GENERAL CONCEPTS AND FIELD OF APPLICATION

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 certain person who organizes work related to the protection of personal data during their processing in accordance with the law;

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

— State register of personal data bases — a single state information system for collecting, accumulating and processing information about registered personal data bases;

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

Social networks and Internet resources in which the subject of personal data leaves his personal data are not considered publicly available sources of personal data (unless the subject of personal data expressly states that the personal data are posted for the purpose of their free distribution and use).

— consent of the subject of personal data — any documented, voluntary expression of will of a natural person to grant permission for the processing of his personal data in accordance with the formulated purpose of their processing;

— depersonalization of personal data — removal of information allowing identification of a person;

— processing of personal data — any action or set of actions, performed in whole or in part in the information (automated) system and/or in personal data files, related to the collection, registration, accumulation, storage, adaptation, change, update, use and distribution (realization), transfer), depersonalization, destruction of information about a natural person;

— personal data — information or a set of information about a natural person who is identified or can be specifically identified;

— administrator of the personal data base — 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 instructed by the owner and/or manager of the personal data base to carry out technical work with the personal data base without access to the content of personal data is not a manager of the personal data base.

— subject of personal data — a natural person whose personal data is processed in accordance with the law;

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

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

1.2. This Regulation is mandatory for 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.

LIST OF PERSONAL DATA BASES

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

basis of personal data of counterparties (clients, buyers).

PURPOSE OF PERSONAL DATA PROCESSING

3.1. The purpose of processing personal data in the system is the storage and maintenance of counterparty data in accordance with Articles 6 and 7 of the Law of Ukraine "On the Protection of Personal Data".

3.2. The purpose of processing personal data is to ensure the implementation of civil legal relations, provision/receipt and settlement of purchased goods/services in accordance with the Tax Code of Ukraine, the Law of Ukraine "On Accounting and Financial Reporting in Ukraine".

PERSONAL DATA PROCESSING PROCEDURE

4.1. The consent of the subject of personal data must be a voluntary expression of the individual's will to grant permission for the processing of his personal data in accordance with the formulated purpose of their processing. The consent of the subject of personal data can be given in the following forms:

— a document on a paper medium with details that allows identification of this document and a natural person;

— an electronic document, which must contain mandatory details that allow identification of this document and a natural person. It is expedient to certify a natural person's voluntary declaration of consent to the processing of his personal data with an electronic signature of the subject of personal data;

— a mark on an electronic page of a document or in an electronic file that is processed in the information system based on documented software and technical solutions.

4.2. The consent of the subject of personal data is given when registering civil legal relations in accordance with current legislation.

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

4.4. The processing of personal data on racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, as well as data related to health or sexual life (special categories of data) is prohibited.

LOCATION OF THE PERSONAL DATA BASE

5.1. The personal data base specified in section 2 of this Regulation is located at the address of the seller.

TERMS OF DISCLOSURE OF INFORMATION ABOUT PERSONAL DATA OF THIRD PARTIES

6.1. The procedure for access to personal data by third parties is determined by the terms of the consent of the subject of personal data given to the owner of the personal data base 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 undertake obligations to ensure the fulfillment of the requirements of the Law of Ukraine "On the Protection of Personal Data" or is unable to ensure them.

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

6.4. The request specifies:

— surname, first name and patronymic, place of residence (location) and details of the document certifying the natural person submitting the request (for the natural person – the 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 the legal entity – the applicant);

— surname, first name and patronymic, as well as other information that allows identification of the natural person in respect of whom the request is made;

— information about the personal data base for which the request is submitted, information about the owner or administrator of this database;

— list of requested personal data;

- The purpose of the request.

6.5. The term for examining a request for its satisfaction cannot exceed ten working days from the date of receipt.

During this period, the owner of the personal data base informs the person who submits the request that the request will be satisfied or that the relevant personal data are not subject to provision, indicating the grounds specified in the relevant regulatory legal act.

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

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

6.7. Delaying 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 term for solving the issues raised in the request cannot exceed forty-five calendar days.

6.8. The notice of postponement is brought to the attention of 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 states:

— surname, first name and patronymic of the official;

— The date of sending the message;

— The reason for the postponement;

— the term during which the request will be satisfied.

6.10. Denial of access to personal data is permitted if access to it is prohibited by law.

6.11. The notice of refusal shall indicate:

— surname, first name, patronymic of the official denying access;

— The date of sending the message;

— the reason for refusal.

