OCTAVA DEFENСE (hereinafter also referred to as the “Company”) considers it its duty to protect the confidentiality and integrity of the information provided to it. In this regard, the Company undertakes to ensure the necessary protection and proper use of personal data (also referred to as “personally identifiable information” or “PII”) received through the Company’s websites.
As a rule, we collect only the personal data that users of our websites provide to us on a voluntary basis in order to provide them with information and/or services or inform them about available employment opportunities. Please carefully read this Privacy Policy of the Company (hereinafter referred to as the “Privacy Policy”) to get a more complete picture of the Company’s procedure for collecting, using, transferring and protecting the personal data received.
1. Information we collect
2. Legal grounds for using the personal data received
3. Your rights
4. Information security and data storage
5. Automatic collection of personal data
5.1. Cookie technology
5.2. IP address
5.3. Internet service Google Analytics
5.4. Web beacons (web beacon technology)
5.5. Widgets and applications in social media
6. Exchange and transfer of personal data that can be identified
7. Children
8. Possibility of choice
9. Links to other websites
10. Changes to the Privacy Policy
11. Questions about the provisions of the adopted policy and measures to comply with it
1. Information we collect
We receive personal data about you if you provide it to us voluntarily – for example, in order to send messages to mailboxes or register for certain services. In some cases, the Company may already have the personal data you provide (for example, if you are a former employee of the Company). When you register or send personal data to the Company, we will use this data in accordance with this Privacy Policy. Your personal data will not be used for any other purpose, unless we receive your permission to use it for other purposes or when such use is required or permitted by law or professional standards.
In some cases, when you register for certain services, we will store – temporarily – your e-mail address until we receive confirmation of the information you have provided to us by e-mail.
2. Legal basis for the use of personal data received
As a rule, the Company collects only the personal data that is necessary to fulfill your request. If we need to obtain additional information, you will be informed about this at the time of data collection.
In order to comply with the requirements of the applicable law, which allows us to process personal data provided that we have a lawful basis for doing so, we will be guided by one of the following processing conditions:
– Performance of a contract: the processing of your personal data is necessary for the performance of our obligations under a contract;
– Statutory obligation: we are required to process your personal data in order to comply with a statutory obligation, such as keeping records for tax purposes or providing information to a governmental or law enforcement agency;
– Legitimate interests: in certain cases, we will process information about you when such processing is within the scope of our legitimate interests in the course of conducting legitimate activities and is necessary for the continued conduct of such activities, provided that such processing does not override your interests; or
– Your consent: we may request your individual consent to the processing of a particular block of your personal data, and the processing of your personal data will be carried out only if we have your consent. You have the right to withdraw your consent at any time by contacting the Company at the address and indicating the purpose for which your contact information was provided to us.
Examples of the above-mentioned legitimate interests are:
– Providing information and/or services to persons visiting our website or informing them about available employment opportunities.
– Preventing fraud or criminal activity and protecting our IT systems.
– To preserve the individual settings and parameters of users of our websites, as well as to improve the functionality and efficiency of the Company’s websites.
– Carrying out marketing activities and analyzing their results.
– Fulfillment of our corporate and social responsibility obligations.
– Compliance with legal requirements and orders of regulatory authorities.
– Transfer of personal data to other related companies for the purposes of internal administrative activities, as described in Section 2.1 of this Privacy Policy.
3. Your rights
When the Company processes your personal data, you have the following rights:
– Access and correction of inaccuracies: You have the right to access your personal data. The document on the basis of which such access is granted is called “Request of the personal data subject for access”. If the provision of personal data to you is required by applicable law, such data will be provided to you free of charge. Prior to providing you with personal data, we may request that you provide proof of identity and the necessary amount of information about the nature of the interaction between us, on the basis of which we will be able to identify your personal data. If your personal data stored by us is incorrect, you have the right to request that we correct the inaccuracies.
– Object to processing: You have the right to object to the processing of your personal data if you believe that we have no right to use it in the future.
