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Ukraine Global Bulgaria Czech Republic Estonia Greece Germany Austria Poland Hungary Italy Latvia Lithuania Netherlands Romania Slovakia Switzerland Turkey Ukraine I. INTRODUCTION AND SCOPE OF APPLICATION
Personal data protection and information security have always been a priority at Raben Group. Being a responsible organisation aware that information has a specific value and it constitutes a resource which requires appropriate protection, it is important for us to keep you informed about matters related to personal data processing, particularly in the light of the personal data protection regulations, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR). For this reason, this privacy policy (hereinafter referred to as the “Policy”) presents key information related to the processing of personal data by the Ukrainian company of Raben Group, i.e.:
This Policy applies to all cases in which Ukrainian company of Raben Group are controllers of data and process them. Therefore, as part of the Policy, we present both information on the processing of personal data in connection with the use of our website https://ukraine.raben-group.com/ and social media sites as well as detailed information clauses concerning processing of personal data by the Ukrainian company of Raben Group outside these channels.
In this document you will also find detailed information regarding situations when the Ukrainian company of Raben Group jointly control personal data with other companies of Raben Group (in particular the list of companies covered by joint controllership, information about the point of contact and indication of the purposes of processing covered by joint controllership).
Privacy policies for Raben Group companies having their registered office in a country other than Ukraine are located in separate tabs of the website dedicated to each country.
II. GENERAL INFORMATION
The Ukrainian company of Raben Group pay special attention to the issue of correct, lawful processing of personal data. We inform individuals about the legal basis for processing of their personal data, the ways in which they are collected and used, as well as the rights of data subjects in relation to it, through numerous communication channels, including in particular this Policy.
The Ukrainian company of Raben Group ensure transparency in the processing of personal data and report on the processing of data in a lawful and timely manner. This applies to cases where we process personal data obtained directly from the data subject, as well as cases in which we obtained personal data from other sources. As part of the detailed information clauses, we provide data subjects with the full range of information required under the provisions of Articles 13 and 14 of the GDPR.
The Ukrainian company of Raben Group ensure that data are collected only to the extent necessary to fulfil the indicated purpose and are processed only for as long as it is necessary. We strive to identify the needs for change in the area of personal data on an ongoing basis and to protect the rights and freedoms of data subjects as much as possible. In order to ensure the fairness and transparency of the processing of personal data, the Ukrainian company of Raben Group keep detailed records of the processing of personal data and, when acting as a processor, records of categories of processing activities.
When processing personal data, the Ukrainian company of Raben Group ensure their security and confidentiality and pay particular attention to the selection and verification of the technical and organisational measures used for the processing (including taking into account data protection in the design phase, conducting appropriate risk analyses and, where necessary, carrying out a data protection impact assessment). Ukrainian company of Raben Group ensures that only duly authorised persons who are obliged to keep the processed data confidential have access to the processed personal data
The Ukrainian company of Raben Group pay great attention to the appropriate selection of business partners, including taking into account the security of personal data they share with them. In the case of using the services of processors, the Ukrainian company of Raben Group carefully check whether a given provider guarantees the appropriate level of security of the entrusted personal data and verify this issue during periodic audits.
In the event that - in spite of the security measures in place - a data protection breach occurs in connection with the processing of personal data, the Ukrainian company of Raben Group will take all possible steps to identify the causes, scope and potential consequences of the breach and fulfil the resulting legal obligations, in particular those related to notifying the supervisory authority and the persons affected by the breach.
The Ukrainian company of Raben Group also pay great attention to issues related to the international transfer of personal data, including in particular the transfer of personal data to personal data processors located outside the European Economic Area (EEA).
Countries outside the EEA may not offer the same level of personal data protection as the EEA countries. Before your personal data are transferred outside the EEA, we will make every effort to ensure that such transfer does not lead to a reduction in the level of your protection guaranteed under the regulations in force in the EEA countries. If your personal data are transferred outside the EEA, the transfer will be based on an adequacy decision or on the basis of standard data protection contractual clauses adopted by the European Commission.
