This Privacy Policy constitutes integral part of the your Contract, entered into with us. In addition, this Privacy Policy applies to Customer’s personal data if the Purchase of the Goods / Services in his interests is carried out by another person authorized by the Customer in an appropriate manner. We have worked out this Privacy Policy for you to get to know about:
- what personal data are;
- which of your personal data we collect;
- how and why we use them;
- to whom we deliver your personal data;
- how we protect privacy of your personal data;
- how to contact us ad whom to contact if you have questions about processing of your personal data.
The terms “Wise IT,” “we,” “us,” “our,” “ours” in this Privacy Policy refer to TOВ «ВАЙЗ АЙ ТІ» (a company registered in Ukraine on October 6, 2014, registration number in the Unified State Register of Legal Entities 1 069 102 0000 032632, EDRPOU code 39427231, legal address: Ukraine, Kyiv, 01133, Yevhena Konovaltsia Street, 44, Building B). Statement on personal data protection We seriously regard the issue of protecting personal data of our customers and other persons who filed a request or claim with WISE IT, therefore we strive to protect privacy of your personal data. WISE IT undertakes to take all necessary measures to prevent improper use of your personal data which become known to us. We will process your personal data in strict compliance with the requirements set forth by the applicable legislation, and only if we have legal grounds for doing so. We control the ways of collecting your personal data, and determine goals for which WISE IT uses personal data. We are a “data controller” or “data processor” within the meaning of the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as “GDPR”) and other applicable EU legislative acts pertaining to data protection, and an “owner of personal data” within the meaning of the Law of Ukraine on Personal Data Protection dated 01.06.2010 No. 2297-VI.
We process your personal data only if at least one of the following, but nor limited to, terms stipulated by Article 6 of GDPR applies:
• you have given consent to the processing of your personal data;
• processing is necessary for entering into or the performance of an agreement with you or in order to render additional services to you;
• processing is necessary for compliance with the legislation of the states to/from where we operate the supply of goods/services, etc.
We may from time to time revise this Privacy Policy, inter alia, if required to do so due to applicable laws. Therefore. We request you to visit WISE IT web-site to make sure you know the up- to-date information.
Main notions (definitions)
Personal data means any personal information allowing a third party to identify a natural person (data subject).
Identifiable natural person means one who can be identified, directly or indirectly, in particular, by reference to an identifier (such as, a name, surname, document number, or any other identifier).
Personal data subject means a natural person to whom personal data are related, and who can be identified by means of such personal data, or who has been identified.
Personal data controller means a natural or legal person which determines the purposes and means of the processing of personal data, and bears the primary responsibility for their processing. Personal data controller is an “owner of personal data” under the terms of the Ukrainian legislation.
Personal data processor means a natural or legal person which based on the controller’s instructions (directives, orders) processes personal data for the controller. Personal data processor is an “administrator of personal data” under the terms of the Ukrainian legislation.
Processing of personal data means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure.
Laws regulating personal data processing
Your personal data are processed in compliance with the requirements set forth by the Law of Ukraine on Personal Data Protection as of 1 June 2010. Personal data of the clients being on the EU territory or being EU citizens is regulated, in particular, by the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as “GDPR”).
Goals of personal data processing
WISE IT provides services/supply goods in the majority of states worldwide. We need to have your personal data in order for us and our partners to fulfill our obligation according to contract, in particular:
• provide you with the whole range of our services;
• have a possibility to familiarize you with all our special offers and other services, including co-operative promotional actions of WISE IT and our partners;
• provide consultations and information support by conclusion and performance of the contract;
In order to send you commercial (marketing) information, we get your specific consent, which can be canceled at any time. We can also send you Push Notifications, messages via Skype, Viber, WhatsApp and other messages using various ОТТ Apps, SMS texts, messages through other communication means to inform you about events undertaken by us or our partners, or to get your feedback concerning the quality of services when we fulfill the terms of the contract. We ask you to inform us only about such personal data that are required to render the service, supply of goods, newsletters, or a reply to you special request/claim. At the same time, if you decide to inform us about any additional personal data, we will be able to process them with due level of protection. If you wish to know more about the companies to which we may disclose your personal data, please see their list on WISE IT web-site.