– Other rights: You have the right to request the deletion of your personal data if you believe that the period of its storage has been unreasonably exceeded, as well as – in certain circumstances – to request that it be processed to a limited extent, and/or to receive information about your personal data that we store electronically.
You can send a request and exercise the above rights by contacting the Company at dataprivacy@octava.ua and indicating the purpose for which you provided us with your contact information, and we, for our part, will make every effort to fulfill your request, provided that it does not contradict applicable law and professional standards.
4. Information security and data storage
The Company has adopted and maintains security measures and policies designed to protect personal data from loss, unauthorized use, modification or deletion. At the same time, in light of all existing threats to information security, it is impossible to provide an absolute guarantee of personal data security, even despite all the efforts that the Company will make. For our part, we do our best to ensure that only those persons who need access to your personal data to perform their official duties have access to it. Persons who have access to personal data are obliged to keep it confidential.
We try to keep personal data only for the period of time during which we need it to:
a) fulfill the individual’s requests, or,
b) to comply with legal, regulatory, internal administrative or policy requirements,
c) or until such time as the individual requests that we delete such data.
The period of storage of such data will depend on the specific events and circumstances under which the information was collected, but in accordance with the requirements of subparagraphs a) – c) above, personal data will be stored no longer than is required by applicable law.
5. Automatic collection of personal data
In some cases, the Company and the service providers with whom it works use cookies, web beacons and other technologies to automatically collect certain types of information when you visit the Company’s websites online or when you exchange emails with us. The collection of such information allows us to save individual settings and parameters of users of our websites, improve the functional characteristics of the Company’s websites, make them more user-friendly and generally increase their efficiency, as well as evaluate the effectiveness of our marketing activities.
5.1. IP address
An IP address is a number that is assigned to your computer every time you access the Internet. It allows computers and servers to recognize each other and exchange information. IP addresses of visitors to our websites will be used for information security and system diagnostics purposes. In most cases, such information will be used in aggregate form to analyze trends in the use of sites and their effectiveness.
5.2. Cookie technology
A cookie is usually a file that is placed on your computer or device connected to the Internet every time you visit our website. This allows the site to remember your computer or device. In addition, cookies may be used for other purposes.
An information banner appearing on some of our websites will ask for your consent to the collection of cookies. Below is a description of the categories of cookies that are collected on our websites and a description of how your consent may affect the operation of certain elements of the websites when you use them:
– Necessary cookies: Necessary cookies are required for users to navigate the site and use its elements, such as logging into secure areas of the site. These cookies must be activated. Otherwise, the site will not function properly.
– Performance cookies: Performance cookies are used to collect information in order to improve the site’s performance. You can manage your consent to the use of performance cookies by using the cookie banner or by setting your browser (usually through the browser menu “Tools and preferences”) to reject cookies.
– Functional cookies: Functionality cookies are used to track user preferences and, depending on them, change the operation or appearance of the site. You can refuse the use of these cookies, but this will affect your interaction with the site and you may need to re-select some settings each time you visit the site. You can manage your consent to the use of functional cookies by using a cookie banner, or by setting your browser (usually through the browser’s “Tools and Preferences” menu) to reject cookies.
– Targeting or advertising cookies: Targeting cookies are used to display website content according to your interests. They may also be used to limit the number of times certain marketing materials are displayed and to evaluate their effectiveness. If you do not consent to the use of targeting cookies, your computer or Internet-connected device will not be tracked for advertising purposes.
– Social media cookies: Social media cookies are set for social media services added to the website that allow you to share our content with friends and other users. Such files are able to track your browser activity on other websites and collect data about your preferences. This may affect the content and messages you see on other websites you visit. If you do not approve the use of these cookies, you may not be able to use such sharing tools or they may not be displayed to you.
You can manage your consent to the use of targeted cookies by using a cookie banner, or by setting your browser (usually through the browser’s “Tools and Preferences” menu) to reject cookies.