III. DATA PROTECTION OFFICER
The Ukrainian company of Raben Group have appointed a Data Protection Officer - Mr Vitaliy Kovalenko. He can be contacted in all matters relating to the processing of personal data and exercising the rights related to data processing:
IV. EXERCISE OF THE RIGHTS OF DATA SUBJECTS
The Ukrainian company of Raben Group pay special attention to the issues related to exercising the rights of natural persons under the GDPR.
You may request to exercise your rights under the GDPR in particular by reporting them to the Data Protection Officer using the communication channels indicated in Section III of the Policy.
If we are not able to identify the natural person on the basis of the request, we will ask the applicant for additional information. It is not compulsory to provide such data, however failure to do so will result in the request not being able to be met (and consequently being refused).
The response to the request should be provided within one month of receipt. If necessary, this time limit may be extended by a further two months, of which the data controller will inform the applicant, indicating the reasons for this action.
Where the request is made electronically, the response will be provided in the same form (unless the applicant has requested a response in another form). In other cases, a response will be given in writing. Where the timing of the request makes it impossible to respond in writing and the extent of the applicant's data allows contact to be made electronically, a response will be given in this form.
The controller handling the request will keep the information about the request and the person who made the request in order to ensure that compliance can be demonstrated and to establish, exercise or defend against possible claims by data subjects. Each request is recorded in the register of requests kept by the controller concerned. This register is kept in such a way as to ensure the integrity and confidentiality of the data contained therein.
As a data subject, you have the following rights:
the right to be informed about the processing of personal data - on this basis we provide the natural person making the request with information about the processing, including in particular the purposes and legal basis for the processing, the scope of the data stored, the entities to whom they are disclosed and the planned date of data erasure;
the right to obtain a copy of the data - on this basis we provide a copy of the processed data relating to the natural person making the request;
right to rectification - we are obliged to rectify any inconsistencies or errors in the processed personal data and to complete them if they are incomplete;
the right to data erasure - on this basis, you may request the erasure of data the processing of which is no longer necessary for the fulfilment of any of the purposes for which they were collected;
the right to restrict processing - where such a request is made, we will cease to carry out operations on the personal data - with the exception of those operations to which the data subject has consented and the storage of the data, in accordance with the adopted retention rules - or until the reasons for restricting the processing cease to exist (e.g. a decision is made by the supervisory authority authorising further processing);
the right to data portability - on this basis, insofar as the data are processed by automated means in connection with a concluded agreement or granted consent, we will release the data provided by the data subject in a computer-readable format. It is also possible to request that these data be sent to another entity, provided, however, that the technical capacity exists for this on both our part and that of the designated entity;
the right to object to processing for marketing purposes - you may object to the processing of your personal data for marketing purposes at any time without having to justify your objection;
the right to object to other purposes of processing - you may object at any time - on grounds relating to your particular situation - to the processing of personal data that is carried out on the basis of our legitimate interests (e.g. for analytical or statistical purposes or for reasons relating to the protection of property); an objection in this respect should contain a justification;
the right to revoke consent - if your data are processed on the basis of your consent, you have the right to revoke it at any time, which does not, however, affect the lawfulness of the processing carried out before its revocation;
the right to lodge a complaint - in case you consider that the processing of your personal data breaches the provisions of the GDPR or other regulations concerning personal data protection, you may lodge a complaint with the authority supervising the processing of personal data, which for the Ukrainian company of Raben Group, this is the Office of the Ukrainian Parliament Commissioner for Human Rights with a registered office in Kyiv, 21/8 Instytutska St., 01008.
V. JOINT CONTROLLERSHIP OF PERSONAL DATA
In order to achieve their business objectives and ensure the highest standards of provided services, Raben Group companies may process personal data not only as independent controllers, but also as joint controllers based on a joint controller agreement concluded pursuant to Article 26(1) and (2) of the GDPR, specifying in particular the purposes of such processing
Raben Group companies, acting as Joint Controllers, jointly determine the purposes and means of processing personal data.
1. List of Joint Controller
The parties to the joint controller agreement concluded by Raben Group companies are the following companies (hereinafter referred to as the “Joint Controllers”):
2. Point of contact
The main point of contact for data subjects in all matters related to joint controllership is the Data Protection Officer of the Ukrainian company of Raben Group, who can be contacted:
In addition, data subjects may, at their own discretion, contact any of the Joint Controllers directly through the communication channels indicated in point 1 above (postal address/e-mail address).
