Personal Data Protection Statement

UMG INVESTMENTS (hereinafter referred to as “we” or “our”) acts as a personal data controller (owner).

UMG INVESTMENTS contacts:

12-B, Bekhterivskyi Lane, Kyiv 04053, Ukraine

Tel. +380 (44) 59 06 444

E-mail: info@umgukraine.com.ua

http://umgi.ua

UMG INVESTMENTS, as a personal data controller, assumes the obligation to effectively and reliably protect your personal data received within UMG INVESTMENTS business processes in compliance with the best world standards.

Personal data protection and information security comprise a part of our corporate policy.

1. Personal data processing principles
2. Personal data utilisation objectives
3. Personal data processing grounds
4. Personal data content
5. Personal data collection
6. Children related personal data collection
7. Personal data processing notice
8. Personal data use
9. Third party use of personal data
10. Personal data protection and keeping
11. Personal data keeping term
12. Personal data removal and destruction
13. Main rights of personal data subjects
14. Right realisation procedure
15. Personal data protection employee

1. Personal data processing principles

UMG INVESTMENTS processes your personal data under the following principles:

• lawful and transparent processing manner;
• clear objectives;
• minimum collection;
• accuracy and relevancy;
• use terms definition;
• protection against illegal processing, damage or destruction;
• accountability and responsibility.

2. Personal data utilisation objectives

We collect your personal information for defined objectives, in particular:

• to implement a contract, agreement you are a party to;
• to process payment transactions;
• to fulfil UMG INVESTMENTS obligations prescribed by law;
• to personalise work with UMG INVESTMENTS resources;
• to manage vacancy filling applications;
• to implement UMG INVESTMENTS employment relations;
• to manage UMG INVESTMENTS relations with clients;
• to support and use ІТ systems;
• to manage newsletters;
• to generalise data for analytics purposes and improvement of UMG INVESTMENTS site operation.

3. Personal data processing grounds

We do not process your personal data unless we receive your consent, except for cases established by the applicable laws.

While processing your personal data, we are guided by the following grounds:

• receipt of your consent to personal data processing for one or several UMG INVESTMENTS objectives;
• processing is necessary to implement a contract, agreement you are a party to;
• processing is necessary to realise rights and fulfil obligations of UMG INVESTMENTS in the employment relations area;
• processing is necessary to comply with the obligation established by law, covering UMG INVESTMENTS.

4. Personal data content

Content of your personal data to be collected by UMG INVESTMENTS is defined in accordance with the determined purpose of such collection and processing.

5. Personal data collection

UMG INVESTMENTS policy provides for the collection solely of that personal data, which is needed to achieve the defined objectives.

UMG INVESTMENTS uses the technology of cookie files, web beacons and other technologies for the automatic collection of certain types of information when you visit UMG INVESTMENTS site or while exchanging electronic messages.

UMG INVESTMENTS requests no confidential information from you while using the site.

UMG INVESTMENTS may obtain your personal data when you visit our site solely in cases when you subscribe to UMG INVESTMENTS newsletters or send an electronic letter to UMG INVESTMENTS. In these cases, UMG INVESTMENTS uses your data solely for newsletters or to provide an answer to electronic letters.

To receive from UMG INVESTMENTS newsletters or send the electronic letter, your consent to cookie files is required.

In addition, UMG INVESTMENTS may use web-pages widgets or buttons in both social networks and electronic mail. Widgets can collect your personal information, in particular e-mail address, as well as can create cookie files necessary for their correct operation. Information collected by the widget is regulated by the confidentiality policy of the company developing this widget.

Be sure UMG INVESTMENTS do not use the technology of cookie files, web beacons and other technologies in order to identify you. Information thus obtained is used by UMG INVESTMENTS for statistical purposes and site improvement only.

Note that you are entitled to individually configure your browser so that only you could decide whether to accept cookie files. You can configure your browser so that cookie files automatically block. Besides, you can any time delete cookie files from your device.

However, we state that in the event you block cookie files some resources of UMG INVESTMENTS site can be unavailable for you.

6. Children related personal data collection

UMG INVESTMENTS neither intentionally collects nor keeps information on persons under 16.

