Privacy policy
This Privacy Policy is drawn up and used by CARD INDUSTRIAL LLC (hereinafter “We” / "Organizer" / “Company” to regulate the collection, processing, use and transferring of personal data of individuals participating in the Loyalty Program (“You” / “Member” / “Loyalty Program Member”), the conditions of which are regulated by the Rules of the Loyalty Program, available at the following link: https://visa.pb.ua/ . (hereinafter referred to as the“ Loyalty Program Rules ”).
The Organizer collects, stores or otherwise processes the personal data of the Loyalty Program Participants for purposes that are somehow related to the Loyalty Program implementation. By collecting, storing and otherwise processing Personal data for the Loyalty Program implementation, the Organizer is considered to be the owner of personal data within the meaning of the requirements provided in Article 2 of the Law of Ukraine "On the Protection of Personal Data". All other personal data processing details are determined by this Privacy Policy.
The Organizer, being a resident of Ukraine, acts in accordance with the legislation of Ukraine, including legislation on the protection of personal data.
The Organizer respects the right of Loyalty Program participants to protect personal data obtained as a result of using this Website, as well as in the framework of participation in the Loyalty Program, and undertakes to take all reasonable measures necessary to maintain the confidentiality and security of such data, including using generally accepted standards of technological and operational protection against possible loss, misuse, alteration or destruction of personal data. Taking into concideration the existance of a number of specific features and threats in the information space today, the Organizer still cannot guarantee absolute protection of participants personal data, but will take whatever action which is appropriate to ensure the utmost protection of Personal data.
For any questions related to the collection, processing, storage and use of personal data by the Company, you can contact the Organizer by sending a message or request to the email address: vip@pb.ua, and we will try to response you as soon as possible.
Terms and definitions
The Organizer is CARD INDUSTRIAL LIMITED LIABILITY COMPANY, established in accordance with the laws of Ukraine with the registered address 79035, Lviv region, Lviv, 186 Zelena street.
Website - means the website https://visa.pb.ua/ through which the Loyalty Program is implemented.
Personal data - information or totality of data about an individual who is identified or can be specifically identified. For the purposes of Loyalty Program implementation, personal data should be deemed as the data specified in this Privacy Policy.
Personal data subject - an individual whose personal data is processed, including the personal data of the Participant or another individual person`s personal data that may be provided by the Participant.
Third party - any person, with the exception of the personal data subject, the owner or personal data controller and The Authorised Human Rights Representative of the Verkhovna Rada of Ukraine to whom the owner or personal data controller transfers personal data.
Applicable Legislation / Legislation - the legislation regulating the processing and protection of personal data, in particular, but not exclusively, the legislation of Ukraine.
All other terms that are capitalized under this Privacy Policy should be interpreted in accordance with the definitions given in the Loyalty Program Rules.
Legal basis for Personal data processing
The Organizer processes personal data that was transferred to him by the Participant solely on the basis of the relationship that arises between the Participant and the Organizer on the basis of an agreement, the conclusion and execution of which is stipulated by the Loyalty Program Rules.
Personal data and purpose of its use
We collect from you and use only the personal data that the Organizer needs to achieve the goals set, as part of the implementation of the Loyalty Program.
To register and participate in the Loyalty Program, as well as to create a Member account on the Loyalty Program website, the Organizer may offer you to provide such personal data as your full name, date of birth, email address, phone number, series and number of the passport, who issued it and when, city of residence, and information on your Visa cards (hereinafter referred to as the "Card" / "Visa Card"), in particular, card number and card expiration date, as well as other data that may be required for to create an account in accordance with Loyalty Program rules.
NOTE: You acknowledge that not providing the Personal data specified above needed for creation of an account, will make it impossible to participate in the Loyalty Program.
Your Visa card data is also used by the Organizer to determine if such a card participates in the Loyalty Program.
The Organizer collects and processes your data to make it possible to credit Bonuses to you, in particular, the Organizer processes your Visa card data, information about sales outlets where you paid with your Visa card, as well as about operations fulfilled by you using a Visa card. Also, to ensure the usage of Reward determined by the Organizer as part of the Loyalty Program and exchanged for the bonuses accumulated by you, the Organizer may process some of your personal data.
NOTE: You acknowledge that not providing your Organizer with your Personal Data, in particular, your Visa card data, will make it impossible to participate in the Loyalty Program, accumulate bonuses and exchange them for Reward.
Information about the number of Bonuses the Participant has accumulated, the number of Bonuses the Participant has exchanged for Rewards or the types of rewards selected by the Participant will be considered personal data of this participant only if they are used along with other personal data allowing identification of the Loyalty Program Participant.
