PROVISIONS
ON THE PROCEDURE FOR PROCESSING PERSONAL DATA
LIMITED LIABILITY COMPANY “SOFT GYM”
National State Registry of Ukrainian Enterprises and Organizations number: 45437242. 
CONTENTS:
1. General Provisions
1.1. General requirements and scope.
1.2. Definition of terms
1.3. Categories of personal data subjects and personal data bases in which they are processed, owned by the Company
1.4. Purpose of personal data processing
1.5. Composition of personal data processed by the Company
1.6. Notification of the rights of personal data subjects
1.7. Warning about visual recording
1.8. Warning for personal data subjects who independently transmit their personal data to the Company via remote communication channels
1.9. Clause on cross-border transfer
2. The procedure for processing personal data owned and managed by the Company.
2.1. Grounds for processing personal data
2.2. Method of collecting and accumulating personal data.
2.3 Processing of personal data in the personal database "Counterparties".
2.3.1. Reservations for transactions with legal entities .
2.3.2. Reservations for transactions with individual entrepreneurs
2.3.3. Reservations for transactions with individuals
2.3.4. Clause on actions in favor of the counterparty.
2.4. Processing of personal data in the personal data base "Clients"
2.4.1 Reservations for transactions with legal entities
2.4.2. Reservations for transactions with individual entrepreneurs
2.4.3. Clauses for transactions with individuals
2.4.4. Clause on actions in favor of the client - the subject of personal data.
2.5. Processing of personal data in the personal data base "Participants".
2.5.1. Caution for participants - legal entities.
2.5.2. Warning for participants who are individual entrepreneurs.
2.5.3. Warning for participants who are individuals
2.5.4. Clause on actions in favor of the participant - the subject of personal data
2.6 Processing of personal data in the personal data base "":
2.6.1. Warnings for employees of individuals
2.7. Special requirements for the processing of personal data
2.8. Notification of personal data processing
2.8.1 Notification of changes in the information subject to notification.
3. Term, conditions of storage and destruction of personal data by the Company.
4. The procedure for access to personal data.
4.1 Access of the Company's employees
4.2. Access of personal data subjects
4.3. Access of third parties
5. Protection of personal data
6. Liability for violation of the procedure for processing personal data
7. Validity of the message

1. General Provisions
1.1. General requirements and scope.
This Regulation on the procedure for processing personal data (hereinafter referred to as the "Regulation") is a public announcement from LIMITED LIABILITY COMPANY “SOFT GYM” (hereinafter referred to as the "Company") to an indefinite number of personal data subjects who in one way or another enter into relations with the Company, about the purpose, grounds, basic principles, rules and warnings when processing their personal data by the Company.
This Regulation has been developed in accordance with the Law of Ukraine "On Personal Data Protection" (hereinafter - the "Law"), the Law of Ukraine "On Information", the Law of Ukraine "On Ratification of the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data and the Additional Protocol to the Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data for Supervisory Authorities and Transborder Flows of Data", the Model Procedure for Personal Data Processing approved by the Order of the Ukrainian Parliament Commissioner for Human Rights No. 1/02-14 dated 08.01.2014,
By announcing this Regulation, the Company aims to regulate relations with personal data subjects in compliance with the requirements of the legislation in the field of information in general and the Law in particular.
The Company will refer to this Regulation in transactions concluded by its representatives, in its public statements and announcements, when providing services, and expects that the Company's clients, representatives of the Company's clients and counterparties, users of the Company's Internet resources where this Regulation is posted, and other interested parties will also familiarize themselves with it.
The Company also reserves the right to interpret the absence of officially expressed objections to the subject matter and content of the Regulation by personal data subjects as confirmation that they have read it, understand it and accept the procedure for processing their personal data by the Company as set forth therein.
Along with the settlement of relations with personal data subjects with the application of this Regulation, transactions concluded by the Company with its clients and counterparties may provide for other regulatory mechanisms without reference to this Regulation.
The Regulation defines the main concepts related to personal data, contains the purpose of personal data processing, the rights of personal data subjects, the procedure for personal data protection, and other requirements of Ukrainian legislation on personal data protection.
1.2. Definition of terms
In these Regulations, the following terms are used in the following meanings:
Personal data base means a named set of organized personal data in electronic form and/or in the form of personal data files. The personal data bases in which the Company processes personal data are called "Participants", "Counterparties", "Clients" and "Employees"
The company that owns the personal data is SOFT GEM Limited Liability Company, which is authorized by law or with the consent of the personal data subject to process this data, which approves the purpose of personal data processing, establishes the composition of this data and the procedure for its processing. Company details: LIMITED LIABILITY COMPANY “SOFT GYM” (45437242), Samiila Kishky 6 street, Kyiv, 03191, Ukraine.
Consent is a voluntary expression of will of an individual (subject to his/her awareness) to grant permission to process his/her personal data in accordance with the formulated purpose of their processing, expressed in writing or in a form that allows to conclude that consent has been granted. In the field of e-commerce, the consent of the personal data subject may be provided during the registration of in the information and telecommunication system of the e-commerce entity by marking the consent to the processing of their personal data in accordance with the stated purpose of their processing, provided that such system does not create opportunities for the processing of personal data before the marking.
Client means a personal data subject who acts in relations with the Company as a representative of a legal entity, individual entrepreneur, individual engaged in independent professional activity, or individual without the status of a business entity, or independently in order to receive paid services provided by the Company, and whose personal data is processed by the Company in the personal data base "Clients" for the purpose determined by this Regulation Counterparty means a personal data subject acting in relations with the Company as a representative of a legal entity, individual entrepreneur, individual engaged in independent professional activity, or individual without the status of a business entity, or independently in order to provide the Company with paid services or supply goods, and whose personal data is processed by the Company in the personal data base "Counterparties" for the purpose determined by this Regulation Processing of personal data means any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, updating, use and dissemination (distribution, sale, transfer), depersonalization, destruction of personal data, including with the use of information (automated) systems
Personal data means information or a set of information about an individual who is identified or can be specifically identified.
Transaction means any civil law/commercial law agreement to which the Company is a party, regardless of its form and subject matter, including agreements on alienation, transfer for use, leasing, provision of services (performance of works), power of attorney, security agreements (pledge, mortgage, surety), insurance agreements, agreements on imposition of encumbrances/restrictions on property, addenda to them, agreements on amendments to them, documents confirming actions aimed at concluding, executing, changing and terminating any of these Personal data controller means an individual or legal entity authorized by the Company or by law to process this data on behalf of the Company Personal data processing period means the period during which the Company processes personal data of the personal data subject, which is calculated from the moment the Company receives personal data and consent to the processing of personal data and does not exceed the period necessary to achieve the purpose of processing and the period determined by the legislation of Ukraine in the field of archival affairs and record keeping
Personal data subject is an individual whose personal data is processed;
Third party means any person, except for the personal data subject, the Company or the personal data controller and the Ukrainian Parliament Commissioner for Human Rights, to whom the Company or the personal data controller transfers personal data.
Member (founder) of the Company shall mean a personal data subject, representative of a legal entity, individual entrepreneur, individual engaged in independent professional activity, or individual without the status of a business entity, or independently, acting in relations with the Company as a person who participated in the establishment of the Company, endowed with rights and obligations in accordance with the current legislation of Ukraine, and whose personal data is processed by the Company in the personal data base "Members" for the purpose determined by this Regulation
The authorized representative of the state authorities on personal data protection is the Ukrainian Parliament Commissioner for Human Rights (hereinafter referred to as the "Commissioner"). Address: 21/8 Instytutska St., Kyiv, 01008.
