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Privacy Policy
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Version 1.0Effective Date: 25 March 2020

Introduction

We are committed to respecting your privacy. We will treat any personal data supplied by you as confidential and will only process such data as permitted by applicable legislation. We have prepared this Privacy Policy in accordance with the General Data Protection Regulation (GDPR) and the best international practices in personal data protection.

In this policy we describe how the SPECTA Group (“we” or “SPECTA Group”) processes your (“you”) personal data in the following cases as well as your rights with respect to personal data.

The terms for processing cookie files are described in the Cookie Policy. Processing activities related to our employees’ personal data are covered in our internal regulations.

SPECTA Group is headquartered in Russia (Specta Interpak LLC) and includes companies in the EU (Specta Strap Oy in Finland and Specta Ruhr GmbH in Germany), Ukraine, Belarus, Kazakhstan and UAE each of which acts as a data controller.

Specta Interpak LLC (Russia) is an administrator of the Website and a controller of the personal data submitted through the Website.

Contacts

For all questions regarding our data protection and privacy practices, you can contact us at any time at privacy@specta.com.

Content

  1. Which data do we process and for what purposes?
  2. How do we collect your personal data?
  3. Who has access to your personal data?
  4. What are your choices and rights with respect to your personal data?
  5. How do we keep your personal data safe and secure?
  6. How long do we store your personal data?
  7. What are our data processing principles?
  8. How will we notify you about changes to the Privacy Policy?
  9. What will we do if there is a personal data breach?
  10. Detailed list of personal data, purposes, period and legal basis (table)

1. Which data do we process and for what purposes?

We make every effort to make our processing activities transparent and open. We process your personal data for the following purposes:

A list of data we process about you, the third parties we share data with and the timeframes during which we process data are specified in the table in Section 10 below.

Should we later decide to use your data in any other way, we will inform you in advance so that you can exercise your rights as a data subject.

We do not process any special categories of data (e.g. data revealing racial or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, or genetic and biometric data) or data related to criminal convictions or offences.

We do not use your personal data for any automated decision making covered by Article 22 of the GDPR.

Our Website is not designed or directed at children.

2. How do we collect your personal data?

We collect your personal data:

3. Who has access to your personal data?

As a group headquartered in Russia, we store all your personal data on Russian servers (hosted by Specta Interpak LLC).

We may share your personal data within the SPECTA group, including with companies located in Russia, Germany, Finland, Ukraine, Belarus, Kazakhstan and UAE. This allows us to comply with local laws and ensures that your personal data is consistent, accurate and up-to-date. It also helps to increase the quality and relevance of our products and services.

We share your personal data with third-party service providers as described in the Privacy Policy

We endeavour to cooperate only with those third parties who respect and comply with personal data processing requirements.

4. What are your choices and rights with respect to your personal data?

Subject to applicable legislation, you have the full legal right to:

We will do our best to fulfil your request in the shortest possible time and in accordance with applicable legislation. In some cases, we may be required to continue storing data for regulatory purposes even though you require us to delete it. Should this be the case, we will inform you about such storage.

If you are not satisfied with our personal data processing activities and/or have any other complaints, contact us (contact details can be found here). You also have the full legal right to lodge a complaint with a supervisory authorities:

5. How do we keep your personal data safe and secure?

We are committed to protecting your personal data by using a combination of administrative, technical and physical measures. These safeguards include strict procedures to prevent the unauthorised access, loss or destruction of your personal data both during transmission and once we receive your personal data.

When interchanging data with third parties, we take appropriate organisational and technical measures to protect your personal data. We ensure that such third parties are bound by confidentiality obligations, and they must ensure the security and confidentiality of data.

Unfortunately, no data transmission or storage system is guaranteed to be 100% secure. If you have any reason to believe that your personal data is no longer secure, you should contact us immediately.

6. How long do we store your personal data?

We store your personal data for as long as necessary to fulfill the purposes for which it was collected, except where otherwise required or permitted by law. Once no longer required, your personal data will be securely destroyed or anonymised (so the data no longer identifies you). Periods of storage of personal data are described in the in the table in Section 10 below.

As to the duration of storage of relevant data using cookies, please see our Cookie Policy.

7. What are our data processing principles?

We have the greatest respect for your personal data, so during the collection and processing of them, we strictly adhere to the best business practices and principles of applicable legislation, including:

8. How will we notify you about changes to the Privacy Policy?

We reserve the right to modify the Privacy Policy at any time. Any modifications will become effective when we post a modified version of the Privacy Policy on the Website.