When using the Website, some your data may be automatically collected and used by the Organizer. This refers to cookies stored in your browser or on the device you use for getting an access to the Website or system files. For more information about cookies and system files, see this privacy policy in the section “automatic collection of personal data”.
You acknowledge and accept that the Organizer may use the Participant’s contact information you have provided for the purpose of receiving technical and informational messages, as well as messages that may contain commercial marketing information, including information related to the Loyalty Program.
In any case, the Organizer undertakes not to collect more personal data about the Participants than it is necessary for the implementation of the goals set and as it required by law, and shall not use the Personal data for other purposes save for the Privacy Policy goals.
Data received from third parties
The Organizer may receive data on your Visa card transactions related to a card registered in the Loyalty Program from third parties, including banks and Visa to keep track of Bonuses credited to you as part of the Loyalty Program. The organizer guarantees that he shall not receive any other personal data not related to the implementation of the Loyalty Program from third parties.
During the Loyalty Program run, the Organizer provides you with an opportunity to register and create an account through an existing profile on a social media (for example, Facebook, etc). In this case, some of your personal data will be imported from your account in the corresponding social media to the Website. Please note that this option allows the Organizer to receive certain personal data about you through the social media, namely your name, surname, age, location, preferences and other information from your public profile. Not all of the above information may be requested by the Organizer, but it will be automatically provided by the social media. However, the Organizer will only use your Personal data necessary to create an account and participate in the Loyalty Program. At the same time, the Organizer will immediately delete all personal data unnecessary to him, if such a data be received by the Organizer from the social media. After creating an account, you can add any information and data you want to share with us and which is necessary for participation in the Loyalty Program. We strongly recommend you to read the social media privacy policy before you start registration in the Loyalty Program, as the Organizer shall not bear any responsibility for purposes and ways the social media uses the personal data of their users.
Underager`s personal data
By providing personal data to the Organizer, you guarantee that you are an adult person who has full legal capacity.
If the Organizer determines that the Participant is a minor, the Account of such a Participant and all his personal data will be immediately removed from the Loyalty Program by the Organizer without mandatory notification of such a Participant.
Transferring of personal data
The personal data that the Participant provides to the Organizer may be transferred to third parties, solely for the purpose of the Loyalty Program implementation the Participant takes part in:
Personal Data Controllers (data owners)
• To implement the Loyalty Program, the Participant’s Personal Data may be transferred to providers of goods and services, discounts and other privileges (hereinafter “Providers”), which are given in the list of rewards on the website at the time when Bonus is exchanged for corresponding rewards, as well as to intermediaries (hereinafter “Intermediaries” »), which ensure Providers the opportunity to provide goods, services, discounts and other privileges. At the same time, the Providers and / or Intermediaries in no case act on behalf of and by order of the Organizer, but are independent owners of the data.
When engaging with the Providers and / or Intermediaries, depending on the Reward chosen by you, the respective Providers and / or Intermediaries may additionally require or offer you to provide Personal data, both of the participant and other individuals accompanying the Participant or who, at the discretion of the Participant must use the Reward.
The Organizer does not have any information on what purposes the Providers and / or Intermediaries may additionally require or offer you to provide Personal Data for and, accordingly, bears no responsiblity in this respect. At the same time, in order to understand how the processing of personal data by Providers and / or Intermediaries is carried out, we strongly recommend you to learn the internal personal data processing regulating documents of such Providers and / or Intermediaries.
• To implement the Loyalty Program, your Personal Data, in particular, information about the accumulated and used Bonuses, may be transferred to the Bank, which is the issuer of your Visa card and gives the card holder the right to make cashless payments for goods and services, receive cash and participate in the Loyalty Program in accordance with its Rules, as well as receive bonuses for card transactions on the conditions specified by the Bank.
All personal data the Bank may offer you to provide or requires from you in the communication process is collected in his own name and for the purposes determined by the Bank independently. The Organizer does not have any information on what purposes the Bank may additionally require or offer you to provide Personal Data for and accordingly, bears no responsibility in this respect. In this regard, we strongly recommend you to learn the internal personal data processing regulating documents of the Bank.
• To implement the Loyalty Program, the Company may transfer personal data to TTN Eesti OU company, which is registered in Estonia. All the details of personal data processing by TTN Eesti OU are defined in its privacy policy, which can be found here.
