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ПОЛІТИКА КОНФІДЕНЦІЙНОСТІ

1. ЗАГАЛЬНІ ПОЛОЖЕННЯ

This Privacy Policy describes why and how we collect and use personal data and provides information about individuals' rights in relation to their personal data. It applies to personal data provided to us both by users of this website and by other persons. We may use personal data provided to us for the purposes described in this Privacy Policy or as otherwise stated at the point of collection. 

In this Privacy Policy, the terms ‘VIYAR’, ‘us’ and ‘we’ refer to the VIYAR network, specifically one or more member firms that may process your personal data. Each member firm of the VIYAR network is a separate legal entity. The controllers of your personal data are one or more companies within the Viyar network. For the purposes of this Policy, the Viyar network comprises the legal entities listed at the following link: www ‘List of Companies’. Further information about the Viyar network is available at: www. ‘What is Viyar’.

We may transfer personal data to other Viyar network firms where necessary to achieve the purposes described in this Privacy Policy. For example, during the fulfilment of a customer’s order, we may transfer personal data to Viyar network firms in the regions involved in the supply chain for the respective customer.

This Website contains links to other websites which may be related to the Website but are not governed by this Privacy Policy. We recommend that you review the respective privacy notices on these websites, which will inform you of the relevant controller and provide additional information regarding their processing of your personal data.

Certain personal information covered by this Privacy Policy may be subject to more specific privacy policies of individual Viyar network firms. In the event of any conflict between the policies of Viyar member firms and this Privacy Policy, this Privacy Policy shall prevail in respect of personal data collected with reference to this Privacy Policy. 

Furthermore, Viyar network firms may have their own web resources with their own privacy policies applicable to personal data collected through those resources. These policies can be accessed directly via the aforementioned resources. 

Personal information obtained from or relating to current, former, or potential clients of Viyar network firms may also be governed by the terms of any specific privacy notice provided to the individual at the time of data collection or by any contractual agreements with such individual. In the event that a contract containing terms for the processing of personal data is entered into with an individual, or a specific data processing notice is provided to them, the provisions of such contract or specific notice shall take precedence.

2. ПРАВОВІ ПІДСТАВИ ДЛЯ ОБРОБКИ ВАШИХ ПЕРСОНАЛЬНИХ ДАНИХ

Local legislation may require us to set out in this Privacy Policy the legal bases on which we rely for the processing of your personal data. In such cases, we rely on one or more of the following bases for processing:

Performance of a contract with you

We may use your personal data where it is necessary for the performance of a contract we are about to enter into or have entered into with you.

Legitimate interests

We may use your personal data where it is necessary for the conduct of our business and the pursuit of our legitimate interests—for example, to prevent fraud and to ensure the best and most secure experience for our customers. We ensure that we consider and balance any potential impact on you and your rights (both positive and negative) before processing your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law).

Legal obligation

We may use your personal data where it is necessary for compliance with a legal obligation to which we are subject. We will identify the relevant legal obligation when relying on this legal basis.

Consent

We rely on consent only in cases where we have obtained your active consent to the use of your personal data for a specific purpose, such as when you subscribe to an email newsletter.

3. ТИПИ ПЕРСОНАЛЬНИХ ДАНИХ, ЯКІ МИ ЗБИРАЄМО ПРО ВАС

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store, and transfer various kinds of your personal data, which we have grouped together as follows:

Identity Data: 

includes first name, last name, any previous names, username or similar identifier, job title, date of birth, and gender.

Contact Data:

includes email address and telephone numbers, as well as billing address and delivery address (where you purchase goods or services after contacting us).

Financial Data:

includes bank account and payment card details (where you purchase goods or services after contacting us).

Transaction Data:

includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data:

includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID, and other technology on the devices you use to access this website.

Profile Data:

includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses, and other data collected from your account (if applicable). 

Usage Data:

 includes information about how you interact with and use our website, products, and services. We may also collect other information that you provide to us in emails and telephone calls.

Marketing and Communications Data:

includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data, such as statistical or demographic data, which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature to analyse general trends in user interaction with our website to help improve the website and our services.

4. ЯК ЗБИРАЮТЬСЯ ВАШІ ПЕРСОНАЛЬНІ ДАНІ?

We use different methods to collect data from and about you, including:

Direct Interactions. 

You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • request marketing to be sent to you;
  • give us feedback or contact us.

Automated Technologies or Interactions.  

As you interact with our website, we automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookie Policy for further details.

Third Parties or Publicly Available Sources. 

We receive personal data about you from various third parties as set out below:

  • Analytics providers such as Google.
  • Search information providers.
  • Contact, Financial, and Transactional Data from providers of technical, payment, and delivery services, etc.
  • Identity and Contact Data from publicly available sources, such as public registers, etc.

Your Enquiries.

