PRIVACY POLICY AND USE OF COOKIES

This Privacy Policy is an integral part of the Terms of Service and the Public Agreement , which was concluded with us at the time of ordering the service (order creation).

It also applies if you have ordered a derivative service (eg cash on delivery) from another company (eg a partner). At the same time, these third parties may also have their own privacy policies (other similar documents) that apply when collecting information about you. In addition, this Privacy Policy and the use of cookies apply to the personal data of the recipient on whose behalf the shipment is made.

I. GENERAL INFORMATION

1. This privacy policy and the use of cookies is a set of rules for the processing of personal data and the collection of cookies (hereinafter: the Policy) LLC "NEW POST" with its registered office at the address 03026, Kyiv, Stolichne shose, 103, building 1, floor 9, National State Registry of Ukrainian Enterprises and Organizations code 31316718 (hereinafter: "NEW POST" LLC or "Administrator" or "Company"), incl. on the website https://novaposhta.ua/ (hereinafter: "Service") determines what data we collect about consumers who use our services, as well as about other persons whose personal data we process in the course of our activities, including job candidates This Policy also applies to the processing of personal data and communication on the Company's social media accounts (for example, Facebook, Instagram, Linkedin, Google), by phone, email or letter, how we use it and with whom we share it. This information also describes the measures we take to protect your personal data.

2. Users can contact the Administrator in the following way:

A. by letter to the following address: "NEW POST" LLC, 03026, Kyiv, Stolichne shose, 103, building 1, floor 9;

B. by e-mail: info@novaposhta.ua;

C. by phone: +380-800-500-609

For more reliable protection of personal data, the Company has appointed a Data Protection Officer (DPO) - Serhii Zimenkov.

If you have any questions, comments or wishes regarding the protection and processing of your personal data, you can contact the DPO in the following convenient way:

A. by letter to the following address: "NEW POST" LLC, 03026, Kyiv, Stolichne shose, 103, building 1, floor 9;

B. by e-mail: dpo@novaposhta.ua

Be sure to include your full name, email address, and detailed questions, comments, complaints, or requests in all correspondence.

3. Personal data is any information relating to an identified or identifiable natural person. The scope of this type of data includes, among others: first name, last name, address, telephone number and e-mail address. Information that cannot be traced back to an identified or identifiable individual (such as statistical data) is not considered personal data.

II. CURRENT LEGISLATION ON PERSONAL DATA PROTECTION AND CONFIDENTIALITY OBLIGATIONS

1. "NEW POST" LLC is subject to the Law of Ukraine "On the Protection of Personal Data" dated 01.06.2010 No. 2297-VI and the provisions of the Regulation of the European Parliament and the Council (EU) 2016/679 of April 27, 2016 on the protection of natural persons regarding processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (hereinafter: - GDPR), as well as other relevant national legislation on data protection.

III. PROTECTION OF INFORMATION

1. "NEW POST" LLC, applying appropriate technical and organizational measures, makes all physical and technical efforts to protect personal data from loss, damage, disclosure to unauthorized persons, alteration or improper use.

2. All notifications regarding the protection of personal data are registered and explained in detail and analyzed in accordance with current legislation.

IV. RIGHTS OF DATA SUBJECTS

1. We are pleased to inform you about your rights regarding the processing of personal data in accordance with the legislation of Ukraine:

• 1
  to know about the sources of collection, the location of their personal data, the purpose of their processing, the location or place of residence (residence) of the owner or manager of personal data or to give a corresponding mandate to receive this information to persons authorized by them, except for cases established by law;
• 2
  to receive information about the terms of providing access to personal data, including information about third parties to whom personal data is provided;
• 3
  to access your personal data;
• 4
  to receive no later than thirty calendar days from the date of receipt of the request, except for cases provided by law, an answer on whether his personal data is being processed, as well as to receive the content of such personal data;
• 5
  present a motivated demand to the owner of personal data with an objection to the processing of his personal data;
• 6
  make a motivated demand for the change or destruction of your personal data by any owner and administrator of personal data, if these data are processed illegally or are unreliable;
• 7
  to protect your personal data from illegal processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of them, as well as protection from providing information that is unreliable or defames the honor, dignity and business reputation of a natural person;
• 8
  file complaints about the processing of your personal data to the Human Rights Commissioner of the Verkhovna Rada of Ukraine or to the court;
• 9
  apply legal remedies in case of violation of the legislation on the protection of personal data;
• 10
  enter a disclaimer on the limitation of the right to process one's personal data when giving 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 decision that has legal consequences for him.

