Privacy Statement

1. INTRODUCTION

This privacy statement serves to inform visitors to our websites about data processing when using this website.

This website is owned and operated by HTL UKRAINE TOV (“HTL” or “we”, “us”, “our”), the subsidiary of NOVOMATIC AG.

HTL sets particular store by protecting your personal data and we would like you to be able to visit our website without any concerns. In most cases it is possible to use our website without providing personal information. The following privacy statement provides a complete overview of how HTL guarantees the protection of your personal data, along with which types of data are collected for which purpose.

Your trust is very important to us. Should you have any further questions regarding the processing of your personal data, please contact:

HTL Ukraine TOV
Letter A, Office 7-1
Holosiivska Street 7 Bldg. 2
03039 Kyiv, Ukraine
Tel.: +380 67 4064609
E-mail: info@novomatic.ua

Or contact the Group Legal Compliance Department of NOVOMATIC AG in writing at:

NOVOMATIC AG
Wiener Straße 158
2352 Gumpoldskirchen
Österreich
Tel.: +43 2252 606 0
E-mail: info@novomatic.com

Contact details of the data protection officer: dataprotection@novomatic.com

2. IP ADDRESS

The IP address is transmitted on every server request to let the server know where the response has to be sent. Your Internet Service Provider (ISP) gives you an IP address as soon as you connect to the Internet, and the ISP can retrace which IP address was assigned to which of its customers at any given time. For as long as the IP address is saved, it is theoretically possible to identify the owner of the Internet connection via the ISP. For this reason, we and our statistics providers do not save the IP address permanently but only temporarily for session recognition and for security reasons (for example to ward off hacker attacks). The IP address is then immediately deleted, so that any collected data are made anonymous and it is no longer possible to identify the user, not even via the ISP.

3. COOKIES

3.1. Legal basis for the use of cookies

In order to provide you with a more personalized and responsive service we need to remember and store information about how you use this website.  We do this by using small text files called cookies. Cookies contain small amounts of information and are downloaded to your computer or other device by a server for this website. Your web browser then sends these cookies back to this website on each subsequent visit so that it can recognize you and remember things like your user preferences.

The legal basis for our use of cookies is your consent given by you to us via our cookie banner. You can revoke your consent at any time by opening the cookie banner again and clicking on “Reject cookies”, without this resulting in any disadvantages for you or restricting the use of our website.

Accept cookies Reject cookies

In addition to these, there are certain cookies that are absolutely necessary in order to provide a service requested by you. The solely purpose of these cookies is to protect our website against unauthorized access and attacks. This means that no consent needs to be given for these cookies.

3.2. Required cookies

When you log on to our website with your user name and password, a session cookie containing a unique identification number is stored on your device. This cookie is required for our website to ensure that you have properly signed in, which means that does not need your consent in our cookie banner.

The session cookie is used exclusively to protect your content against unauthorized access and thus to ensure the security of our website. It is automatically deleted as soon as you end your session, i.e. close the browser.

3.3. Cookies for website statistics

We use a variety of data collected during visits to our website for statistical evaluations. Such data will only be processed internally and will not be passed on to third parties. We do this to continuously improve our website and to adapt it to your requirements.

We use the privacy-friendly analysis software Matomo (https://matomo.org/) to compile usage statistics. For this purpose, cookies are stored on your computer which identify your browser session and assign recurring accesses to our website. These cookies remain stored until you revoke your consent or delete them manually.

The following data are collected and evaluated when you visit our websites:

• Pages viewed (e.g. www.beispiel.de/index.html)
• Browser type and version (e.g: Internet Explorer 6.0)
• Browser language
• Operating system used (e.g: Windows 10)
• Internal resolution of the browser window
• Screen resolution
• JavaScript activation
• Plug-ins (Java, Flash, Real, QuickTime ...)
• Cookies on/off
• Depth of color
• The previously visited page incl. parameters (e.g: search engine with search terms)
• IP address to determine the country of origin and the provider
• Time stamp
• Clicks made

4. PROCESSING OF PERSONAL DATA

Pursuant to Articles 8 and 12 of the Law of Ukraine On Protection of Personal Data №2297-VI dated June 1, 2010 (“Data Protection Law”),  we hereby inform you about collecting and processing the personal data processed within the framework of this website or within the framework of a (pre-) contractual business relationship and the privacy claims and rights to which you are entitled.