Although most browsers accept cookies automatically, you can set your browser so that only you decide whether to accept or block a cookie (see the “Tools” or “Settings” menu of your browser). You can delete cookies from your device at any time. However, please note that if you do not accept cookies, you may not be able to use certain functions of the website.
For more information on managing cookies, please refer to your browser’s help file or to specialized websites, such as www.allaboutcookies.org.
You can find a more detailed list of the types of cookies used on our websites here.
Third-party tools and widgets will be used from time to time on our individual web pages to provide additional features to online visitors. In this case, a cookie will be placed on your device to make it easier to use the tools and widgets and to properly display your communication with other users on our websites.
By themselves, cookies do not tell us your email address or identify you in any other way. In our analytical reports, we will use other identifiers, including IP addresses, but only for the purpose of determining the number of unique users of our websites and collecting information about their geographic location, and not to identify individual users of our websites.
5.3. Google Analytics Internet service
The Company uses the Google Analytics Internet service. Detailed information about the Company’s use of Google Analytics can be found here: http://www.google.com/analytics/learn/privacy.html.
To provide website visitors with more choices about how their data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The browser add-on communicates with Google Analytics JavaScript (ga.js) so that information about your website visit is not transmitted to Google Analytics. The Google Analytics Browser Add-on does not interfere with the flow of information to the website itself or to other web analytics services.
5.4. Web beacons (web beacon technology)
A web beacon is a small graphic file on a web page that can be used to obtain certain information from your computer, such as your IP address, the duration of your visit to the web page, your browser type, and the presence of cookies previously created by the same server. The Company uses these web beacons in strict accordance with the applicable law.
The Company or service provider organizations will use web beacons to monitor the performance of third-party websites that provide us with recruitment or marketing services, or to collect aggregate statistics about users of our websites and manage cookies.
You have the option to disable some web beacons by blocking the cookies associated with them. In this case, the web beacon will be able to register an anonymous visit from your IP address, but the information in the cookie will not be recorded.
5.5. Widgets and applications in social media
In most cases, the Company’s websites will provide for the possibility of exchanging information through third-party social media applications, such as the Facebook Like button and Twitter widget, as well as by filling out online forms posted on the said social media. Social media applications will collect and use information about how you use the resources of the Company’s websites (for more information about cookies, see the section “Sharing information on social networks” above). All personal data that you transmit through such social media applications will generally be collected and used by other members of the particular application, and such interactions are governed by the privacy policies of the companies providing the application. We do not control these companies and are not responsible for how they use your personal data.
In addition, the Company’s websites will host blogs, forums, crowdsourcing applications and other applications or services (collectively, “social media elements”). The purpose of these elements is to facilitate the transfer of knowledge and content sharing. All personal data you provide to a Company social media element will generally be shared with others on that element (unless otherwise specified at the time of collection), over whose activities and actions we generally have little or no control.
6. Exchange and transfer of identifiable personal data
6.1 Transfer of personal data among the Company’s related parties
We transfer information about you to other related parties of the Company within the framework of international projects when we have an obligation to comply with the requirements stipulated by the laws and regulations of other countries of the world, or when compliance with such requirements is desirable. Other companies affiliated with the Company also provide services to us and you, such as hosting and supporting IT applications, arranging certain forms of liability insurance for the Company and its clients, performing conflicts of interest checks with other clients and checks in accordance with anti-money laundering laws, assisting in the provision of services within client projects and other services designed to ensure the continuity of the Company’s business.
6.2 Transfer to third parties
We do not transfer personal data to third parties, except when it is necessary for the purposes of our professional activities, processing your requests and/or required or permitted by law or professional standards. This includes the following persons, cases and authorities:
– Our service providers: we transfer your personal data to our third-party service providers, such as providers of (IT) systems, hosting services, payroll services, consulting services (legal advisors), as well as providers of other goods and services. The Company works with service providers to whom we may entrust the processing of your personal data. The Company transfers personal data to them only if their activities meet our high standards in the field of data processing and security. We transfer personal data only to the extent that they need it to provide services.