If we decide to do so, we will post a notification on the Website. If the modifications are significant, we will provide a more prominent notice when required by applicable law.

9. What will we do if there is a personal data breach?

If there is a personal data breach, we will without undue delay and where feasible, no later than 72 hours after having become aware of it, notify the competent supervisory authority of the personal data breach unless we reasonably decide that such a breach is unlikely to result in any risk to the rights and freedoms of data subjects.

If a data breach is likely to result in a high risk to your rights and freedoms, we will notify you in the following way:

10. Detailed list of personal data, purposes, period and legal basis (table)

No.PurposeList of personal dataThird parties (not SPECTA Group)Period of processingLegal basis
1.To communicate with you when you submit requests at the Website: 
  • when you submit a “contact us” form
  • when you submit a form in the “catalogues” section
Name
Email address
Phone number
Company
Country
NoWithin 6 months from the receipt, if the request does not require legal actions
Within 3 years from last communication, if the request requires legal actions
Legitimate interest to answer your question and communicate with you (Art. 6 para. 1f GDPR).
  • when you use the “send a link to email” form
EmailNoUntil sending a link to the email
2.To send you a newsletter if you subscribed to it, analyse conversion of mailingsFull name
Email address
Phone number
Position
Company
Country and city
Information on the opening of e-mails and links contained in e-mails with newsletters
Service provider of the tool for e-mail marketingUnless you withdraw your consent or opts outLegitimate interest or consent depending on whether we have business relations with you as a client or a counterparty (Art. 6 para. 1a or 1f GDPR)
3.To communicate with you after conferences and expositions or other social events where you provided us with your contacts or business cardFull name
E-mail
Phone number
Position
Company
Country, city
No3 yearsLegitimate interest or consent depending on whether you provided your data via a standard form (Art. 6 para. 1a or f GDPR)
4.To search for and communicate with potential clients, counterparties, vendors, business partners or investorsFull name
Email address
Phone number
Position
Company
No3 yearsLegitimate interest (Art. 6 para. 1f GDPR)
5.To analyse and respond to incoming requests, claims or other correspondenceFull name
Position
Company
NoWithin 6 months from the receipt, if the request does not require legal actions
Within 3 years from last communication, if the request requires legal actions
Legitimate interest (Art. 6 para. 1f GDPR)
6.To find candidates for vacant positions at the SPECTA GroupInformation in CVs (e.g. full name, email address, phone number, date of birth, qualification)NoDuring the evaluating and 2 weeks after the decision is madeLegitimate interest (Art. 6 para. 1a or f GDPR)
7.To agree on, enter, execute, communicate in relation to and terminate agreements with counterpartiesFull name
Email address
Phone number
Position
Date of birth
Details of passport or other ID (if you sign an agreement)
Details on PoA or other ground for the authorities (if any)
NoDuring the period of contract validity or supplyLegitimate interest (Art. 6 para. 1a or f GDPR)
8.To comply with tax, accounting, customs, currency control requirementsFull name
Position
Company name
Email address
Phone
Date of birth
Details of passport or other ID, including ID number, date of issuance and issuing authority
Details of the PoA or decision on appointment of the general director (No, date, powers granted)
Details of the agreement signed
Tax, customs, other authorities, courts as the case may beWithin the validity of the agreement / execution of supply and up to 10 years after its terminationLegitimate interest (Art. 6 para. 1a or f GDPR)
9.To protect our legal interest, file legal claims, comply with national law or execute requests of authorities, courts, law enforcement officialsFull name
Email address
Phone number
Position
Date of birth
Number of an identity document and information on the granting
Requisites of the power of attorney
Authorities, courts, law enforcement officials as the case may beWithin the validity of the agreement / execution of supply and up to 3 years from the contract termination dateLegitimate interest (Art. 6 para. 1a or f of GDPR)
10.To maintain the Website, to improve it and make it more user friendly, to analyse how you interact with our Website, to present you content and advertising in line with your preferencesCookie files (technical, analytical, marketing)Google LLC (Google Analytics)
Yandex LLC (Yandex. Metrica)
AddToAny
Depending on the cookie type (in line with our Cookie Policy)Legitimate interest or consent depending on cookie type (Art. 6 para. 1a or f GDPR)
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