Personal Data Processing

Notice on Personal Data Processing

In accordance with paragraphs 1 and 2 of Part Two of Article 8 and Part Two of Article 12 of the Law of Ukraine “On Personal Data Protection”, EKO LLC (hereinafter — EKO LLC), legal entity identification code in the Unified State Register of Enterprises and Organizations of Ukraine — 23494714, legal address: 8 Nauky Avenue, Kyiv, 03039, actual location: 15-A Ivan Ohiienko Street, Kyiv, 03049, hereby informs about the data controller, data processor, location, composition and purpose of personal data collection, personal data processed using automated management systems and software systems, third parties to whom such personal data may be transferred, as well as the rights of personal data subjects.

Collection of Personal Data

The collection of surname, name, patronymic (if available), and other personal data of an employee is carried out using software tools or through the direct provision of personal data by the individual upon employment.

The personal data of EKO LLC are processed in the employee personal data database of EKO LLC.

Personal data held by EKO LLC are processed on paper media and within automated systems of EKO LLC.

Personal data processing means any action or set of actions, carried out wholly or partially in automated systems, related to the collection, registration, accumulation, storage, adaptation, modification, renewal, use and dissemination, depersonalization, and destruction of information about employees of EKO LLC.

Personal Data Processor

The processor of personal data is EKO LLC
(legal entity identification code — 23494714).

Purpose of Personal Data Processing

Personal data processing at EKO LLC is carried out for the purpose of ensuring security and implementing labor and social-labor relations, human resources management, military record keeping (in accordance with the Labor Code of Ukraine, the Laws of Ukraine “On Personal Data Protection”, “On Military Duty and Military Service”, “On Labor Protection”, the Civil Code of Ukraine, and the Charter of EKO LLC), as well as accounting and tax relations (in accordance with the Tax Code of Ukraine, the Laws of Ukraine “On Accounting and Financial Reporting in Ukraine”and “On Remuneration of Labor”).

The processing of employees’ personal data is necessary for:

personnel records management;

preparation of statutory statistical and other reporting;

documentation support of the above-mentioned relations.

Composition of Personal Data

Depending on the purpose of processing, applicable legal acts, and business activities of EKO LLC, the following personal data may be processed in personal data databases as required by the Laws of Ukraine:

surname, name, patronymic;

date and place of birth;

passport details;

identification code (taxpayer registration number);

military service records (for persons liable for military service and conscripts), to the extent necessary for military registration;

employment history contained in employment records;

education details, special knowledge or training (where required by job qualifications);

health information (processed in accordance with Article 24 of the Labor Code of Ukraine to the extent necessary for labor relations and occupational safety);

biographical data;

marital status and family members, to the extent necessary for labor relations;

actual place of residence, phone numbers, personal e-mail address;

trade union membership information;

data confirming entitlement to benefits and compensations under the law;

photographs;

other personal data, the processing of which is required by law or related to the activities of EKO LLC.

Transfer of Personal Data to Third Parties

The transfer of employees’ personal data to third parties is determined by the employee’s consent to personal data processing provided upon employment or in accordance with the requirements of the law.

Such transfer is permitted only to the minimum necessary extent and solely for the performance of tasks consistent with the purpose of data collection.

Access to personal data shall not be granted to a third party that refuses or is unable to ensure compliance with the requirements of the Law of Ukraine “On Personal Data Protection”.

Employees’ personal data may be transferred to banking institutions exclusively for the implementation of salary card projects, based on the employee’s consent.

Without employee consent, personal data may be transferred only in cases where:

such transfer is directly provided for by Ukrainian law and is necessary in the interests of national security, economic well-being, or human rights;

a lawful request is received from state or local authorities acting within their statutory powers.

In all other cases, access to an employee’s personal data by third parties is granted only with the employee’s written consent for each individual request, in accordance with Parts 3–5 of Article 16 of the Law.

The transfer of employees’ personal data by telephone or fax is strictly prohibited.

Rights of the Personal Data Subject

An employee has the right to obtain any information about themselves contained in automated personal data databases without stating the purpose of the request.

In accordance with Part Two of Article 8 of the Law of Ukraine “On Personal Data Protection”, a personal data subject has the right to:

know the sources of collection, location of their personal data, the purpose of processing, and the location or residence of the data controller or processor;

receive information on the conditions of access to personal data, including information on third parties to whom such data are transferred;

access their personal data;

receive, within no more than thirty calendar days from the date of the request (unless otherwise provided by law), information on whether their personal data are processed and the content of such data;

submit a reasoned objection to the processing of their personal data;

submit a reasoned request for modification or destruction of their personal data if such data are processed unlawfully or are inaccurate;

protection of personal data from unlawful processing and accidental loss, destruction, or damage, as well as protection against the provision of false or defamatory information;

lodge complaints regarding personal data processing with the Ukrainian Parliament Commissioner for Human Rights or a court;

apply legal remedies in case of violations of personal data protection legislation;

know the mechanism of automated personal data processing;

protection from automated decisions that have legal consequences for them.