection and internal documents regarding the processing and protection of personal data in personal data databases.

7.6. Employees who have access to personal data, including those who process them, are obliged not to disclose in any way personal data that has been entrusted to them or that has become known in connection with the performance of professional or official or labor duties. This obligation remains in effect after they cease activities related to personal data, except in cases established by law.

7.7. Individuals who have access to personal data, including those who process them, in case of violation of the requirements of the Law of Ukraine "On Personal Data Protection" bear responsibility in accordance with the legislation of Ukraine.

7.8. Personal data must not be stored longer than is necessary for the purpose for which such data is stored, but in any case not longer than the storage period of the data defined by the consent of the data subject to process these data.

8. Rights of the data subject.

8.1. The data subject has the right:

• to know about the location of the personal data database containing their personal data, its purpose and name, the location and/or residence (stay) of the owner or manager of this database or to give appropriate instructions regarding the receipt of this information to authorized persons, except in cases established by law;
• to receive information about the conditions for access to personal data, including information about third parties to whom their personal data contained in the relevant personal data database is transferred;
• to access their personal data contained in the relevant personal data database;
• to receive no later than thirty calendar days from the date of receipt of the request, except in cases provided by law, a response about whether their personal data is stored in the relevant personal data database, as well as to receive the content of their personal data that is stored;
• to submit a reasoned demand against the processing of their personal data by state authorities, local self-government bodies in the exercise of their powers provided by law;
• to submit a reasoned demand for the change or destruction of their personal data to any owner and manager of this database if such data is processed unlawfully or is inaccurate;
• to protect their personal data from unlawful processing and accidental loss, destruction, damage in connection with intentional concealment, non-provision, or untimely provision, as well as to protect against the provision of information that is inaccurate or defames the honor, dignity, and business reputation of the individual;
• to contact state authorities, local self-government bodies regarding the protection of their rights concerning personal data;
• to apply legal remedies in case of violation of legislation on personal data protection.

9. Procedure for handling requests from the data subject.

9.1. The data subject has the right to receive any information about themselves from any subject of relations related to personal data without indicating the purpose of the request, except in cases established by law.

9.2. Access to the data subject's data about themselves is provided free of charge.

9.3. The data subject submits a request for access (hereinafter referred to as the request) to the owner of the personal data database.

The request must include:

• surname, name, and patronymic, place of residence (place of stay) and details of the document certifying the data subject;
• other information allowing to identify the data subject;
• information about the personal data database in relation to which the request is submitted, or information about the owner or manager of this database;
• list of personal data being requested.

9.4. The time for studying the request for satisfaction may not exceed ten working days from the date of its receipt.

9.5. During this period, the owner of the personal data database informs the data subject that the request will be satisfied or that the relevant personal data is not subject to provision, indicating the basis defined in the relevant regulatory act.

9.6. The request is satisfied within thirty calendar days from the date of its receipt, unless otherwise provided by law.

10. State registration of personal data databases.

10.1. State registration of personal data databases is carried out in accordance with Article 9 of the Law of Ukraine "On Personal Data Protection".