7. Personal data processing notice

UMG INVESTMENTS, as a data controller, notifies you of the content of personal data collected, purpose of personal data collection when your personal data is being collected, or in other cases.

8. Personal data use

UMG INVESTMENTS, as a personal data controller, uses, collects, processes, accumulates, keeps, adapts, changes, transfers, protects and removes your entrusted personal data.

9. Third party use of personal data

UMG INVESTMENTS may take actions to grant partially or fully right to process personal data to third parties under your consent or in compliance with the applicable laws.

UMG INVESTMENTS may use your personal data jointly with third parties solely in cases allowed by law.

If UMG INVESTMENTS uses your personal data jointly with third parties, UMG INVESTMENTS applies contractual arrangements and follows the standards of data protection, confidentiality, security and lawfulness of your personal data transfer.

UMG INVESTMENTS provides no access to your personal data to third parties if they refuse to assume the obligation to ensure a proper level of protection and security while processing your personal data by them, or unable to ensure this.

UMG INVESTMENTS transfers no personal data to third parties, except for cases, when allowed by law and/or necessary for purposes of UMG INVESTMENTS professional activity.

10. Personal data protection and keeping

UMG INVESTMENTS provides a proper level of security for your personal data applying at all stages of its processing physical, administrative, technical means of protection to prevent unauthorised access, use and/or disclosure of such data.

At the same time, while processing your personal data UMG INVESTMENTS accounts risks related to accidental or illegal destruction, loss, disclosure or access to your data.

11. Personal data keeping term

UMG INVESTMENTS keeps your personal data processed for the time necessary to achieve the purpose it has been collected for or until the moment when you request to remove your personal data, unless such removal is prohibited by law.

12. Personal data removal and destruction

Your personal data in UMG INVESTMENTS personal data bases are subject to destruction or removal in case when:

• data keeping term defined by your consent to this data processing or law expires;
• legal relations between UMG INVESTMENTS and you terminate;
• you request to remove personal data, unless such removal is prohibited by law;
• the Ukrainian Parliament Commissioner for Human Rights or officials of the Ukrainian Commissioner for Human Rights Secretary appointed by him/her issue a relevant prescription;
• a court decision to remove your personal data becomes valid.

13. Main rights of personal data subjects

You, as a personal data subject, have the following rights:

• Right to access information. This right includes the right to know whether data in relation to you is processed, if so, the right to access this data, as well as additional information in respect of the collection purpose, the category of data processed, etc.
• Right to correct. If personal data is inaccurate, you have the right to correct it.
• Right to remove or to be forgotten. All information on you must be removed if we receive from you a relevant request, except for cases provided by law. The right to be forgotten, in turn, includes the opportunity to apply to search services, claiming to remove reference to the information containing your personal data.
• Right to limit data processing. You have the right to limit your data processing. If a limit imposed, your personal data may be processed only under your consent or when legal grounds for data processing are available.
• Right to data transfer. You, as a personal data subject, have the right to transfer personal data in relation to you, which you provide to UMG INVESTMENTS, other controller without obstruction on UMG INVESTMENTS side.
• Right to personal data processing refusal. You have the right to refuse to allow your personal data use at all times, except for cases when your data processing is carried out on legal grounds.
• Right to revoke the consent. You have the right to revoke your consent to process your personal data at any time. However, revocation of your consent does not affect the lawfulness of processing based on the consent prior to its revocation.
• Right to information on data leaks. You have the right to be informed of your personal data leak within 72 hours upon such event.
• Right to appeal in respect of personal data processing actions.
• Right to receive reimbursement.

14. Right realisation procedure

To realise the above-mentioned rights, access your personal data or in case you have any questions related to your personal data protection, you, as a data subject, are entitled to individually apply to UMG INVESTMENTS at legal or electronic addresses with questions, claims or feedback.

We will consider your request and provide exhaustive answer to your questions.

15. Personal data protection employee

Personal data protection employee organises work related to personal data protection when processed in UMG INVESTMENTS, with whom you can freely connect by our contact data.

^{Please be accordingly informed that the Personal Data Protection Department of the Ukrainian Commissioner for Human Rights Secretary located at 21/8 Instytutska St., Kyiv-08, 01008, tel. +380 44 253 81 94, functions as a personal data protection body in Ukraine.}