POLICY ON PERSONAL DATA PROCESSING WHEN USING THE WEBSITE OF EST LLC

To ensure proper access and use of the Website and the receipt of goods and services by Users, EST LLC shall collect and process the Personal Data of Users.

EST LLC acts as the owner and controller of the Personal Data of Users, depending on the circumstances under which such data were collected. To obtain information on who is the owner and controller of Personal Data, Users may send an enquiry to the Data Protection Representative of EST LLC using the e-mail address info@estec.com.ua (the response is provided solely in respect of the person who sent such an enquiry).

EST LLC does not collect or process Personal Data provided by individuals under the age of 16.

EST LLC does not collect or process such categories of Personal Data as data on racial or ethnic origin, political, religious or worldview convictions, membership in political parties and trade unions, criminal convictions, as well as data relating to the health, sex life, biometric or genetic data of Users (“sensitive personal data”).

EST LLC undertakes to ensure all available measures to protect the Personal Data of Users, taking into account the provisions of the current legislation on personal data protection (including the provisions of GDPR and CCPA in cases where it is applicable) and the specifics of the scope of activities of EST LLC.

Contact details

For any questions regarding Personal Data, Users may send an enquiry or complaint to the Data Protection Representative of EST LLC using the e-mail address info@estec.com.ua

Categories of Personal Data, purpose and legal grounds for their collection and processing

Depending on how Users use the Websites and what Services are requested, the scope, manner, purpose and legal grounds for the collection and processing of Personal Data by EST LLC may vary.

EST LLC collects and processes the following categories of the Personal Data of Users:

• surnames, names, patronymics of Users; e-mail addresses of Users; mobile phone numbers of Users; cities and countries of residence of Users;
• Cookies, technical data for the Website;
• other Personal Data that may be provided by Users voluntarily and on their own initiative and that cannot be deleted by EST LLC without destroying other information and/or personal data, which must be stored by the Company in accordance with legal requirements and for the protection of their rights and legitimate interests.

EST LLC also collects anonymised data, which are not personal data (EST LLC cannot identify Users on its own). Anonymised data are collected and processed in a consolidated manner and used for market research and analytics.

EST LLC collects and processes Personal Data of Website Users on the following legal grounds:

• consent to the collection and processing of personal data;
• fulfilment of the contractual obligations of EST LLC;
• compliance with legal requirements that apply to EST LLC;
• legitimate interest of EST LLC.

EST LLC collects and processes Personal Data of Website Users for the following purposes:

• to provide Users with access to the Website of EST LLC;
• to track the preferences of Users in order to provide personalised information on goods and Services of EST LLC;
• to respond to search and information requests of Users regarding the goods and Services of EST LLC;
• to ensure that Users participate in polls, promotions, loyalty programmes of EST LLC;
• to use feedback forms on the Website of EST LLC;
• to conduct market research and analyse trends to improve the goods and Services of EST LLC;
• to improve the operation of the Website of EST LLC;
• to defend against possible claims of Users within the limitation period established by law for this type of claim.

Legitimate interest of EST LLC

EST LLC also processes such category of Personal Data as the sound of the voice of the User during communication between a representative of EST LLC and such User by means of telephone. The purpose of such processing is to store the conversation with the User for further recording of the agreements reached during the telephone conversation, as well as to improve the level of service of EST LLC and protect the interests of EST LLC in case of possible claims of Users regarding the quality and subject matter of the services provided at least within the limitation period during which the User may file such a claim according to the current legislation of Ukraine.

Personal Data must be provided by Users in order to use the Website fully, as well as to receive the goods and Services of EST LLC.

The User is responsible for ensuring that the Personal Data provided by them are up to date and should provide EST LLC with appropriate notification of any changes to their Personal Data. In case the User fails to provide notification of any changes to their Personal Data, as a result of which they do not receive any communication/service etc., as they were sent in accordance with the Personal Data that were provided by the User before, the Company shall not be held liable in any manner whatsoever for such action and the communication/service shall be considered to be such that was provided properly.

EST LLC processes each category of Personal Data for a period that is necessary to fulfil each of the aforementioned purposes, after which such Personal Data shall be deleted. In any case, EST LLC is entitled to store Personal Data for a period that is necessary to fulfil its obligations to Users to provide goods and services of EST LLC, as well as to exercise the rights and fulfil the obligations provided for by the current legislation.

Rights of Users regarding Personal Data

• the right to access Personal Data;
• the right to make changes to Personal Data;
• the right to receive information on the ways of processing Personal Data;
• the right to receive information on the violation of the integrity of Personal Data;
• the right to request the transfer of Personal Data to third parties to the extent requested by Users;
• the right to request suspension of processing of Personal Data;
• the right to request deletion of Personal Data.

Users may send an enquiry or complaint regarding Personal Data to the Data Protection Representative of EST LLC using the e-mail address info@estec.com.ua Users are also entitled to apply to the competent state authorities in the field of personal data protection.

Transfer of Personal Data to third parties

EST LLC transfers Personal Data to third parties (including the cross-border transfer of Personal Data) only to the extent required to fulfil the purpose of collection and processing of Personal Data in respect of which such collection and processing were previously carried out directly by EST LLC.

EST LLC carries out such transfer of Personal Data only when necessary, to the minimum extent and for the minimum period required for that purpose.

For the purpose of proper provision of Services of EST LLC, access to relevant Websites/Mobile Apps as well as to improve the provision of such Services and access, EST LLC may transfer Personal Data:

• to partner companies of EST LLC;
• to third parties, including government authorities (if required by the law);
• to third parties in the event of legal procedures for the reorganisation of EST LLC.

By transferring the Personal Data of Users to third parties, EST LLC takes all available legal, organisational and technical measures to ensure the proper level of protection of Personal Data.