3. List of purposes of processing covered by joint controllership
Raben Group companies listed in section 1 above jointly control personal data in the following processes in pursuit of the jointly agreed objectives indicated below:
| Process | Goal | Joint Controllers |
| Recruitment - creating databases of job applicants | Conducting the recruitment process and creating a database of job applicants | RABEN UKRAINE LLC |
| Recruitment - selection of job applicants (decision-making process) | Conducting the recruitment process | RABEN UKRAINE LLC jointly controls data with each individual Joint Controller (for key positions) |
| Recruitment - acceptance/selection of job applicants for employment by RABEN UKRAINE LLC | Conducting the recruitment process | RABEN UKRAINE LLC jointly controls data with each individual Joint Controller (for key positions) |
| Recruitment - future recruitments | Creating a database of job applicants | RABEN UKRAINE LLC jointly control the data |
| Employment - access to employee data of Raben Group companies | Human resources management according to the Group standard | RABEN UKRAINE LLC. jointly controls data with each individual Joint Controller (with respect to remuneration data) |
| Employment - access to employee data of Raben Group companies | Sharing a database for internal recruitment | RABEN UKRAINE LLC jointly control the data |
| Archiving - setting archiving rules - scope, retention, access rights | Ensuring the security of the archived data and the compliance of the archiving process with regulations | RABEN UKRAINE LLC jointly controls the data with each individual Joint Controller |
| Customer service (returns/claims) - support in the claims handling process and decision-making in claims procedures | Undertaking actions necessary for the conduct and completion of the claims handling process | RABEN UKRAINE LLC jointly controls the data with each individual Joint Controller |
| Customer service - Track & Trace | Taking the necessary measures for the correct execution of deliveries (information on the status of the shipment) | RABEN UKRAINE LLC and Joint Controllers to the extent that they provide services to customers |
| Customer service - running the Subscription Centre | Management of information on customer consents (maintaining correct communication with customers) | RABEN UKRAINE LLC and Joint Controllers to the extent that they provide services to customers |
| Customer service - service quality surveys | Satisfaction survey on the provided services | RABEN UKRAINE LLC and Joint Controllers to the extent that they provide services to customers |
| Customer service - enquiries | Taking the necessary steps to conclude the agreement | RABEN UKRAINE LLC and Joint Controllers to the extent that they provide services to customers |
| Customer service - operating forms on websites (for customer service and sale of services) | Communication with customers and potential customers | RABEN UKRAINE LLC and Joint Controllers to the extent that they provide services to customers |
| Sale of services | Undertaking activities aimed at selling services provided by Raben Group companies | RABEN UKRAINE LLC and Joint Controllers to the extent that they provide services to customers |
| Customer service | Performance of concluded agreement | RABEN UKRAINE LLCand Joint Controllers to the extent that they provide services to customers |
| Document flow - transfer of data and financial documents | Maintaining the integrity of the accounting system and meeting legal obligations | RABEN UKRAINE LLCwith each individual Joint Controller (with respect to certain quota thresholds resulting from Corporate Governance) |
| Cybersecurity - security tests | Ensuring IT security | RABEN UKRAINE LLC jointly controls the data with each individual Joint Controller |
| Cybersecurity - cybersecurity incident management | Identification and resolution of security incidents | RABEN UKRAINE LLC jointly controls the data with each individual Joint Controller |
| Helpdesk - with respect to software bugs/errors | Troubleshooting the software in use | RABEN UKRAINE LLC jointly controls the data with each individual Joint Controller |
| Physical security - theft prevention | Ensuring security of goods | RABEN UKRAINE LLC jointly controls the data with each individual Joint Controller |
| Internet marketing - running FP on social media | Building Raben Group's image, promotion of the provided services | RABEN UKRAINE LLC with each individual Joint Controller who runs a separate social media profile |
| Internet marketing - organizing competitions on social media | Building Raben Group's image, promotion of the provided services | RABEN UKRAINE LLC with the company or companies organising the competition in question |
| Internet marketing - newsletter (subscription and content preparation) | Building Raben Group's image, promotion of the provided services | RABEN UKRAINE LLC jointly controls the data with each individual Joint Controller |
| Internet marketing - personalisation of offers and profiling | Building Raben Group's image, promotion of the provided services | RABEN UKRAINE LLC jointly controls the data with each individual Joint Controller |