Name and contact details of the data controller:

HTL Ukraine TOV
Letter A, Office 7-1
Holosiivska Street 7 Bldg. 2
03039 Kyiv, Ukraine
Tel.: +380 67 4064609
E-mail: info@novomatic.ua

4.1. Your consent to processing of personal data

Personal data that you enter yourself when filling in the forms for "Information request”, "Application" and "Contact us" are processed.  Such personal data may include: your name; e-mail address; your phone number;  employment details; your IP address; your browser type and language; your access times; details of how you like to interact with us and other similar information. By entering your personal data into said forms you grant us your consent to collecting and processing your personal data.

We process your personal data exclusively for the following purposes:

• Developing our businesses and services.
• Providing information to you about us and our range of products and services.
• Making personal data available to our employees for performing our obligations under agreements concluded.
• Performing analytics such as relationships maps or sales opportunities.
• Security, quality and risk management activities
• Administering, managing and developing our businesses.
• Managing our relationship with clients.
• Hosting or facilitating the hosting of events.
• Maintaining and using our IT systems.
• Administering and managing our website and systems and applications.

This consent to the processing your personal data for the stated purposes remains valid until you revoke it, at any time, within the scope of the data protection regulations.

We also process the personal data that are public information and/or information in the form of open data received from public sources, including from public state registers, without the consent of the personal data subject. The respective information may be copied, published, disseminated and used in other ways, including for commercial purposes in combination with other information or by including in our own product, only in the scope corresponding to the above stated purpose of processing with the mandatory reference to the source from which such information was received.

Legal basis of the data processing: 

We process the personal data based on the grounds stipulated by the Article 11 of the Data Protection Law including:

• Your express consent to the processing of your personal data.
• A necessity to fulfil our obligation defined by the law of Ukraine.
• Conclusion and performance of a legal contract by HTL, to which personal data subject is a party or which is concluded in favor of a personal data subject, or to perform actions leading to the conclusion of a legal contract at the request of a personal data subject;

A necessity to protect the legitimate interests of HTL or third parties to which HTL transfers personal data except for cases when the needs related to protection of the basic rights and liberties of private individuals within the framework of processing of their data prevail over the respective interests. Storage period or criteria for determining the period: 

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected, including as required by applicable law or regulation.   In the absence of specific legal, regulatory or contractual requirements, our typical retention period for records and other documentary evidence created in the course of our business  does not exceed [10] years.

Transmission to third parties: 

Your personal data held by us may be transferred to:

• NOVOMATIC AG or other companies of NOVOMATIC Group.
• Third party organizations that provide applications/functionality, data processing or IT services to us.
• Third party organizations that otherwise assist us in providing goods, services or information.
• Auditors and other professional advisers.
• Tax authority, law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation.

When we share the personal data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

4.2. Your statutory rights

According to Article 8 of the Data Protection Law, you have the right to:

• Know about the sources of collection, location of your personal data, purpose of processing, location and/or place of residence (staying) of the controller or processor of such personal data, or to issue a respective order to the authorized persons regarding the receipt of this information, except for cases established by the law.
• Receive the information concerning the conditions of provision by HTL of access to your personal data, in particular information about third persons who obtain your personal data.
• Access to your personal data, processed by HTL.
• Receive a response with regard to whether your personal data is processed in a proper way as well as to receive the content of your personal data, not later than 30 days from the moment the request was sent to HTL unless otherwise is prescribed by the law of Ukraine.
• Submit motivated requests to a personal data controller objecting against processing your personal data.
• Provide a motivated request with regard to change or destruction of your personal data by any controller and processor of such personal data, if such data is processed illegally or are inaccurate.
• Protect of your personal data from illegal processing and accidental loss, destruction, damage due to a deliberate concealing, failure to provide them or provision of such data with delay, as well as to protection from provision of information which is inaccurate or are disgraceful for the honor, dignity and business reputation of a private individual
• Lodge complaints regarding the processing of your personal data to the Authorized Human Rights Representative of the Verkhovna Rada or directly to a court.
• Apply measures of legal protection in case of violation of legislation on protection of personal data.
• When granting consent, make reservations to restrict the right to process his/her personal data.
• Withdraw consent to personal data processing.
• Be informed on the procedure for automated processing of personal data.
• Be safeguarded against an automated decision having legal implications for you.

