NOVA POST UK LTD PRIVACY POLICY
This Privacy Policy (hereinafter: "Policy") is intended to inform you about the processing of your personal data by NOVA POST UK LTD (hereinafter: "Company", "Nova Posta" and/or "we"), "us", " our") when visiting the website https//novapost.com/en-gb/, as well as when using the services provided as part of our economic activity as a postal operator (hereinafter: "Services"").
Before starting to use the Services, we recommend that you familiarize yourself with this Policy, as it contains all the information necessary to fulfill our obligations set out in Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data, as well as the repeal of Directive 95/46/EC (hereinafter: the UK GDPR). This Policy also applies to the processing of personal data and communications carried out by the Company's accounts in social networks (for example, Facebook, Linkedin), including with regard to other related activities, such as customer support, direct marketing, recruitment, as well as video surveillance during visits to our branches.
I. WHO IS THE DATA CONTROLLER UNDER THE UK GDPR FOR THE PROCESSING OF YOUR PERSONAL DATA
NOVA POST UK LTD, a company incorporated under the laws of Great Britain under company registration number 15032836 with its head office and management address at c/o RWK Goodman, 69 Carter Lane, London, England, ec4v 5eq; is the data controller responsible for the processing of your data within the scope of the activities listed below.
If you have any questions or complaints about data protection, please contact us at the following coordinates:
- 1By mail to: c/o RWK Goodman, 69 Carter Lane, London, England, ec4v 5eq;
- 2External data protection officer
Privacity GMBH
Neuer Wall 50, 20354 Hamburg, Excellent
Business Center
Hamburg, Germany
Email: dpo@novapost.com
II. CURRENT LEGISLATION ON THE PROTECTION OF PERSONAL DATA AND OBLIGATIONS TO CONFIDENTIALITY
- 1The company, as a data controller, is subject to the provisions of the General European Data Protection Regulation (GDPR); General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018 (DPA 2018).
- 2NOVA POST UK LTD, acting as a licensed postal operator under the UK Postal Act 2000, is also required to maintain the confidentiality of correspondence and ensure the integrity of postal items.
III. INFORMATIONAL SECURITY
- 1New Post takes appropriate technical and organizational measures to protect personal data from loss, damage, unauthorized disclosure, changes or any form of improper use.
- 2All legal notices on this website regarding the protection of personal data are drafted in accordance with applicable data protection legislation.
IV. HOW WE COLLECT YOUR PERSONAL DATA
- 1NOVA POST UK LTD collects your personal data through different channels and sources, for different purposes and on different legal grounds in accordance with the UK GDPR.
- 2In order to provide our Services, we collect your personal data directly from you when you send your parcels. In addition, we receive personal data from third party senders when you are the recipient of the shipment.
- 3We also collect your personal data each time you visit our website to ensure safe and full access to website features and content. In addition, you may provide us with additional personal data if you choose to register on our website in order to use the Services presented on it (shipment placement, tracking and forwarding of packages, etc.).
- 4Your personal data is also collected when you contact us through communication channels such as the contact form available on our website, email or telephone.
- 5Our website also uses cookies and other tracking technologies that are stored in your device's browser. These technologies serve to improve the functionality of our website, to remember your preferences and settings on it, to analyze user behavior for statistical purposes, and to provide advertising content tailored to your interests.
More information about what cookies are, the different types of cookies and tracking tools used on our website and how we use them in accordance with applicable data privacy laws can be found in our Cookies Policy cookie
IV. RIGHTS OF DATA SUBJECTS
- 1As a data subject, you have the following rights under the UK GDPR and DPA 2018:
- 1.1The right to access your personal data stored by us, in accordance with Art. 15 UK GDPR;
- 1.2The right to rectification of your personal data that we store that is incorrect and/or incomplete in accordance with Art. 16 UK GDPR;
- 1.3The right to delete your personal data that we store, in accordance with Art. 17 of the UK GDPR (right to be forgotten);
- 1.4The right to request restriction of processing of your personal data in accordance with Art. 18 UK GDPR if you dispute the accuracy of the data; the processing is unlawful; The Company no longer needs the personal data for its purposes, but you need it to establish, exercise or defend legal claims; or if you have objected to the processing in accordance with Art. 21 https://ico.org.uk/global/contact-us/;
- 1.5The right to transfer data in accordance with Art. 20 UK GDPR, i.e. you may require us to provide you with your personal data in a structured, commonly used and machine-readable format, including requiring us to transfer this data to another data controller;
- 1.6The right to lodge a complaint with a national supervisory authority in the Member State of your habitual residence, place of work or place of alleged breach if you believe that the processing of your personal data by us infringes the UK GDPR.