2. Other rights of personal data subjects in accordance with the GDPR

In addition to the Ukrainian legislation on the protection of personal data, "NEW POST" LLC pays close attention to ensuring your rights established by the GDPR, including:

A. to receive information and have access to data concerning him/her (data subject's right of access according to Art. 15 GDPR);

B. correct your personal data that is incorrect and update your data (right to data rectification, Article 16 GDPR);

C. request the deletion of your personal data (the right to data deletion according to Article 17 of the GDPR);

D. requests to stop processing (the right to limit processing according to Article 18 GDPR);

E. request the transfer of data to another administrator (the right to transfer data in accordance with Article 20 GDPR);

F. objection to the processing of his/her personal data (right to object according to Art. 21 GDPR).

V. EXERCISE OF RIGHTS UNDER GDPR

• 1
  Access to personal data. You have the right to request confirmation from us as to whether we are processing personal data relating to you and, in such cases, to request access to your personal data that we are processing, or to provide information about the personal data if direct access is not available.
• 2
  Correction of personal data. If you believe that information about you is incorrect or incomplete, you have the right to ask us to correct it.
• 3
  Withdrawal of consent. Since we process your personal data based on your consent, you have the right to withdraw your consent to the processing of personal data at any time.
• 4
  Objection to data processing for the purpose of providing direct marketing and sending commercial and marketing information. You have the right to object at any time to the processing of your personal data for the purpose of placing targeted advertising.
• 5
  Objection to processing based on legitimate interests. You have the right to object to the processing of personal data that we process based on our legitimate interests, but we will continue to process your data even if you object if we have compelling reasons to continue processing the personal data. To exercise the above rights, please send a written request to us or to our DPO as specified in Section 1 of this Policy.
• 6
  Removal. In certain circumstances, you have the right to ask us to delete your personal data, but this does not apply where the law requires us to retain the data. To exercise the above rights, please send a written request to us or to our DPO as specified in Section 1 of this Policy.
• 7
  Restrictions on processing. Under certain circumstances, you have the right to restrict the processing of your personal data. Please note that if you make a request to restrict the processing of your data, this may affect your ability to receive our services. To exercise the above rights, please send a written request to us or to our DPO as specified in Section 1 of this Policy.
• 8
  Data transfer. Finally, you have the right to receive or transfer your personal data to another data controller. These rights only include data that you have provided to us based on your consent or contract and where the processing is automated. To exercise the above rights, please send a written request to us or to our DPO as specified in Section 1 of this Policy.

VI. CATEGORIES OF PERSONAL DATA. PURPOSES OF THEIR PROCESSING AND LEGAL BASIS

1. In order to provide Services and fulfill the Agreement with its customers (Senders, Recipients) [According to Art. 6 ch. 1b) GDPR] "NEW POST" LLC as an Administrator processes such necessary data as:

A. Customer data (registration data, data of contact persons on the customer's side, i.e. name, surname, phone number, signature, e-mail address);

B. Sender data (shipping address and necessary contact data, signature, payment information and other data necessary to perform the service ordered by the sender);

C. data of the addressee (name and surname, signature, address, postal code, city, country and, if desired, other data necessary for implementation, provided to the Data Administrator by the sender of the shipment or specified by him as the addressee, such as an e-mail address, phone number).