6.12. The decision to postpone or deny access to personal data can be appealed to the authorized state body for the protection of personal data, other state authorities and local self-government bodies, whose powers include the implementation of personal data protection, or in court.

PROTECTION OF PERSONAL DATA

7.1. The owner of the personal database has system, software and communication tools that prevent loss, theft, unauthorized destruction, distortion, forgery, copying of information and meet the requirements of international and national standards.

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

The duties 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:

— to know the legislation of Ukraine in the field of personal data protection;

— to develop procedures for access to personal data of employees in accordance with their professional or official or labor duties;

— to ensure that the employees of the owner of the personal data base fulfill the requirements of the legislation of Ukraine in the field of personal data protection and internal documents regulating the activity of the owner of the personal data base regarding the processing and protection of personal data in personal data bases;

— to develop a procedure (procedure) for internal control over compliance with the requirements of the legislation of Ukraine in the field of personal data protection and internal documents regulating the activity of the owner of the personal data base on the processing and protection of personal data in personal data bases, which, in particular, should contain norms on the periodicity of implementation such control;

— to notify the owner of the personal data base about the facts of violations by the employees of the requirements of the legislation of Ukraine in the field of personal data protection and internal documents regulating the activities of the owner of the personal data base on the processing and protection of personal data in personal data bases no later than one working day from the moment of detection of such violations;

— to ensure the storage of documents confirming the provision by the subject of personal data of consent to the processing of his personal data and notification of the said subject about his rights.

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

— receive the necessary documents, in particular orders and other administrative documents issued by the Owner of the personal data base, related to the processing of personal data;

— make copies of received documents, in particular copies of files, any records that are in local computer networks and autonomous computer systems;

— to participate in the discussion of the duties performed by him in the organization of work related to the protection of personal data during their processing;

— submit for consideration proposals for improving activities and improving work methods, submit comments and options for eliminating identified deficiencies in the process of personal data processing;

— to receive explanations on the processing of personal data;

— to sign and certify documents within the limits of their competence.

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, regarding the processing and protection of personal data in personal databases.

7.6. Employees who have access to personal data, including those who carry out their processing, are obliged not to allow the disclosure in any way of personal data that was entrusted to them or became known in connection with the performance of professional, official or labor duties responsibilities Such an obligation comes into effect after they cease activities related to personal data, except for cases established by law.

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

7.8. Personal data must not be stored longer than necessary for the purpose for which such data is stored, but in no case longer than the data storage period determined by the consent of the subject of personal data to the processing of this data.

RIGHTS OF THE SUBJECT OF PERSONAL DATA

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

— to know the location of the personal data base containing his personal data, its purpose and name, location and/or place of residence (residence) of the owner or manager of this database, or to give the relevant instructions to obtain this information to persons authorized by them, except in cases established by law ;

— to receive information about the conditions for providing access to personal data, including information about third parties to whom his personal data contained in the relevant personal data base are transferred;

— to access your personal data contained in the relevant personal data base;

— to receive, no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, an answer on whether his personal data is stored in the relevant personal data base, as well as to receive the content of his stored personal data;

— submit a motivated demand with an objection to the processing of your personal data by state authorities, local self-government bodies in the exercise of powers provided for by law;

— submit a motivated demand with an objection to the processing of your personal data by state authorities, local self-government bodies in the exercise of powers provided for by law;

— to protect your personal data from illegal processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of them, as well as protection from providing information that is unreliable or dishonors the honor, dignity and business reputation of a physical person individuals;

— to apply for the protection of personal data rights to state authorities, local self-government bodies, whose powers include the protection of personal data;

— apply legal remedies in case of violation of the legislation on personal data protection.

PROCEDURE FOR WORKING WITH PERSONAL DATA SUBJECT REQUESTS

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

9.2. The access of the subject of personal data to personal data is free of charge.

9.3. The subject of personal data submits a request for access (hereinafter - request) to personal data to the owner of the personal data base.

The request specifies:

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

— other information allowing identification of the subject of personal data;

— information about the personal data base for which the request is submitted, information about the owner or administrator of this database;

— a list of requested personal data.

9.4. The term for examining a request for its satisfaction cannot exceed ten working days from the date of receipt.

9.5. During this period, the owner of the personal data base notifies the subject of personal data that the request will be satisfied or that the relevant personal data are not subject to provision, indicating the grounds specified in the relevant regulatory legal act.

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

STATE REGISTRATION OF 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 Protection of Personal Data".