We, «Tavrida» Group (hereinafter «Tavrida», «we», «our», and/or «us»), are concerned with personal data protection of our clients, web-site visitors and all other people, whose personal data we collect, use, transfer and process in different ways. Privacy of our clients is of utmost importance for us and we are committed to protecting and safeguarding your data privacy rights.
The General Data Protection Regulation («GDPR») was adopted on 24 May 2016 and came into force on 25 May 2018. This is a single EU-wide regulation on the protection of personal data of EU citizens. We are legally responsible for ensuring that all personal data of EU citizens that we hold and use throughout our activities is done so in a way that meets the data protection principles of the GDPR.
1. Key Definitions
«Personal data», «personal information» is any kind of information about you that can identify you, including name, ID, location and address, IP, phone number etc.
«Processing» means any operation performed by us and our processors on your personal data, including gathering, usage, storage of personal data.
«Consent» means any freely given, specific, informed and unambiguous indication that you agree on the processing of your personal data by us.
«Joint Controllers» means us, Tavrida Group, as legal entities that jointly determine the purposes and means of the processing of your personal data.
«Processor» means any person or legal entity that processes your personal data on our behalf and under our control.
- visitors to our website www.tavrida.com from EU which might appear as our current, prospective or former clients;
- any person that gets in touch with our consultants by e-mail or phone and which might appear as our current, prospective or former client.
Please note that our website and services are intended for adults, and not for use by those under the age of 16 years. Tavrida will not knowingly collect or disclose personal information from children.
3. The Joint Controllers of Your Personal Data and Contact Information
«Tavrida» Group companies, namely OOO Tavrida Electric, Tavrida Electric AG, Tavrida Electric GMBH, Tavrida Electric Export AS, Tavrida Electric Poland SP. Z.O.O and Energobit Tavrida SRL, are joint data controllers. This means we together decide how your personal data is processed and for what purposes.
The joint controllers of your personal data are:
- OOO Tavrida Electric (5th Yamskogo Polya street, 5 bld. 1, floor 18, premises 1, office 2, Moscow 125040, Russia) is a legal entity incorporated under the laws of Russian Federation, registration No. 5177746201672; representative of OOO Tavrida Electric in EU is Tavrida Electric GMBH (Im Leimen 14, Tettnang 88069, Germany);
- Tavrida Electric AG (Bahnhofstrasse 27, 6300 Zug, Switzerland) is a legal entity incorporated under the laws of Switzerland; representative of Tavrida Electric AG in EU is Tavrida Electric GMBH (Im Leimen 14, Tettnang 88069, Germany);
- Tavrida Electric GMBH (Im Leimen 14, Tettnang 88069, Germany) is a legal entity incorporated under the laws of Germany;
- Tavrida Electric Export AS (Harjumaa, Tallinn, Visase tn 14, 11415, Estonia) is a legal entity incorporated under the laws of Estonia;
- Tavrida Electric Poland SP. Z.O.O (Graniczna, 44 43-100, Tychy, Poland) is a legal entity incorporated under the laws of Poland;
- Energobit Tavrida SRL (Strada Taietura Turcului, Nr: 47/11, Cluj-Napoca, 400221, Romania) is a legal entity incorporated under the laws of Romania.
4. The Processors of Your Personal Data
Processor is any person or entity that processes your personal data on our behalf and under our control. Our processors that take part in the processing of your personal data on behalf of Tavrida are:
- Hosting company TimeWeb (timeweb.com);
- Google Analytics (analytics.google.com);
- Yandex Metrica (metrica.yandex.com);
- JivoChat (www.jivochat.com);
- LiveInternet (www.liveinternet.ru );
- CMS Bitrix (www.1c-bitrix.ru);
- Microsoft Azure (azure.microsoft.com).
These processors provide Tavrida with the services of support systems for our services. They process your personal data in accordance with the terms of the written contracts concluded between Tavrida and the processors. These contracts provide that the processors shall process and use your personal data only to the extent provided in the contract. The terms of the contracts do not violate the processors’ obligations provided in Art.28 GDPR and your rights as a personal data subject.
5. How We Obtain Your Personal Data
- When you visit our website www.tavrida.com, we automatically obtain your Internet log information and details of your behavior patterns without any identifiable data.
- When you fill in the forms on our website www.tavrida.com, we obtain your personal data, such as your name, occupation, phone number, e-mail or any other personal data you disclose to us, directly from you upon your consent.
- When you consult with our stuff by any means in order to become our client or provide any further personal data in order to conclude a contract with us, we obtain your personal information, directly from you upon your consent and in order to perform our contractual obligations.
6. Why We Need Your Personal Data and What Personal Data We Collect
To provide you our products and services, consult you on the matters you are interested in, contact with you or conclude and perform a contract with you, we must process information about you. Below you can find the description of the personal data Tavrida uses, for which purposes and on basis of which legal grounds.
Information we collect from visitors of our website www.tavrida.com
- If you visit our website www.tavrida.com, we automatically collect Internet log information and details of visitor behavior patterns without any identifiable data. However, this information is only processed in a way that does not identify you and therefore the processing of this data does not violate your data protection rights under the GDPR. In case we want to collect your personal information that can identify you, we always explain you for what purposes and on which legal basis we need this kind of personal data and ask your consent when it is needed.
- If you fill in a contact form through www.tavrida.com, we register your name, e-mail, phone number, country, city, occupation as well as the reason for contacting us and/or any comments you have entered on the form. We obtain this information from you upon your explicit consent for Tavrida to process your personal data. This information is then used to handle your contact request in the most appropriate way in accordance with your request and inform you about our new products in the future.