The competent data protection authority for NOVA POST UK LTD is the Information Commissioner's Office (hereafter: " ICO "), website: https://ico.org.uk/global/contact-us/.
- 2You can exercise the above rights by contacting us at dpo@novapost.com by sending us an email in any form and specifying the specific right you wish to exercise. If we have reasonable doubts, we may ask you to provide additional information to verify your identity.
V. WITHDRAWAL OF CONSENT TO PERSONAL DATA PROCESSING
- 1If the basis for data processing is your consent, you have the right to withdraw it at any time. You can request the withdrawal of your consent by emailing us at dpo@novapost.com or by mail at c/o RWK Goodman, 69 Carter Lane, London, England, ec4v 5eq.
- 2However, the withdrawal of consent does not affect the lawfulness of the previous processing of your personal data.
- 3The withdrawal of consent may not be effective if the processing of your personal data is necessary for the proper provision of the Services to you or for the performance of an ongoing agreement with you, including the handling of a complaint. In this case, the withdrawal of the above consent becomes effective after the refusal to use the Services, the termination/termination of the agreement or the complaint process.
- 4Despite the actual withdrawal of your consent, the Company may continue to process your personal data to the extent necessary for:
- 4.1presentation of lawsuits related to the concluded contract;
- 4.2fulfillment of legal obligations assigned to Nova Post;
- 4.3performance of a task in the public interest or during the exercise of government powers granted to the Company;
- 4.4purposes arising from the legitimate interests of the Company or a third party, unless these interests are overridden by your interests or fundamental rights and freedoms as a data subject.
VI. CATEGORIES OF PERSONAL DATA. PURPOSES OF THEIR PROCESSING AND LEGAL BASIS
Below you can find information about each data processing we carry out, including the categories of personal data we collect from you, the purposes for which this data is processed and the legal grounds on which this processing is based in accordance with the UK GDPR:
- 1Processing of personal data when using our Services
- 1.1To provide you with the requested Services both in our branches and online through our website and/or application (for example, creating a shipping order, forwarding parcels, tracking parcels, etc.), respectively, to fulfill the relevant agreement with you as our customer (to the sender and/or recipient of postal parcels delivered by Nova Post), it is necessary to process the following categories of data:
- 1.1.1Identification data: for natural persons: name, personal identification code (PIN), signature and other relevant data contained in the document certifying the identity of the sender, respectively the recipient of the parcel, or his/her authorized representative, contact person; for contact persons/legal representatives of legal entities and for individual entrepreneurs: full name, company identification number, position;
- 1.1.2Contact information: address (postal code, city, country, etc.), e-mail address, phone number; location (for contact persons/legal representatives of legal entities and individual entrepreneurs);
- 1.1.3Financial information: bank account number, payment card details stored on our website/app, payment status and details contained in invoices and payment receipts;
- 1.1.4Data related to the services used: country of dispatch and delivery of the parcel, type of shipment, description of the item, distribution and time of delivery, information about the sender and recipient of the shipment, tracking number and status of the package, location of the package, number of items included in the package, weight, size, contents and value of the parcel, method of receipt, customs information, if applicable;
- 1.1.5Voice data contained in recorded telephone calls made for the purpose of resolving unresolved issues, inquiries and/or complaints to the Company;
- 1.1.6Geolocation data is processed for the purpose of tracking parcels.
- 1.2The above personal data is necessary for us to provide the requested Services (sending and delivery of postal parcels), including for the following purposes:
- 1.2.1draw up accounting and payment documents;
- 1.2.2if necessary, confirm your identity as the recipient of the package; Nova Post does not collect and/or store copies of ID cards;
- 1.2.3to draw up the necessary documents related to the movement and tracking of the parcel, to contact you at any time, if it is necessary for the successful, high-quality and timely execution of your assignment;
- 1.2.4provide customer support, respond to, consider and process your inquiries, requests and/or complaints, etc. with respect to the Services provided;
- 1.2.5to carry out solvency control, compliance programs, surveys on satisfaction with the Services provided (as well as analyze the results of conducted surveys and contact customers about such surveys).