We collect personal data when an individual contacts us with a question, complaint, or feedback (for example, name, contact details, and the content of the message). In such cases, the individual controls the personal data they provide to us. We use this data only to the extent necessary to respond to the communication or resolve the complaint.

5. ВИКОРИСТАННЯ ВАШИХ ПЕРСОНАЛЬНИХ ДАНИХ. ЦІЛІ ОБРОБКИ

The table below sets out a description of the purposes of processing for which we plan to use various categories of your personal data in accordance with this Policy, as well as the legal bases we rely on to do so. Where appropriate, we have also identified our legitimate interests.

In summary, the purposes for which we process your personal data are:

  • sales/order processing;
  • communication;
  • analytics;
  • compliance with legal obligations;
  • marketing.

More detailed information regarding the purposes, types of data, and legal bases for processing is set out below. 

Table of Purposes for Processing Personal Data: 

Purpose of processingData typeLegal basis
Registration of a new client/user of our services(a) Identity data (b) Contact data(a) Performance of a contract with you
Order processing and delivery, including processing payments and data required for address delivery(a) Identity data
 (b) Contact data
 (c) Financial data
 (d) Transaction data 
 (e) Marketing and Communications data(b) Performance of a contract with you
 (c) Legitimate interest (to protect our interests in the event of disputes)
Quality control and dispute resolution(a) Identity data
 (b) Contact data
 (c) Financial data
 (d) Transaction data 
 (e) Marketing and Communications data(b) Performance of a contract with you 
 (c) Legitimate interest (to protect our interests in the event of disputes)
To manage our relationship with you, which will include: (a) Notifying you of changes to our terms or privacy policy (b) Responding to your inquiries, complaints and requests(a) Identity data
 (b) Contact data
 (c) Profile data 
 (d) Marketing and Communications data(a) Performance of a contract with you
 (b) Legal obligation
 (c) Legitimate interest (to protect our interests in the event of disputes)
Administering and protecting our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and data hosting)(a) Identity data
 (b) Contact data
 (c) Technical data
 (d) Usage data 
(f) Profile data 
 (e) Marketing and Communications data 
 (g) Any other data received from you within the framework of the cooperation that meets the specified purposes(a) Legitimate interest (for business operations, provision of administrative and IT services, network security, fraud prevention and in the context of business reorganisation or group restructuring)
 (b) Legal obligation
Using data analytics to improve our website, products/services, customer relationships and experiences, and to measure the effectiveness of our communications and marketing(a) Technical data
 (b) Usage data(a) Legitimate interest (to identify customer types for our products and services, keep our website up to date, develop our business and shape our marketing strategy)
Marketing activities, including sending you relevant marketing messages and making personalized offers and recommendations for products or services that may interest you based on your profile data(a) Identity data
 (b) Contact data
 (c) Technical data
 (d) Usage data 
 (f) Profile data 
 (e) Marketing and Communications data(a) Legitimate interest (for direct marketing, development of our products/services and business development)
 (b) Consent (marketing activities are carried out after obtaining your prior consent to receive direct marketing communications)
Recruitment and employment when you contact us with a resume or otherwise(a) Identity data
 (b) Contact data
 (с) Job candidate information
 (d) Health data(a) Legitimate interest (to manage our relationship with you and protect our interests)
 (b) Consent (if you send us your resume or contact us in another way and provide the data necessary for employment, you give us your consent to process the data received for the specified purpose)
Organization of marketing events and other activities(a) Identity data
 (b) Contact data
 (с) Information related to the event at which the data was collected 
(d) Health data (if necessary)(a) Legitimate interest (for direct marketing, development of our products/services and business development)
 (b) Consent (marketing activities are carried out after obtaining your prior consent to receive direct marketing communications)
Attracting potential clients and contractors based on the results of exhibitions or other events in which we participated or acted as organizers(a) Identity data
 (b) Contact data
 (с) Information related to the event at which the data was collected
 (d) Health data (if necessary)(a) Legitimate interest (for direct marketing, development of our products/services and business development) 
(b) Consent (marketing activities are carried out after obtaining your prior consent to receive direct marketing communications)
Compliance with the lawAny requested information, the disclosure of which is required by law(a) Legitimate interest
 (b) Legal obligation

When your personal data is collected on our website, you may be invited to specify your preferences regarding the receipt of marketing communications from us via email, SMS, or telephone. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and have not opted out of receiving such communications.

We may also analyse your Identity, Contact, Technical, Usage, and Profile Data to form a view on which products, services, and offers may be of interest to you, in order to subsequently send you relevant marketing communications.

Third-Party Marketing

We will obtain your express opt-in consent before sharing your personal data with any third party outside the Viyar network for their own direct marketing purposes.

Cookies

For further information about the cookies we use and how to manage your cookie settings, please refer to our Cookie Policy.

