Raben logo

Privacy

policy

I. INTRODUCTION

Protection of personal data and information security has always been a priority for Raben Group. Raben Group is a responsible organization that understands that information has specific value and is a resource that requires appropriate protection. It is important for us to keep you informed about the processing of personal data.  The document provides key information on legal basis for personal data processing, the methods of collection and use of personal data as well as information on the rights of users of our website.

Personal data is an information or a collection of information about an individual who is or may be specifically identified. It is any information or part of information that can identify you directly (e.g. your name) or indirectly (e.g. through anonymous data such as a unique identification number). This means that personal data includes e-mail/home address/mobile phone number, logins, profile photos, personal preferences, user content, financial information, etc. It may also include unique numeric identifiers such as the IP-address of your computer or the MAC-address of your mobile device as well as cookies.

Before submitting any data to us or otherwise viewing our website, you should read the full text of this Privacy Policy to ensure that you are satisfied with our practices of information collection and privacy issues. We also reserve the right to make changes to this Privacy Policy in our sole discretion without any prior notice. Therefore, we ask the users to review these terms of use before each visit to the website and to take into account any changes and/or additions. This Policy does not apply to websites that are navigated to by hyperlinks located on website of RABEN UKRAINE LLC.

This website and the information provided therein are not intended or approved for use in the United States or the European Union, or by the United States or European Union citizens or residents. We recommend that you use the website of Raben Management Services Sp. or its affiliated companies in the European Union.

II. RABEN GROUP

In the understanding of this Policy, Raben Group companies are:  

  • Raben Group N.V. with the registered office in Oss in the Netherlands, Raben Group Intellectual Properties B.V. with the registered office in Oss in the Netherlands, or Cougar Investments Holding B.V. with the registered office in Oss in the Netherlands, as well as
  • each company seated both in Poland and abroad in relation to which Raben Group N.V., Raben Group Intellectual Properties B.V. or Cougar Investments Holding B.V. (separately or jointly) is the “dominant entity” in the understanding of the Polish Accounting Act dated September 29, 1994, (consolidated text from Journal of Law 2009, No. 152, item 1223).

In the understanding of this Policy Raben Group companies are also companies which will be established in the future and which will meet at least one of the conditions stipulated in point 1) or point 2).  

For the purposes of understanding of this section, RABEN UKRAINE LLC is part of Raben Group.

III. PRIVACY POLICY

This Privacy Policy applies to all cases where Raben Group administers and processes personal data. This applies in cases where we process personal data obtained directly from the data subject and in cases where we have received personal data from other sources. Raben Group complies with its disclosure obligations under the law.

Name of the responsible entity in Ukraine: RABEN UKRAINE LLC.

Address of the responsible entity: 150 Brovarska str., Velyka Dymerka, Brovarskii district, Kyiv region, 07442, Ukraine.

IV. SCOPE OF APPLICATION, METHODS AND TASKS OF DATA PROCESSING

We want to maintain transparency regarding the methods and legal grounds for processing personal data as well as the purposes for which we process personal data. In order to make our explanation of these issues as clear as possible, below we present a list of transactions for the processing of personal data.

At the same time, each time we process personal data based on the legitimate interests of the data administrator/responsible person we try to analyze and balance our interest and potential impact on the data subject (positive and negative) and the rights of that person. We do not process personal data when we conclude that the impact on the data subject is in our best interest, unless we have another legal basis, e.g. if we have the appropriate consent or if the law requires or allows it.

V.1. Processing personal data of people visiting the website of RABEN UKRAINE LLC or people using services provided electronically.

1. BASIC INFORMATION

Individuals who visit our website or use the services provided by us electronically have control over the personal data they provide to us, but we guarantee that the collection and use of user information is limited to the minimum necessary to provide them with the services.

RABEN UKRAINE LLC uses personal data primarily to ensure functioning of this website. Any further processing of data is carried out on the basis of other duties or permits established by law or if the respective user has given the consent to RABEN UKRAINE LLC.

