Privacy and Personal Data Protection Policy

General provisions

Data management of www.tbt-broker.com (hereinafter —the «Site»):  carried out by the LLC “TBT – Insurance broker”, a legal entity registered and operating in accordance with the requirements of the legislation of Ukraine (hereinafter — the «Organization»).

The organization has great respect for the confidential (personal) information of all persons without exception who visited the Site, as well as those who use the services provided by the Site; in this connection, the Organization seeks to protect the confidentiality of personal data (information or aggregate information about an individual who is identified or can be specifically identified), thereby creating and ensuring the most comfortable conditions for the use of the Site services for each user.
This privacy and personal data protection Policy (hereinafter — the «Policy») establishes the procedure for the Organization to process personal data, the types of personal data collected, the purpose of using such personal data, The Organization’s interaction with third parties, security measures to protect personal data, conditions of access to personal data, as well as contact information for the user regarding access, modification, blocking or deletion of their personal data and handling any questions that You may have regarding the practice of personal data protection.

Collection and usage of personal data

The owner and Manager of the personal data of users of the Site is the TBT – Insurance Broker, LLC.

When the user uses the services of the Site, the Organization processes the user’s data, namely:

• data provided by the user both when filling in the registration forms and during the use of the services;
• cookies;
• IP addresses;
• parameters and settings of Internet browsers (User — agent).

The organization collects only those personal data (for example, Your name and surname, login and password, e-mail address, contact phone number, date of birth, gender, etc.) that are knowingly and voluntarily provided by You as a subject of personal data for the purpose of using the services of the Site, which in accordance with the requirements of the legislation is the consent of the data subject to the processing of their personal data in accordance with the purpose of its processing formulated in this Policy.

When you visit the Site, all logins are recorded. Other user traffic information is not processed or stored. Please note: the Organization is limited to the collection of the minimum amount of information necessary only to fulfill the request of the data subject. In any case, when information that is not required to be provided is requested, the user will be notified at the time of collection of such information.

The organization does not collect any information on the processing of which the legislation establishes certain requirements, such as information on racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, conviction for criminal punishment in the Commission of a crime or conviction for criminal punishment, as well as data relating to health, sex life, biometric or genetic data (according to article 7 of the Law of Ukraine «on protection of personal data»). The Organization collects data on the statistics of Site visits. The information may contain information about connections, traffic, the user’s browser, as well as the date, time, duration of work on the Internet and stay on the Site.

Personal data processing

Processing and storage of the provided personal data is carried out in data centers, where the equipment that provides the functioning of the Site services is located. The provided personal data is processed and can be stored in the personal data Base or in a separate table of the Site Database. The place of storage and processing of personal data is located at:

TBT – Insurance Broker, LLC

04119, Kyiv, Dekhtyarivska street, Building G, office 311.

tel. +38 044 290 71 75

e-mail: office@tbt.kiev.ua

Purposes of usage of personal data

Your personal data is used to ensure the provision of Internet services of the Site, exchange of information / news, relations in the field of advertising and communication in accordance with and in compliance with the laws of Ukraine, including, but not limited to: «on protection of personal data», «on ratification of the Convention on protection of persons in connection with automated processing of personal data and Additional Protocol to the Convention on protection of persons in connection with automated processing of personal data regarding Supervisory authorities and cross-border data flows», «on information», «on advertising», «on telecommunications», «On protection of information in information and telecommunication systems», «on state support of mass media and social protection of journalists», as well as in accordance with the Rules of use of the Site and other acts regulating the activities of the Organization.

The retention period of personal data

Personal data is stored for no longer than is necessary for the purpose of processing. After the data subject ceases to be a user of the Site by deleting his account on the Site, his personal data is also automatically deleted.

Use of cookies

The Site also performs the function of obtaining information about users and their actions through cookies. We ask the Site users to agree to the processing of cookies by storing information or accessing information already stored on their telecommunication devices.

Consent to the processing of cookies is made, in particular, by means of a button containing a statement of consent to the processing of cookies or confirmation of acquaintance with its terms. This consent may be withdrawn at any time, free of charge, and described in the section about managing cookies. In most cases, the browser settings allow you to add cookies to the device by default. If the User does not agree to save these files, the browser settings must be changed accordingly. You can disable saving them for all connections from a particular browser or site, and delete them.

The interaction of the Site with other resources

When the user uses the services, the site may contain codes of other Internet sources and third parties, with the result that such Internet resources and third parties receive Your data. Therefore, these Internet sources can receive and process information that you have visited these pages, as well as other information that is transmitted by the user’s browser. Such Internet resources can be:
— banner displaying systems (e.g., DoubleClick for Publishers, Admixer AdRiver, etc. )
— social network plugins (e.g. Discus, Facebook, Twitter).