1.3. Categories of personal data subjects and personal data bases in which they are processed, owned by the Company.
The Company processes personal data of subjects in the personal data base "Counterparties", "Clients", "Participants" and "Employees", personal data of subjects who independently apply to the Company and provide it with their personal data. The Company processes such personal data:
- in the database "Counterparties" for the purpose determined by this Regulation, in cases of communications with entities that are employees, represent or act in the interests of persons who are the Company's counterparties, and to the extent that such entities provide information about themselves (business communication, communications related to the conclusion and execution of transactions, representatives of authorized state bodies, media representatives);
- in the database "Clients" for the purpose determined by this Regulation, in cases of communication with entities that have expressed an intention to use the services provided by the Company, wish to receive sports and recreation services from the Company or act as official representatives of entities or persons who are clients of the Company (including employees, agents, founders), and to the extent that such entities provide information about themselves (representatives by power of attorney, representatives by law, authorized persons, persons contacting the Company via distance channels)
- in the Participants database for the purpose determined by this Regulation, in cases of communications with entities that are employees, represent or act in the interests of persons who are members (founders) of the Company, and to the extent that such entities provide information about themselves (business communication, communications related to the exercise of functions and powers of the Participants, etc.)
- in the "Employees" database for the purpose of establishing and maintaining legal relations in the field of labor, employment, internships, employment in cases of communication with entities that contact the Company via publicly available communication channels to provide information about themselves, which contains personal data of such entities, is intended to interest the Company in establishing labor relations with such entities (applicants for vacant positions, persons wishing to undergo industrial training, etc
In all of these cases, the Company assumes that by contacting the Company, such personal data subjects have automatically consented to the processing of their personal data for the time necessary for this purpose and in accordance with the purpose specified in this Regulation, since otherwise they would not have contacted the Company.
1.4. Purpose of personal data processing
The purpose of processing personal data is determined depending on the classification of the database in which such personal data may be processed.
Personal data in the "Counterparties" database is processed by the Company for the purpose of:
− conducting business activities, including obtaining services by the Company;
− Maintaining accounting, financial and management records;
− ensuring intermediary legal relations;
− business correspondence, including responding to requests from government agencies;
− Preparing statistical, administrative and other reporting information on the Company's activities in accordance with the requirements of the law and the Company's internal documentation;
− compliance with taxation legislation;
− ensuring communication with counterparties and their representatives;
− Ensuring the rights and legitimate interests of the Company and its stakeholders.
Separate reservations made by the Company and its counterparty in transactions between them may also provide for another purpose of processing not specified in this Regulation.
Personal data in the "Clients" database is processed by the Company for the purpose of:
− provision of services by the Company and related transactions;
− compliance with the requirements of the legislation in the field of financial monitoring;
− Preparing statistical, administrative and other reporting information on the Company's activities in accordance with the requirements of the law;
− compliance with taxation legislation;
− ensuring communication with clients;
− providing advice and information on the Company's services;
− conducting marketing events, research and campaigns, and analyzing consumer sentiment;
− Ensuring the rights and legitimate interests of the Company and its stakeholders;
− ensuring the implementation of relations in the field of services provided by the Company; 
− administrative and legal (including relations in the field of public administration), tax and accounting relations;
− other relations requiring the processing of personal data and aimed at generating income and implementing the provisions of the Civil Code of Ukraine, the Commercial Code of Ukraine, other laws governing the Company's activities, the Company's Charter and its internal regulations.
Separate reservations made by the Company and its client in transactions between them may also provide for another purpose of processing not specified in this provision.
Personal data in the Participants database is processed by the Company for the purpose of:
− compliance with the requirements of the legislation in the field of financial monitoring;
− Preparing statistical, administrative and other reporting information on the Company's activities in accordance with the requirements of the law;
− compliance with taxation legislation;
− ensuring communication with participants;
− Ensuring the rights and legitimate interests of the Company, its shareholders and stakeholders;
− ensuring the implementation of relations in the field of corporate governance;
− administrative and legal (including relations in the field of public administration), tax and accounting relations;
− other relations requiring the processing of personal data and aimed at generating income and implementing the provisions of the Civil Code of Ukraine, the Commercial Code of Ukraine, the Company's Charter and its internal regulations.
Separate reservations made by the Company and its members may also provide for other purposes of processing not specified in this Regulation.
Personal data in the Employees database is processed by the Company for the purpose of:
− establishing and maintaining legal relations in the field of labor, employment, internship, employment in cases of communication with entities that contact the Company via publicly available communication channels in order to provide information about themselves, which contains personal data of such entities, intended to interest the Company in establishing labor relations with such entities;
− Ensuring the implementation of labor relations, administrative, legal, tax and accounting relations, relations in the field of human resource management, including human resources in accordance with the Labor Code of Ukraine, the Law of Ukraine "On Accounting and Financial Reporting in Ukraine", the Law of Ukraine "On Employment of the Population"
Separate reservations made by the Company and its employee in transactions between them may also provide for other purposes of processing not specified in this Regulation.
1.5. Composition of personal data processed by the Company
Information about the personal data subject, related persons, family members, relatives, guarantors, contact persons and representatives of the personal data subject reflected in transactions, legal documents and information (automated) systems, databases of the Company is personal data processed in the personal databases "Counterparties", "Clients", "Participants" and "Employees". In particular, such personal databases process information about:
− surname, name and patronymic (if any) of the subject;
− passport data (including civil and foreign passports, permanent or temporary residence permits and other identity documents);
− citizenship (nationality) or lack of citizenship (nationality);
− the entity's residence;
− a sample of a personal signature;
− data on the registration of the entity as a person engaged in independent professional activity or an individual entrepreneur;
− age;
− gender;
− date and place of birth; 
− place of permanent residence or temporary residence, duration of residence;
− place of registration;
− the registration number of the taxpayer's account card (if the person has it) or information on the refusal to obtain such a number;
− marital status;
− family composition and the number of dependents, surnames, names, patronymics of such persons, their gender, age, place of registration and residence, contact details;
− contact persons (surnames, names, patronymics of such persons, their date of birth, telephone numbers, e-mail address);
− profession, specialization, qualification class;
− work experience and places of employment;
− attitude to military duty;
− health status to the extent that the subject provides it voluntarily;
− data on charges of a crime or sentencing to a criminal penalty, the processing of which has been explicitly agreed to by the subject;
− education (including academic titles, advanced training courses, etc.), language skills;
− driving license and driving experience;
− positions held;
− images (photos, videos) and sound (audio);
− telephone numbers (business and personal landline and mobile), e-mail address (corporate and personal), Skype, fax, etc;
− bank account details;
− identifying data of the client's counterparties that became known to the Company in connection with the provision of services to the client;
− data required by the legislation in the field of financial monitoring, from those not listed above;
− other information, the purpose of processing of which coincides with the purpose of processing personal data, and which will be provided by the subject independently or received by the Company in the course of the Company's activities, including, but not limited to, the provision of services.
In any case, the specific composition and content of the subject's personal data collected by the Company is contained in the primary sources of information about the subject, in particular, in documents issued in his/her name, documents signed by him/her, information provided by the subject to the Company about himself/herself.
