Privacy Policy
Regarding the use of the website https://procurement.energo.dtek.com/
DTEK ENERGY LLC (the “Company,” “we”) is committed to protecting your privacy and processing and storing your personal data responsibly, including in compliance with the requirements of the General Data Protection Regulation (GDPR). On this page, you can find out what information we collect about you when you interact with DTEK ENERGY LLC and how we process the personal data you provide.
This Privacy Policy (“Policy”) applies between you and DTEK ENERGY LLC. It describes how we process the data you provide to us through our website https://procurement.energo.dtek.com/ (“Website”), including through the contact form, when you interact with us via our email address DEP@dtek.com, during video calls or phone calls, or otherwise provide us with information about yourself.
In accordance with the Law of Ukraine “On the Protection of Personal Data”, when processing your personal data, DTEK ENERGY LLC may act as the owner of personal data or the controller of personal data.
In accordance with Article 4 of the GDPR, we act as a personal data controller, as we determine the purposes and means of processing users' personal data. In cases where we process data on behalf of another organisation, we act as a processor.
You may be a Website Visitor or a Customer:
• You are considered a Website Visitor when you only browse our Website and provide us with your data through cookies and other tracking technologies, or contact us by email, phone, or using the contact forms on our Website;
• You are considered a Customer when you contact us by email, through contact forms on our Website, share personal data during video or phone calls, or otherwise provide us with personal data.
Definitions
According to the Law of Ukraine “On the Protection of Personal Data,” the terms listed below have the following meanings:
“Law” – Law of Ukraine “On the Protection of Personal Data” dated June 1, 2010, No. 2297-VI;
“Personal data owner” – a natural or legal person who determines the purpose of personal data processing, establishes the composition of such data and the procedures for its processing, unless otherwise specified by law;
“personal data controller” – a natural or legal person who is granted the right by the owner of personal data or by law to process such data on behalf of the owner;
“personal data subject” means a natural person whose personal data is being processed;
“personal data” means information or a set of information about a natural person who is identified or can be specifically identified (e.g., name, email address, address, etc.);
“processing” – any action or set of actions, such as collection, registration, accumulation, storage, adaptation, modification, renewal, use and dissemination (distribution, sale, transfer), depersonalization, destruction of personal data, including using information (automated) systems.
Types of personal data we collect
We collect and process information about you in accordance with this Policy. We may collect the following personal data about you through the Website (including contact forms), email, and during video or telephone calls or through other means of communication:
(a) Contact Information. When you submit your details via email or through contact forms available on the Website, including when you share your personal data during video or phone calls, we may collect your personal data. This information may include your first name, last name, company name, phone number, email address, and any other data you provide to us.
(b) Communication Information. We may collect certain information when communicating with you, such as the content of emails, messages, or video/phone conversations. This may include a brief summary of the conversation, key details related to our communication, or, with your consent, a recording of the conversation.
(c) Information about cookies. We may use cookies and other tracking technologies on our Website to ensure its proper functioning, for analytics, marketing activities, remembering your preferences, and other purposes. Such use may include the transfer of information from us to you and from you to a third-party website or to us. To learn more about our use of cookies, please see the “Use of Cookies” section of our Privacy Policy and our Cookie Policy.
We use the personal data we collect and process only for the purposes specified in this Policy. We may transfer personal data to third parties solely for the purposes specified in this Policy.
We do NOT sell your data.
We do NOT use automated decision-making that has legal consequences for the data subject or similarly significantly affects the data subject.
We do NOT intentionally collect or process personal data of children and any sensitive personal data (about racial or ethnic origin, political, religious or philosophical beliefs, membership in political parties and trade unions, criminal convictions, as well as data concerning health, sex life, biometric or genetic data). Please refrain from providing sensitive personal data relating to yourself or third parties.
We process your personal data in accordance with the Law. The Law provides an exhaustive list of legal grounds that allow us to process your personal data, namely:
Article 11 (part 1, paragraph 2): necessity for the conclusion and performance of a contract
We process personal data in cases where it is necessary for the conclusion and performance of a contract to which you are a party, or to take action at your request prior to entering into such a contract. Such processing is a prerequisite for providing you with the relevant services or fulfilling mutual obligations.
Article 11 (Part 1, Paragraph 6): Protection of legitimate interests
We process your personal data to protect our legitimate interests, such as:
• preventing fraud and laundering of legally obtained funds;
• ensuring the security of our Website;
• providing you with an uninterrupted user experience.
We collect and use only the data strictly necessary to achieve these purposes, provided that the needs to protect the fundamental rights and freedoms of the data subject do not override such interests.
Article 11 (Part 1, Paragraph 1): Consent to the provision of personal data
We process the personal data that you have chosen to provide to us for communication with you on grounds other than those specified above, with your consent.
You can always withdraw your consent by sending us an email at DEP@dtek.com.
Use of cookies
When you visit our Website, we automatically collect certain information using cookies. Cookies help us understand your interaction with our Website, improve your browsing experience, improve our Website and services, and conduct marketing activities. Information about the types of cookies we use and how you can adjust your cookie preferences can be found in our Cookie Policy.