- 1.3We process the above personal data on the following legal grounds in accordance with the UK GDPR:
- 1.3.1to provide the Services in accordance with a contractual agreement with you or to take steps at your request prior to entering into such an agreement − Art. 6, par. 1, letter "b" of the UK GDPR;
- 1.3.2to comply with our statutory obligations as a licensed postal operator under the UK Postal Act 2000 to properly charge for the Services provided, review and deal with complaints about the Services etc. − Art. 6, par. 1, letter "c" of the UK GDPR;
- 1.3.3to fulfill our statutory obligations arising from the current financial and accounting legislation (Accounting Act, Corporate Income Tax Act, Value Added Tax Act, etc.) regarding accounting reporting and tax control −Art. 6, par. 1, letter "c" of the UK GDPR;
- 1.3.4to fulfill our legal obligations arising from the Law on Customs Affairs, regarding compliance with customs requirements for international shipments −of Art. 6, par. 1, letter "c" of the UK GDPR;
- 1.3.5on the basis of our legitimate interest, −Art. 6, par. 1, letter (f) UK GDPR, to carry out solvency checks, compliance programmes, satisfaction surveys with the Services provided to you as our customer;
- 1.3.6on the basis of our legitimate interest, −Art. 6, par. 1, letter (f) UK GDPR to respond to and process your enquiries, inquiries about the Services provided to you as our customer;
- 1.3.7based on your express consent− Art. 6, par. 1, letter "a" of the UK GDPR relating to your geolocation data for the purpose of tracking your shipment.
- 1.4Provision of personal data for statutory or contractual requirements of Nova Post is necessary for you to receive the requested Services. Failure to provide such data or a request to delete or restrict the processing of such data may result in us not being able to provide you with the requested Services.
- 2Processing of personal data when visiting our website or mobile application
- 2.1Every time you visit our website www.novapost.com, a log file is created that contains the following information:
- 2.1.1IP address;
- 2.1.2Domain name;
- 2.1.3date and time of access;
- 2.1.4response code;
- 2.1.5operating system name and version;
- 2.1.6web browser name and version;
- 2.1.7visited pages;
- 2.1.8Screen extension;
- 2.1.9data related to placing an order and actions aimed at its fulfillment.
- 2.2We collect and process the above data from your device to provide you with secure and full access to our website and its services, including monitoring and detecting security-related events, suspicious login attempts, potential threats and other performance details website. This data is collected through log entries or strictly necessary cookies used by the website.
More information about cookies and other similar technologies used on our website can be found in our Cookie Policy. - 2.3Personal data that is processed with the help of long records and strictly necessary cookies is based on our legitimate interests - Art. 6, par. 1, letter "f" of the UK GDPR. You can choose to block the use of strictly necessary cookies in your web browser settings. However, in this case, certain features and functions on our website may become unavailable to you or may stop working properly.
- 2.4Authentication through social networks, Face ID and FingerID:
Our mobile application may offer the possibility of authorization through an account on popular social networks such as Facebook, Google or others. In such case, if you choose this login method, we may receive limited information from your account on the relevant social network, such as your name, email address or other personal data that you allow us to receive in accordance with the privacy settings of your profile in a social network. This information is used only to authenticate the user and provide access to the functionality of the application.
In addition, our application may support biometric authentication technologies such as FaceID for Apple devices or FingerID (fingerprint scanning) for devices that support this feature. If you choose to use these technologies to log in to our App, we will store your biometric data locally on your device and use it only to authorize your access to the App.
- 3Processing of personal data when creating a user profile on our website
- 3.1You may choose to register on our website/app to access advanced settings and request additional services and make online payments. If you create a user profile, we will process certain categories of data to identify you as a user and to handle your inquiries regarding the online services available on our website/app. The categories of personal data processed for these purposes include:
- 3.1.1Telephone number and international telephone code specific to your country of residence;
- 3.1.2Email address;
- 3.1.3First and last name;
- 3.1.4Geolocation data.
- 3.2We collect and process the above data directly from you in order to give you access to additional features available on our website and app.
- 3.3This processing of personal data is necessary to fulfill contractual obligations - Art. 6, par. 1, letter "b" of the UK GDPR. Geolocation data can be processed only on the basis of your express consent - Art. 6, par. 1, letter "a" of the UK GDPR.