1.6. Notification of the rights of personal data subjects.
The Company hereby notifies personal data subjects of the inclusion of their personal data in the Company's personal data bases, as well as of their rights as personal data subjects stipulated by Article 8 of the Law of Ukraine "On Personal Data Protection" (as amended), including:
− to know about the sources of collection, location of their personal data, the purpose of their processing, location or place of residence (stay) of the owner or manager of personal data or to give an appropriate order to obtain this information to persons authorized by him/her, except in cases established by law;
− receive information about the conditions for granting access to personal data, including information about third parties to whom their personal data is transferred;
− to access their personal data;
− receive a response no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, on whether their personal data is processed, as well as the content of such personal data;
− submit a reasoned request to the Company with an objection to the processing of their personal data;
− to make a reasoned request to change or destroy their personal data by any owner and administrator of personal data if this data is processed illegally or is 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 inaccurate or discrediting the honor, dignity and business reputation of an individual;
− file complaints about the processing of their personal data with the Commissioner;
− apply legal remedies in case of violation of personal data protection legislation;
− to make reservations regarding the restriction of the right to process their personal data when giving consent;
− withdraw consent to the processing of personal data;
− know the mechanism of automatic processing of their personal data;
− to be protected from an automated decision that has legal consequences for them.
1.7. Warning about visual recording
The peculiarities of processing personal data through video surveillance, including the use of video recording, take into account the requirements of applicable law. The Company uses this method of data processing at its premises in accordance with internal regulations governing such activities, including the period of data processing. The purpose of such activities is to ensure the rights and legitimate interests of the Company and interested parties. Processing of personal data in this way may be carried out as part of an information and telecommunication system with the use of network protection against unauthorized access during the processing of personal data. The Company carries out video surveillance based on the statement that visits to the Company's premises, provided that the Company is notified of the fact of video recording, indicate the consent of personal data subjects to the processing of their video images by the Company.
The Company processes personal data in a photo format in accordance with internal regulations governing such activities, including the period of data processing. The purpose of such activities is to ensure the rights and legitimate interests of the Company and interested parties. Processing of personal data in this way may be carried out as part of an information and telecommunication system with the use of network protection against unauthorized access during the processing of personal data. The Company receives a photo image of the personal data subject from the personal data subject (for example, when applying for a job), or creates a photo image independently. Such activities are carried out by the Company on the basis of legislation or on the basis of the consent of the personal data subject obtained in the manner prescribed by law. A photo image may also be distributed without the permission of the individual depicted in it, if it is caused by the need to protect his or her interests or the interests of other persons in accordance with Article 308 of the Civil Code of Ukraine.
1.8. Warning for personal data subjects who independently transmit their personal data to the Company via remote communication channels
The Company processes personal data of subjects in the personal data base "Participants", "Counterparties", "Clients" or "Employees" who independently contact the Company for any purpose and provide it with their personal data via remote communication channels.
In any case, the Company assumes that by contacting the Company, such personal data subjects have automatically consented to the processing of their personal data for the time necessary for this purpose and in accordance with the purpose, since otherwise they would not have contacted the Company.
1.9. Clause on cross-border transfer
The Company shall transfer personal data of the subject to foreign parties to relations related to personal data only if the relevant state ensures proper protection of personal data in cases established by law or an international treaty of Ukraine. The member states of the European Economic Area, as well as the states that have signed the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, are recognized as ensuring an adequate level of personal data protection. 
The list of states that are not included in the list of Member States of the European Economic Area, as well as states that have signed the Council of Europe Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data, but ensure adequate protection of personal data, is determined by the Cabinet of Ministers of Ukraine.
Personal data of subjects in the event of cross-border transfer may be disseminated by the Company only for the purpose for which they were collected.
Personal data may be transferred by the Company to foreign subjects of relations related to personal data also in the case of:
− the personal data subject's unequivocal consent to such transfer;
− the need to conclude or execute a transaction between the personal data controller and a third party - a personal data subject - in favor of the personal data subject;
− the need to protect the vital interests of personal data subjects;
− the need to protect the public interest, establish, fulfill and enforce a legal claim;
− providing the personal data owner with appropriate guarantees of non-interference in the personal and family life of the personal data subject.
2. The procedure for processing personal data owned and managed by the Company.
2.1. Grounds for processing personal data
The grounds for processing personal data in the Company's personal databases shall be as follows:
− consent of the personal data subject to the processing of his or her personal data;
− permission to process personal data granted to the Company in accordance with the law, solely for the purpose of exercising its powers;
− Conclusion and execution of a transaction to which the personal data subject is a party or which is concluded in favor of the personal data subject or for the purpose of taking measures preceding the conclusion of a transaction at the request of the personal data subject;
− protection of the vital interests of the personal data subject;
− the need to fulfill the Company's obligations under the law;
− The need to protect the legitimate interests of the Company or a third party to whom personal data is transferred, unless the need to protect the fundamental rights and freedoms of the personal data subject in connection with the processing of his or her data outweighs such interests.
2.2. Method of collecting and accumulating personal data.
The Company collects personal data by:
− receiving personal data directly from the personal data subject;
− obtaining personal data from representatives (by law, by contract, by power of attorney) of the personal data subject;
− obtained in the course of the Company's interaction with the personal data subject;
− obtaining personal data from public authorities and local self-government bodies in cases stipulated by the current legislation of Ukraine.
The Company accumulates personal data by combining and systematizing personal data and storing them in personal cards, personal files, and in information databases of HR or accounting programs.
2.3 Processing of personal data in the personal database "Counterparties"
The subject's consent to the processing of his or her personal data is voluntary and informed. Consent may be provided by the subject in writing or electronically, which allows us to conclude that it has been provided.
The Company shall notify the personal data subject of the composition and content of the collected personal data, his/her rights under the Law, the purpose of collecting personal data and the persons to whom his/her personal data is transferred:
− at the time of collection of personal data, if personal data is collected from the personal data subject; 
− in other cases, within thirty business days from the date of collection of personal data.
2.3.1. Reservations for transactions with legal entities
Hereby, the Company and its counterparty (collectively, the "Applicants") mutually confirm that they have all legal grounds to provide each other with personal data of individuals in the manner and on the conditions stipulated by the current legislation of Ukraine for the purpose of entering into a transaction and to provide in the future in connection with or for the execution of any transactions that have been or will be concluded between them, personal data of individuals (including their clients/participants/founders/managers/authorized persons/employees and related parties) for the purposes specified in this Regulation, in particular:
− entering into and performing the transaction in connection with which this clause is used, as well as other transactions between them;
− exercising their rights provided for and/or related to such transactions;
− inclusion of this data in the "Counterparties" personal data base and its processing within the period necessary to fulfill the purpose;
− implementation of other relations that require processing of such personal data and are aimed at implementing the requirements of the law, the applicants' statutory documents and their internal regulations.
The Company and its counterparty also mutually confirm that the terms of the transfer allow them to transfer personal data on such individuals, including, but not limited to, managers (enterprises, institutions and organizations of all forms of ownership, public authorities or local governments, individual entrepreneurs who have been granted or will be granted the right to process personal data by the Company and its counterparty or applicable law), archival institutions and other persons providing information storage services to applicants and
The terms of the counterparty's consent do not require the Company to notify the transfer of the counterparty's personal data to third parties.
In case the Company's counterparty has the status of a non-resident of Ukraine, the counterparty hereby confirms that there are no contractual restrictions or restrictions established by the law of the country of the personal data subject, other restrictions that would make it impossible to transfer, receive and process his/her personal data under the terms of this Regulation.
2.3.2. Reservations for transactions with individual entrepreneurs
Hereby, the Company and its counterparty (collectively, the "Applicants") mutually confirm that they have all legal grounds to provide each other with personal data of individuals (including their clients/authorized persons/employees and related parties) in the manner and on the terms provided by the current legislation of Ukraine for the purpose of entering into a transaction and to provide in the future in connection with or for the execution of any transactions that have been or will be concluded between them, in particular, for the purpose specified in this Regulation:
− entering into and performing the transaction in connection with which this clause is used, as well as other transactions between them;
− exercise of their rights provided for and/or related to such transactions;
− inclusion of this data in the personal database "Counterparties" and its processing within the period necessary to fulfill the purpose;
− implementation of other relations that require processing of such personal data and are aimed at implementing the requirements of the law, the Company's charter documents and its internal regulations.