The use of these services of the Organization is necessary for the operational analysis of Site visits, internal and external evaluation of site traffic, visit depth, user activity. Data received from these services, the Organization does not store or process. Accordingly, if the user for any reason does not want these services to access his personal data, the user can voluntarily log out of his account or profile, clear cookies (in his browser).

Interaction of the Organization with third parties regarding personal data

The organization does not transfer personal data to third parties, except when such transfer is required by law, at the request of the data subject or in other cases set forth in this Policy.

The Organization understands that personal information is valuable and integral content, including the moral rights of any individual, and therefore takes all possible measures to protect the personal information of users, voluntarily and knowingly transmitted by the latter to the Organization.

The Site may contain links to other websites (for information purposes only).

When linking to other websites the effect of this Policy on such sites will not be distributed. In this regard, the Organization recommends that you read the privacy and personal data policy of every site before you transfer personal data on which You can be identified.

Personal data protection

The Organization uses generally accepted standards of technological and operational protection of information and personal data from loss, misuse, alteration or destruction. However, despite all efforts, the Organization cannot guarantee absolute security against any threats arising outside the Organization’s regulation. The Organization ensures that all relevant confidentiality obligations and technical and organizational security measures are in place to prevent the unauthorized or unlawful disclosure or processing of such information and data, or their accidental loss, destruction or damage. The Organization provides access to information and personal data only to authorized employees who have agreed to ensure the confidentiality of such information and data in accordance with the requirements of the Organization. The distribution of personal data without the consent of the data subject or the person authorized by him is allowed in cases determined by law, and only (if necessary) in the interests of national security, economic welfare and human rights.

Terms of access to personal data

The procedure for access to personal data of third parties is determined by the terms of the user’s consent provided to the owner of personal data for the processing of this data, or in accordance with the requirements of the law. The user has the right to obtain any information about himself from any subject of relations related to personal data, provided that the surname, name and patronymic, place of residence (place of stay) and details of the document certifying the natural person submitting the request are specified except as provided by law. User access to personal data is free of charge. Postponing the user’s access to his personal data is not allowed. Postponing access to personal data of third parties is allowed if the necessary data cannot be provided within thirty calendar days from the date of receipt of the request. At the same time, the total period of resolution of the issues raised in the request may not exceed forty-five calendar days. The notice of deferral shall be communicated to the third party who has submitted the request in writing, explaining the procedure for appealing the decision.  The decision to postpone or deny access to personal data may be appealed to the Commissioner for the human rights of the Verkhovna Rada of Ukraine or through the court.

Rights of the data subject

The organization brings to Your attention information about Your rights as a data subject, which are regulated by the Law of Ukraine» on protection of personal data», namely:
1) to be aware of the sources of collection, location of personal data, the purpose of their processing, location or residence (stay) of the owner or Manager of personal data or to provide an appropriate order regarding the receipt of this information to the persons authorized by them, except in cases established by law;
2) receive information about the terms of access to personal data, in particular, information about third parties to whom personal data is transferred;
3) access to your personal data;
4) receive no later than thirty calendar days from the date of receipt of the request, except as provided by law, the answer on whether the personal data are processed, as well as receive the content of such personal data;
5) submit a reasoned request to the owner of personal data with an objection to the processing of their personal data;
6) to make a reasoned request regarding the change or destruction of their personal data by any owner and Manager of personal data, if these data are processed illegally or are unreliable;
7) to protect their personal data from illegal processing and accidental loss, destruction, damage due to deliberate concealment, failure to provide or late provision, as well as to protect against the provision of information that is inaccurate or dishonor the honor, dignity and business reputation of an individual;
8) to appeal to the Commissioner for the human rights of the Verkhovna Rada of Ukraine or to the court for the processing of their personal data;
9) apply legal remedies in case of violation of the legislation on personal data protection;
10) make reservations regarding the restriction of the right to process their personal data at the time of consent;
11) withdraw consent to the processing of personal data;
12) know the mechanism of automatic processing of personal data;
13) to protect against an automated solution that has legal consequences. To update, access, amend, block or delete your personal data, withdraw your consent to the processing of personal data that You have provided to the Organization in accordance with this Policy, or in case of any comments, requests or claims regarding Your personal data that are processed by the Organization, please contact the Organization:

TBT – Insurance Broker, LLC

04119, Kyiv, Dekhtyarivska street, Building G, office 311.

tel. +38 044 290 71 75

e-mail: office@tbt.kiev.ua

Policy change

This Policy periodically and without prior notice about it of subject can be modified and amended, including,  change of requirements of the legislation. In case of significant changes in this Policy, the Organization will post a message on the Website and specify the date of entry into force of these changes. If you do not refuse to accept them in writing within the specified period, this will mean that you agree to the relevant changes to the Policy. Please review this Policy from time to time to be aware of any changes or additions.