You may request deletion of your user profile at any time by contacting us at dpo@novapost.com.
- 4Direct marketing
- 4.1In order to send you relevant commercial and marketing communications about our latest products and services, including specific offers, discounts, etc., we process the following categories of personal data by electronic means:
- 4.1.1Phone number taking into account direct marketing SMS messages;
- 4.1.2Email regarding direct marketing communications sent by email;
- 4.1.3Information about your device using which you access our website/app for the purpose of push marketing notifications.
- 4.2We process your personal data above to inform you, in particular, about our latest product and service offers provided by NOVA POST UK LTD.
- 4.3This data processing can be carried out on one of two legal grounds:
- 4.3.1if you are already a client of "Nova Post" and have previously used our Services (you sent postal parcels), we rely on our legitimate interest in processing your personal data and sending you direct marketing messages related to Art −. 6, par. 1, letter "f" of the UK GDPR. For each case of commercial solicitation based on our legitimate interest, we provide you with the option to easily opt out of receiving such marketing communications in the future. This opt-out can be easily done through the same channels through which you received direct marketing communications, such as clicking the opt-out button in a marketing email received from us, using a free SMS opt-out message, etc.; or
- 4.3.2if you are not a Nova Post customer, we can only rely on your express, freely given consent to send you any direct marketing content art −. 6, par. 1, letter "a" of the UK GDPR. You have the right to withdraw your consent at any time after it has been given. This withdrawal, however, will not affect the lawfulness of the processing carried out on the basis of consent before its withdrawal.
- 5Recruitment of personnel
- 5.1In cases where you contact us in relation to vacancies available on our website careers page or through communication channels such as email, contact form or through other public platforms used for professional purposes (e.g. Linkedin), we will request and process the following categories of your personal data:
- 5.1.1Identification data: names, surnames, date of birth, if any;
- 5.1.2Contact Information: address, telephone number, e-mail address;
- 5.1.3Application details: resume, cover letter, certificates, job references, interview notes and any data you provide us or wish to provide during the interview;
- 5.1.4Photo, if available;
- 5.1.5Citizenship and work permit, if any;
- 5.1.6Health data to assess your fitness for work, if applicable.
- 5.2We process your personal data for the following purposes related to our internal recruitment process:
- 5.2.1evaluate your job application and suitability for the open position;
- 5.2.2to communicate with you about the status of your application, arrange and interview you, etc.
- 5.2.3to store your application for future vacancies at Nova Post.
- 5.3The data processing activities described above (collecting job applications, conducting the recruitment process and assessing the suitability of the job candidate) are necessary to fulfill contractual obligations or take pre-contractual measures at your request− Art. 6, par. 1, letter "b" of the UK GDPR. In addition, we may ask you to consent to the processing of the details of your job application for future positions at NOVA POST UK LTD in accordance with Article 6 para. 1, letter "a" of the UK GDPR and Article 7 of the UK GDPR.
- 5.4The personal data you have provided to us through public platforms used for professional purposes (LinkedIn) are processed in accordance with the applicable terms of the company responsible for managing the platform. We recommend that you read the privacy policy of the respective platform to learn more about the processing of your personal data.
- 6Video surveillance
- 6.1We monitor and process your personal data (video recordings) when you visit our branches, both for your personal safety and for the safety of our employees, customers and property.
- 6.2Video surveillance is carried out without identification in compliance with strict security and confidentiality rules using modern technologies and equipment.
- 6.3The legal basis on which we conduct our video surveillance activities is our legitimate interest− Art. 6, par. 1, letter " f" of the UK GDPR to ensure the safety and security of staff and customers and to protect our property.
- 7Customer support
- 7.1When contacting our support service, all calls are recorded in order to improve our customer support services. In this context, we process voice data related to you, and the data processing begins when your call is answered and ends when the call ends. During each telephone call, we inform you of this data processing activity and give you the opportunity to opt out of the recording of the call in real time or by taking a further action, such as requesting the deletion of your voice data by contacting us at dpo@novapost.com.
We base our call recording operations on our legitimate interests to improve the quality of our customer support services− Art. 6, par. 1, letter "f" of the UK GDPR. - 7.2When you conduct chat and/or chatbot sessions, our program records the following information:
- 7.2.1Session time;
- 7.2.2Names of the consultant and client participating in the chat session, if applicable.