The Company and its counterparty mutually confirm that the terms of transfer allow them to transfer personal data on such individuals, including, but not limited to, to managers (enterprises, institutions and organizations of all forms of ownership, public authorities or local governments, individual entrepreneurs who have been granted or will be granted the right to process personal data by the Company and its counterparty or applicable law), archival institutions and other persons providing information and document storage services to applicants. 
The counterparty also grants the Company permission to process (including collection, registration, accumulation, storage, adaptation, modification, updating, use, distribution, dissemination, sale, transfer to any third party, depersonalization, deletion, destruction) of his or her own personal data.
The terms of the counterparty's consent do not require the Company to notify the third parties of the transfer of the counterparty's personal data.
The Counterparty, as a personal data subject, confirms that it has been notified by the Company of the inclusion of its personal data in the personal data base "Counterparties" and of its rights under Article 8 of the Law of Ukraine No. 2297-VI dated 01.06.2010 "On Personal Data Protection" (as amended) in connection with the processing of its personal data in this database.
The Counterparty, as a personal data subject, agrees to the storage of his/her personal data by the Company for the period determined in accordance with the Company's internal documents and the current legislation of Ukraine.
The counterparty confirms that it has been notified of the composition and content of the personal data collected by the Company about it, which are contained in the primary sources of information about the counterparty, in particular in documents issued in its name, documents signed by it, and information provided by the counterparty to the Company about itself.
The counterparty guarantees that it has legal grounds to transfer personal data of those personal data subjects, information about which will be at the disposal of the Company, in connection with the counterparty's actions, and that the terms of transfer do not contradict this Regulation. The Company will also consider a separate written consent of such subjects, if provided by the counterparty, as sufficient confirmation of the existence of legal grounds for the said actions.
In case the Company's counterparty has the status of a non-resident of Ukraine, the counterparty hereby confirms that there are no contractual restrictions or restrictions established by the law of the country of the personal data subject, other restrictions that would make it impossible to transfer, receive and process his/her personal data under the terms of this Regulation.
2.3.3. Reservations for transactions with individuals.
The Counterparty grants the Company permission to process (including collection, registration, accumulation, storage, adaptation, modification, updating, use, distribution, dissemination, sale, transfer to any third party, depersonalization, deletion, destruction) of its own personal data for the purposes specified in this Regulation, in particular:
− entering into and performing the transaction in connection with which this clause is used, as well as other transactions between them;
− exercise of their rights provided for and/or related to such transactions;
− inclusion of this data in the personal database "Counterparties" and its processing within the period necessary to fulfill the purpose;
− implementation of other relations that require processing of such personal data and are aimed at implementing the requirements of the law, the Company's charter documents and its internal regulations.
The counterparty also grants the Company permission to transfer its personal data, including, but not limited to, to managers (enterprises, institutions and organizations of all forms of ownership, public authorities or local governments, individual entrepreneurs who are or will be granted the right to process personal data by the Company or applicable law), archival institutions and other persons providing the Company with information and document storage and related services; participants and affiliates of the Company and persons
The terms of the counterparty's consent do not require the Company to notify the third parties of the transfer of the counterparty's personal data.
The Counterparty, as a personal data subject, confirms that it has been notified by the Company of the inclusion of its personal data in the personal data base "Counterparties" and of its rights under Article 8 of the Law of Ukraine No. 2297-VI dated 01.06.2010 "On Personal Data Protection" (as amended) in connection with the processing of its personal data in this database. 
The Counterparty, as a personal data subject, agrees to the storage of his/her personal data by the Company for the period determined in accordance with the Company's internal documents and the current legislation of Ukraine.
The counterparty confirms that it has been notified of the composition and content of the personal data collected by the Company about it, which are contained in the primary sources of information about the counterparty, in particular in documents issued in its name, documents signed by it, and information provided by the counterparty to the Company about itself.
The counterparty warrants that it has legal grounds to transfer personal data of those personal data subjects to the Company, information about which will be at the disposal of the Company in connection with the counterparty's actions, and that the terms of transfer do not contradict this Regulation. The Company will also consider a separate written consent of such subjects, if provided by the counterparty, as sufficient confirmation of the existence of legal grounds for the said actions.
If the Company's counterparty has the status of a non-resident of Ukraine, the counterparty hereby confirms that there are no contractual restrictions or restrictions established by the law of the country of the personal data subject, other restrictions that would make it impossible to transfer, receive and process his or her personal data under the terms of this Regulation
2.3.4. Clause on actions in favor of the counterparty.
The personal data subject who is a representative of the counterparty grants the Company permission to process (including collection, registration, accumulation, storage, adaptation, modification, updating, use, distribution, dissemination, sale, transfer to any third party, depersonalization, deletion, destruction) of his or her personal data for the purpose that coincides with the purpose of processing personal data in the "Counterparties" database owned by the Company.
A personal data subject who is a representative of a counterparty confirms that he or she has been notified by the Company of the inclusion of his or her personal data in the personal data base "Counterparties" and of his or her rights under Article 8 of the Law of Ukraine "On Personal Data Protection" (as amended) in connection with the processing of his or her personal data in this database.
The personal data subject who is a representative of the counterparty agrees to the storage of his or her personal data by the Company for the period determined in accordance with the Company's internal documents and the current legislation of Ukraine.
The personal data subject who is a representative of the counterparty confirms that he or she has been notified of the composition and content of personal data collected by the Company about him or her, which are contained in the primary sources of information about him or her, in particular in documents issued in his or her name, documents signed by him or her, and information provided by the representative to the counterparty about himself or herself.
When entering into a relationship with a personal data subject who is a representative of the counterparty, the Company may assume that it has legal grounds for processing the counterparty's personal data, since the representative acts to conclude and/or perform a transaction to which the counterparty is a party or which is concluded in favor of the counterparty or to take measures preceding the conclusion of a transaction at the counterparty's request.
2.4. Processing of personal data in the personal data base "Clients".
The subject's consent to the processing of his or her personal data is voluntary and informed. Consent may be provided by the subject in writing or electronically, which allows us to conclude that it has been provided.
The Company shall notify the personal data subject of the composition and content of the collected personal data, his/her rights under the Law, the purpose of collecting personal data and the persons to whom his/her personal data is transferred:
− at the time of collection of personal data, if personal data is collected from the personal data subject;
− in other cases, within thirty business days from the date of collection of personal data. 

2.4.1 Reservations for transactions with legal entities
Hereby, the Company and its client (collectively, the "Applicants") mutually confirm that they have all legal grounds to provide each other with personal data of individuals (including their clients/participants/founders/managers/authorized persons/employees and related parties) in the manner and on the terms and conditions provided by the current legislation of Ukraine for the purpose of entering into a transaction and to provide in the future in connection with or for the execution of any transactions that have been or will be concluded between them, in particular, for the purpose determined by this Regulation:
− entering into and performing the transaction in connection with which this clause is used, as well as other transactions between them;
− exercise of their rights provided for and/or related to such transactions;
− inclusion of this data in the personal data base "Clients" and its processing for the period necessary to fulfill the purpose;
− implementation of other relations that require processing of such personal data and are aimed at implementing the requirements of the law, the applicants' statutory documents and their internal regulations.
The Company and its client mutually confirm that the terms of transfer allow them to transfer personal data regarding such individuals, including, but not limited to, administrators (enterprises, institutions and organizations of all forms of ownership, public authorities or local governments, individual entrepreneurs who have been granted or will be granted the right to process personal data by the Company and its client or by applicable law), archival institutions and other persons providing information and document storage services to applicants, and
If the Company's client has the status of a non-resident of Ukraine, the client hereby confirms that there are no contractual restrictions or restrictions established by the law of the country of the personal data subject, or other restrictions that would make it impossible to transfer, receive and process his or her personal data under the terms of this Regulation.