Personal data which we process
Please see the table below to find out which of your personal data we process to fulfill the terms of contract with you:
Supply of Goods / Services by WISE IT
Processed Personal Data
b) name
с) surname
d) e-mail
е) telephone number(-s)
f) sex
g) payment address, payment details
h) city, state, postal code
i) company name, registration number of enterprise (when paying on behalf of a legal entity)
j) position in company (when paying on behalf of a legal entity)
k) domain name
Sending of commercial (marketing) messages*
Processed Personal Data
a) e-mail
b) name
с) surname
d) company name, registration number of enterprise (when paying on behalf of a legal entity)
е) position in company (when paying on behalf of a legal entity)
f) telephone number
Complaints
Processed Personal Data
a) name
b) surname
c) contract number
d) banking details
e) telephone number
f) e-mail
g) postal code and address
h) city, state
i) payment receipts for services/goods
j) company name, registration number of enterprise (when paying on behalf of a legal entity)
k) position in company (when paying on behalf of a legal entity)
l) other personal data which you provide to us
Various questions to general mail
Processed Personal Data
a) name
b) surname
с) e-mail
d) telephone number
e) other personal data which you provide to us
Your posts, messages, remarks, questions in social networks addressed to WISE IT, and online comments to WISE IT publications or about WISE IT in social networks
Processed Personal Data
a) link to your social network profile
b) user name
c) language of application
d) communications
e) other personal data which you provide to us
Visiting WISE IT web-site
Processed Personal Data
a) IP address
b) cookies and similar technologies are used on WISE IT web-site.
Please find more information below in this Privacy Policy
* From time to time we may contact you to inform you of special offers of goods and services, advantages of our services, co-operative promotional actions of WISE IT and partners, our news via e-mail. You can accept or refuse to receive such information, indication the option you choose when concluding the contract. Later, you will be able to refuse marketing newsletters in each e-mail you receive from us.
In addition to the aforesaid, we can process any other personal data if you decide to provide them to WISE IT. If storage of your personal data is not necessary for the provision of services to you, or is not required under applicable legislation, we will delete it.
Special categories of data
When rendering services to you, we do not collect and process personal data using which it is possible to determine your physical or mental health. Such information is deemed “sensitive personal data” in accordance with GDPR.
Place of personal data storage
To ensure safety personal dats, we use cloud services of Google (Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043 USA). Data stored by Google are kept at data processing centers by following link www.google.com/about/datacenters/inside/locations
Disclosure of your personal data to third parties
In order to enable you to use our services, we must disclose your personal information to third parties, which include the following:
Public authorities
In cases stipulated by law, we are required to disclose your personal information to government agencies. These agencies may include law enforcement agencies, tax bodies, other state bodies.
Partner companies
While fulfillment our obligations according the contract we must share some of your personal information with our partner companies. We will share your personal information with these companies only in cases where they are involved in fulfillment of your contract. In addition, if any of the partner companies is involved in fulfillment of your contract, it will have a possibility to disclose your personal data to their partners.
If you want to know more about the companies we may share your personal data with, please see their list on WISE IT website.
If you want to know more about the rules of processing of your personal data by our counteragents, you can also read their privacy policies.
Technical, organizational and other measures of data protection
For safe storage of your personal data we have implemented various technical and organizational measures to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage.
WISE IT observe the principle of personal data minimization. We process only the information we need, or the information you provide by your consent beyond the required processing range. In addition, we have configured all the interfaces of our website and services application to comply with highest confidentiality requirements, which settings you can adjust at your own convenience. We always use the safest and most proven routes of data transmission, when transferring personal data to public authorities.
Personal data processing (storage) time
We will not store your data longer than it is necessary to fulfill the purpose for which they are processed, or to comply with the statutory requirements. To determine the appropriate storage period, we identify the nature and category of personal data, the purposes for which we process them, and if we can achieve purpose through other means.
By the general rule, the time limit for personal data processing in WISE IT is 1095 days from the date of submission of tax reports for the period in which the corresponding transaction was performed (e.g. supply of goods/services). The specified processing time is consistent with the provisions of the Tax Code of Ukraine on the document retention period, where such documents are connected with taxes and fees charge and payment. As legislation of the countries, to/from which WISE IT perform supply of goods/ services, may establish additional requirements, periods for personal data storage may differ from those specified in this paragraph. In particular, if legislation of any country, to/from which WISE IT perform supply of goods/services, contains provisions on the statute on limitations on claims, during which you have the right to submit a claim or file a suit against WISE IT, and we need evidence for the existence of the legal relationship between us, we may process your personal data during this period. Over time, we can minimize your personal data that we use, or can even make your data anonymous, for them not to be any more associated with you personally. In this case, we can use this information without further notice to you.
Cookies and other tracking technologies
Cookies are small text files that save websites on your computer or mobile devices at the moment when you start to use them. Thus, the website for some time will remember your preferences and the actions you performed, including, for the purposes you don’t have to re-enter the data. Our cookies do not identify any individual user by themselves, but identify only a computer or a mobile device you use.
