Privacy Policy

Last modified: 01.11.2018

WEBSITE PRIVACY POLICY

 

Alcor-Ukraine LLC (“Alcor”, ”Company” or “We”) is a business process outsourcing company with its headquarters in Kyiv, Ukraine. Alcor controls the collection and processing of any personal data provided to it in relation to this website alcor-bpo.com (our “Website”).

 

This Policy (including our Cookie Notice) describes in detail the types of personal information that Alcor, including respective affiliates, may collect from you or that you may provide when you visit the Website and explains our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on this Website, in email, text, and other electronic messages between you and this Website, other information provided or acquired through the use of our Website, whether accessed via a computer, mobile device, or other means.

 

Contents

  1. Data that we collect
  2. Legal grounds & how we can use your personal data
  3. Your rights with respect to personal data
  4. How long do we keep your personal data
  5. Sharing and transferring personal data
  6. Personal data security
  7. Contacts
  8. DATA THAT WE COLLECT

“Personal data” is any information that relates to you and that identifies you either directly from that information or indirectly, by reference to other information that we have access to. The personal data that we collect, and how we collect it, depends upon how you interact with us. Categories of personal data that we collect include:

  • Contact information (name, email, telephone number);
  • Personal information that you disclose to us in your requests or when applying to one or more of our open positions via our Website (job title, employer, citizenship, physical address, professional experience, education etc.);
  • Information about your equipment and interaction with our Website, online identifiers (IP address, cookies etc.)

We collect personal data directly from you when you send an inquiry, subscribe to our news or apply for a job via the Website.

When you visit our Website and provide your consent to the use of cookies (except for the strictly necessary cookies which are vital for the functioning of our Website), we automatically collect, store and use technical information about your equipment and interaction with our website. This information is sent from your computer to us using a variety of cookies, which may be provided either by us or by our online service providers, such as Google LLC, Facebook Inc. (see more in our Cookie Notice).

We do not intentionally collect any sensitive personal data (data that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health or data concerning sex life or sexual orientation) from (or about) you via the Website. Our intention is not to process such information.

Our Website is not directed to children under the age of eighteen years and we do not knowingly solicit, collect or process personal data from persons under eighteen years of age. If we become aware of the fact that personal data of persons less than eighteen years of age has been collected via the Website, we will take the appropriate steps to delete this information without undue delay.

  1. LEGAL GROUNDS & HOW WE CAN USE YOUR PERSONAL DATA

Your local law may require us to set out the legal grounds on which we rely in order to process your personal data. Depending on the situation, we rely on one of the following processing conditions:

  • our legitimate interest in the effective delivery of information and services to you and in the effective and lawful operation of our business, developing and improving our business, services, and offerings (provided these do not interfere with your rights);
  • to perform our obligations under a contractual arrangement with you;
  • to satisfy any requirement of law, regulation or professional body of which we are a member (for example, for some of our services, we have a legal obligation to provide the service in a certain way); or
  • if you have agreed to us processing your personal information for the relevant purpose.

Alcor may use the collected personal data for the following purposes:

  • to handle and process inquiries and job applications submitted by visitors of our Website;
  • to improve the user experience;
  • to send our subscribers informational content they subscribed to;
  • for own direct marketing purposes;
  • to provide, maintain, administer, support, protect and improve the services;
  • to meet the regulatory compliance requirements set forth in the applicable laws;
  • to provide customer support;
  • to protect the rights, property, and safety of Alcor and third parties;
  • for troubleshooting, investigating and fixing Website-related errors;
  • to respond to user’s requests for exercising user’s rights under the applicable data protection laws.
  1. YOUR RIGHTS WITH RESPECT TO PERSONAL DATA

You may have certain rights under your local law in relation to the personal information we hold about you:

Access

If you ask us, we will confirm whether we are processing your personal data and, if necessary, provide you with a copy of such personal data (along with other details). There are exceptions to this right; for example, where information is legally privileged or if providing you with the information would reveal personal data about another person.

Data portability

You have the right, in certain circumstances, to receive your personal data provided by you to us and the right to reuse it elsewhere or to send the data to another organization (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

Rectification

You may require us to update or correct any inaccurate personal data, or to complete any incomplete personal data, concerning you. If you do, we will take reasonable steps to check the accuracy of, and correct the information. Please let us know if any of your information changes so that we can keep it accurate and up to date.