2.4.2. Reservations for transactions with individual entrepreneurs
Hereby, the Company and its client (collectively, the "Applicants") mutually confirm that they have all legal grounds to provide each other with personal data of individuals (including their clients/managers/authorized persons/employees and related parties) in the manner and on the terms and conditions provided by the current legislation of Ukraine for the purpose of entering into a transaction and to provide in the future in connection with or for the execution of any transactions that have been or will be concluded between them, in particular, for the purpose determined by this Regulation:
− entering into and performing the transaction in connection with which this clause is used, as well as other transactions between them;
− exercise of their rights provided for and/or related to such transactions;
− inclusion of this data in the personal data base "Clients" and its processing for the period necessary to fulfill the purpose;
− implementation of other relations that require processing of such personal data and are aimed at implementing the requirements of the law, the Company's charter documents and its internal regulations.
The Company and its client mutually confirm that the terms of transfer allow them to transfer personal data regarding such individuals, including, but not limited to, to administrators (enterprises, institutions and organizations of all forms of ownership, public authorities or local governments, individual entrepreneurs who have been or will be granted the right to process personal data by the Company and its client or applicable law), archival institutions and other persons providing information storage services to applicants and The client also grants the Company permission to process (including collection, registration, accumulation, storage, adaptation, modification, updating, use, distribution, dissemination, sale, transfer to any third party, depersonalization, deletion, destruction) of his or her own personal data.
The terms of the client's consent do not require the Company to notify the client of the transfer of personal data to third parties.
The Client, as a personal data subject, confirms that he/she has been notified by the Company of the inclusion of his/her personal data in the personal data base "Clients" and of his/her rights under Article 8 of the Law of Ukraine No. 2297-VI dated 01.06.2010 "On Personal Data Protection" (as amended) in connection with the processing of his/her personal data in this database.
The Client, as a personal data subject, by entering into business relations with the Company, concluding transactions with it and/or receiving services from it, agrees to the storage of his/her personal data by the Company for the period determined in accordance with the internal documents of the Company and the current legislation of Ukraine.
The Client confirms that he/she has been notified of the composition and content of personal data collected by the Company about him/her, which are contained in the primary sources of information about the Client, in particular, in documents issued in his/her name, documents signed by him/her, information provided by the Client to the Company about himself/herself.
The Client guarantees that he/she has legal grounds to transfer to the Company personal data of those personal data subjects, information about which will be at the Company's disposal in connection with the Client's actions (disposal of property that is the object of joint marital property, provision of information about contact persons, etc. The Company will also consider a separate written consent of such entities, if provided by the client, as sufficient confirmation of the client's legal grounds for the said actions.
The Client also confirms that he/she has been notified by the Company that the Company may take photographs and video surveillance, as well as record contacts with the Client (including audio recording of telephone conversations, etc.) at the Company's premises in order to ensure the safety and proper servicing of the Client. The Company shall have the right to store video recordings, recordings of telephone conversations and photographs in the future, as well as to distribute them in cases provided for by the transactions concluded by the client with the Company and the current legislation of Ukraine. Video recordings, photographs, and recordings of telephone conversations may be used as evidence in legal proceedings.
If the Company's client has the status of a non-resident of Ukraine, the client hereby confirms that there are no contractual restrictions or restrictions established by the law of the country of the personal data subject, or other restrictions that would make it impossible to transfer, receive and process his or her personal data under the terms of this Regulation.
2.4.3. Reservations for transactions with individuals
The Client grants the Company permission to process (including collection, registration, accumulation, storage, adaptation, modification, renewal, use, distribution, sale, transfer to any third party, depersonalization, deletion, destruction) of his/her personal data for the purposes specified in this Regulation, in particular:
− entering into and performing the transaction in connection with which this clause is used, as well as other transactions between them;
− exercise of their rights provided for and/or related to such transactions;
− inclusion of this data in the personal data base "Clients" and its processing for the period necessary to fulfill the purpose;
− implementation of other relations that require processing of such personal data and are aimed at implementing the requirements of the law, the Company's charter documents and its internal regulations.
The client also grants the Company permission to transfer his/her personal data, including, but not limited to, to managers (enterprises, institutions and organizations of all forms of ownership, public authorities or local self-government bodies, individual entrepreneurs who are or will be granted the right to process personal data by the Company or applicable law), archival institutions and other persons providing the Company with information and document storage and related services; participants and affiliates of the Company and persons,
The terms of the client's consent do not require the Company to notify the client of the transfer of personal data to third parties.
The Client, as a personal data subject, confirms that he/she has been notified by the Company of the inclusion of his/her personal data in the personal data base "Clients" and of his/her rights under Article 8 of the Law of Ukraine No. 2297-VI dated 01.06.2010 "On Personal Data Protection" (as amended) in connection with the processing of his/her personal data in this database.
The Client, as a personal data subject, by entering into business relations with the Company, concluding transactions with it and/or receiving services from it, agrees to the storage of his/her personal data by the Company for the period determined in accordance with the Company's internal documents and the current legislation of Ukraine.
The Client confirms that he/she has been notified of the composition and content of personal data collected by the Company about him/her, which are contained in the primary sources of information about the Client, in particular, in documents issued in his/her name, documents signed by him/her, information provided by the Client to the Company about himself/herself.
The Client guarantees that he/she has legal grounds to transfer to the Company personal data of those personal data subjects, information about which will be at the Company's disposal in connection with the Client's actions (disposal of property that is the object of joint marital property, provision of information about contact persons, etc. The Company will also consider a separate written consent of such entities, if provided by the client, as sufficient confirmation of the client's legal grounds for the said actions.
The Client also confirms that he/she has been notified by the Company that the Company may take photographs and video surveillance, as well as record contacts with the Client (including audio recording of telephone conversations, etc.) at the Company's premises in order to ensure the safety and proper servicing of the Client. The Company shall have the right to store video recordings, recordings of telephone conversations and photographs in the future, as well as to distribute them in cases provided for by the transactions concluded by the client with the Company and the current legislation of Ukraine. Video recordings, photographs, and recordings of telephone conversations may be used as evidence in legal proceedings.
If the Company's client has the status of a non-resident of Ukraine, the client hereby confirms that there are no contractual restrictions or restrictions imposed on the personal data subject by the law of the country of the personal data subject, or other restrictions that would make it impossible to transfer, receive and process his or her personal data under the terms of this Regulation.
2.4.4. Clause on actions in favor of the client - the subject of personal data
A personal data subject who is a client's representative grants the Company permission to process (including collection, registration, accumulation, storage, adaptation, modification, updating, use, distribution, dissemination, sale, transfer to any third party, depersonalization, deletion, destruction) of his or her own personal data for the purpose that coincides with the purpose of processing personal data in the "Clients" database owned by the Company.
The personal data subject, who is a representative of the client, confirms that he/she has been notified by the Company of the inclusion of his/her personal data in the personal data base "Clients" and of his/her rights under Article 8 of the Law of Ukraine No. 2297-VI dated 01.06.2010 "On Personal Data Protection" (as amended) in connection with the processing of his/her personal data in this database.
A personal data subject who is a client's representative agrees to the storage of his/her personal data by the Company for the period determined in accordance with the Company's internal documents and the current legislation of Ukraine.
A personal data subject who is a client's representative confirms that he or she has been informed of the composition and content of personal data collected by the Company about him or her, which are contained in the primary sources of information about him or her, in particular in documents issued in his or her name, documents signed by him or her, and information provided by the representative to the Company about himself or herself.