Cookies and other tracking technologies on our website and in applications can be used in various ways, for example, for the purpose of operating the website, to analyze traffic or for advertising purposes. We use cookies and other tracking technologies, in particular, to improve the quality and efficiency of our services. You can find the list of cookies, other tracking technologies, which WISE IT use, as well as their exact purpose on our website here.
For more information about what cookies are, how they work and how to manage or how to delete them, visit www. allaboutcookies.org
Please be informed that you can disable cookies and other tracking technologies in the settings of some Internet browsers. In this case, you must understand that if you disable some cookies, functionality of WISE IT website may be restricted, including possible incorrect operation of some services, and you will not be able to take advantage of all their benefits.
Rights of personal data subjects
The rights of personal data subjects in accordance with the legislation of Ukraine
We are pleased to inform you about your rights regarding the processing of personal data in accordance with the legislation of Ukraine:
• you have the right to know about the sources of collection, storage of your personal data, purpose of their processing, the location or place of residence (stay) of the controller or processor of personal data, or give appropriate instructions on obtaining this information to their authorized persons, except to the extent permitted by applicable law;
• to obtain information on the terms for granting access to personal data, including information about third parties who your personal data are disclosed to;
• to access to your personal data;
• to obtain the answer on whether your personal data are being processed, no later than thirty calendar days from the date of receipt of the request, except to the extent permitted by applicable law, as well as to obtain the contents of such personal data;
• to submit a reasoned request to the personal data controller with objection against your personal data processing;
• to submit a reasoned request for the modification or destruction of your personal data by any controller and processor of personal data, if such data are processed illegally or are inaccurate;
• to protect your personal data against unlawful processing and accidental loss, destruction, damage in connection with concealment, failure to provide or untimely provision of them, as well as to protection from provision of the information that is unreliable or discrediting the honor, dignity and business reputation of an individual;
• to file complaints as to processing of your personal data to the Ukrainian Parliament Commissioner for Human Rights or to the court;
• to apply legal remedies in case of violation of data protection laws;
• to make a reservation on the limitation of the right to process your personal data when granting consent;
• to withdraw your consent to personal data processing;
• to know the mechanism of automatic processing of personal data;
• for protection against an automated solution that has legal consequences for you.
Other rights of personal data subjects in accordance with GDPR
In addition to the Ukrainian data protection laws, WISE IT are considerate towards ensuring your rights established by GDPR.
Right to information
We are ready to give data subjects the information on their personal data which we process.
If you want to know which of your personal data we process, you can request this information at any time. You can find the list of data we must provide you in Articles 13 and 14 of the GDPR. Thus, when applying you must state your specific requirements, so we could legitimately consider your request and provide a response.
Please note that if we are unable to verify your identity by e-mail messages or at your application to the call center, or in the case of reasonable doubts concerning your identity, we may ask you to provide a proof of identity. This is the only way we can avoid disclosing your personal data to a person who can perpetrate your identity.
We will process your request in the shortest possible time, but at the same time please remember that it is a complex process to provide you a full and legitimate answer in relation to your personal data, that can take up to a month.
Right to correct your personal data
If you find that some personal data which we process about you are incorrect or outdated, please inform us about it. In this case, we may ask you to provide a proof of identity. In some cases we will not be able to change your personal information. In particular, such case can include the event when your personal information has already been used during the execution of the contract of carriage and/or they are contained in a tax document that was issued in accordance with tax legislation.
Withdrawal of consent to personal data processing and right to be forgotten
If WISE IT processes your personal data subject to a consent to personal data processing (in particular, for the purpose of sending commercial newsletters), further processing can be terminated at any time. All you must do is to withdraw your consent to such processing. You may also exercise your right to be forgotten. In cases stipulated in Article 17 of GDPR, WISE IT will delete your personal data it processes, except for those personal data which we are obliged to store in accordance with the requirements set forth by the applicable legislation.
Furthermore, in this case, for the purposes of safety, WISE IT may request you to present your ID document.
Persons you can address to protect your personal data
If you have any questions, remarks, complaints or comments relating to the protection and processing of your personal data, feel free to apply to:
Mr. Dmytro Udovyk
LIMITED LIABILITY COMPANY “WISE IT”
Ukraine, Kyiv, 01133, Yevhena Konovaltsia St, 44Б.
info@wiseit.com.ua
You can also send your questions, remarks, or complaints relating to your personal data via WISE IT web-site.
Personal Data Protection Authority in Ukraine
The administrative authority in charge of the personal data protection in Ukraine is the Department for Personal Data Protection of the Secretariat of the Ukrainian Parliament Commissioner for Human Rights. You may submit your complaints or comments thereto if you believe that your rights are violated due to the processing of your personal data.