PRIVACY NOTICE

This Privacy Notice is designed to provide general information on the processing of personal data of any legally capable natural person (user), who intends to receive the services and/or receives the services and/or uses the website http://sanctions-finder.com (website), as well as our approach to third person’s personal data processing, included in sanctions lists.

This Privacy Notice is constructed under the General Data Protection Regulation (GDPR) and UK General Data Protection Regulation (UK GDPR) and might include provisions which can be further defined or described in GDPR and UK GDPR.

I. CONTROLLER

1. The controller is the entity that determines the purposes and means of the processing of a user’s personal data, and is responsible for the processing of such personal data.

2. The controller of the user’s personal data and personal data included in the sanctions/restrictive measures lists is Sanctions Finder (Bohdan Bernatskyi and Bogdan Protsiuk, private individuals residing in Kyiv, Ukraine, email: sanctionsfinder@gmail.com).

II. PURPOSES AND BASIS OF THE PROCESSING

1. The processing is any activity performed on personal data, e.g., collection, structuring, storage, adaptation use, disclosure by transmission, dissemination or otherwise making available. In order to lawfully process personal data controller has to rely on a legal basis for the processing.

2. Personal data provided by the user. The table below shows user’s personal data processed by Sanctions Finder, purposes and basis of the processing.

3. Sanctions Finder may process any other personal data provided voluntarily by the user. The user is not obliged to provide personal data by law or under any agreement, however, Sanctions Finder services might not be available or might be impossible to be provided without some types of personal data.

4. Retention period. Sanctions Finder retains and processes the user’s personal data as long as it is necessary to fulfill the purposes defined and the basis of the processing activity exists (e.g., as long as user has the account, or his paid subscription is active), or until a request to delete personal data is received.

5. Personal data included in the sanctions/restrictive measures lists. The services provided on the website are mainly based on the open and publicly available data (name, middle name, surname, gender, ID details, address, date and place of birth, occupation, type of restrictive measures applied, etc.), which is present in sanctions or similar restrictive measures lists published by governmental authorities in the EU, UK, the USA or by intergovernmental organizations such as United Nations. Sanctions Finder does not collect information included in sanctions lists directly from the data subject.

6. Sanctions Finder does not have an establishment in the UK or EU. In addition, all sanctions lists, generally, do not include personal data of data subjects who are in the EU or UK, thus GDPR and UK GDPR is not applicable to such processing activities.

7. In cases, where Sanctions Finder processes personal data of the data subjects, who are in the EU or UK, Sanctions Finder process such data for the purpose of transparency and accountability and rely on the legitimate interests to provide accessible and coherent information regarding restrictive measures to journalists, legal entities or the general public, as a basis for the processing. 

8. Retention period. Sanctions Finder retains and processes the data subject’s personal data as long as the sanctions/restrictive measures are active.

III. TRANSFER OF PERSONAL DATA

1. Recipients. In some cases personal data may be disclosed by Sanctions Finder to such recipients:

a) our contractors (marketing manager, IT specialist, customer support manager etc.), those operating within the jurisdiction outside the EU, particularly in Ukraine;

b) hosting provider, particularly Amazon Web Services, Inc. with servers within EEA;

c) third parties that perform Sanctions Finder customer traffic analysis, for example, Google Analytics. Data collected by Google Analytics may be transferred outside the for processing;

d) purchaser during M&A process.

2. Purposes of transfer. Sanctions Finder might transfer the user’s personal data in order to provide services, fulfill obligations before the user, analyze the user’s activity or display appropriate advertisements. The list above is not exhaustive and, if necessary, may be expanded solely for the purpose of providing Sanctions Finder services.

3. International transfer. In case, where user’s personal data is transferred outside the EU, Sanctions Finder enforces the appropriate legal documents that ensure the safeguard of personal data, particularly, the Data Processing Agreement and Standard Contractual Clauses.

IV. PROCESSING OF PERSONAL DATA

1. Sanctions Finder is processing user’s personal data by automated means. Personal data is kept in electronic form on the website, on Amazon Web Services, Inc. servers and on computers, access to which only authorized Sanctions Finder contractors has.

2. The user’s personal data is not subject to automated decision-making, including profiling.

V. USER RIGHTS

1. User has the right:

a) to access its personal data processed by Sanctions Finder;

b) to rectify (modify) its personal data;

c) to erase its personal data (right to be forgotten);

d) to restrict the processing of personal data, when giving consent or by sending an appropriate request to Sanctions Finder via the email address indicated in the Contacts section;

e) to object to the processing of personal data;

f) to obtain and reuse its personal data for its own purposes (right to data portability);

g) to withdraw consent for the processing of personal data by sending an appropriate request to Sanctions Finder via the email address indicated in the Contacts section if the processing activity is based on the user’s consent;

h) to unsubscribe from receiving Sanctions Finder email newsletters and other marketing materials. To do this, it is necessary to follow the instructions specified in the email received by the user;

i) to lodge a complaint with a supervisory authority.

VI. REQUEST. DELETION AND MODIFICATION OF PERSONAL DATA

1. If necessary, any user may send an email to sanctionsfinder@gmail.com to make changes to their personal data, to request information about its processing, and to send requests for other issues related to the processing of personal data. In the case of the consent withdrawal and personal data removal, the user may request so by emailing sanctionsfinder@gmail.com. In the case of a notice of consent withdrawal and removal of personal data, Sanctions Finder undertakes to remove such data within 30 days after the identification of the user.

2. In the case of a request as provided in the previous paragraph, Sanctions Finder has the right to contact the user by telephone or by e-mail in order to carry out such identification, if necessary, in order to confirm the user’s actions outlined in the previous paragraph.

VII. CHILD PRIVACY

1. Sanctions Finder services are not intended for use by children under the age of 16 (or 13 if you reside in the UK). We do not knowingly collect personal data from them.

2. If Sanctions Finder becomes aware that has collected personal data from children without parental consent, we will take steps to remove that information from our servers or servers of our service providers.

VIII. USE OF COOKIES

1. Sanctions Finder uses cookies on website to properly and accurately display the content on it, analyze user’s use of website. Sanctions Finder encourages all website users to make sure that their browser settings match their desire to accept cookies or not. The user may set the browser to warn before accepting cookies or to reject them immediately. Accepting cookies is not a prerequisite for navigating and using the Sanctions Finder website. For more information please read our Cookie Notice.

IX. OTHER PROVISIONS

1. If the user has any questions or comments about this Privacy Notice, it may seek advice or clarification from Sanctions Finder by emailing sanctionsfinder@gmail.com.

2. This Privacy Notice is subject to change and revision and Sanctions Finder reserves the right to modify and update it. We advise user’s to review the Privacy Notice periodically.

3. In case of significant changes to the Privacy Notice (e.g. change of ability to exercise rights, change in processing purpose/basis, change of the identity of the controller) we will communicate such changes via electronic means.

4. This Privacy Notice went into effect on June 22, 2022.