2. The provision of personal data is voluntary, but necessary for the performance of the Services provided by NEW POST LLC. If the Sender provides additional personal data of the Addressee in connection with the selection of one of the Additional Services, the Sender is responsible for the correct collection of this data, in particular, for obtaining the consent of the Addressee for their transfer to "NEW POST" LLC.

3. In some cases, data is also processed:

A. on the basis of consent [According to Art. 1 a) and Art. 7 GDPR] - in particular, for marketing purposes or in relation to data voluntarily provided by the addressee in connection with the delivery of the shipment.

B. and legitimate interests of the Administrator [According to Art. 6 part 1 f) GDPR] - in particular, such as: control of solvency, compliance programs or sanctions, surveys (including telephone) regarding satisfaction with the services provided (as well as for analyzing the results of surveys conducted as part of this survey, and the possibility feedback from the person providing the answer), implementation of video surveillance.

4. "NEW POST" LLC, as a registered postal operator, also processes personal data for the purpose of fulfilling its legal obligations [According to Art. 6 part 1c) of the GDPR] arising, in particular, from the Law of Ukraine "On Postal Communications" and the Law of Ukraine "On Accounting and Financial Reporting in Ukraine" (for example: proper calculation for the provided service, consideration of complaints).

5. The use of the website and application of "NEW POST" LLC may involve the processing of personal data for the following purposes:

A. Placement of the order and measures aimed at its execution.

B. Tracking shipments [According to Art. 6 ch. 1b) GDPR] – the parcel number is required to provide information on the status of the parcel.

C. Application through the contact form [According to Art. 6 part 1f) GDPR] – data sent through the contact form, such as: first and last name, address, postal code, city, e-mail address, necessary for processing and responding to the request; [According to Art. 6 ch. 1a) GDPR] consent to the processing of such data as: e-mail address, telephone number is necessary for communication in order to submit a commercial offer.

D. Communication with the consultant via chat [According to Art. 6 ch. 1f) GDPR] - data sent during a conversation with a consultant, such as e-mail address, first and last name, address, zip code, city, are processed for the purpose of checking the question posed and answering the question.

E. Parcel forwarding [According to Art. 6 ch. 1b) GDPR] - through the website of "NEW POST" LLC The addressee has the opportunity to change the delivery address if he or she cannot receive the parcel in person. For this purpose, we collect the following personal data:

1.a. name and surname of the addressee or name of the enterprise;

1.b. street / house number;

1. c. postal code / place of residence;

1.d. email address and description of desired location.

6. Geolocation. Your Personal Data, including location information, is processed so that you can find the nearest branch/ post office. Use of this feature is optional and not required for proper use of the application. The legal basis for the processing of this data is your consent (Article 6 Part 1 Letter a GDPR), expressed in the form of permission in the mobile application " Answear – fashion store » use the location services of your mobile device. Consent may be withdrawn at any time by revoking the mobile application's permissions to access location information from your mobile device. Withdrawal of consent does not affect the lawfulness of processing for which consent was given before its withdrawal.

7. Direct marketing and sales promotion. In order to inform about promotions and new offers of goods and services, the Administrator will process your data as provided during registration on the Website / application. The legal basis for data processing is the legitimate interest of the Administrator, which consists in the direct marketing of the Administrator's products and services (Article 6 part 1 letter f) GDPR)

A. Sending commercial and marketing information using electronic means of communication and push notifications. In order to inform about promotions and new products from the joint offer of goods and services of the Administrator and Partners using electronic means of communication (SMS, e-mail, push messages), the Administrator will process your data, for which you have voluntarily given consent to their use, as stated above. The legal basis for data processing is the consent obtained by the administrator (Article 6 Part 1 Letter a GDPR). You have the right to withdraw your consent at any time, the withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of the consent before its withdrawal.

8. Selection of candidates. During the recruitment process, the following categories of your data will be processed for the purposes and on the lawful basis.