| Occupational health and safety - activities concerning safety incidents | Prevention and management of health and safety incidents | RABEN UKRAINE LLC with each individual Joint Controller (with respect to more serious incidents) |
| Occupational health and safety - reporting safety incidents within the Group | Prevention and management of health and safety incidents | RABEN UKRAINE LLC with each individual Joint Controller (with respect to more serious incidents) |
| Legal services | Support in reviewing agreements, participation in negotiations, support in concluding agreements, support in claims processes and other activities related to legal security of Raben Group companies | RABEN UKRAINE LLC jointly controls the data with each individual Joint Controller |
| Cooperation with banks | Execution of transactions and other issues related to the conduct of activities before banks with which Raben Group companies cooperate | RABEN UKRAINE LLC jointly controls the data with each individual Joint Controller |
| Activities of the “managing company” | Other issues related to the direction of activities of Raben Group companies | RABEN UKRAINE LLC jointly controls the data with each individual Joint Controller |
4. Essential content of the arrangements between the Joint Controllers
In fulfilment of the obligation set out in the provision of Article 26(2) of the GDPR, below we set out the essential content of the arrangements between the Joint Controllers made under the joint controller agreement:
VI.PROCESSING OF PERSONAL DATA BY A UKRAINIAN COMPANY OF RABEN GROUP IN CONNECTION WITH THE OPERATION OF THE WEBSITE AND SOCIAL NETWORKS
1. Introduction
In order to comply with the information obligations imposed on us, below we set out the key issues relating to our processing of the personal data of the users of the website https://ukraine.raben-group.com/ (hereinafter referred to as the “Website”) as well as social media sites.
Information about the processing of personal data via websites by Raben Group companies having their registered office in a country other than Ukraine is located in separate tabs of the website dedicated to each country.
Natural persons who visit the Website or social media sites, or communicate about services through these channels, are in control of the personal information they provide to us, while we ensure that we limit the collection and use of your information to the minimum necessary to provide you with the level of service you expect.
We use technology on our websites to automatically collect and analyse, purely anonymously, information about user activity on the websites. Read more HERE.
To a limited extent, we may collect personal data automatically via cookies and other technologies on our websites. Detailed information on the collection and use of cookies is available in our cookie policy, which can be found HERE
Our Website offers various possibilities of contacting us. Apart from contact forms, we also use application forms used to commence employment and cooperation, as well as notification forms and subscriptions to our newsletter. The use of the aforementioned forms usually requires you to provide your personal data. These data are processed for the purposes and in accordance with the legal basis referred to in the communications accompanying these forms.
2. Joint controllership of personal data by the companies of Raben Group in connection with the operations of the Website and social networks
The Ukrainian company of Raben Group jointly control the personal data processed via the Website and social media sites together with the Raben Group companies indicated in the content of section V. point 2. for the following purposes:
related to the handling of contact forms used for the sale of services and customer service,
managing the consents granted as part of our Subscription Centre, i.e. a tool for handling consents grated by natural persons,
personalising communications and profile offers on the basis of the information aggregated in the customer service, sales and marketing processes in conjunction with the relevant data from cookie files and other technologies,
performing the newsletter service,
providing customers and transport participants with information on the current status of the shipment as part of the Track &Trace service,
operating social media sites, including the organisation of competitions through them.
To the remaining extent, Ukrainian company of Raben Group is an independent controller of personal data processed via the Website.
Notwithstanding the above:
Raben Group companies and Facebook are the joint controllers of the data of users who have liked the fanpage of Raben Group companies. Facebook as the brand owner of Instagram, also jointly controls the data of persons who follow the fanpage of Raben Group companies on Instagram;
Raben Group companies and YouTube are the joint controllers of the data of users who have liked the fanpage of Raben Group companies.
Raben Group companies together with LinkedIn are the joint controllers of user data.