– In case of reorganization of the Company or its sale to another organization: in most cases, the Company will also disclose personal data in connection with the sale, assignment or other form of transfer of any component of the Company’s business to which such personal information relates.
– Common law courts, arbitration courts, law enforcement or regulatory authorities: The Company will disclose personal data in order to respond to requests from common law courts, arbitration courts or law enforcement authorities, or if it is necessary or appropriate to comply with applicable law, decisions or orders of common law courts, arbitration courts or regulations of governmental authorities or professional regulatory bodies.
– Audits: disclosure of personal data will also be required to ensure data integrity or to verify information security measures and/or to investigate or prepare an adequate response to a claim or threat to information security.
In addition, the Company may transfer certain personal data outside the country to third-party organizations working with us or on our behalf or acting on our behalf for the purposes specified in this Privacy Policy. In these cases, your personal data will continue to be protected in accordance with the terms of the agreements we have with these organizations. The Company undertakes not to transfer the personal data provided by you to third parties for the purpose of its further use by these parties for direct marketing purposes. In most cases, the Company will store personal data within Ukraine.
7. Children.
The Company fully recognizes the importance of respecting the privacy of children, especially in the environment of communication through electronic communication channels. Our websites are not intended for children under the age of 14. In accordance with our policy, we never purposefully collect and store information about persons under the age of 14, except for the collection and storage of such information as part of the performance of professional services.
8. Choice.
In general, you are not obliged to provide us with any personal data, but the Company will require certain personal data from you in order to provide you with additional information about our services and events. The Company will also request your permission to use your personal data for certain purposes, and you may either grant or refuse to grant such permission. If you subscribe to specific services or newsletters, such as electronic newsletters, you may opt out of receiving them at any time by following the instructions included in each material sent to you. If you decide not to receive mailings and/or request that your data be deleted, we will endeavor to process your request as soon as possible, but we may require additional information from you.
As stated in the section “Cookies” above, if you do not want cookies to track your navigation on our website, you can configure your browser to block all cookies or to warn you when a cookie is sent. Please note that if you block cookies, some resources of the site may not be available.
9. Links to other websites
In most cases, the Company’s websites will contain links to other websites, including websites maintained by other related companies, which are subject to the provisions of other personal data protection documents, usually different from this Privacy Policy. Before disclosing any personal data, we encourage users to read the privacy policy posted on each website.
By registering on any of the Company’s websites and using your account to access a website maintained by another affiliated company, you agree to the use of your personal data in accordance with the Privacy Policy of the Company’s website you are currently visiting.
10. Changes to the Privacy Policy
The Company may make changes to this Privacy Policy from time to time in order to reflect the current data protection practices. Each time we make changes, we will indicate the date of the new version at the top of this page. In order to learn how the Company ensures the protection of your personal data, we recommend that you regularly review this Privacy Policy to find and study new provisions.
11. Questions about the provisions of the adopted policy and measures to comply with it
The Company considers it its duty to protect the integrity of your personal data.
If you have any questions or comments regarding our handling of your personal data, please contact the person responsible for handling personal data in the Company at dataprivacy@octava.ua You can also use this address to report any problems related to our compliance with the Privacy Statement. We will acknowledge receipt of your email within 14 days and take steps to resolve the problem you have within one month from the date of receipt of the relevant email. If the problem is complex or if we are dealing with more than one problem at a time, we will inform you that it will take more than a month to resolve your problem and that we will take all steps to resolve the problem within three months from the date you first notified us of it.
If for any reason you are not satisfied with the response you receive, you may raise your issue to a higher level, to the Personal Data Protection Officer, by sending an e-mail to dataprivacy@octava.ua We may either accept your request for consideration (in which case we will apply one of the measures mentioned in the section “Your Rights” above) or legally refuse to accept it for consideration.
In any case, you always have the right to lodge a complaint with the supervisory authority responsible for personal data protection.