• The Organizer has the right to transfer any of your Personal Data that is stored and processed by the Organizer in case the Organizer decides to sell or transfer all or part of its business or assets. In the event of such a sale or transfer, the Organizer will try to take reasonable efforts to ensure the assignee has the documents containing the same provisions as this Privacy Policy. At the same time, the Organizer will try to obtain guarantees from the assignee that the Personal data transfered to him as part of the Loyalty Program was used exclusively for the purposes specified in this Privacy Policy.
Personal data Processors (controllers).
• The Organizer may, at its discretion, transfer the Personal data provided by you or collected by the Organizer during the implementation of the Loyalty Program to companies that operate and process personal data on behalf of or by order of the Organizer. For example, these may be companies that provide the technical functioning of the Website or provide services for support of the Loyalty Program participants and conducting accounting as part of the implementation of the Loyalty Program.
Your rights
The Organizer respects the rights of each Participant who takes part in the Loyalty Program, and therefore takes all necessary measures to enable the realization of such Participants rights. You, at any convenient time, can access the Personal data processed by the Organizer as part of the Loyalty Program implementation, in particular, those stored in your Account by sending us a request in the way specified by this Privacy Policy.
You have a right to send a request to the Organizer with a demand to delete the Personal Data you have provided to the Organizer as part of the Loyalty Program. The Organizer undertakes to delete the Personal Data upon your request as soon as possible. Along with this, you acknowledge that the receipt of your request for the removal of personal data by the Organizer will be deemed as your voluntary will to terminate your participation in the Loyalty Program.
You have the right to send a request to the Organizer with a demand to suspend the processing of personal data, both for certain purposes and in general. The organizer undertakes to suspend the processing of personal data upon your request as soon as possible. At the same time, you acknowledge that the receipt of a request to suspend the processing of personal data, both for certain purposes and in general, is the reason for terminating your further participation in the Loyalty Program.
You have the right to file a complaint with the relevant regulatory authorities of Ukraine if you believe that the Organizer is processing Personal Data in violation of the applicable Law.
In case the Personal data is processed illegally or is unreliable, you have the right to submit a reasoned request to change or destroy your personal data by the Organizer and the controller of personal data. At the same time, you guarantee that all personal data provided by you is accurate and reliable.
You can learn all the other rights that are granted to you in the light of processing of personal data during the implementation of the Loyalty program in the Law of Ukraine "On the Protection of Personal Data" and the Organizer will be happy to help you in realizing them.
Data storage and deletion
The personal data you have provided the Organizer with to participate in the Loyalty Program, as well as the personal data collected by the Organizer during the implementation of the Loyalty Program, are stored during the entire period of your participation in the Loyalty Program. Upon the termination of your participation in the Loyalty Program, the Organizer deletes all Personal Data you have provided.
The Organizer may process some personal data you have provided the Organizer with to participate in the Loyalty Program, as well as personal data collected by the Organizer during the implementation of the Loyalty Program, when it is required to fulfill the obligations stipulated by the legislation of Ukraine, the subject of which is the Organizer, but for no longer than within 5 (five) years from the date of termination of your participation in the Loyalty Program. For example, this may relate to cases when the Organizer uses personal data to file, execute or protect against claims or lawsuits, within the limitation period, or when it is necessary for tax reporting or proper accounting and document management.
Personal data security
The organizer, taking into account the latest developments, cost and implementation, the context, scope, goals of processing Personal data, as well as the risks to the fundamental rights and freedoms of individuals, takes all the necessary organizational and technical measures to ensure the appropriate level of personal data security.
Wherever possible, the Organizer uses technical means to pseudonymize and encrypt data to prevent unauthorized persons from accessing it, leak personal data, unauthorized entry into the relevant databases or to prevent changing personal data in any illegal way.
The Organizer does him best to ensure the confidentiality, accessibility, safety and flexibility of all information systems within which the personal data is stored or processed. At the same time, the Organizer guarantees the possibility of restoring quick access to personal data in the event of any physical or technical failure.
The organizer provides constant monitoring and assessment of the conformity level of the adopted organizational and technical measures, in accordance with the requirements related to ensuring the personal data security, in particular in the context of modern threats.
On top of it, the Organizer has developed internal documents, procedures and regulations by which the processing of personal data within the company is regulated to ensure the maximum protection of personal data.
The organizer consideres carefully the issue of providing access to personal data to his employees, as well as to all other persons who may one way or another take part in the Loyalty Program implementation. All employees and persons involved in the processing of personal data have an obligation to the Organizer to observe the confidentiality of information in the framework of the Loyalty Program implementation.
Automatic collection of personal data
The Organizer may collect certain information using automatic means, such as cookies and system files in the process of Loyalty Program implementation.