Withdrawal of consent

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. Your withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Objection

You can ask us to stop processing your personal information, and we will do so, if we are:

  • relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or
  • processing your personal information for direct marketing purposes.

Erasure

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If you are entitled to erasure and if we’ve shared your personal data with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Restriction of processing

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us. If you are entitled to restriction and if we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

Rights in relation to automated decision-making and profiling

You have the right to be free from decisions based solely on automated processing of your personal data, including profiling, that affect you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us or you provide your explicit consent.

This is why we request your consent before analyzing your information (on our own or via our providers) to build individual profiles. These profiles may be used to find out your interests and display targeted (online) advertisement. The aim is to provide you with offers that are relevant and interesting for you. The profiling is based on repeated interaction with Alcor Website, emails, and content. As we will not collect your name and other important personal data, such as addresses or bank details in the course of such profiling, we expect that such profiling will have no further impact, other than providing you with a more pleasant user experience when surfing the Internet. No automated decisions will be made that would result in legal effects or similarly significantly affect an individual.

Complaint

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal data, you can report it to the relevant Supervisory Authority.

 

Please note that some of these rights may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of legal professional privilege or professional secrecy obligations.

You can exercise the above rights, where applicable, by contacting our data privacy team – dpo@alcor-bpo.com. We will require you to provide satisfactory proof of your identity in order to ensure that your rights are respected and protected. This is to ensure that your personal data is disclosed only to you.

  1. HOW LONG DO WE KEEP YOUR PERSONAL DATA

We do not keep your personal data for any longer than is necessary to fulfill the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims.

For example, we will keep your personal data obtained in connection with your subscription to our emails until you unsubscribe, personal data obtained in connection with your service inquiries – until the matter of inquiry is resolved, for cookie files (depending on the type of cookie) – during the term specified in our Cookie Notice (unless we have a separate legitimate purpose for keeping such information).

Please contact our data privacy team (dpo@alcor-bpo.com) if you have any questions about how we keep your personal data.

  1. SHARING AND TRANSFERRING PERSONAL DATA

Since Alcor is headquartered in Kyiv, your personal data will be mostly processed outside of the EEA, particularly in Ukraine. If you are from one of the EEA (EU) countries, you should be informed that European Commission hasn’t determined Ukraine as a country which offers an adequate level of data protection, which entails certain risks of losing the protection provided under the General Data Protection Regulation, when your personal data is transferred outside of the EEA.

Still, we do our best to protect your data by sticking to appropriate internal policies and using state-of-the-art security means that follow EU requirements for the safe and lawful processing of personal data.

We do not share personal data with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or as described herein. We may share personal data with Alcor affiliated companies where necessary in connection with the purposes described in this Policy – for example, we may share personal data with our affiliates that may be involved in the provision of services requested by the user of our Website. We also may transfer your personal information to our third party service providers, such as our IT systems providers, our website hosting providers, data analysis, data backup, security and cloud storage services, consultants and other providers.

We work with such providers so they can process your personal information on our behalf. Alcor will only transfer personal information to them when they meet our strict standards on the processing of data and security and flow those same standards down to their sub-processors. We only share personal information that allows them to provide their services and will not transfer the personal information you provide to any third parties for their own direct marketing use.

  1. PERSONAL DATA SECURITY

We have security measures in place to protect our and our clients’ information (including personal data), which involve preventing, detecting, investigating and resolving security threats.

We have implemented technical and organizational measures to safeguard and secure your personal data. All our personnel and third parties that we engage to process your personal data are obliged to respect your data’s confidentiality.

We restrict access to your personal information, and only employees who need to access your personal information to perform specific jobs are granted with such access. We are working with service providers and third-party players to ensure that physical security of computer hardware and software solutions are at the highest level.

Although we use industry-standard precautions to safeguard your personal data, the transmission of data over the Internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but 100% complete security does not presently exist anywhere online or offline.

  1. CONTACTS

If you have questions or complaints regarding this Policy or the way your personal data is processed, or would like to exercise a legal right in relation to your personal data, please contact us by one of the following means:

Email: dpo@alcor-bpo.com

Telephone: +380-44-359-13-60

Postal address: 03056, UKRAINE, KYIV, POLIOVA STR., 24D

We may from time to time update this Policy to reflect changes in our practices. We recommend you to check this page from time to time to inform yourself of any changes in the Policy or any of our other policies/notices.