When entering into a relationship with a personal data subject who is a client's representative, the Company may assume that it has legal grounds for processing the client's personal data, since the representative acts to conclude and/or perform a transaction to which the client is a party or which is concluded in favor of the client or to take measures preceding the conclusion of a transaction at the client's request.
2.5. Processing of personal data in the personal data base "Participants"
The subject's consent to the processing of his or her personal data is voluntary and informed. Consent may be provided by the subject in writing or electronically, which allows us to conclude that it has been provided.
The Company shall notify the personal data subject of the composition and content of the collected personal data, his/her rights under the Law, the purpose of collecting personal data and the persons to whom his/her personal data is transferred:
− at the time of collection of personal data, if personal data is collected from the personal data subject;
− in other cases, within thirty business days from the date of collection of personal data.
2.5.1. Caution for participants - legal entities
Hereby, the Company and its member (collectively, the "Applicants") mutually confirm that they have all legal grounds to provide each other with personal data of individuals (including their clients/participants/founders/managers/authorized persons/employees and related persons) in the manner and on the terms and conditions provided by the current legislation of Ukraine for the purpose of entering into a transaction and to provide in the future in connection with the exercise by the member of its legal functions and powers, for the purpose determined by this Regulation, in particular:
− including this data in the Participant personal data base and processing it for the period necessary to fulfill the purpose;
− ensuring the legal rights of the participant;
− implementation of other relations that require processing of such personal data and are aimed at implementing the requirements of the law, the applicants' statutory documents and their internal regulations.
The Company and its member mutually confirm that the terms of transfer allow them to transfer personal data on such individuals, including, but not limited to, to managers (enterprises, institutions and organizations of all forms of ownership, public authorities or local governments, individual entrepreneurs who have been granted or will be granted the right to process personal data by the Company and its member or by applicable law), archival institutions and other persons providing information and document storage services to applicants If the participant has the status of a non-resident of Ukraine, the participant hereby confirms that there are no contractual restrictions or restrictions established by the law of the country of the personal data subject, other restrictions that would make it impossible to transfer, receive and process his or her personal data under the terms of this Regulation.
2.5.2. Warning for participants who are individual entrepreneurs.
Hereby, the Company and its member (collectively, the "Applicants") mutually confirm that they have all legal grounds to provide each other with personal data of individuals (including their clients/participants/founders/managers/authorized persons/employees and related persons) in the manner and on the terms and conditions provided by the current legislation of Ukraine for the purpose of entering into a transaction and to provide in the future in connection with the exercise by the member of its legal functions and powers, for the purpose determined by this Regulation, in particular:
− including this data in the Participants' personal data base and processing it for the period necessary to fulfill the purpose;
− ensuring the legal rights of the participant;
− implementation of other relations that require processing of such personal data and are aimed at implementing the requirements of the law, the applicants' statutory documents and their internal regulations.
The Company and its participant also mutually confirm that the terms of transfer allow them to transfer personal data on such individuals, including, but not limited to, to managers (enterprises, institutions and organizations of all forms of ownership, public authorities or local governments, individual entrepreneurs who have been granted or will be granted the right to process personal data by the Company and its participant or by applicable law), archival institutions and other persons providing applicants with information and document storage services.
The participant also grants the Company permission to process (including collection, registration, accumulation, storage, adaptation, modification, updating, use, distribution, dissemination, sale, transfer to any third party, depersonalization, deletion, destruction) of his or her own personal data.
The terms of the shareholder's consent do not require the Company to notify the shareholder of the transfer of personal data to third parties.
The Participant, as the subject of personal data, confirms that he/she has been notified by the Company of the inclusion of his/her personal data in the Participants personal data base and of his/her rights under Article 8 of the Law of Ukraine No. 2297-VI dated 01.06.2010 "On Personal Data Protection" (as amended) in connection with the processing of his/her personal data in this database.
By entering into legal relations with the Company, the Participant, as a personal data subject, agrees to the storage of his/her personal data by the Company for the period determined in accordance with the Company's internal documents and the current legislation of Ukraine.
The participant confirms that he/she has been notified of the composition and content of personal data collected by the Company about him/her, which are contained in the primary sources of information about the participant, in particular in documents issued in his/her name, documents signed by him/her, information provided by the participant to the Company about himself/herself.
The participant guarantees that it has legal grounds to transfer to the Company personal data of those personal data subjects, information about which will be at the Company's disposal in connection with the participant's actions (disposal of property that is the object of joint marital property, provision of information about contact persons, etc. The Company will also consider a separate written consent of such entities, if provided by the shareholder, as sufficient confirmation of the existence of legal grounds for the said actions.
The participant also confirms that he/she has been notified by the Company that the Company may take photographs and video recordings, as well as record contacts in the premises and communication channels of the Company, in order to ensure the safety and legitimate interests of the participant. The Company shall have the right to store video recordings and photographs in the future, as well as to distribute them in cases provided for by the authorizations (consents) of the participant and the current legislation of Ukraine. Video recordings, photographs and recordings of telephone conversations may be used as evidence in legal proceedings.
In the event that a member of the Company has the status of a non-resident of Ukraine, the member hereby confirms that there are no contractual restrictions or restrictions established by the law of the country of the personal data subject, or other restrictions that would make it impossible to transfer, receive and process his or her personal data under the terms of this Regulation
2.5.3. Warning for participants who are individuals.
The Participant grants the Company permission to process (including collection, registration, accumulation, storage, adaptation, modification, updating, use, distribution, dissemination, sale, transfer to any third party, depersonalization, deletion, destruction) of his/her personal data for the purposes determined by this Regulation, in particular:
− including this data in the Participants' personal data base and processing it for the period necessary to fulfill the purpose;
− ensuring the legal rights of the participant;
− implementation of other relations that require processing of such personal data and are aimed at implementing the requirements of the law, the Company's charter documents and its internal regulations.
The participant also grants the Company permission to transfer his/her personal data, including, but not limited to, to managers (enterprises, institutions and organizations of all forms of ownership, public authorities or local self-government bodies, individual entrepreneurs who are or will be granted the right to process personal data by the Company or applicable law), archival institutions and other persons providing the Company with information and document storage and related services; participants and affiliates of the Company and persons,
The terms of the shareholder's consent do not require the Company to notify the shareholder of the transfer of personal data to third parties.
The Participant, as the subject of personal data, confirms that he/she has been notified by the Company of the inclusion of his/her personal data in the Participants personal data base and of his/her rights under Article 8 of the Law of Ukraine No. 2297-VI dated 01.06.2010 "On Personal Data Protection" (as amended) in connection with the processing of his/her personal data in this database.
By entering into legal relations with the Company, the Participant, as a personal data subject, agrees to the storage of his/her personal data by the Company for the period determined in accordance with the Company's internal documents and the current legislation of Ukraine.
The participant confirms that he/she has been notified of the composition and content of personal data collected by the Company about him/her, which are contained in the primary sources of information about the participant, in particular in documents issued in his/her name, documents signed by him/her, information provided by the participant to the Company about himself/herself.
The participant guarantees that it has legal grounds to transfer to the Company personal data of those personal data subjects, information about which will be at the Company's disposal in connection with the participant's actions (disposal of property that is the object of joint marital property, provision of information about contact persons, etc. The Company will also consider a separate written consent of such entities, if provided by the shareholder, as sufficient confirmation of the existence of legal grounds for the said actions.
