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1. Scope
NLMK may process the Personal Data of contact persons of suppliers, clients or any other business contact in the context of its activities.
In accordance with applicable data protection laws, such as the General Data Protection Regulation 2016/679 and national data protection laws, NLMK wishes to clarify what Personal Data we collect from you and how your data will be used in the context of the activities of NLMK through this statement (hereinafter referred to as the "Notice" or "Statement"). This Notice also sets out the rights of third parties and website visitors to the NLMK website in relation to their Personal Data.
This Notice applies to:
- contact persons of our clients;
- individuals who enter into a contract with us in the name and on behalf of a supplier, service provider, or partner for which they work and the contact persons of such organizations;
- users/visitors of our website https://eu.nlmk.com/
- Any other individuals who initiate contact with us or who otherwise express their interest in our services
Insofar as we are likely to collect and process data from third parties that you have communicated to us, we kindly ask you to inform said third parties of the existence of this Notice so that they can be aware of the processing that we carry out on their data and of their rights.
This Privacy Policy does not cover the processing of personal data of individuals submitting job applications through our website or other channels, except for the general processing described in Section 4.2, which applies to all website visitors. Data related to job applicants is subject to a separate Privacy notice, available on our website.
2. Who are we?
NLMK as a controller
Several European entities of NLMK group are involved in the processing of your personal data and must be, thus, considered as controllers (hereinafter referred to as "we", "us" or "NLMK"). You may find the details of the different controllers (European entities of NLMK) in Annex1.
You may contact the data controller regarding this website and/or this statement by using the following email address: info@eu.nlmk.com
As controllers, we are responsible for the processing of the personal data that we collect and use. Through this privacy statement, we take the necessary steps in order for you to:
- be informed of the processing of your personal data and your rights;
- retain control over the personal data that we process;
- be able to exercise your rights with regard to personal data. You can find more information about your rights in point 9 of this Statement.
Data protection officer
NLMK has also appointed a Data Protection Officer (DPO) for each European entities. The DPO's task is to inform everyone about the personal data that are processed. The DPO also advises and monitors whether there is compliance with the General Data Protection Regulation (GDPR).
You may contact the DPO about any matters relating to the processing of your personal data and the exercise of your rights in this context.
Contact details of the DPO:
- Email: DPO@eu.nlmk.com
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Address:
NLMK Belgium holdings SA
Rue des Rivaux 2,
7100 La Louvière
Belgium
Should this contact details change, you will be informed as soon as possible.
3. Definitions
For the purposes of this Statement, the following terms shall have the following meaning:
- Personal data means information relating to an identified or identifiable person (the data subject).
- Processing means any operation (or set of operations) which is performed on personal data. It may be the collection, recording, organisation, storage, adaptation or alteration, consultation, use, disclosure by transmission, restriction, erasure or destruction for example.
- Data subject means a person who may be identified or identified, directly or indirectly, by personal data.
- Controller means the physical or moral person which determines, alone or jointly with others, the purposes and means of the processing of personal data and processes personal data in its own interest and on its own behalf.
- Processor means a natural or legal person which processes personal data on behalf of the controller.
- Data protection officer means a person or a team charged to inform everyone about the personal data that are processed. It also advises and monitors whether there is compliance with the General Data Protection Regulation (GDPR).
- GDPR means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 26 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
4. What categories of personal data are processed, for what purposes and on what legal basis?
4.1. Data of clients, suppliers and third parties
Purpose of processing |
Categories of data |
Legal basis |
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Information, communication and request handling (via any means, including contact form, e-mail, telephone or post, physical events). |
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Managing business relationship with the company that you represent (internal creation process of clients, negotiation/conclusion of the relevant client contracts, management of the contractual relationship, handling claims, etc.) |
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Managing our own commercial arrangements with suppliers (negotiation and conclusion of the relevant vendor contracts, management of the contractual relationship, prior screening of all third parties, etc.). |
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Marketing communications (via e-mail or other channels) |
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Ensuring our security within and around our premises (via surveillance cameras, registration of all external visitors, etc.) |
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Fulfilling our legal obligations and complying with request from authorities |
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Handling whistleblowing reports from internal or external stakeholders and ensuring proper follow-up on each report. Data collected during a whistleblowing report includes personal data of the reporting person, the person reported, individuals assisting or connected to the reporting person (e.g., facilitators, colleagues, family members), as well as any other individuals mentioned in the report. |
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In general, we process Personal Data that we receive from you or your employer/company that you represent in the course of our business relationship.
