Data processing

POSITION

on the processing and protection of personal data in personal data databases owned by the ComfortLife.MARKET online store

1. General concepts and scope

1.1. Definition of terms:

personal data base - a named set of organized personal data in electronic form and/or in the form of personal data files;

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

personal data base owner - a natural or legal person who is granted the right to process this data by law or with the consent of the personal data subject, who approves the purpose of processing personal data in this database, establishes the composition of this data and the procedure for its processing, unless otherwise specified by law;

The State Register of Personal Databases is a single state information system for collecting, accumulating and processing information on registered personal databases;

publicly available sources of personal data – directories, address books, registers, lists, catalogs, other systematized collections of open information containing personal data, posted and published with the consent of the personal data subject.

Social networks and Internet resources in which the subject of personal data leaves their personal data are not considered publicly available sources of personal data (except for cases where the subject of personal data explicitly states that the personal data is posted for the purpose of its free distribution and use);

consent of the subject of personal data - any documented, in particular written, voluntary expression of will of an individual regarding the granting of permission for the processing of his personal data in accordance with the formulated purpose of their processing;

depersonalization of personal data - removal of information that allows for the identification of a person;

personal data processing - any action or set of actions performed in whole or in part in an information (automated) system and/or in personal data filing systems, which are related to the collection, registration, accumulation, storage, adaptation, modification, renewal, use and dissemination (dissemination, sale, transfer), depersonalization, destruction of information about an individual;

personal data - information or a set of information about an identified or specifically identifiable natural person;

personal data base administrator - a natural or legal person who is granted the right to process this data by the owner of the personal data base or by law.

A person who is entrusted by the owner and/or administrator of the personal database to carry out technical work with the personal database without access to the content of the personal data is not a personal database administrator;

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

third party - any person, except for the subject of personal data, the owner or manager of the personal data base and the authorized state body for personal data protection, to whom the owner or manager of the personal data base transfers personal data in accordance with the law;

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

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

2. List of personal data bases owned by the ComfortLife.MARKET online store

2.1. The online store ComfortLife.MARKET is the owner of the following personal data bases:

- Personal data base of employees of the ComfortLife.MARKET online store ;

- Personal database of counterparties of the ComfortLife.MARKET online store ;

3. Purpose of processing personal data

3.1. The purpose of processing personal data in personnel documentation of the ComfortLife.MARKET online store is:

- ensuring labor relations at the enterprise;

- ensuring the implementation of administrative and legal relations and human resources management;

- ensuring the implementation of tax, accounting, statistical and other accounting, reporting, auditing, etc.;

- ensuring relations in the field of culture, leisure, sports and social activities;

- ensuring relations in the transport sector;

- ensuring relations in the field of occupational safety and health;

- other relationships requiring the processing of personal data

In accordance with: the labor legislation of Ukraine (Article 4 of the Labor Code), the Charter, the Tax Code of Ukraine, the Law of Ukraine "On Accounting and Financial Reporting in Ukraine", the Labor Code of Ukraine and other regulatory legal acts of Ukraine, the Law of Ukraine "On Employment of the Population".

3.2 The purpose of processing personal data of counterparties of the ComfortLife.MARKET online store is:

- other relationships requiring the processing of personal data:

In accordance with: the Charter, the Tax Code of Ukraine, the Law of Ukraine "On Accounting and Financial Reporting in Ukraine", the Commercial Code of Ukraine, the Civil Code of Ukraine and other regulatory legal acts of Ukraine

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

4.1. The consent of the personal data subject must be documented, in particular a written, voluntary expression of the will of an individual to grant permission for the processing of his or her personal data in accordance with the stated purpose of their processing.

4.2. The consent of the personal data subject must be provided by signing the text of the consent-notification approved by order of the director of the ComfortLife.MARKET online store .

4.3. The consent-notification is drawn up in two copies, one of which, after being signed by the personal data subject, remains with him, and the other is stored in the ComfortLife.MARKET online store throughout the entire period of processing the personal data of the specified personal data subject.

4.4. The text of the counterparty's consent-notification is included in the text of the contract with this counterparty. The signing of this contract by the counterparty is the fact of the counterparty's consent to the inclusion of his personal data in the personal data base of the ComfortLife.MARKET online store.

4.5. Notification of the personal data subject about the inclusion of his personal data in the personal data base, the rights defined by the Law of Ukraine "On Personal Data Protection", the purpose of data collection and the persons to whom his personal data is transferred is carried out when signing the contract, and of the employee - when registering employment relations in accordance with labor legislation.

5. Location of the personal data base

5.1. The personal data bases specified in section 2 of these Regulations are located at the following address: Smila, Nezalezhnosti st., building 67g.