The participant also confirms that he/she has been notified by the Company that the Company may take photographs and video recordings, as well as record contacts in the premises and communication channels of the Company, in order to ensure the safety and legitimate interests of the participant. The Company shall have the right to store video recordings and photographs in the future, as well as to distribute them in cases provided for by the authorizations (consents) of the participant and the current legislation of Ukraine. Video recordings, photographs and recordings of telephone conversations may be used as evidence in legal proceedings.
If the Company's member has the status of a non-resident of Ukraine, the member hereby confirms that there are no contractual restrictions or restrictions established by the law of the country of the personal data subject, or other restrictions that would make it impossible to transfer, receive and process his or her personal data under the terms of this Regulation.
2.5.4. Clause on actions in favor of the participant - the subject of personal data.
A personal data subject who is a representative of a participant grants the Company permission to process (including collection, registration, accumulation, storage, adaptation, modification, updating, use, distribution, dissemination, sale, transfer to any third party, depersonalization, deletion, destruction) of his or her own personal data for the purpose that coincides with the purpose of processing personal data in the Participants database owned by the Company.
The personal data subject, who is a representative of the participant, confirms that he/she has been notified by the Company of the inclusion of his/her personal data in the Participants personal data base and of his/her rights under Article 8 of the Law of Ukraine No. 2297-VI dated 01.06.2010 "On Personal Data Protection" (as amended) in connection with the processing of his/her personal data in this database.
A personal data subject who is a representative of a participant agrees to the storage of his or her personal data by the Company for the period determined in accordance with the Company's internal documents and the current legislation of Ukraine.
A personal data subject who is a representative of a participant confirms that he or she has been notified of the composition and content of personal data collected by the Company about him or her, which are contained in the primary sources of information about him or her, in particular in documents issued in his or her name, documents signed by him or her, and information provided by the representative to the Company about himself or herself.
When entering into a relationship with a personal data subject who is a representative of a participant, the Company may assume that it has legal grounds for processing the participant's personal data, since the representative acts to enter into and/or perform a transaction to which the participant is a party or which is concluded in favor of the participant or to take measures preceding the conclusion of the transaction at the request of the participant.
2.6 Processing of personal data in the personal data base "Employees"
The subject's consent to the processing of his or her personal data is voluntary and informed. Consent may be provided by the subject in writing or electronically, which allows us to conclude that it has been provided.
The Company shall notify the personal data subject of the composition and content of the collected personal data, his/her rights under the Law, the purpose of personal data processing and the persons to whom his/her personal data is transferred:
− at the time of collection of personal data, if personal data is collected from the personal data subject;
− in other cases, within thirty working days from the date of collection of personal data
2.6.1. Warnings for employees.
The Employee grants the Company permission to process (including collection, registration, accumulation, storage, adaptation, modification, updating, use, distribution, dissemination, sale, transfer to any third party, depersonalization, deletion, destruction) of his/her personal data for the purposes specified in this Regulation, in particular:
− Establishment and maintenance of legal relations in the field of labor, employment, internships, employment in cases of communications with entities that contact the Company via publicly available communication channels in order to provide information about themselves, which contains personal data of such entities, intended to interest the Company in establishing labor relations with such entities;
− Ensuring the implementation of labor relations, administrative, legal, tax and accounting relations, relations in the field of human resource management, including human resources in accordance with the Labor Code of Ukraine, the Law of Ukraine "On Accounting and Financial Reporting in Ukraine", the Law of Ukraine "On Employment of the Population"
The employee also grants the Company permission to transfer his/her personal data, including, but not limited to, to managers (enterprises, institutions and organizations of all forms of ownership, public authorities or local governments, individual entrepreneurs who are or will be granted the right to process personal data by the Company or applicable law), archival institutions and other persons providing the Company with information and document storage and related services; participants and affiliates of the Company and persons
The terms of the employee's consent do not require the Company to notify the employee of the transfer of personal data to third parties.
The Employee, as a personal data subject, confirms that he/she has been notified by the Company of the inclusion of his/her personal data in the Employees personal database and of his/her rights under Article 8 of the Law of Ukraine No. 2297-VI of 01.06.2010 "On Personal Data Protection" (as amended) in connection with the processing of his/her personal data in this database.
By entering into legal relations with the Company, an employee, as a subject of personal data, agrees to the storage of his or her personal data by the Company for the period determined in accordance with the Company's internal documents and the current legislation of Ukraine.
The employee confirms that he/she has been notified of the composition and content of personal data collected by the Company about him/her, which is contained in the primary sources of information about the participant, in particular, in documents issued in his/her name, documents signed by him/her, information provided by the employee to the Company about himself/herself.
The employee also confirms that he/she has been notified by the Company that the Company may take photographs and video surveillance, record telephone conversations, as well as record contacts in the premises and communication channels of the Company, in order to ensure the safety and legitimate interests of the employee and the Company. The Company shall have the right to keep video recordings and photographs in the future, as well as to distribute them in cases provided for by the employee's authorizations (consents) and the current legislation of Ukraine. Video recordings, photographs and recordings of telephone conversations may be used as evidence in legal proceedings.
If an employee of the Company has the status of a non-resident of Ukraine, the employee hereby confirms that there are no contractual restrictions or restrictions established by the law of the country of the personal data subject, or other restrictions that would make it impossible to transfer, receive and process his or her personal data under the terms of this Regulation.
2.7. Special requirements for the processing of personal data.
The Company processes personal data to which special processing requirements apply. Such personal data include: data on conviction to a criminal penalty, data relating to the health and biometric data of the personal data subject.
The Company processes personal data subject to special processing requirements on the basis of the personal data subject's unequivocal consent to the processing of such data and, in some cases, on the grounds provided for by the Law.
2.8. Notification of personal data processing
To comply with the provisions of the Law, the Company shall notify the Commissioner of the processing of personal data that poses a particular risk to the rights and freedoms of personal data subjects within thirty (30) business days from the date of commencement of such processing.
The types of personal data processing that pose a particular risk to the rights and freedoms of personal data subjects and the categories of subjects subject to the notification requirement are determined by the Commissioner.
The Company shall submit a notice of personal data processing in the form and in the manner prescribed by the Commissioner.
2.8.1 Notification of changes in the information to be reported
The company, upon request to comply with the provisions of the Law, also undertakes to notify the Commissioner of each change in the information subject to notification within ten (10) business days from the date of such change.
3. Term, conditions of storage and destruction of personal data by the Company.
Personal data is stored for no longer than necessary in accordance with the purpose of its processing, unless otherwise provided by the legislation in the field of archival and record keeping. 
Personal data on paper is stored under the following conditions:
− the room in which the paper carriers with personal data are placed is located in the premises rented by the Company and operating at the specified address, or in the premises of a person authorized to store the relevant data (lawyers' associations, banking or archival institutions);
− The premises are located in a capital building of the second degree of fire resistance;
− doorways are equipped with metal doors with a locking device;
− window openings are equipped with bars;
− The premises are equipped with surveillance cameras and fire alarms
Personal data is stored electronically under the following conditions:
− in the HR and accounting computer programs located in the premises of the relevant unit;
− computers containing personal data are password protected, do not have connections to the international electronic network Internet, and are protected by anti-virus software;
− access to computers containing personal data shall be granted only to employees whose job duties include processing personal data of the relevant category to perform their professional or official duties or employment.
Personal data is deleted or destroyed in accordance with the procedure established in accordance with the requirements of the Law.
The selection for destruction of documents with personal data whose storage periods have expired is made by an expert committee.
Personal data shall be destroyed in a manner that excludes the possibility of further recovery of such personal data.
4. The procedure for access to personal data
All personal data, except for depersonalized personal data owned by the Company, is classified as restricted information by access mode.
