Privacy Policy Statement
This Privacy Policy Statement was updated on Jan 24, 2020
- Data controller
- What kind of data we collect
- The personal data recipients or categories of recipients
- Personal data transfers to third countries
- Your rights regarding the personal data processing
- Contact details
On our website (metinvestholding.com, hereinafter – “Site”) we can collect your personal data in the manner and for the purposes described below.
We highly appreciate the confidentiality of the Site visitors, so we provide for the safe storage and use of a visitor’s data in accordance with the requirements of the Law of Ukraine “On Personal Data Protection”, as well as the European General Data Protection Regulation ("GDPR").
This Privacy Policy Statement ("Statement") describes the types of information we collect on this Site, including information relating to identified or identifiable individuals ("personal data"), for which purposes we use such personal data, with whom we may share it, and the rights and choices available to you regarding our use of your personal data. This Statement also describes how you can contact us about our privacy practices.
Please read this Statement before using or submitting any personal data on the Site.
By accessing and using this Site, you confirm that you have read and that you understand the way we collect, process, use and disclose your personal data as described in this Statement.
As further detailed in Section 2 below, we will use the data collected on this Site for the purposes of:
- maintaining and upgrading of the Site
- providing information about the company's activities;
- keeping the data on the Site users’ personal preferences and settings;
- improving the products and (or) services and developing the new ones;
- gathering statistics about users; and
- monitoring the status of the user's session (access).
1. Data controller
The company METINVEST HOLDING, LLC (or "we, "us" or "our") is the controller of your personal data (within the meaning of the GDPR), which are collected on and processed through this Site.
METINVEST HOLDING, LLC
Ukraine, 87534, Mariupol, Nakhimova av., 116-A
+380 44 251 83 05, ext. 1610
2. What kind of data we collect for which purposes/on which legal basis
a) Name, e-mail address and phone number.
The Site uses forms where you can put your name, email address or phone number. When completing the form, this data will be saved and can be used for the purpose of providing you with the information requested: news, announcements; and also to communicate with you.
Your name, email address and phone number are stored in the system within 36 months after the form is filled.
The legal basis for such processing of your email address is your consent as provided by ticking a specific box displayed on the relevant form. You can withdraw your consent to the storage and use of your email address for the purpose described above at any time by sending a request at the following email: DPO@metinvestholding.com. Then the specified email address will be deleted and we will no longer be able to communicate with you using such email address.
b) Automatically collected data
Every time the Site is visited, the system automatically collects information about the device the visitor uses to browse:
- The type and version of the browser
- Operating system
- IP address
Collection and temporary storage of this data is necessary for the purpose of displaying the contents of the Site on the user's computer correctly. The data will be deleted as soon as there is no longer a need for using them – at the end of the session (when the user leaves the Site) or the storage period indicated below (section 3-a) has passed.
We do not establish a link between the data automatically collected by the information system and other personal data of individuals.
The legal basis for such processing of the information about your device is the necessity for the good working of our Site.
c) Cookies
A cookie is a file that is stored on the hard disk of the user's personal computer when he visits the Site pages. Such a file contains a character set that allows to identify the user's device or browser when he visits the Site again.
We use cookies for the following purposes: to make the Site more user-friendly, to personalize the content or settings of the Site, as well as to anonymously collect statistical information. [We may use statistical information to improve our products and (or) services and developing the new ones.] Cookies are also necessary for the correct operating of some of the Site functions: for example, to save the session when the user navigates through the pages.
The legal bases for such processing of your personal data collected by means of cookies is:
- your consent [as provided by clicking the ["continue" / "ok" / …] button on the Site cookie banner]. You will always be able to withdraw your consent and change your choice by amending your browser settings in the future, as detailed below.
We use the following categories of cookies:
|
Name of the cookie |
Description |
Storage |
|---|---|---|
|
CookieConsentAccepted |
The file to identify the user who gave consent to the personal data collection |
36 months |
|
_ga |
Creates a unique identifier in the Google Analytics system that is randomly generated and used to gather statistics about how a visitor uses the Site. |
2 years |
|
_gid |
A file to identify a user of the Site in the Google Analytics system |
24 hours |
|
_gat |
Uses Google Analytics to limit the frequency of demands |
1 minute |
|
.ASPXAUTH |
Identifies the user during authentication |
During the session |
|
ASP.NET_SessionId |
Keeps the status of the visitor's session when he navigates through the pages of the Site |
During the session |
|
ARRAffinity |
Used to disperse traffic between multiple servers in order to optimize the response time |
During the session |
| _rl | Saves language preferences | 1 yaer |
The processed cookies are deleted or anonymized upon the achievement of the above mentioned processing purposes or there is no further need to achieve these objectives, or in the event of the expiration of the storage period indicated above.