You can contact RABEN UKRAINE LLC through social networks such as Facebook or LinkedIn, or partner sites. If you initiate such a process, for example, by liking a post on Facebook, you allow Facebook to provide us with information from your Facebook profile. In any case, when you submit information to social network, you should check its privacy policy and tools. RABEN UKRAINE LLC is not responsible for the privacy measures of third-party websites and social networks.

We may share your information with third parties or Raben Group companies for marketing or analytical purposes. In this context, your data is processed by a third party acting as the data controller that applies its own terms of use and privacy policy.

We may disclose your data to our partners if:

  • the service you requested is jointly developed by RABEN UKRAINE LLC and its partner. RABEN UKRAINE LLC and its partner process your data separately for their own purposes. Such data will be processed by: 1) RABEN UKRAINE LLC according to this Policy; 2) the Partner who acts as data controller according to the terms of its own privacy policy;
  • we may publish content from social media. In the event that you use social media content on our site, a cookie from that social network may be stored on your device. We encourage you to review the cookie policy of these social networks for more information.

We may also disclose your information in the following cases:

  • in legal proceedings or law enforcement investigations;
  • blogs and online posts, reviews. We may allow users to share comments, messages, feedback and other information. If you send us such information, it may be disclosed to the public. Such information may be read, collected and used by others who have access to it.

2. LOG FILES

Each time you access the website, our system automatically collects data and information from your computer system and opens a page. The following data is downloaded:

  • information about the type and version of browser;
  • user’s operating system;
  • user’s IP address;
  • date and time the page was accessed;
  • sites from which the user’s system has accessed our website (so-called reference);
  • websites that were called by the user system through our website.

Data is also stored in our system files. Data is not stored together with the personal data of another user. Based on this data, the person cannot be identified, since the IP-address is only available in hidden forms. The data provided are also stored and processed in the log file for error analysis and for statistical purposes.

Temporary storage of IP-address system is necessary in order to provide access to a website with user’s computer. To do this, the IP-address of the user must be stored for the duration of the session. Saving log files is aimed to ensure the functionality of the website. In addition, the data is used to optimize the website and ensure the security of our IT systems. Therefore, no data analysis is performed for marketing purposes.

3. CONTACT FORM

Creation and management of contact forms is a result of information collected when filling out the form on website. This data may include:

  • first and last name;
  • company's name;
  • telephone number;
  • e-mail.

You may provide your contact details by filling in the contact form on our website. We will use your details to respond to your request.

The processing and use of your data is based on legal provisions that justify these operations on the basis that processing is necessary to respond to your request.

If you have not given your consent for a longer storage period, e.g. during our customer relationship management, we will store your data for as long as is necessary to fulfil the above purpose or as long as required by the statutory provisions.

You can change or update your personal data by sending an e-mail to: Marketing-PR.ukraine@raben-group.com.

4. DATA RETENTION PERIOD

We store your data as long as necessary for the purposes for which we store your data in order to meet your needs or in accordance with your obligations. We use the following criteria in determining retention periods:

  • When you refer a question to us, we keep your data for as long as it is necessary to process your question;
  • When you send us a contact form, we will retain your data until you make a request to delete your data or after a period of inactivity as defined in the individual provisions;
  • When you have subscribed to a newsletter until you unsubscribe from such a newsletter or request a data deletion;
  • If cookies are stored on your computer, we will hold them for as long as necessary to achieve our purposes (for example, for the duration of a session identifier) and for a period determined by local law;
  • When we no longer need to use your data, it will be removed from our systems and records or anonymized, which will no longer identify you.

5. OPPOSITIONS TO DATA COLLECTION

When you voluntarily register on our website, we add your name and e-mail to our mailing list. If you do not wish to receive our e-mails, you can request to be removed from our mailing list or database by sending an e-mail to: Marketing-PR.ukraine@raben-group.com.  If you do not want to receive messages from us, you can write an e-mail to: Marketing-PR.ukraine@raben-group.com.