NLMK may also collect publicly available information in order to verify the information we have collected and to manage and develop our business.
4.2. Data of website visitors
WEBSITE VISITORS |
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Purpose of processing |
Categories of data |
Legal basis |
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Information, communication and request handling (via the contact form or other means) |
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Ensuring the security and proper technical functioning of our website through the use of strictly necessary cookies (and similar technologies), including:
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Ensuring an enhanced user experience, traffic analysis, and personalized content and ads through the use of non-essential cookies. |
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We collect the personal data of website visitors through cookies, tracking technologies, and user-provided information such as contact forms.
If you would like more information on how we use cookies, please consult our Cookie notice on our website.
To increase our visibility on the Internet and ensure that we are close to our current and future customers, we also have a presence on social media such as [Facebook, LinkedIn and YouTube].
By visiting these sites, you can choose to share some of your Personal Data with us directly by contacting us, commenting and/or sharing our articles.
In addition, we recommend that you read the Privacy Notice published by these third parties on their sites in order to find out how your Personal Data is processed by these third parties in their capacity as Data Controllers.
5. Which other people do we share your personal data with?
The employees of the group companies who must have access to personal data to carry out their professional duties can access such personal data. These people act under our supervision and responsibility.
To the extent that our group is international and that our headquarter is located in Russia, your personal data may be transferred outside the EU and/or EEA, as described in point 7 of this Statement.
We also call on external suppliers who handle certain types of processing so that we can offer you our products and services, namely IT, legal, financial, accounting and other services. Given that these third parties have access to personal data in the context of the performance of the requested services, we have taken technical, organisational and contractual steps in order to ensure that your personal data are only processed and used for the purposes mentioned in point 3 of this Statement.
When we have a legal obligation to do so, we may provide your personal data to supervisory authorities, tax authorities and any other public authority (e.g. police).
6. Where do we store and process your personal data?
Personal Data may be accessed by or transferred to our partners or service providers in countries outside the European Union (EU) or the European Economic Area (EEA). When such a transfer takes place, NLMK ensures that a level of protection equivalent to that in force within the EEA/EU in accordance with the GDPR is guaranteed.
In particular, your personal data will be transferred toRussia, for the following reasons:
- some of our host servers are located in Russia,
- each NLMK entities may transmit web visitors' personal data to its headquarter, NLMK PJSC, located in Russia as part of our centralised communication policy.
In order to guarantee that your personal data will be protected by an adequate level of protection we have concluded with NLMK IT and NLMK PJSC, both located in Russia, standard contractual clauses based on the model approved by the European Commission.
Should you want a copy of this contract, please contact us as explained in point 10 of this Statement.
7. How long do we retain your personal data?
We will not keep your personal data for no longer than the time required to achieve the objectives mentioned in point 4 of this Statement. Any derogations from or clarifications of this principle are explicitly indicated under the different purposes mentioned in point 4 of this Statement.
Given that the need to retain personal data depends on the type of personal data we process and the purpose of the processing, retention periods may vary considerably.
Below you will find the criteria we use as a basis to define the length of retention periods:
- how long do we need your personal data to be able to provide the requested service?
- have we defined and announced a specific retention period?
- have we been granted permission to extend the retention period?
- are we subject to a legal or contractual obligation, or a comparable obligation?
As soon as we no longer need your personal data and are no longer legally obliged to retain them, we will permanently delete them or, if this is not possible, anonymise them in our systems.