4.3. Implementation of your statutory rights

In accordance with the provisions of the  Data Protection Law, you have the right to information at any time about the data processed in HTL to your person, their origin as well as possible recipients of transmissions and the purpose of the data use. In order to obtain such information or use other statutory right please send  your written request to HTL Ukraine TOV at the address: Letter A, Office 7-1, Holosiivska Street 7 Bldg. 2, 03039 Kyiv

If all legal requirements for the processing of your request have been met, we will comply with it and grant you the relevant access to your personal data or implement your other legitimate request within a period of 30 days unless other period is stipulated by Data Protection Law.

4.4. Revocation of consent

In accordance with the provisions of the Data Protection Law, you have the right to revoke your consent to the processing of your personal data at any time, without stating any reasons. In this case, we will not process your data further and will erase them, taking into account any statutory retention periods, within a period of 30 days.

4.5. Complaining to the authority

In accordance with the provisions of the Data Protection Law), you have the right to lodge a complaint with the government authority (www.ombudsman.gov.ua) if you believe that the processing of your personal data is in violation of the Data Protection Law.

5. Privacy Policy

The NOVOMATIC AG regards privacy (data protection), information security and reliability as the basis for stable and successful customer relations. We would therefore like to take this opportunity to inform you about the Privacy Policy we have in place for the entire NOVOMATIC AG.

5.1. Privacy Principles

Protecting privacy and safeguarding your personal data is very important to us.

All data applications operated by HTL comply with the provisions of the Data Protection Law and the General Data Protection Regulation of the European Union (GDPR for short)., All employees of HTL are obliged to process your personal data lawfully, in good faith and in a manner that can be understood by you, and to comply with the rules on data confidentiality as defined in  Data Protection Law.

Compliance with the data protection and data security regulations is guaranteed across the entire NOVOMATIC Group by the following binding measures:

• Privacy Concept
• Privacy Policy
• Privacy Program
• Privacy Management System

5.2. Privacy Concept

The Privacy Concept lays down the desired level of data protection security (the protection requirements) as defined by the legal representatives of the NOVOMATIC AG. This serves as the basis for the development of the demands on Privacy Policy and on the continuous privacy improvement process within the entire NOVOMATIC Group.

5.3. Privacy Policy

On account of the assessment of privacy-related processes and the relevant data protection legislation, a written Privacy Policy was drawn up for the NOVOMATIC Group to serve as a basis for the implementation of the Privacy Program and the establishment of the Privacy Management System.

5.4. Privacy Program

As part of the Privacy Program, data protection goals are continuously being specified and the measures to be implemented are defined in the form of a work program and provided with corresponding implementation deadlines.

5.5. Privacy Management System

The Privacy Management System defines the rules, policies, measures, resources, methods, responsibilities, procedures and organization structures for implementing and monitoring the Privacy Program.

Modeled on the international standards ISO 9001:2015 and ISO/IEC 27001:2017, our Privacy Policy was designed along the lines of the PDCA (Plan, Do, Check, Act) model to achieve continuous improvement.

5.6. Processing activities

HTL maintains a so-called "record of processing activities" in which the data applications operated by HTL as well as the relevant processing activities are documented. This existing record should always be kept up-to-date.

5.7. Special categories of personal data

HTL does not process any special categories of personal data within the meaning of Article 7(1) of the Data Protection Law on its website.

5.8. Guaranteed Data Protection

In principle, we do not process your personal data without your consent or within the framework of the existing contractual relationship with you and for the agreed purpose. We store your personal data in accordance with the applicable prescribed statutory time periods.

5.9. Transferring and Surrendering Data

Any transfer of personal data to third parties is made only with your consent. Excepted from this are data transfers that are necessary due to a legal obligation or for fulfilment of a contract. The transfer of personal data to processors (service providers) shall, in principle, be limited to those undertakings providing sufficient guarantees to implement appropriate technical and organisational measures in such a manner that processing the personal data complies with the requirements of the Data Protection Law and ensures the protection of the rights of the data subject.

5.10. Data Security

The technologies employed by HTL to process your personal data (hardware, software, network, infrastructure) comply with state-of-the-art security technologies. Appropriate technical and organisational measures have been set for these procedures, in order to comply with the requirements of the Data Protection Law.