In order to understand how your data will be processed, we will first explain the terms used in this Policy:
- Personal data: any information which is related to an identified or identifiable natural person (including information about you);
- Personal data subject: an identified or identifiable natural person (including you) whose personal data is processed by the data controller responsible for processing it;
- Personal data processing: any operation or set of operations performed in relation to personal data or a set of personal data, whether or not by (automated) information systems, such as the collection, recording, accumulation, structuring, storage, adaptation, modification, retrieval, anonymization, use, and disclosure through sharing, dissemination or making such data accessible otherwise, as well as combination, restriction or destruction of personal data;
- Restriction of data processing: the marking of stored personal data with the aim of limiting their processing in the future;
- Personal data controller: a natural or legal person (including the Association) which, alone or jointly with others, determines the purpose of the processing of personal data, data contents, and processing procedures;
- Personal data processor: a natural or legal person, which is authorized to processes personal data on behalf of the controller;
- Third party: any natural or legal person other than the data subject, controller, or processor, who, receives personal data from the controller or the processor and is authorized to process it;
- Consent of the data subject: freely and unambiguously expressed consent of a natural person to the processing of his or her personal data in accordance with the formulated processing purpose;
- IP-address: a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet.
2. What data do we collect?
When you contact us via any means of communication, including but not limited to email, fax, telephone, and social networks, fill an online form, send any files or resumes, use your personal email on the website or enter into agreements with us, we may collect your personal data, including:
- contact information (name, surname, date of birth, position, company, telephone number, fax number, email address, links to personal social media pages, etc.);
- passport details;
- photos, videos, etc.
We may also collect data that contains the domain name and the IP address as well as information about the date and duration of the Internet user’s visit to the Bel Group website. Such data is automatically collected when the user visits the website. We combine this information with other data to discover what content appeals to our visitors the most. Also, it helps us identify faulty equipment.
3. Cookies policy
4. How we use your data
The Bel Group collects your data to:
- contact you;
- send you messages containing information about news and events that we think might be of interest you;
- answer your queries, questions, and respond to your needs;
- conduct surveys and research;
- store, update, and analyze data using corporate software (CRM);
- employ (candidates);
- share information with companies that provide courier, legal, and accounting services, as well as to banks;
- manage the way you use the Website and its functionality;
- manage your account, the Bel Group websites, and improve the Bel Group web services (develop new features and offers, etc.).
Please note that in addition to the above purposes, we may also process your personal data to provide law enforcement agencies with information that is necessary for criminal proceedings, or in cases when it is required for the performance of any other legitimate duty. The purpose of such processing is to protect your vital interests as a data subject or the interests of another individual, as well as any legitimate interests of the Bel Group or third party that do not violate your fundamental rights and freedoms as a personal data subject.
A legitimate interest means the interest of the Bel Group in connection to the performance of its statutory activities. When we process your personal data for purposes that are consistent with our legitimate interests, we make sure to balance any potential impact it may have on you and your rights. Our legitimate interests do not automatically override your interests.
We process personal data for specific legitimate purposes, such as:
- contacting you;
- sending you emails about news, events, etc. that we think might be of interest you.
We may also collect data that does not relate to the natural person directly (non-personal data). We may collect, use, share, and disclose such information for any purpose. If we combine non-personal data with personal data, the combined data will be treated as personal for as long as it remains combined.
5. For how long do we store your data?
We try to make it easier for you to track the accuracy, completeness, and timeliness of your personal data. We will retain your personal information for the period necessary to fulfill the purposes set out in this Policy. When we determine the duration of such periods, we first decide whether we need to collect personal data at all. If such a need indeed exists, we only store it for the period of time necessary to achieve the purpose of data collection (for example, for the duration of your employment with the Bel Group, etc.), except when the law prescribes a longer retention period.
6. Who receives your data?
We do not disclose your personal data to companies, organizations, or persons outside the Bel Group, except for the data that belongs to:
- the employees of the Bel Group companies, which can be disclosed to postal services, email delivery services, accounting firms, restaurants, banks, payment platforms, taxi services, journalists, security companies, file-sharing services, mobile operators, and public authorities within the scope of the statutory activities of the Bel Group and its contractors (e.g., courier services);
- persons participating in events organized by or affiliated with the Bel Group, which may be disclosed to the protocol services of public authorities, administrations of buildings where the event takes places to provide free entry, and event speakers (moderators);
- the Bel Group suppliers, which may be disclosed to the Group’s companies, accounting firms, banks, etc.
Only names, email addresses, photos, and positions of persons participating in events organized by or affiliated with the Bel Group, members of the Bel Group management boards, and employees of the Bel Group companies may be published on the Bel Group website(s).
7. How we protect your data
The Bel Group takes the protection of your personal data very seriously. We protect it in various ways to maintain its confidentiality and integrity, prevent unauthorized use or disclosure, and protect your personal data from loss, misuse, unauthorized access, disclosure, modification, and destruction.
First and foremost, the Bel Group has corporate procedures that determine how employees leave their workplace when they leave the office (the clean desk policy). In addition, every Bel Group employee has a unique password to access the administrative section of the website, as well as passwords to access the local database.
Hosting and file sharing service providers protect data using encryption. Some types of data stored in a file-sharing service may be restricted for a specific user group. For instance, employees in one department cannot access data from other departments.
Premises with laptops and local servers have alarm systems and are not accessible outside working hours. To access such premises, one must always have a key and a password.
8. How can you manage your data?
You have the right to amend, delete, or access your personal data, restrict their processing, or object to the processing of your personal data. If the processing is performed with your consent, you have the right to revoke it at any time.
To exercise these rights, please contact us at:
9. Data sharing
The information we collect may be shared, stored, and processed in any country where one or more of the Bel Group companies or the third parties are located. If third parties are located outside Ukraine and the European Economic Area (EAЕ), the processing of your personal data will involve the transfer of data outside Ukraine and the EEA.
Amongst other things, we may share the personal data of employees of the Bel Group companies with the US-registered electronic mail service The Rocket Science Group LLC to send informational messages, newsletters, invitations, offers, and more.
We may also share personal data with the operator of our file-sharing service, Microsoft Corporation, registered in the United States, to store the data on it.
Data may also be shared with Google LLC via the Google Analytics platform using cookies. In this case, Google LLC acts as the data processor.
Although these countries may not have the same standards of personal data protection as yours, we will protect the personal data we share in accordance with the provisions of this Policy.