The Organizer uses automatically collected personal data to improve the operation of the website, implement the Loyalty Program, as well as to provide the Participants with information on the Loyalty Program in a timely and efficient manner.
Use of cookies
Cookies - information in the form of text or binary data received from the Website on a web server, stored on the user's computer by the user's web browser while the user is browsing. The use of cookies, for example, helps the Organizer determine whether the Participant has visited the Website before, as well as the time of visiting. The information collected through cookies also allows the Organizer to forward proposals for new Rewards that can be exchanged for bonuses.
In general, the Organizer may use the following types of cookies:
• Mandatory Cookies;
• Statistics cookies;
• Marketing cookies.
Mandatory cookies help us maintain the Website in good condition and ensure its smooth operation. The use of mandatory cookies also provides an opportunity for Partisipants to take part in the Loyalty Program, in particular to accumulate and use bonuses. Using such files allows you, first and foremost, to use the Website properly.
Cookies can also be used for statistics and analysis allowing to find out how many users visited the Website and the corresponding pages of the Website that were interesting for these users. This helps to improve the Website in the part the most visited by users, as well as to understand the shortcomings in the work of the Website that should be immediately removed.
Marketing cookies provide an opportunity to understand your preferences, regarding the Rewards offered on the Website, and help the Organizer to select the most relevant information in the framework of the Loyalty Program that may be interesting for the Participant, and which may be sent in the form of messages that may contain commercial information, including related to the Loyalty Program.
If you do not want the cookies containing your Personal data to be used by the Organizer, you can use the browser settings to configure the appropriate cookie management options. For example, you can configure and manage cookies on the corresponding browser here:
Internet Explorer | https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies |
Firefox | |
Google Chrome | http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647 |
Opera | |
Safari | |
Safari iOS (iPhone, iPad, iPod touch) |
Use of system files
When using the Website, the Organizer can automatically collect some log files, for example, such as IP address, browser type, links / page exit and URL, number of clicks and interactions with the Website, domain name, landing pages / content, revised pages / content, device identifier and location.
An IP address is a special identifier that is used by certain electronic devices to identify and communicate with each other on the Internet. When the Participant visits the Website, the Organizer has an opportunity to collect information about the IP address of the device the Participant uses to connect to the Internet.
In combination with other data, the information contained in the system files helps the Organizer to find out which pages are the most attractive to our visitors. System files also help the Organizer to ensure the proper Loyalty Program implementation and functioning of the Website.
Third part cookies
When using the Website, third parties, such as Google Analytics, may use cookies about you for analytics and statistics purposes. Google Analytics collects information about the browser, device type, device model, location, country, city, screen resolution (on mobile), time spent on the Website, language, operating system, visited pages on the Website etc. Information generated by cookies and system files (including IP address) can be transferred and stored by Google on servers located outside of Ukraine (for example, in the USA). Google Analytics is involved by the Organizer in order to improve the Website, by receiving, analyzing the analytical data generated by Google Analytics.
Reference to other web resources
The Organizer, ensuring the proper implementation of the Loyalty Program, may public links to other web resources on the Website that function independently. At the same time, the operation of web resources, links to which are published on the Website, is carried out by other persons not affiliated with the Organizer, and therefore the Organizer is not responsible for their functioning. The organizer is not responsible for the content of these web resources, any products or services that may be offered through these web resources, or any other use of them.
Within the framework of these web resources, there may be own documents regulating their performance and the users personal data processing procedure of relevant web resources. We strongly recommend you to learn such documents before using such web resources.
Modifications
The Organizer, at its discretion, may, from time to time, make changes to this Privacy Policy by publishing the changes on the Website. The Organizer is not obligated to inform you of these changes to this Privacy Policy, save for by publishing them on this Website. Changes to this Privacy Policy take effect from the date they are published on the Website. Each Member undertakes to independently and on a regular basis check the updates to this Privacy Policy. You agree that by continuing participation in the Loyalty Program and further using the Website, you accept all changes made to this Privacy Policy. If you do not agree with the changes to this Privacy Policy, you must stop using the Website and stop participating in the Loyalty Program by removing your account.
Сomplaints
If you wish to address a complaint concerning the processing of your personal data to the Organizer, please contact the Organizer at following address vip@pb.ua. Be sure to indicate the name of the Loyalty Program in which you participate and on which issue, in the processing of Personal Data, you address.
Miscellaneous
By using the Website, you agree to this Privacy Policy and all conditions regarding the processing of your personal data.
This Privacy Policy is set forth on the Website as amended on "03" November 2020. All updates, changes and additions to this Privacy Policy will be published on this page.