You can limit the use of cookies using your browser settings:
Internet Explorer | Edge | Safari | Chrome | Firefox | Opera
The way you may prevent your data from being used by Google Analytics is detailed in the section 3.a) below.
Please note that if you change the browser settings, the Site functionality may be limited, and some content may not displayed incorrectly.
3. The personal data recipients or categories of recipients
We collect and store the data, including on Google services, as detailed below.
a) Google Analytics
This site uses Google Analytics, Google LLC (“Google”) web-based analytics service, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Google Analytics uses cookies. The cookie-created information about your visiting the Site is sent to a Google server in the United States and stored there.
With the help of cookies, Google Analytics can distinguish unique users; limit the frequency of demands; remember the number and time of previous visits; record the traffic source; determine the beginning and end of the session; remember the values of the visitor level user-declared variables. Information about your device (the browser and its version, the operating system), with which you browse the Site, can be sent to Google Analytics.
We use the IP anonymizing feature on this Site, which means that your IP address will be shortened before it is sent. The IP address that your browser sends to Google Analytics will not be combined with other Google data.
We use the data in the Google Analytics system to maintain statistics and store them no more than 36 months.
Google will use the received information for statistical analysis and reporting, which will help to optimize the Site making it more comfortable for the visitors.
You can also forbid Google to collect and process the data generated by the cookies, based on the use of the Site (including your IP address) by downloading and installing the browser plug-in at the following link.
b) Google Maps
This site uses Google Maps features. Google Maps is a service operated by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. If you visit one of our pages containing Google Maps, you are connected to Google servers. In addition to your IP address, the servers can also specify which of the pages of the site you are currently visiting.
If you are logged in to your Google Account, Google can add this information to your profile.
We do not have control over these Google Maps features, and over the relevant methods of processing of your personal data by Google through such features. We disclaim any responsibility for such processing. You should check Google Privacy Statement to learn about the conditions applicable to the processing of your personal data since this Statement applies only to this Site.
c) LLC «METINVEST DIGITAL» (Metinvest Digital)
When performing technical and organizational activities aimed at ensuring the Site operation and protecting the information stored in its system, the Metinvest Digital employees can have access to the above mentioned data on a need to know basis.
Metinvest Digital, located in 87504, Ukraine, Mariupol, Nikopolsky avenue, 54 processes the data only as processor on the basis of the documented instructions of METINVEST HOLDING, LLC and provides sufficient guarantees of data privacy protection and complying with the conditions specified in this statement.
The Metinvest Digital participation in data processing is regulated by the agreement with METINVEST HOLDING, LLC.
d) Vimeo
We use Vimeo video player operated by Vimeo, Inc. (555 West 18th Street, New York, New York 10011). Vimeo can set essential cookies to enable certain features and to remember your preferences (for example, language or volume settings).
4. Personal data transfers to third countries
The recipients identified in Section 3 above may be located in the Unites States, which include countries outside the EEA that are not recognised as providing an adequate level of protection by the European Commission. In any case, we will only transfer personal data to recipients that provide an adequate level of data protection or as permitted by data protection laws by implementing appropriate safeguards.
Google has certified adherence to the EU-US Privacy Shield Framework of the US Department of Commerce which establishes an adequate level of data protection according to European Commission decision C/2016/4176 (Article 46, 2., (f) of the GDPR). It's current EU-US Privacy Shield certification can be reviewed at privacyshield.gov.
5. Your rights regarding the personal data processing
In accordance with the legislation on the personal data protection, you have rights you need to know about.
a) Your right to access your personal data (Article 15 of the GDPR).
You have the right to know about the fact that we process or store your personal data. You can exercise this right by requesting a copy of your personal data (hereinafter - Access request).
You can make a written Request to the address below, to find out what data are processed and how they are processed.
In addition to receiving copies of the personal data we process, you have the right to know:
- what your personal data are used for;
- to whom your personal data are transferred;
- duration of personal data storage;
- information about your rights as described in this section 5;
- your right to lodge a complaint with the supervisory authorities;
- the source of your personal data where it is not collected from you;
- whether your personal data are used for automated decision making, including profiling;
- whether your personal data are transferred to non-Member states or an international organization outside the EU and the appropriate safeguards implemented to cover such transfer.