- 7.3Chat sessions involve providing customer support services and are conducted between the customer and a Nova Post support employee, while chatbot sessions are customer support sessions between an automated chatbot and a customer. The content of the chatbot responses is mainly collected from the website and other public sources available to anyone. At the beginning of the session, customers are provided with instructions for using the chatbot. The customer is not asked any personal questions, and the customer cannot solve personal questions through the chatbot service. If a customer provides the chatbot service with digitally identifiable information, such as a phone number, this information is automatically deleted after one hour. The legal basis for storing data related to a customer service chat and chatbot session is our need to fulfill contractual obligations or to take pre-contractual measures at your request− Art. 6, par. 1, letter "b" of the UK GDPR
- 7.4If we send an SMS request to a customer who has contacted our service number by phone for customer support, the following data is recorded:
- 7.4.1Request time;
- 7.4.2the client's phone number;
- 7.4.3Written responses of the customer to the request.
We base this data processing related to the customer support services provided via SMS on our contractual necessity or to take pre-contractual measures at your request− Art. 6, par. 1, letter "b" of the UK GDPR.
VII. RECIPIENTS OF YOUR PERSONAL DATA
- 1New Mail, as a data controller, may provide personal data related to you to the following third-party recipients:
- 1.1legal entities that are part of the "Nova Post" corporate group and/or subcontractors (for example, transport partners, operating parcel reception points or parcel storage rooms) both in the European Union and in the European Economic Area or outside its borders for the purpose of delivery of parcels sent from the sender to the corresponding recipient;
- 1.2legal entities that are subjects of a contract for the provision of services with "Nova Post" or on behalf of "Nova Post", which act as data processors, in particular IT service providers;
- 1.3banks and payment service operators for transactions;
- 1.4when it is required to report data in accordance with the law, a court order or other legal procedures - to employees of law enforcement agencies, state bodies and institutions in order to comply with the requirements of the law, participate in legal proceedings to protect the property of "Nova Post" and conduct investigations into violations of the Company's policies and terms of use, including unauthorized access or illegal use of Nova Post equipment, or any other illegal activity.
- 2In cases of international transfer of personal data, NOVA POST UK LTD relies on the derogations provided for in Article 49, par. 1, subparagraphs "b" and "c", according to which these transfers are legal, as they are necessary for the performance of the contract on the provision of postal services between the data subject and the Company, as a data controller, or for the conclusion or performance of a contract concluded in the interests of the data subject.
- 3Only the sender and recipient of the postal package have the right to receive information about the shipment (content description, size, weight, tracking number, etc.). NOVA POST UK LTD may only provide such information to others in the cases specified in the relevant provisions of applicable laws and regulations, including the Postal Services Act, the Customs Act and relevant secondary legislation.
VIII. DATA STORAGE AND DELETE PERIODS
1 New Post only processes personal data for the time necessary to achieve the purpose for which the data was originally collected. Storage terms are determined according to the following criteria:
- 1operational requirements: the period during which personal data is necessary for the performance of the provided Services;
- 2legal requirements: the specific statutory period during which NOVA POST UK LTD is required to comply with applicable laws and regulations;
- 3legitimate interests of "Nova Post": the period during which the data is processed for the purpose of establishing, considering and defending against possible claims in connection with the provided Services.
2 What information do we collect about you and how long do we keep it?
- What data do we collect/process?Collection and delivery of parcels
The name of the sender and recipient of the package, address of the place of delivery, phone number, email address and other information provided to us by the sender, as well as the signature of the recipient of the package (provided at the time of receipt).
Data created by us: parcel number, delivery confirmation, GPS data of the place of receipt and delivery of the parcel.Execution of contracts (offers)For individuals: surname, first name, patronymic, address, telephone number, e-mail address.
For representatives of legal entities on whose behalf the contract is concluded (for example, company employees, contact persons): surname, first name, patronymic, position, telephone number, e-mail address, signature.Customs administrationSurname, first name, phone number, e-mail address, parcel number, sent messages, content and price of the product.
Making payments and keeping accounting recordsData contained in accounting and tax control documents: surname, first name, patronymic, tax number, contact information, bank account number, payment details, details of services provided and other information in accordance with current legislation.