Data retention periods
We retain personal data for as long as necessary to fulfill the purposes outlined in this Policy.
Notwithstanding any of the above data retention periods, you may submit a request to object to the processing of your personal data by emailing us at DEP@dtek.com.
Data security and integrity
We have implemented appropriate organizational, technical, administrative, and physical security measures designed to protect your personal data from unauthorized access, disclosure, use, and modification. We regularly review our security procedures and policies to take into account new technologies and methods.
International transfer of personal data
When transferring personal data outside the European Economic Area (EEA), we ensure an adequate level of protection in accordance with Articles 44-49 of the GDPR. This may include the use of Standard Contractual Clauses (SCCs), European Commission adequacy decisions, or other appropriate safeguards.
Links to third-party websites
This Privacy Policy applies only to this Website. We encourage you to review the privacy policies of any Websites you may visit via hyperlinks on our Website. We have no control over the privacy policies and data processing practices of other websites and are not responsible for their actions.
Age of the data subject
We do not knowingly collect personal data from persons under the age of 18. By providing us with your personal data, you confirm that you are at least 18 years old and that you can independently consent to the processing of your personal data.
If we learn that we have collected or received personal data from a child, we will delete that information. If you have reason to believe that a child has provided us with their personal data, please contact us at DEP@dtek.com.
Your rights under the law
In this section, we have summarized the rights you have under the Law of Ukraine “On the Protection of Personal Data.”
You can exercise your rights by submitting a request to DEP@dtek.com
Please note that we may need to verify your identity in order to process your requests. Therefore, we may not be able to fulfill your request if you do not provide us with sufficient details to verify your identity and respond to your request.
- The right to be informed (Article 8, Part 2, Clauses 1-2 of the Law). You have the right to: know the sources of collection, location of your personal data, the purpose of its processing, the location or place of residence (stay) of the owner or controller of personal data, or give appropriate instructions to obtain this information to persons authorized by you, except in cases established by law; receive information about the conditions for providing access to personal data, in particular, information about third parties to whom your personal data is transferred. All information about how we collect and use your personal data is described in this Privacy Policy and Cookie Policy.
- Right of access (Article 8, Part 2, Clauses 3-4 of the Law). You have the right: 1) to access your personal data; 2) no later than thirty calendar days from the date of receipt of the request, except in cases provided for by law, to receive a response as to whether your personal data is being processed, as well as to receive the content of such personal data.
- Right to object (Article 8, Part 2, Clause 5 of the Law). You have the right to submit a reasoned request to the personal data controller objecting to the processing of your personal data.
- Right to rectification (Article 8, Part 2, Clause 6 of the Law). You have the right to submit a reasoned request to any personal data controller or processor to change or destroy your personal data if it is being processed unlawfully or is inaccurate.
- Right to protection of personal data (Article 8, Part 2, Clause 7 of the Law). You have the right to protect your personal data from unlawful processing and accidental loss, destruction, damage in connection with intentional concealment, non-provision or untimely provision, as well as from the provision of information that is unreliable or defamatory to the honor, dignity, and business reputation of an individual.
- Right to lodge a complaint (Article 8, Part 2, Clause 8 of the Law). You have the right to lodge complaints about the processing of your personal data with the Commissioner (as defined below) or with a court.
- Right to seek legal remedies (Article 8, Part 2, Clause 9 of the Law). You have the right to seek legal remedies in case of violation of personal data protection legislation.
- Right to object (Article 8, Part 2, Clause 10 of the Law). You have the right to object to the restriction of the right to process your personal data when giving your consent.
- Right to withdraw consent (Art. 8, Part 2, Clause 11 of the Law). You have the right to withdraw your consent to the processing of personal data.
Rights of data subjects under the GDPR
In accordance with Articles 15–22 of the GDPR, you have the following rights:
- The right to access your personal data (Article 15);
- Right to rectification of inaccurate or incomplete data (Article 16);
- Right to erasure of personal data (‘right to be forgotten’, Article 17);
- Right to restriction of processing (Article 18);
- Right to data portability (portability, Art. 20);
- Right to object to processing (Art. 21);
- Right not to be subject to a decision based solely on automated processing, including profiling (Art. 22).
Complaints
If you have any questions regarding the processing of your personal data, we encourage you to contact us directly. For inquiries and complaints, please use this address: dpm@dtek.com.
In cases provided for by law, you have the right to lodge complaints about the processing of your personal data with the Ukrainian Parliament Commissioner for Human Rights (the Commissioner) or with a court.
We will cooperate with the relevant state authorities to resolve any complaints related to the protection of personal data that cannot be resolved by mutual agreement between you and us.
If you believe that the processing of your personal data violates the provisions of the GDPR, you have the right to lodge a complaint with the supervisory authority in your EU member state (Article 77 of the GDPR).
If you have any questions regarding this Policy, our data processing activities, or your rights as a data subject under the Law of Ukraine “On the Protection of Personal Data” and other applicable laws, you can contact us:
- Our company: DTEK ENERGY LLC
- Our address: Kyiv, Gareth Jones st, UNIT. City, 20D
- Our email: DEP@dtek.com