We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.
Copies of your personal data are free.
We have the right to charge a reasonable fee for administrative expenses if you request additional copies or if your request is “manifestly ill-founded or excessive”.
b) Your right to rectification (Art.16 GDPR):
You have the right to ask us to rectify the information you consider inaccurate. You also have the right to ask us to complete information that, in your opinion, is incomplete.
For that purpose, you should inform us in writing to the address below:
• that you question the accuracy of your data and want them to be rectified;
• clearly indicate which data you want to correct or complete;
• explain how we should rectify or complete your personal data (e.g., by means of providing a supplementary statement);
• provide evidence of your identity.
We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.
The rectification or updating of your personal data is free of charge.
We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”.
c) Your right to erasure or "the right to be forgotten" (Art. 17 GDPR)
You have the right to ask us to erase your personal data without undue delay, notably if you:
• withdraw your content to process your personal data;
• believe that your personal data are processed unlawfully ;
• object to the processing of personal data with the purpose of direct marketing.
To exercise your right to erase your data, you should inform us in writing at the address below about your desire to do it and, if possible, explain why you believe that your personal data are processed unlawfully.
We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.
Erasing your personal data is free of charge.
We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”.
d) Your right to restriction of processing (Art. 18 GDPR):
You have the right to ask us to restrict the processing of your personal data processing (we will only store them), notably if you:
• contest the accuracy of your personal data, during the period of our verification of the accuracy of your personal data;
• believe that your personal data are processed unlawfully , but object to its erasure;
• require your personal data for the establishment, exercise or defence of legal claims, although we no longer need your personal data for the purposes of the processing.
To exercise your right to restriction of processing, you should inform us in writing at the address below:
• that you want to restrict your personal data processing;
• clearly indicate the processing of which data you want to limit.
We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.
Limitation of your personal data processing is free of charge. We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”.
e) Your right to data portability (Art. 20 GDPR):
You can exercise your right only with respect to the personal data that concerns you and that you have provided to us. You have the right to ask us to receive such data in a structured, commonly used and machine-readable format and to transmit it to another controller. This right is exercised only if the data processing is based on your consent or necessary for the performance of a contract to which you are party and this processing is carried out by automated means.
To exercise your right to data portability, you should inform us in writing at the address below about your desire to receive your data or to transmit data and indicate the contact details of the addressee.
We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.
The transfer of your personal data is free of charge.
We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”.
f) Your right to object to the processing (Art. 21 GDPR):
You have the right to object, on grounds relating to your particular situation, at any time, to your personal data processing that is based on our (or third parties') legitimate interests and we may have to stop processing your data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims. You have the right to object, at any time, to the processing of your personal for direct marketing purposes.
For this purpose, you should inform us in writing at the address below that you object to your personal data processing and indicate the reason why you object (unless you object to the processing of your personal for direct marketing purposes).
We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.
Objecting to the processing of your personal data is free of charge. We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”.
g) The right to withdraw your consent (Art. 7(3) GDPR):
If you have declared your consent for any personal data processing activities as described in this Statement, you have the right to withdraw your consent at any time, by contacting us at the
address below. Such a withdrawal will not affect the lawfulness of the processing prior to withdrawal of the consent.
We will respond to your request within one month. In certain circumstances, we may inform you that we need additional time to respond to your request, but not more than two months.
Withdrawing your consent of your personal data processing is free of charge.
We have the right to charge a reasonable fee for administrative expenses if your request is “manifestly ill-founded or excessive”.
h) Right to lodge a complaint with a supervisory authority (Art. 77 GDPR):
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the country where you live, work or where the alleged violation occurred, if you consider that the processing of your personal data violates applicable law.
If you are in one of the Member States of the EU, you can lodge a complaint with one of the supervisory authorities, the contact details of which are indicated at the following link.
If you are in Ukraine, you can lodge a complaint with the Human Rights Commissioner of the Verkhovna Rada, whose contact details are indicated at the following link.
6. Contact details
If you have any question on this Statement or if you wish to exercise your rights listed in section 5 above, you can contact our personal data protection officer by sending a message:
- over email: DPO@metinvestholding.com
- to the mailing address: Laboratornyi lane, 12, 01133, Kyiv, Ukraine
Please indicate “For the Legal Department” on the envelope.