• 1
  Basic data (name, date of birth), if possible;
• 2
  Contact information (address, phone number, email address, etc.), if available;
• 3
  Application details (resume, cover letter, certificates, references, interview notes and any data you provide us or wish to provide during the interview);
• 4
  Photo, video, if possible;
• 5
  Citizenship and work permit, if any;
• 6
  Health information for work, if available;
• 7
  A criminal record if it relates to a job being advertised, for example for drivers;
• 8
  Data that you have provided through public platforms used for professional purposes, in accordance with the applicable terms of the company responsible for managing the platform;
• 9
  Communication and means of communication (eg confirmation of your application or information about a telephone/ video interview if possible).

In addition to these categories of data, in order to evaluate each job application, we need data that tells us how well suited you are to the position in question.

To manage our relationship with you, including

• 1
  to assess your suitability for work (purposes), the legal basis for processing is contract performance
• 2
  for organizing and conducting (video) interviews (purpose), the legal basis of processing is the performance of the contract
• 3
  to check your data for compliance with applicable sanctions lists and laws (purpose), the lawful basis for processing is a.) legal obligation and b.) legitimate interest.

We collect data directly from you when you provide your details on our careers website or through other communication channels. When you use another channel, for example through public platforms used for professional purposes, such as LinkedIn, we will process your data in accordance with the applicable terms of that platform. When we work with recruitment agencies, we receive your data indirectly. In this case, these institutions are responsible for ensuring the accuracy of the data and transferring it to us in accordance with applicable law.

9. Video cameras and video surveillance. We monitor and process your personal data when you visit our branches, both for your personal safety and for the safety of our employees, customers and property. Video surveillance is carried out in compliance with strict security and confidentiality rules using modern technologies and equipment. Video surveillance records are stored in our systems for up to 30 calendar days.

10. Registration and recording of telephone conversations. Personal data and categories of data subjects in the register.

The following phone call identification data is registered:

• 1
  Call start and end time
• 2
  Subscriber number
• 3
  Called the service number
• 4
  Name and phone number of the official.

All calls to service numbers are recorded. Entries are made in a predetermined way. Recording starts when the call is answered and ends with the end signal.

The following chat and chatbot session details are recorded:

• 1
  Session time
• 2
  The name of the consultant and the client in the chat

Chat sessions store the content of the session between the customer and the advisor, while chatbot sessions store the content of the session between the automated chatbot and the 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 use.

The customer is not asked any personal questions and the customer cannot solve personal questions through the chatbot service. If a customer provides digital identification data, such as a phone number, to the chatbot service, the data is automatically deleted after one hour.

If we send an SMS request to a customer who contacted our service number by phone, the following data is recorded:

• 1
  Request time
• 2
  Customer phone number
• 3
  Written responses of the customer to the request

The following data is registered for the identification of customers who receive information about the actual beneficial owners:

• 1
  Person's name and identification code

VII. DATA EXCHANGE

1. "NEW POST" LLC may provide personal data:

A. To all companies that are directly and/or indirectly owned or controlled by the same ultimate beneficial owners as "NEW POST" LLC, as well as subcontractors (for example, transport partners, operating parcel reception points or parcel storage chambers) within Ukraine and of the European Union or outside their borders for the purpose of delivering parcels from the sender to the addressee [According to Art. 49 part 1b) respectively c) GDPR];

B. entities that are the subjects of a contract for the provision of services for "NEW POST" LLC or on behalf of "NEW POST" LLC (Processors), in particular IT service providers;

C. other persons or organizations in accordance with current legislation;

D. banks and payment operators to carry out the transaction (including payments made using codes);

E. to law enforcement officers and authorities to comply with national security requirements or as part of a legal process regarding the protection of property, or to continue the investigation of violations of the principles and policies of NEW POST LLC, unauthorized access or use of NEW POST LLC equipment, or any other illegal activity.

