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Consent to personal date processing

Consent to personal date processing

GENERAL REGULATIONS

1.1 This Policy on personal data processing (hereinafter referred to as the Policy) defines the activity of the Limited Liability Company ‘MYUNIVER’, registered at the address: 220013, Republic of Belarus, Minsk, 37B-11/1 2-ya Shestaya liniya Str. (hereinafter referred to as the Company or the Operator) with regard to personal data processing.

1.2 This Policy is developed in compliance with the requirements of the Law of the Republic of Belarus No. 99-3 of 07.05.2021 ‘On Personal Data Protection’ (hereinafter - the Law).

1.3 The concepts contained in Article 1 of the Law are used in this Policy with the same meaning.

1.4 The following terms are used in this Policy:

Services - any services, products, programmes, events, activities, services of the Company.

Site - https://myuniver.org/ and other sites owned by the Company, as well as subdomains of these sites.

1.5 This Policy applies to all operations performed by the Operator with personal data with or without the use of automation tools.

1.6 This Policy comes into force from the moment of its approval.

 

CATEGORIES OF PERSONAL DATA SUBJECTS AND SCOPE OF PROCESSED PERSONAL DATA

2.1 The Operator processes personal data that can be obtained from the following subjects of personal data:

Company's participants and Company's affiliates;

the Company's employees, former employees, candidates for vacant positions;

the Company's counterparties and clients who are natural persons; 

representatives and/or employees of the Company's counterparties and clients who are legal entities or individual entrepreneurs; visitors to the Company's Sites and Services;

persons who have provided personal data to the Company by subscribing to mailing lists, sending feedback, appeals, filling out questionnaires during promotional and other events organised by the Company;

persons who provided personal data to the Company in other ways.

2.2 The Operator processes the following personal data of the subject:

  • personal data; 
  • surname, first name, patronymic; 
  • gender; 
  • date of birth; 
  • e-mail address; 
  • telephone number; citizenship; 
  • history of requests and browsing on the Company's Sites and Services; 
  • other information (the above list may be reduced or expanded depending on the specific case and purposes of processing).

2.3 To analyse the operation of the Sites and Services, the Operator processes such data as:

ІР-address; 

  • browser information; 
  • data from cookies; 
  • addresses of requested pages; 
  • access time.

2.4 The Operator ensures compliance of the content and amount of processed personal data with the stated processing purposes and, if necessary, takes measures to eliminate their redundancy in relation to the stated processing purposes.

2.5 The Operator does not process biometric personal data with the consent of the personal data subject or without consent in other cases provided for by the legislation of the Republic of Belarus.

2.6 The Operator does not process special personal data concerning racial, nationality, political views, membership in trade unions, religious and other beliefs, health, sex life, administrative or criminal liability, unless the personal data subject has independently provided such data to the Operator, or they became known to the Operator in accordance with the legislation of the Republic of Belarus.

2.7 The Operator, if necessary to achieve the purposes of processing, has the right to transfer personal data to third parties in compliance with the requirements of the legislation of the Republic of Belarus.

PURPOSES OF PERSONAL DATA PROCESSING

3.1 The Operator processes personal data for the following purposes:

  • realisation of communications with the subjects of personal data; 
  • execution of various transactions with personal data subjects, their subsequent execution, and, if necessary, modification and cancellation (termination); 
  • providing personal data subjects with the Company's Services; providing personal data subjects with information on the Company's activities, on the development of new Sites and Services by the Company; 
  • sending notices, commercial offers, advertising and information messages to the subjects of personal data; 
  • conducting by the Company of promotions, surveys, interviews, tests on the Company's Sites and Services; 
  • assessing and analysing the performance of the Company's Services, controlling and improving the quality of the Company's Services; informing about the performance of the Company's Sites; 
  • registration and maintenance of accounts on the Company's Sites and Services; 
  • processing of appeals and requests received from subjects of personal data; 
  • attracting candidates for vacant positions of the Company; 
  • maintaining personnel work and organising the Company's employee records; 
  • preparation of statistical reports, conducting research; 
  • carrying out economic activities; 
  • fulfilment of other powers and duties assigned to the Operator by the legislation of the Republic of Belarus.

GENERAL RIGHTS AND RESPONSIBILITIES OF THE OPERATOR AND THE PERSONAL DATA SUBJECT

4.1 The Operator has the right:

  • to receive from the personal data subject reliable information and/or documents containing personal data; 
  • to request from the personal data subject information on the relevance and reliability of the personal data provided; 
  • to refuse to satisfy the personal data subject's requests to stop processing of his/her personal data and/or their deletion if there are grounds for processing provided for by the legislation of the Republic of Belarus, including if they are necessary for the stated purposes of their processing.

4.2 The Operator is obliged:

  • to process personal data in accordance with the procedure established by the legislation of the Republic of Belarus; 
  • to ensure protection of personal data in the process of their processing; 
  • to take measures to ensure the reliability of personal data processed by it, make changes to personal data that are incomplete, outdated or inaccurate; 
  • to consider applications of personal data subjects on the issues of personal data processing and give reasoned answers to them; 
  • to provide the subject of personal data with information about his/her personal data.