Direct marketing (informing about our services and conducting surveys to evaluate the quality of our services)First name, last name, email address, phone number, device information
Managing our social media accountsFirst name, last name, account name, gender, contact information (if you provide it to us), country, photo, comments on our posts, distribution of our posts, reactions to our posts, reviews and ratings left, information about, when you started following or liking our social network account, messages sent to us with attachments, your message history with us (message content and when they were received/sent)
Processing requests, complaints and appeals (internal administration)Name, surname, contact details and any other information or documents you provide to us.
Recording of conversations in order to ensure the quality of the provision of customer support and information services, protection of the rights and legitimate interests of employees and interested parties.Voice data (telephone call recording), name of the support service operator, subscriber's phone number, call date, start and end time are collected
Ensuring the security of parcels stored in post offices and protecting the Company's assets (video surveillance)Video data (video recordings), date and time of collection
Analyzing user experience and quality to improve our servicesThe following data is collected and processed from visitors to our website: IP address, operating system, user ID and other information about the visitor's activities on our website and other websites.
This information is collected and stored as part of log entries or through strictly necessary cookies. - Legal basisCollection and delivery of parcels
In the case of the sender:
(1) execution and conclusion of a contract with the data subject −Art. 6, par. 1, letter "b" of the UK GDPR; and
(2) compliance with a legal obligation applicable to the Company. −Art. 6, paragraph 1, lit. "c" of the UK GDPR.
In the case of the recipient of the package:
(1) compliance with legal obligations applicable to the Company −Art. 6, par. 1, letter "c" of the UK GDPR; and
(2) our legitimate interest in delivering the parcel to the correct recipient (identity confirmation) −Art. 6, par. 1, letter "f" GDPR UK.Execution of contracts (offers)(1) Execution and conclusion of a contract with a data subject −Art. 6, par. 1, letter "b" of the UK GDPR.
(2) Our legitimate interest in concluding and executing a contract with the other party to the contract through its representative (for the purpose of concluding, executing, communicating, identifying, signing documents, etc.) Art. 6, par. 1, letter "f" of the UK GDPR.Customs administrationCompliance with legal obligations applicable to the Company −Art. 6, par. 1, letter "c" of the UK GDPR
Making payments and keeping accounting recordsFulfilling the legal obligation to maintain proper accounting and tax control documents −Art. 6, paragraph 1, lit. "c" of the UK GDPR, in particular under the Companies Act 2006, International Financial Reporting Standards (IFRS), the Corporation Tax Act 2010 and the Value Added Tax Act 1994.
Direct marketing (informing about our services and conducting surveys to evaluate the quality of our services)(1) If the data subject is a client of the Company's Services, the data is processed on the basis of our legitimate interests, −Art. 6, par. 1, letter "f" GDPR, and the Privacy and Electronic Communications Rules (EU Directive) (as amended) 2011;
(2) If the data subject is not a customer of the Company's Services, the data is processed with the express consent of the data subject− Article 6, paragraph 1, letter "a" GDPR and the Privacy and Electronic Communications Regulations (EU Directive) (as amended) 2011
3) We conduct surveys based on our legitimate interests in improving the quality of our Services− Article 6, paragraph 1, letter “f” GDPR.Managing our social media accountsOur legitimate interest in maintaining public admin pages in various social media in order to increase our online presence −Art. 6, par. 1, letter "f" GDPR
Processing requests, complaints and appeals (internal administration)It is our legitimate interest in the proper and prompt consideration of received complaints, inquiries and requests− Art. 6, paragraph 1, letter “f” GDPR
Recording of conversations in order to ensure the quality of the provision of customer support and information services, protection of the rights and legitimate interests of employees and interested parties.Our legitimate interest in improving our customer support services− Art. 6, par. 1, letter "f" GDPR.
Ensuring the security of parcels stored in post offices and protecting the Company's assets (video surveillance)Our legitimate interest in ensuring the security of parcels stored in post offices (branches), as well as in the protection of the Company's assets and the health of employees and customers− Art. 6, par. 1, letter "f" GDPR
Analyzing user experience and quality to improve our servicesOur legitimate interest in ensuring secure and full access to the website and detecting security-related events− Art. 6, par. 1, letter "f" GDPR
- Expiration dateCollection and delivery of parcels
3 (three) months for other categories of data after the date of provision of Services. After this period, the data is anonymized and stored for 3 (three) years in an archive, unless it is necessary to continue the storage for the legitimate purposes of the Company, such as identification, prosecution and defense against legal claims.