F. to mobile cellular operators (PJSC "VF Ukraine" (National State Registry of Ukrainian Enterprises and Organizations 14333937) and/or PJSC "KYIVSTAR" (National State Registry of Ukrainian Enterprises and Organizations 21673832) and/or LLC "LIFECELL" (EDRPOU 22859846), as well as provide the Client with telecommunication services and process data, related to the provision of such services - (hereinafter - the Operator), information in the following composition: known telephone number of the Client in the mobile (mobile) network of the Operator in order to prevent unauthorized access and protect interests from fraudulent actions by third parties.

2. Only the Sender and the Addressee have the right to receive information about the shipment. LLC "NEW POST" can provide such information to other persons only in the cases specified in the relevant provisions of the law, in particular in the Law of Ukraine "On Personal Data Protection".

VIII. TERM OF DATA STORAGE AND DELETE

1. "NEW POST" LLC processes personal data only for the time necessary to achieve the purpose for which they were collected. The data storage period is determined based on the following requirements:

A. operational requirements: the period during which the information is necessary to perform the Services provided.

B. legal requirements: the period during which "NEW POST" LLC must store data for a specified period of time in order to comply with the law.

C. legitimate interests of "NEW POST" LLC: the period during which the data is processed for the purpose of their implementation, in particular, to establish and consider possible lawsuits in connection with the provided Services.

2. What information do we collect about you and how do we use it?

3. Archive data after anonymization is available only to authorized employees. 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 ECONOMIC AREA

1. Personal data are transferred to third countries in case the services provided by "NEW POST" LLC must also be performed on the territory of a third country. Personal data may also be transferred to subcontractors of "NEW POST" LLC (for example, organizations that deliver a parcel on the territory of a third country) and organizations that provide tax, legal, audit and settlement advice to "NEW POST" LLC, if they work in a third country.

2. "NEW POST" LLC does not transfer personal data to international organizations.

3. "NEW POST" LLC does not transfer personal data to third countries, if this is impossible or contrary to generally accepted legislation.

4. The level of protection of personal data outside the European Economic Area ("EEA") does not coincide with the level provided for by European legislation. Thus, "NEW POST" LLC transfers personal data outside the EEA only when necessary, ensuring an adequate level of data protection, mainly through:

A. cooperation with subjects of personal data processing in countries in respect of which a relevant decision of the European Commission was issued to ensure an adequate level of personal data protection;

B. the use of standard contractual provisions issued by the European Commission, provided that an adequate level of personal data protection is ensured;

5. In the case of a justified intention to transfer personal data outside the EEA, in addition to the above, "NEW POST" LLC will notify about this fact at the appropriate stage of data processing in accordance with current legislation.

X. INFORMATION ABOUT DATA COLLECTED THROUGH THE WEBSITE

1. Log of events and cookies. Every time a user visits the website of NEW POST LLC, data is stored in a log file. The volume of temporarily stored data includes:

A. IP number of the computer from which the request was received;

B. domain name;

C. date and time of access;

D. Response code http ;

E. visited pages;

F. name and version of the operating system;

G. browser name and version;

H. Screen resolution.

2. The use of the websites of "NEW POST" LLC may be related to the use of cookies by the servers of "NEW POST" LLC. These files are used by site administrators. Each user can adjust their browser settings so that they do not accept cookies. In this case, no data will be stored on the visitor's computer. Information stored in cookie files will not be sent to "NEW POST" LLC.

XI. COOKIES

1. Cookies are Internet data, in particular text files, which are stored on the end device (computer, mobile phone, tablet) of the User. First of all, they contain the name of the website of their origin, their unique number and the time of storage on the end device. Cookies are used to provide the Administrator with statistical information about the visits of Users, the activity of Users and the way of using the Service. They allow you to customize content and services according to the User's preferences.

2. In connection with our use of cookies, we provide the most important information about their use:
cookie mechanism is not used to obtain any information about Users, except for information about their behavior on the pages of the Service.