6. YOUR RIGHTS AS A SUBJECT OF PERSONAL DATA

You can claim the right to access the data at any time. You may also claim such rights provided that you comply with the relevant requirements:

  • The right to receive information on how we use your data;
  • The right of access to personal information that we store about you;
  • The right to update your data;
  • The right to delete data;
  • The right to restrict data processing;
  • The right to file a complaint with the competent authority.

7. SAFETY MEASURES

We are committed to the safe storage of your data and use all measures to do so. We always do our best to protect your personal data and once we have received your data we use strict procedures and security features to prevent unauthorised access.

We have administrative, technical and physical measures in place to protect the data you provide against accidental, illegal or unauthorized access, destruction, loss, alteration, disclosure or use.

Because the transmission of information over the Internet is not completely secure we cannot guarantee the security of your data transmitted to our site. Therefore, any transmission is at your own risk.

8. COOKIES

To a limited extent, we may automatically collect personal information through cookies placed on our websites. A cookie is a small piece of IT data stored on a computer, tablet or smartphone that is intended for use on websites. Cookies typically contain the name of the page from which they originate, the time they are stored on the end device and a unique set of key attributes.

Cookies are used for purposes:

  • customisation of websites to suit your preferences and optimise your use of websites;
  • personalisation of content, displayed for a specific website user;
  • creating statistics, explaining how to use websites, thus improving their structure and content [so-called content];
  • maintaining a user session (after logging in), which allows you to skip the log in to each sub-page of the website;
  • optimizing the advertising and marketing offer for a particular user of the website.

There are three main types of cookies: “session”, “permanent” and “external”.

Session cookies are temporary files stored on user’s computer, tablet or smartphone until the user logs out, leaves the site or closes the browser. This type of cookies is used to support services that require authentication at a particular website.

Permanent cookies are stored on your computer, tablet or smartphone for the time specified in the cookie settings or until they are deleted by the user. This type of cookies is used to remember the settings selected by the user and personalize the interface.

External cookies (also known as third party cookies) collect information about how to use websites and provide users with promotional content that is optimally tailored to the interests of individual users.

Personal data collected with the help of cookies are encrypted to prevent access by unsuitable and unauthorised parties. It is only collected to perform certain functions for the user.

Raben Group informs you that most web browsers contain settings that allow you to accept cookies by default. If you do not agree to monitor your website activity, you can disable cookies in your browser at any time. In addition, you have the right and opportunity to adjust cookie settings in your browser that will automatically block their use.

Using our website without the use of cookies is possible, however, in certain situations this may lead to some limitations in page functionality.

Detailed information about the possibilities and methods of processing cookies is available in the software settings, i.e. the web browser.

We use Google Analytics, a network analysis service of Google Inc. to analyze user behaviour (“Google”).

Google Analytics uses cookies which are stored on your computer to analyse how you use the website. The cookies used by Google Analytics may be temporary or permanent cookies which are typically valid for a maximum of two years. The information generated by the cookie about your use of the website is usually transmitted to and stored by Google on servers in the United States.

By activating IP anonymization, your IP-address is shortened in member states of the European Union or in other countries that are party to the agreement on the European Economic Area before being transferred to a Google server in the USA. Only in exceptional cases over which we have no control the complete IP address will be transmitted to a Google server in the USA and shortened there. As part of our order, Google will use the above information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to the website and internet usage. The IP-address provided by your browser as part of Google Analytics is not compatible with other data held by Google.

We would like to point out that you can prevent the registration and transmission of the data generated by the cookie (Google) in respect of the use of the website (including your IP-address) in Google as well as the processing of this data by Google, if you download and install the browser plugin located at: tools.google.com/dlpage/gaoptout.

9. CONTACT INFORMATION

If you have any questions or concerns about the processing or use of your personal data, or you wish to use one of your rights, please contact us via e-mail: Marketing-PR.ukraine@raben-group.com or by writing to us (RABEN UKRAINE LLC) at the address: 150 Brovarska str., Velyka Dymerka, Brovarskii district, Kyiv region, 07442, Ukraine,  please make a note “for the attention of the marketing department”.