3. Data Protection Officer
For all matters relating to the processing of your personal data through the Website and social media sites and the exercise of your rights in relation to data processing, you can contact our Data Protection Officer through the following communication channels:
by directing inquiries to the postal address: RABEN UKRAINE LLC, 150 Brovarska St., Brovarsky district, Brovarsky village, Kyiv region, 07442, Ukraine, marked “personal data protection”;
by directing inquiries to the e-mail address: vitaliy.kovalenko@raben-group.com
4. Data recipients and data transfer to third countries
Your data are shared with the providers of the services we use (e.g. maintenance of websites, social media sites, IT systems, sending newsletters).
Your personal data may be transferred to data processors established outside the European Economic Area (EEA).
Countries outside the EEA may not offer the same level of personal data protection as the EEA countries. Before your personal data are transferred outside the EEA, Raben Group will make every effort to ensure that such transfer does not lead to a reduction in the level of your protection guaranteed under the regulations in force in the EEA countries. If your personal data are transferred outside the EEA, their transfer will be based on an adequacy decision or standard data protection contractual clauses adopted by the European Commission. You may also request additional information with regard to the transfer of the data outside the EEA by contacting us as described in point 3.
5. Your rights and profiling
The joint controllership of personal data under the provision Article 26(1) of the GDPR does not affect the exercise of your rights under the GDPR. As agreed between the Joint Controllers, each Joint Controller is the entity responsible for the processing of personal data in accordance with the GDPR.
You have the right to request access to your personal data, their rectification, erasure or restriction of processing, or to object to processing as well as the right to data portability. If the data are processed on the basis of a consent, you have the right to revoke your consent at any time without affecting the lawfulness of the processing conducted on the basis of the aforementioned consent prior to its revocation.
The companies will verify your requests, demands or objections in accordance with applicable data protection legislation. In response to your request, the Companies may ask you to verify your identity, to provide information that will help the Companies better understand the request. The Companies will make every effort to justify their decision to you if your requests are not met.
At the same time, please be advised that you have the right to lodge a complaint with the supervisory authority competent for the Raben Group Company running the Website and communication with you. For the Polish companies of Raben Group, the competent authority in this respect is the the Office of the Ukrainian Parliament Commissioner for Human Rights with a registered office in Kyiv, 21/8 Instytutska St., 01008.
Your personal data may be processed by automated means (including profiling), however in this case this will not have any legal effect on you or similarly materially affect your situation. The profiling of personal data in this case consists of the processing of your data (including by automated means) to evaluate certain information about you, including aggregated customer service data, website traffic analysis, statistics, predicted interests and personal preferences for the marketing of our services.
You have the right to object at any time - on grounds relating to your particular situation - to profiling based on Article 6(1)(f) of the GDPR. In that case, we can no longer process these personal data unless we can demonstrate the existence of compelling legitimate grounds for processing that override your interests, rights and freedoms or grounds for establishing, exercising or defending against claims.
6. Processing of personal data of visitors to the website https://ukraine.raben-group.com/
6.1. Purpose of data processing
The activity of Website users, including their personal data, is recorded using cookies and other technologies and is processed for the purpose of personalising and profiling marketing communications. You can find more information about this in our cookie policy HERE.
6.2. Legal basis for data processing
The legal basis for the processing of personal data via the Website is the legitimate interest of each controller (Article 6(1)(f) of the GDPR), consisting of the need to ensure that the users of the Website have access to the content and communication published therein through the channels available through the Service and to keep statistics in order to improve the functionality of the Service.
6.3. Duration of data processing
Where data are processed on the basis of a legitimate interest, the data will be processed for a period allowing the fulfilment of that interest or until an effective objection to the processing is raised. In the case of installed cookies, their processing time is determined by the period set for each cookie or until you revoke your consent.
6.4. Obligation to provide data
The provision of data is voluntary, however necessary for the uninterrupted and fully correct use of the Website's functionalities.
7. Processing of personal data of visitors to social media sites operated by the Ukrainian company of Raben Group
7.1. Purpose of data processing
The Ukrainian company of Raben Group process personal data of users visiting Raben Group profiles related to the Website operated in social media (Facebook, Instagram, Yotube, LinkedIn). Data shared directly on social media is processed in connection with the operation of the profile, including to inform users about Raben Group activities and to promote various types of services and products.
On the Website, with your consent, we use cookies and other technologies to profile content directed to you via social media.