Execution of contracts (offers)3 (three) months after the end/termination of the contract; After this period, the data is pseudo-anonymized and stored for 3 (three) years in an archive, unless it is necessary to continue the storage for the legitimate purposes of the Company, such as identification, prosecution and defense against legal claims.
Customs administration6 (six) months in the Company's active database; After this period, the data is pseudo-anonymized and stored for 3 (three) years in an archive, unless it is necessary to continue the storage for the legitimate purposes of the Company, such as identification, prosecution and defense against legal claims.
Making payments and keeping accounting records10 (ten) years after drawing up the documents.
Direct marketing (informing about our services and conducting surveys to evaluate the quality of our services)1) The customer's personal data is processed for direct marketing purposes for the duration of the current contractual relationship with the customer or until the customer decides to opt out of receiving marketing communications, whichever occurs first.
2) Personal data processed on the basis of express consent are stored for 2 (two) years from the date of receipt of consent or until data subjects withdraw their consent, whichever occurs first.
3) Data used to conduct surveys will be processed within 3 (three) months from the date of provision of Services.Managing our social media accounts1 (one) year from the time you last interacted with our social media account
Processing requests, complaints and appeals (internal administration)The data is stored for 3 (three) years after the problem is resolved; Personal data may be retained for a longer period of time if necessary for the Company's other legitimate purposes, such as the establishment, prosecution and defense of legal claims.
Recording of conversations in order to ensure the quality of the provision of customer support and information services, protection of the rights and legitimate interests of employees and interested parties.6 (six) months, except when it is necessary to extend the retention for the legitimate purposes of the Company, such as establishing, prosecuting and defending against legal claims
Ensuring the security of parcels stored in post offices and protecting the Company's assets (video surveillance)30 (thirty) calendar days, except when there are reasons to believe that:
1) the video recording indicates an administrative offense, criminal offense or other violation of current legislation, labor discipline and/or professional ethics;
(2) video recording data is necessary for pre-trial or pending legal proceedings; or
(3) the official request of state authorities for access to video recording data is received before the end of the data storage period.
In such cases, the video recording data must be kept for the period necessary to fulfill the above purposes and must be deleted/destroyed immediately when it is no longer needed.Analyzing user experience and quality to improve our servicesUp to 6 (six) months after the creation of log files
2 Archive data (pseudo-animated) is still personal data, but it is only accessible to certain authorized employees of the Company. After the expiration of the data storage period, they are permanently deleted.
IX. TRANSFER OF PERSONAL DATA TO COUNTRIES THAT ARE NOT MEMBERS OF THE EUROPEAN UNION OR THE EUROPEAN ECONOMIC AREA
- 1Your personal data may be transferred to internal third parties (companies) that are directly and/or indirectly owned or controlled by the same ultimate beneficial owners as Nova Post, as well as to subcontractors (for example, transport partners, operating parcel reception points or storage chambers parcels) within the borders of Ukraine and the European Union or outside them only for the purpose of delivering parcels from the sender to the addressee (in accordance with Article 49, paragraph 1, letter "b", respectively, letter "c" GDPR);
- 2NOVA POST UK LTD does not transfer personal data to international organizations.
- 3NOVA POST UK LTD does not transfer personal data to third countries if this is impossible or contrary to generally accepted legislation.
- 4The level of protection of Personal Data outside the European Union ("EU") and the European Economic Area ("EEA") does not coincide with the level provided for by European legislation. Therefore, NOVA POST UK LTD transfers personal data outside the EU and EEA only when necessary, ensuring an adequate level of data protection, mainly through:
- 4.1cooperation with subjects of personal data processing in countries in respect of which a relevant decision of the European Commission has been issued to ensure an adequate level of personal data protection;
- 4.2the use of standard contractual provisions issued by the European Commission, provided that an adequate level of personal data protection is ensured.
- 5In the case of a justified intention to transfer personal data outside the EU and EEA, in addition to the above, the Company will notify the data subject of this fact at the appropriate stage of data processing, in accordance with current legislation.
X. CHANGES TO THIS POLICY
Any changes that may be made to this Policy in the future will be posted on the website https//novapost.com. We advise you to regularly review this Policy to be aware of the processing of your personal data. In each case, we will take reasonable steps to provide you with clear information about the changes made.