4.1 Access of the Company's employees
The Company shall keep records of employees who have access to personal data of subjects. The Company determines the level of access of these employees to the personal data of the subjects. Each of these employees shall have access only to the personal data (or a part thereof) of the subjects that is necessary for them in connection with the performance of their professional, official or employment duties.
All other employees of the Company have the right to full information only regarding their own personal data.
Employees who have access to personal data shall give a written undertaking not to disclose personal data entrusted to them or which they have become aware of in connection with the performance of their professional or official duties or employment.
The date of granting the right of access to personal data is the date of the obligation by the relevant employee.
The date of deprivation of the right of access to personal data is the date of dismissal of the employee, the date of transfer to a position whose duties are not related to the processing of personal data.
In the event of dismissal of an employee who had access to personal data or transfer to another position that does not involve work with personal data of subjects, measures shall be taken to prevent such person's access to personal data, and documents and other media containing personal data of subjects shall be transferred to another employee.
4.2. Access of personal data subjects.
Access of an individual whose personal data is processed by the Company shall be granted in accordance with the procedure provided for by the legislation of Ukraine and internal documents of the Company, based on a written request of an individual - the subject of personal data. The request shall contain the following information: surname, name and patronymic, place of residence (place of stay) and details of the document certifying the individual submitting the request.
The personal data subject's access to data about himself/herself is free of charge.
4.3. Access of third parties
This provision provides for the possibility of access to personal data of third parties based on the consent of the personal data subject provided to the Company for the processing of such personal data, or (in some cases) in accordance with the requirements of the Law.
Access to personal data shall not be granted to a third party if the said person refuses to undertake obligations to ensure compliance with the requirements of the Law or is unable to ensure them.
To obtain access to personal data, the subject of relations related to personal data shall submit a request to the Company, which shall specify the following:
− surname, 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, name and patronymic of the person certifying the request; confirmation that the content of the request corresponds to the powers of the legal entity (for the legal entity - applicant);
− surname, name, and patronymic, as well as other information that allows to identify the individual in respect of whom the request is made;
− information about the personal data base in respect of which the request is made, or information about the owner or manager of personal data;
− a list of requested personal data;
− the purpose and/or legal basis for the request.
The Company shall review the request for its satisfaction within ten (10) business days from the date of its receipt.
Within this period, the Company shall notify the person submitting the request that the request will be granted or the relevant personal data will not be provided, indicating the reason.
The request shall be satisfied within thirty (30) calendar days from the date of its receipt, unless otherwise provided by the Law.
It is allowed to postpone access to personal data of third parties if the necessary data cannot be provided by the Company within thirty (30) calendar days from the date of receipt of the request. In this case, the total period for resolving the issues raised in the request may not exceed 45 (forty-five) calendar days.
In the notice of postponement, the Company shall indicate:
1) surname, name and patronymic of the official;
2) the date of sending the message;
3) the reason for the delay;
4) the time period within which the request will be granted.
Denial of access to personal data is permitted if access to such data is prohibited by law. In the notice of refusal, the Company shall state:
− name, surname, patronymic of the official who denies access;
− date of sending the message;
− the reason for the refusal.
5. Protection of personal data
The Company is equipped with system, software, hardware and communication facilities and takes all necessary measures to ensure the protection of personal data at all stages of its processing, including through organizational and technical measures to prevent loss, theft, unauthorized destruction, unlawful processing or access to personal data.
Organizational measures include:
− determining the procedure for access to personal data of the Company's employees;
− determining the procedure for keeping records of operations related to the processing of the subject's personal data and access to them;
− development of an action plan in case of unauthorized access to personal data, damage to technical equipment, or emergencies;
− regular training of employees who work with personal data.
The Company shall keep records of employees who have access to personal data of subjects. The Company determines the level of access of these employees to the personal data of the subjects. Each of these employees shall have access only to the personal data (or a part thereof) of the subjects that is necessary for them in connection with the performance of their professional, official or employment duties. Employees who have access to personal data shall give a written undertaking not to disclose personal data entrusted to them or which they have become aware of in connection with the performance of their professional, official or employment duties. This written obligation defines the level of responsibility of employees who have access to personal data. Employees who have access to personal data, including those who process it, shall be liable in accordance with the laws of Ukraine in case of violation of the Law.
The Company also appoints a responsible person who organizes the work related to the protection of personal data during their processing in accordance with the Law. The responsible person shall be appointed by order of the Company's Head. The responsibilities of the responsible person for organizing work related to the protection of personal data during their processing shall be specified in the job description. Information about the said responsible person shall be reported to the Commissioner, who shall ensure its disclosure.
The responsible person is obliged to:
− know the legislation of Ukraine in the field of personal data protection;
− develop procedures for access to personal data of employees, in accordance with their job responsibilities;
− Ensure that the Company's employees comply with the requirements of Ukrainian legislation in the field of personal data protection and the Company's internal documents regulating the Company's activities related to the processing and protection of personal data;
− notify the Company's management of the facts of violations by employees of the requirements of the legislation of Ukraine in the field of personal data protection and internal documents governing the Company's activities in relation to the processing and protection of personal data within one business day from the date of detection of violations;
− ensure the storage of documents confirming that the personal data subject has provided consent to the processing of his or her personal data and notified the said subject of his or her rights
In order to fulfill his/her duties, the responsible person has the right to:
− Receive from the Company's employees the necessary documents, including orders and other administrative documents issued by the Company's manager, related to the processing of personal data;
− make copies of the received documents;
− access to all premises and documents of the Company;
− Participate in discussions on the organization of work related to the protection of personal data during their processing;
− to submit proposals for the Company's CEO to improve the Company's activities and work methods, to submit comments on the Company's activities and options for eliminating identified shortcomings in the process of personal data processing
− sign and visa documents within his/her competence
The Company keeps records of operations related to the processing of personal data of the subject and access to them. For this purpose, the Company keeps information about: 
− date, time and source of collection of the subject's personal data;
− change of personal data;
− viewing personal data;
− any transfer (copying) of the subject's personal data;
− date and time of deletion or destruction of personal data;
− an employee who performed one of the above transactions;
− the purpose and grounds for changing, reviewing, transferring and deleting or destroying personal data.
The Company independently determines the procedure for storing information on operations related to the processing of personal data of the subject and access to them. In the case of processing personal data of subjects using an automated system, such system automatically records the specified information. This information shall be stored by the Company for one year from the end of the year in which the said operations were performed, unless otherwise provided by the legislation of Ukraine.
In order to ensure the security of personal data processing, the Company also takes special technical protection measures, including to prevent unauthorized access to personal data processed and the operation of the hardware and software system used to process personal data.
6. Liability for violation of the procedure for processing personal data
Violation of the legislation on personal data protection and non-compliance with the requirements of this Regulation shall entail liability established by the regulatory legal acts and internal documents of the Company.
7. Validity of the Notice
This Regulation has been announced by the Company based on the requirements of the current legislation of Ukraine.
Amendments to this Regulation by the Company will require re-obtaining consent from personal data subjects whose consent was obtained with reference to the previous version of the Regulation, if such changes will narrow the rights of the subjects compared to the previous version. In order to obtain consent from personal data subjects, the Company shall publicly announce the new version of the Regulation by re-posting it on the Company's website. The personal data subject shall decide on the impact of the new version of the Regulation on the validity of the consent provided by him/her independently. Consent to the application of the terms of the new version of the Regulation from subjects whose consent must be obtained by the Company again shall be deemed to be granted by them if the Company has not received written objections from them within thirty (30) calendar days from the date of announcement of the new version of the Regulation. For the subjects whose rights have been narrowed and who have submitted written objections before the expiration of the period established for settlement, the version of the Regulations that was applied in the previous case of obtaining their consent shall be deemed effective.