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

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

6.2. Access to personal data is not granted to a third party if the specified 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 personal data to the owner of the personal data base.

6.4. The request shall specify:

- surname, first 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, first 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, first name and patronymic, as well as other information that allows identifying the individual in respect of whom the request is made;

- information about the personal data base in respect of which the request is submitted, or information about the owner or administrator of this database;

- list of personal data requested;

- the purpose of the request.

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

During this period, the owner of the personal data base shall inform the person submitting the request that the request will be granted or that the relevant personal data shall not be provided, indicating the grounds specified in the relevant regulatory legal act.

6.6. All employees of the ComfortLife.MARKET online store are obliged to comply with the confidentiality requirements regarding personal data.

6.7. Postponement of access to personal data of 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 period for resolving the issues raised in the request cannot exceed forty-five calendar days.

6.8. The notice of postponement shall be communicated to the third party who submitted the request in writing, with an explanation of the procedure for appealing such a decision.

6.9. The notice of postponement shall state:

- surname, first name and patronymic of the official;

- date of sending the message;

- reason for postponement;

- the period within which the request will be satisfied.

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

6.11. The refusal notice shall state:

- surname, first name, patronymic of the official who denies access;

- date of sending the message;

- reason for refusal.

6.12. The decision to postpone or refuse access to personal data may be appealed to the authorized state body for personal data protection, other state authorities and local self-government bodies whose powers include the protection of personal data, 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, period of storage of personal data.

7.1. The ComfortLife.MARKET online store is equipped with system and software and hardware and communication means that prevent loss, theft, unauthorized destruction, distortion, forgery, and copying of information and meet the requirements of international and national standards.

7.2. The standards of technical information protection comply with the legislation and acts of Ukraine, in particular the regulatory legal acts of the Commission, agreed with the state body designated by the legislation of Ukraine, responsible for establishing standards of technical information protection in Ukraine.

7.3. The responsible person organizes work related to the protection of personal data during their processing, in accordance with the law.

The responsible person is determined by order of the director of the ComfortLife.MARKET online store .

7.4 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.

7.5. 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 the legislation of Ukraine in the field of personal data protection and internal documents regulating the activities of the company 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 to prevent the disclosure in any way of personal data that has been entrusted to them or that has become known in connection with the performance of professional, official or labor duties. Such an obligation is valid after their termination of activities related to personal data, except for cases established by law.

7.7. Persons who have access to personal data, including those who process them, are liable in accordance with the legislation of Ukraine if they violate the requirements of the Law of Ukraine "On Personal Data Protection".

7.8. Personal data shall not be stored for longer than is necessary for the purpose for which such data are stored, but in any case not longer than the data storage period determined by the consent of the personal data subject to the processing of such data and/or by the legislation on the depository system and on labor.

7.9. The storage period of personal data contained in the personnel documentation of the ComfortLife.MARKET online store is determined in accordance with the regulatory legal acts of Ukraine.

8. Rights of the personal data subject

8.1. The subject of personal data has the right to:

- to know about the location of the personal data base containing his personal data, its purpose and name, the location and/or place of residence (stay) of the owner or manager of this base or to give the appropriate instruction to obtain this information to persons authorized by him, except in cases established by law;

- receive information about the conditions for providing access to personal data, in particular information about third parties to whom his personal data contained in the relevant personal data database are transferred;

- to access their personal data contained in the relevant personal data database;

- receive no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, a response on whether his personal data is stored in the relevant personal data database, as well as receive the content of his personal data that is stored;

- submit a reasoned request with an objection to the processing of their personal data by state authorities and local self-government bodies in the exercise of their powers provided for by law;

- submit a reasoned request to change or destroy their personal data to any owner and administrator of this database, if these data are processed illegally or are unreliable;

- to protect their personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision, as well as to protect against the provision of information that is unreliable or defamatory of the honor, dignity and business reputation of an individual;

- to address issues of protecting their rights regarding personal data to state authorities and local self-government bodies whose powers include the protection of personal data;

- apply legal remedies in case of violation of personal data protection legislation.

9. Procedure for handling requests from a personal data subject

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

9.2. The personal data subject's access to data about himself/herself is free of charge.

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

The request states:

- surname, first name and patronymic, place of residence (place of stay) and details of the document certifying the identity of the subject of personal data;

- other information that allows identifying the person of the personal data subject;

- information about the personal data base in respect of which the request is submitted, or information about the owner or administrator of this database;

- a list of personal data requested.

9.4. The period for examining a request for its satisfaction may not exceed ten working days from the date of its receipt.

During this period, the owner of the personal data base shall inform the personal data subject that the request will be satisfied or the relevant personal data shall not be provided, indicating the grounds specified in the relevant regulatory legal act.

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

10. State registration of the personal data base

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