Information we collect prom our prospective clients
- If you contact our consultants in any way in order to know about our products or services and become our client, we register all relevant personal information you present to us for the purposes of initial consultation on what services we can offer you. We obtain this personal information from you in order to take steps at the request of you prior to entering into a contract. On the basis of your consent we can use your personal data in order to provide you with all information on our products and services and inform you about our new products and special offers.
- If you contact our company in any way in order to know about our products or services and become our client, but afterwards do not turn out our client, we record, store and transfer information about you on the basis of your consent. We use your personal data to inform you about our products or services, special offers.
Information we collect from our clients
· If you have already become our client, we process your data and keep records for the performance of a contract, in particular to contact with you. We use your name, address, telephone number and e-mail address, company name, your job title. On the basis of your consent we can use your personal data to provide you information you about our new products and special offers.
We can some of your personal data, in particular your name, company name, position, contact details of your company (not your personal), on the basis of legitimate interest for marketing purposes, inter alia effectiveness evaluation of our advertisements, analysis of sales system in our companies, development of our products and services.
7. How long we keep your personal data
The personal data we collect is stored electronically and processed for the purposes of providing you with all information on our products and services upon your request, initial consultations on our services and performance of the contract concluded with you.
Therefore, we store your relevant personal data for as long as it is needed to fulfill the purposes for which it was obtained. After the purpose for which the personal data was obtained is fulfilled we delete your personal information.
However, in some cases your personal information can be stored for a longer period in that scope, which is needed for these purposes:
- For contacting with you. If you ever got in touch with us, we can store your name and contact information in order to communicate with you. Anyway, the contact information will not be stored longer than 3 years after the last contact with you.
- For fulfillment of legislative requirements. If laws of one of the countries stipulate the storage of personal information we will process it in order, specified in such laws. Moreover, if we get a complaint or lawsuit from you we will store your personal information until then the dispute will not be resolved.
8. Your Rights
You as the data subject have the following rights relating to the processing of your personal data:
- Right of access (right to obtain from Tavrida as the controller confirmation as to whether your personal data are being processed and other information concerning your personal data, including information about the purposes of processing, the categories of processed personal data, the categories of recipients of tour personal data, the period of personal data storage, the existence of automated decision-making, including profiling, in respect of your personal data);
- Right to lodge a complaint with a supervisory authority (a supervisory authority is a state authority in your country which supervises the compliance with GDPR by legal and natural persons that process personal data of data subjects);
- Right to rectification (right to the rectification of inaccurate personal data concerning you);
- Right to erasure (right to obtain the erasure of personal data concerning you);
- Right to restriction of processing (right to obtain from Tavrida as the controller restriction of processing on the legal grounds provided in Art.18 GDPR (for example, when the accuracy of the personal data is contested by you or we no longer need the personal data for the purposes of the processing));
- Right to data portability (the right to receive the personal data concerning you, which you have provided to Tavrida, in a structured, commonly used and machine-readable format, and the right to transmit those data to another controller without hindrance from us);
- Right to object (right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, including the right to object at any time to processing of personal data concerning you for marketing purposes);
- Right not to be subject to a decision based solely on automated processing, including profiling;
- Right to file the request or complaint to Tavrida as the controller of your personal data.
- Right to withdraw your consent for personal data.
9. Protection of Your Personal Data
We employ reasonable security measures to protect your information from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. These measures include: 1) personal data encryption; 2) technical measures in order to ensure the ongoing confidentiality; 3) personal data back-up to restore access to personal data following an incident; 4) test the effectiveness of the measures on the regular basis.
Besides, we use the system of authentication, restrict the access to our servers that store your personal data, and provide the appropriate update of our software necessary for securing your personal data. We may update the list of such measures from time to time, provided that such updates and modifications do not result in the degradation of the overall security of personal data processing.
10. Personal Data Disclosure. Recipients of Your Personal Data
We will not share, sell or distribute any of the information you provide to us without your consent. However, upon certain events we are entitled to share your personal data without your consent:
- with the relevant authority such as the police or a court, if necessary for compliance with a legal obligation to which we are subject, e.g. a court order;
- with our regulatory body or our insurance company in the event of a complaint or insurance claim being brought against us; or
- with our solicitor in the event of any investigation or legal proceedings being brought against us.
11. Personal Data Transfers to Countries Outside EU
When you fill in a contact form through www.tavrida.com, the personal data you provide us automatically flows to our hosting company TimeWeb which is located in Russia, a country outside EU. Russia is not considered to provide the same level of protection of personal data as EU under the GDPR. Therefore, before you fill in a contact form through our website and give us consent on the processing of your personal data, we inform you that your data will be transferred to Russia. We request your explicit consent for personal data transfer to Russian Federation before beginning of processing.
If you are planning to become our client or is our client your personal data may be transferred to Russian Federation for the purposes of performance of a contract or implementation of pre-contractual measures (art.49 (1) (e) GDPR).
After your personal data is processed by TimeWeb, it is being sent to one of the joint controllers for further handling. We also inform you that two of the joint controllers are located outside EU:
- OOO Tavrida Electric is located in Russia which is not considered to provide the same level of protection of personal data as EU under the GDPR;
- Tavrida Electric AG is located in Switzerland which is considered to provide the same level of protection of personal data as EU under the GDPR.
12. Automated Decision-Making
Automated decision-making takes place when an electronic system uses your personal information to make a decision without human intervention.
Tavrida does not use automated decision-making. You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
13. Final Provisions
Effective day: 30 May 2019