7.2. Legal basis for processing
The legal basis for processing of personal data by the Ukrainian company of Raben Group for the above purposes is the legitimate interest (Article 6(1)(f) of the GDPR) consisting in aggregating information and profiling on this basis to promote communications promoting own products and services to customers and other persons who communicate via forms on the Website dedicated to customer services in relation to your consent to the tracking of cookies in accordance with the cookie policy, which you can find HERE.
7.3. Duration of data processing
Data of users of social media sites will be processed for the period of existence of legitimate interest of the Ukrainian company of Raben Group, for the period when the user follows Raben Group profiles and in case of communication via social media sites, for the period necessary to close the conversation.
7.4. Obligation to provide data
We obtain all your data through the owners of the social media, from your public profile or fanpage posts and, if you have granted your consent, also from the registration of your activity on the Website. The provision of data is voluntary, however in the case of communication via social media, it is necessary in order to handle cases and maintain the relationship carried out in the given communication.
8. Processing of personal data of persons contacting us via the contact forms available on the Website
The use of the forms usually requires you to provide your personal data. The following provides general information on the purposes and legal grounds for processing data through the forms available on the Website. In addition, there is information next to each form indicating the purpose and legal basis for the processing of personal data by the specific form.
8.1. Purpose of data processing
When enquiries are made via the forms available on the Website, the personal data contained in the correspondence are processed for:
establishing contact and responding to your inquiry;
establishing or exercising civil law claims in the course of business, as well as the defence against such claims;
personalising communications and profile offers on the basis of aggregated customer service information in conjunction with relevant cookies;
undertaking other activities carried out on the basis of your consent, such as conducting surveys - e.g. opinion or satisfaction surveys, sending newsletters or providing information about the offered services, new offers and promotional opportunities, on the communication channel of your choice.
8.2. Legal basis for data processing
The legal basis for the processing of personal data for the aforementioned purposes is the legitimate interest (Article 6(1)(f) of the GDPR) consisting in conducting effective communication with persons making inquiries via the website, securing and exercising claims and providing tailored information regarding offers and services or consent (Article 6(1)(a) of the GDPR)
8.3. Duration of data processing
Your personal data will be processed until:
in relation to the processing of your data on the basis of Article 6(1)(f) of the GDPR, until you lodge an objection if, after consideration by the controller, it is found to be effective, or until the expiry of the statute of limitations for claims, as appropriate;
in relation to the processing of your data on the basis of Article 6(1)(a) of the GDPR - until you revoke your consent
Revocation of consent does not affect the lawfulness of the processing which was carried out on the basis of the consent prior to its revocation
8.4. Obligation to provide data
Providing personal data is voluntary, however necessary in order to establish contact and respond to your inquiry, request or demand and/or to carry out communications on the basis of the granted consents.
VII. DETAILED INFORMATION CLAUSES CONCERNING THE PROCESSING OF PERSONAL DATA BY COMPANIES OF RABEN GROUP OUTSIDE THE WEBSITE AND FANPAGES IN SOCIAL MEDIA.
Websites and fanpages in social media are not the only channels through which Raben Group processes personal data.
In order to fulfil the information obligations imposed on us, below we present key issues related to processing of personal data outside the website and fanpage on social media sites of transport participants, drivers, carriers, providers, customers, the so-called "contact persons", newsletter users, visitors to our facilities, representatives of legal persons and media representatives.
Information for transport participants
Information for the driver (employed/cooperating with the carrier providing services for companies of Raben Group)
Information for a driver (employed/co-operating with a carrier providing services for companies of Raben Group) covered by “monitoring” of telematics devices
Information for the carrier
Information for Customer
Information for driver - TMLE litle aplication
Information for suppliers
Information for Track & Trace users
Information for contact persons
Information on video surveillance and Raben Group visitor service
Information for media
Information for representatives of legal persons
Information for whistleblowers
VIII. AMENDMENTS TO THIS POLICY
We are committed to regularly review this Policy and amend it if it proves necessary or desirable due to: new legal regulations, new guidelines of authorities responsible for supervising the processes of personal data protection, best practices applied in the area of personal data protection.
We also reserve the right to amend this Policy in the event of changes in technology we use to process personal data (if the change affects the wording of this document), and in the event of changes in methods, purposes or legal grounds for processing of personal data.
This document was last updated on 19th of January 2024.