Your personal data will, however, be retained and used for the period necessary for the fulfilment of our legal obligations, the settlement of disputes or the conclusion of contracts.
8. How do we secure your personal data?
Your personal data are considered strictly personal. We take appropriate technical and organisational steps to protect the personal data provided and collected from any accidental destruction, loss or alteration, as well as from any damage or accidental or unlawful access, or other unwarranted data processing.
9. What are your rights?
Below you will find an overview of your rights as a data subject.
Note that these rights are not absolute and may depend on the fulfilment of certain conditions.
The right of access to your personal data
You have the right to access and inspect the personal data processed by NLMK at all times. At your request, NLMK will provide a copy of these personal data.
The right to have your personal data rectified
You have the right to have inaccurate, incomplete, inappropriate or outdated personal data erased or rectified without undue delay.
The right to obtain the erasure of your personal data
You have the right to obtain from NLMK the erasure of your personal data where one of the following grounds applies:
- the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- the personal data were unlawfully processed;
- you object to the processing for justified reasons.
The right to limit certain processing operations
You have the right to obtain from NLMK restriction of processing where one of the following applies:
- you contest the accuracy of your personal data, for a period enabling NLMK to verify the accuracy of your personal data;
- the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
- NLMK no longer needs the personal data for the purposes of the processing, but you require your personal data for the establishment, exercise or defence of legal claims;
- you have objected to processing pending the verification whether the legitimate grounds of NLMK override yours.
The right to transfer personal data
You have the right to receive your personal data processed by NLMK in a structured, commonly used and digital form so that you can retain them for personal (re)use, or transmit those personal data to another controller without hindrance from NLMK. This right applies insofar as this is technically possible for the controller (NLMK).
The right to object to certain processing operations
You are entitled at all times to object to processing for reasons relating to your specific situation.
NLMK will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Right to lodge a complaint with the supervisory authority
If you are of the opinion that the processing of your personal data does not comply with the legislation and/or if we do not grant (correctly) your rights request, you can lodge a complaint before your local data protection authority (depending of your residential country). Please see here a link to the national data protection authorities located in the European Union and the European Economic Area.
Right to withdraw your consent
NLMK may, from time to time, ask you to consent for a specific processing. Should this situation take place, you have the right to withdraw your consent, at any time, without having to give a specific reason.
10. How can you exercise you rights?
To exercise the privacy rights mentioned above, your request must be dated and signed and a copy of your identity must be included. This request is sent either:
- by email to DPO@eu.nlmk.com or ;
- by post to the following address: NLMK Belgium holdings SA Rue des Rivaux 2, 7100 La Louvière Belgium
This request is free of charge, except where NLMK considers the request to be manifestly unfounded or excessive (as in the case of a repeated request).
For any additional copy requested, we may also request payment of a reasonable fee based on administrative costs.
Your request will be processed within one month. This period of time may be extended by two months, taking into account such factors as the complexity and number of requests. In the event of an extension of the term, you are informed of this and of the reasons for the extension.
Where necessary, we will notify the third parties to whom your personal data were communicated of any rectification, erasure or limitation that has been carried out unless this is not possible or requires a disproportionate effort.
11. How can you ask a question or lodge a complaint?
If you have any question or wish to lodge a complaint concerning the processing of your personal data, you may contact us via
- by email to DPO@eu.nlmk.com or;
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by post to the following address:
NLMK Belgium holdings SA
Rue des Rivaux 2,
7100 La Louvière
Belgium
If you are not satisfied with our response, if you have comments regarding the exercising of your rights or if you believe that the processing does not comply with legislation, a complaint may be lodged before your local data protection authority (depending of your residential country). Please see here a link to the national data protection authorities located in the European Union and the European Economic Area.
12. Modification of this Statement
NLMK reserves the right to modify this Statement and update it at any time.
In the case of significant changes, you will be informed accordingly.
We encourage you to consult this Privacy Statement periodically in order to learn how we process and protect your personal data by consulting our websites.