6. ПЕРЕДАЧА ПЕРСОНАЛЬНИХ ДАНИХ

Cross-Border Transfers

Where we process your personal data, it may be transferred to and stored outside the country in which you are located. PLEASE NOTE that such data transfers may occur to countries outside the European Economic Area (EEA), as well as to countries that do not have legislation providing adequate protection for personal data. 

Processing of Personal Data of EU and UK Citizens

In cases where we transfer your personal data to countries whose legislation does not provide the same level of data protection as the laws of the EU and the UK, we always ensure that your data is afforded a similar degree of protection by implementing the necessary safeguards required by EU and UK law.

Third-Party Service Providers

We may transfer or disclose the personal data we collect to third-party contractors, subcontractors, and/or their subsidiaries and affiliates, including but not limited to entities that assist in providing, operating, and managing IT systems. Examples of third-party contractors we use include providers of identity management, hosting and website management, data analysis, data backup, security, and cloud storage services, etc. 

Third-party providers may engage their own subcontractors who have access to personal data (sub-processors). Our policy is to use only those third-party providers who are professionally obligated to maintain appropriate levels of security and confidentiality.

Disclosure of Your Personal Data

We may share your personal data, where necessary, with the parties set out below:

*Professional advisers, such as law firms, where necessary for the establishment, exercise, or defence of our legal rights, or to obtain advice regarding the conduct of our business. Personal data may be transferred to these advisers as required in connection with the services for which they have been engaged;

*Law enforcement, regulatory, and other government authorities, as well as professional bodies, as required by and/or in accordance with the applicable laws or regulations of the country of incorporation of the Viyar network firm to which your data was provided under this Policy. 

* Where necessary for the conduct of conferences or events organised by a third party;

*Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. БЕЗПЕКА

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. ЗБЕРІГАННЯ ТА ДОСТУП ДО ДАНИХ

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes for which it was collected, including for the performance of contracts and for the purpose of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

Access to the data obtained from you is restricted to member firms of the Viyar network that receive your data in accordance with the processing purposes, as well as service providers who ensure the technical operation of this website and related systems used for data storage and processing. Relevant entities may retain data to the extent necessary to achieve the purpose for which the data was transferred to them.  

In certain circumstances, you may ask us to delete your data. Data erasure is carried out in accordance with applicable legislation.

9. ВАШІ ПРАВА ЩОДО ПЕРСОНАЛЬНИХ ДАНИХ

Under the laws of your country, you may have certain rights in relation to the personal data we hold about you. In particular, you may have the right to:

- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

- Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that specific use of your data (including profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object. You also have the absolute right to object at any time to the processing of your personal data for direct marketing purposes.

- Request transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • If you want us to establish the data's accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

- Withdraw consent: In cases where we process personal data based on consent, individuals have the right to withdraw their consent at any time. 

If you believe that the processing of your personal data violates the law, you have the right to lodge a complaint with the data protection authority responsible for enforcing data protection legislation in the country where you habitually reside or work, or in the place where the alleged infringement occurred.

Our policy is to collect only the minimum necessary personal information. If you believe that excessive information has been collected about you, please contact us to voice your concerns

10. ЯК ВІДМОВИТИСЯ ВІД МАРКЕТИНГОВИХ ПОВІДОМЛЕНЬ

You may contact us at any time to request that we stop sending you marketing communications by email. If you wish to unsubscribe, you should find and follow the instructions we have provided in the relevant communications sent to you.

If you wish to stop receiving only certain types of communications, please specify such communications in your request.

If you opt out of receiving marketing communications, you will still receive service-related communications that are necessary for administrative purposes or customer service, such as order confirmations, product warranty registrations, appointment reminders, updates to our policies, verification of your contact details, etc.

11. ЗМІНИ ДО ЦІЄЇ ПОЛІТИКИ КОНФІДЕНЦІЙНОСТІ

We may make changes or additions to this Privacy Policy from time to time.

To notify you of changes to this Privacy Policy, we will update the date indicated at the top of this page. The new, amended, or supplemented Privacy Policy will take effect from the date of such update. We therefore recommend that you periodically review this Privacy Policy to stay informed about how we are protecting your data.

This Privacy Policy was written in the English language. In the event of any discrepancy between a translated version of this Privacy Policy and the English version, the English version shall prevail."

12. КОНТАКТНА ІНФОРМАЦІЯ

If you have any questions regarding this Privacy Policy or the use of your personal data, or if you wish to exercise your privacy rights, please contact us via one of the following methods:

· Email: [email protected] 

. Postal address: To the registered office of the relevant Viyar network firm with which you have communicated or have a contractual relationship. The postal addresses of the firms are available at: : www ‘List of Companies’.

Your privacy is important to us. If you believe that we are not adhering to the security principles for your data, or if you simply want to learn more about how we protect your data, please email us at [email protected]. Our support team will carefully review your request and contact you shortly.