A. The Administrator stores cookies on Users' computers in order to:

1.a. proper adaptation of the Service to the needs of Users and optimization of the use of websites;

1.b. remembering the User's preferences and individual settings, recognizing the User's device and properly displaying the website according to his needs (full version, mobile version of the website);

1. c. creation of statistics of website visits, which help to understand how Users use websites, which allows to improve their structure and content;

1.d. support of the User's session (after login), so that the User does not need to re-enter the login and password on each sub- page of the Website;

1.e. saving the shopping cart data in the online store so as not to lose them after visiting the Service again.

3. The website uses two main types of cookies: session (session cookies) and permanent (persistent cookies). Session cookies are temporary files that are stored on the website user's end device until the user logs out, leaves the website or closes the software (web browser). Persistent cookies are stored on the end device of the Website User for the time specified in the cookie settings or until they are deleted by the Website User.

4. The service uses two main types of cookies:

• 1
  "Necessary" cookies that allow you to use the services available on the Website, such as authentication cookies that are used for services that require authentication on the Website, cookies that are used to ensure security, such as those that are used to detect authentication fraud on the Website;
• 2
  "Functional and analytical" cookies that allow "remembering" the settings selected by the User and personalize the User interface, for example, regarding the User's selected language or region, font size, appearance of the website and allow collecting information about how use the pages of the Website, etc.;
• 3
  "Advertising" cookies that allow Website Users to provide advertising content that is more relevant to their interests.

5. When you first visit the website, you will be shown information about the use of cookies. The use of the website requires the processing of "necessary" cookies. The processing of other cookies is possible after giving consent to the use of cookies in accordance with the provisions of this Policy. You can always withdraw your consent by changing the cookie settings in your browser. These settings can be changed, in particular, in such a way as to block the automatic processing of cookies in the web browser settings or to inform each time they are placed on the end device of the Website User. Detailed information on the possibilities and methods of processing cookies is available in the software (web browser) settings.

"Advertising" and "analytical" cookies placed on the end device of the Website User may also come from the Administrator's partners and be used for analytical and marketing purposes. Detailed information on this can be found in the privacy policy of this partner. The administrator uses the following analytical and marketing tools provided by partners:

a. Google Ads - files used by Google to configure advertising in its services, for example in the search engine or to display advertising on the Internet, more information: https://policies.google.com/technologies/partner-sites

b. Facebook pixels – files used to match advertising on Facebook services to the individual preferences of the recipient, more information: https://www.facebook.com/privacy/policies/cookies/

c. Google Analytics - files used to analyze how users use the website, create statistics and reports, more information: https://policies.google.com/technologies/partner-sites

XII. BLOCKING COOKIE FILES

1. In many cases, web browsers by default allow cookies to be stored on the User's end device. Website users can change their cookie settings at any time, for example, to block the automatic processing of cookies or to notify each time they are published on the website user's device. Detailed information on the possibilities and methods of processing cookies is available in the browser settings or on the following websites:

A. in the Internet Explorer browser;

B. in the Mozilla browser Firefox ;

C. in the Chrome browser ;

D. in the Safari browser ;

E. in the Opera browser ;

2. However, the administrator informs that restricting the use of cookies may affect some functions available on the Website pages.

XIII. COMPLAINTS

1. If you have a complaint about how NEW POST LLC processes your data, please submit it in writing, providing as much detail as possible, using the contact information in Section I of this Policy. "NEW POST" LLC will cooperate with you to solve any problems without delay.

2. The administrative body for the protection of personal data in Ukraine is the Office for Protection of Personal Data of the Secretariat of the Commissioner of the Verkhovna Rada of Ukraine for Human Rights . You can contact him with complaints or suggestions if you believe that your rights have been violated in connection with the processing of personal data.

XIV. CHANGES TO THIS POLICY

1. Any changes that "NEW POST" LLC may make to this privacy policy in the future will be published on the website https://novaposhta.ua/. New terms may be displayed on the screen and you may be required to read and accept them in order to continue using any/all NEW POST LLC Services.

This version of the Policy was updated on 09/15/2023