4.3 The personal data subject has the right:

  • to receive information regarding the Operator's processing of his/her personal data; 
  • to amend his/her personal data in case the personal data is incomplete, outdated or inaccurate; 
  • to withdraw his/her consent to the processing of personal data; 
  • to receive information regarding the provision of his/her personal data to third parties; 
  • to stop processing of his/her personal data, including its deletion, in the absence of grounds for processing; 
  • to appeal against the Operator's action/inaction and decision relating to the processing.

4.4 The personal data subject is obliged to:

  • to provide the Operator with exclusively reliable information about himself/herself; 
  • if necessary, to provide the Operator with documents containing personal data to the extent necessary for the purpose of their processing; 
  • to inform the Operator about changes in his/her personal data.

4.5 A person who provided the Operator with incomplete, outdated, unreliable information about himself/herself or information about another subject of personal data without the consent of the latter shall be liable in accordance with the legislation of the Republic of Belarus.

PROCEDURE AND CONDITIONS OF PERSONAL DATA PROCESSING

5.1 The basis for processing of personal data is the consent of the subject of personal data, except for cases established by the legislation of the Republic of Belarus, when processing of personal data is carried out without obtaining such consent.

5.2 The consent of the personal data subject is a free, unambiguous, informed expression of his/her will, through which he/she authorises the processing of his/her personal data.

Refusal to consent to the processing of personal data entitles the Operator to deny the subject of personal data access to the Website.

5.3 Processing of personal data by the Operator includes the following actions with personal data: collection, systematisation, storage, modification, use, depersonalisation, blocking, distribution, provision, deletion, other actions in accordance with the legislation of the Republic of Belarus.

5.4 Methods of personal data processing by the Operator: non-automated processing of personal data; automated processing of personal data with or without transmission of the received information via information and telecommunication networks; mixed processing of personal data.

5.5 Storage of personal data is carried out in a form that allows to identify the subject of personal data, for a period not longer than required by the purposes of personal data processing, except in cases when the period of personal data storage is established by the legislation of the Republic of Belarus, the contract concluded (to be concluded) with the subject of personal data, in order to perform the actions established by this contract.

5.6 The condition for termination of personal data processing may be the achievement of the purposes of personal data processing, expiry of the term of personal data processing, withdrawal of the personal data subject's consent to the processing of his/her personal data, as well as detection of unlawful processing of personal data.

5.7 When processing personal data, the Operator shall take the necessary legal, organisational and technical measures to ensure protection of personal data from unauthorised or accidental access to them, modification, blocking, copying, distribution, provision, deletion of personal data, as well as from other unlawful actions in relation to personal data.

MECHANISM OF EXECUTION OF THE PERSONAL DATA SUBJECT'S RIGHTS

6.1 The personal data subject has the right to withdraw his/her consent to the processing of personal data by submitting to the Operator an application in writing sent by registered mail or in the form of an electronic document. The application must contain: surname, first name, patronymic of the personal data subject; date of birth; statement of the essence of the request; personal signature or electronic digital signature.

Within 15 days after receipt of the application, the operator stops processing of personal data (if there are no grounds for processing according to the legislation), deletes them, in the absence of technical possibility of deletion takes measures to prevent further processing of personal data, including their blocking, and notifies the subject of personal data within the same period.

6.2 The personal data subject has the right to obtain information from the Operator regarding the processing of his/her personal data by submitting an application to the Operator in accordance with the procedure stipulated in clause 6.1 of this Policy. 6.1 of this Policy. Within 5 working days after receipt of the application, the Operator shall provide the personal data subject with the relevant information or notify him/her of the reasons for refusal to provide such information.

6.3 The personal data subject has the right to request the Operator to amend his/her personal data in case it is incomplete, outdated or inaccurate, by submitting an application to the Operator in the manner prescribed by clause 6.1 of this Policy. 6.1 of this Policy, attaching documents (duly certified copies) confirming the need to make such changes. Within 15 days after receiving the application, the Operator shall make changes to the personal data and notify the personal data subject thereof or notify the reasons for refusal to make changes.

6.4 The subject of personal data has the right to receive information from the Operator about the provision of his/her personal data to third parties once a calendar year free of charge, by submitting an application to the Operator in accordance with the procedure stipulated in clause 6.1 of this Policy. 6.1 of this Policy. Within 15 days after receipt of the application, the Operator shall provide the subject of personal data with information on what personal data of this subject and to whom it was provided during the year preceding the date of submission of the application, or notify him/her of the reasons for refusal to provide such information.

CONCLUDING REGULATIONS

7.1 Issues relating to the processing of personal data not set out in this Policy shall be governed by the legislation of the Republic of Belarus.

7.2 In the event that any regulation of the Policy is found to be contrary to the legislation, the remaining regulations that comply with the legislation shall remain in force and be valid, while any invalid regulation shall be deemed deleted/amended to the extent necessary to ensure its compliance with the legislation.

7.3 The Operator shall have the right at its discretion to amend and/or supplement the terms of this Policy without prior and/or subsequent notification of personal data subjects. The current version of the Policy is permanently available at the address: 220013, Republic of Belarus, Minsk, 37B-11/1 2-ya Shestaya liniya Str.