APPROVED
Minutes of the General Meeting of Participants of Tech and Business Solutions LLC
No. 17 dated 10/01/2024
Revision 1.00 dated 10/02/2024
1.1. This Policy on the processing of personal data (hereinafter referred to as the Policy) defines the activities of the management company of the holding "1AK-GROUP" - Limited Liability Company "Tech and Business Solutions", registered at the address: Republic of Belarus, 225710, Brest region, Pinsk, Kalinovsky proezd, 2, off. 7 postal address: Republic of Belarus, 225710, Brest region, Pinsk, Kalinovsky proezd, 2, off. 7. (hereinafter referred to as the Company or the Operator) in relation to the processing of personal data.
1.2. This Policy has been developed in compliance with the requirements of the Law of the Republic of Belarus dated 07.05.2021 No. 99-3 "On the Protection of Personal Data" (hereinafter referred to as the Law).
1.3. The concepts contained in Art. 1 of the Law are used in this Policy with the same meaning:
1.4. The following terms are used in this Policy:
Services are any services, products, programs, events, services of the Company (including, but not limited to, Bitrix, iSpring, etc.).
Websites – 1ak-group.com and other websites owned by the Company, subdomains of these websites, as well as other services with which the company works.
1.5. This Policy applies to all operations performed by the Operator with personal data using automation tools or without them.
1.6. This Policy comes into force from the moment of its approval.
2.1. The operator processes personal data that may be obtained from the following personal data subjects:
2.2. The operator processes the following personal data of the personal data subject:
2.3. To analyze the operation of the Sites and Services, the Operator processes the following data:
2.4. The operator ensures that the content and volume of personal data processed correspond to the stated purposes of processing and, if necessary, takes measures to eliminate their redundancy in relation to the stated purposes of processing.
2.5. The operator processes biometric personal data only subject to the consent of the subject of personal data or without consent in other cases stipulated by the legislation of the Republic of Belarus.
2.6. The Operator does not process special personal data related to race, nationality, political views, membership in trade unions, religious and other beliefs, health, sexual life, administrative or criminal liability, except for cases when the subject of personal data 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.
3.1. The operator processes personal data for the following purposes:
4.1. The operator has the right:
4.2. The operator is obliged to:
4.3. The subject of personal data has the right:
4.4. The subject of personal data is obliged to:
5.1. The basis for the 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 the processing of personal data is carried out without obtaining such consent.
5.2. The consent of the subject of personal data is a free, unambiguous, informed expression of his will, by which he permits the processing of his personal data.
The Subject's consent may be obtained in writing, in the form of an electronic document or in another electronic form.
In other electronic form, the consent of the Subject may be obtained through:
5.3. Before receiving the consent of the personal data subject, the Company is obliged to provide the personal data subject with information in written or electronic form corresponding to the form of expression of such consent, containing:
Before receiving the Subject's consent, the Company is obliged to explain to the Subject in simple and clear language his rights related to the processing of personal data, the mechanism for implementing such rights, as well as the consequences of the Subject's consent or refusal to give such consent. This information must be provided by the Company to the Subject in written or electronic form corresponding to the form of expression of his consent, separately from other information provided to him.
5.4. When giving consent to the Company, the Subject shall indicate his/her last name, first name, patronymic (if any), date of birth, identification number, and, in the absence of such number, the number of the document certifying his/her identity, except for the case provided for in part two of this clause.
If the purposes of processing personal data do not require the processing of the information specified in the first part of this paragraph, this information shall not be processed by the Company upon receipt of the consent of the Subject.
5.5. The burden of proof of obtaining the Subject's consent rests with the Operator. Refusal to give consent to the processing of personal data entitles the Operator to refuse the subject of personal data access to the Company's Websites and Services.
5.6. The processing of personal data by the Operator includes the following actions with personal data: collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, deletion, and other actions in accordance with the legislation of the Republic of Belarus.
5.7. Methods of processing personal data by the Operator:
5.8. Personal data shall be stored in a form that allows the identification of the subject of personal data, for a period no longer than required by the purposes of processing the personal data, except in cases where the storage period of personal data is established by the legislation of the Republic of Belarus, an agreement concluded (being concluded) with the subject of personal data, for the purpose of performing the actions established by this agreement.
5.9. The condition for termination of the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the period for processing personal data, the revocation of the consent of the subject of personal data to the processing of his personal data, as well as the identification of unlawful processing of personal data.
5.10. When processing personal data, the Operator takes the necessary legal, organizational and technical measures to ensure the protection of personal data from unauthorized or accidental access to them, modification, blocking, copying, distribution, provision, deletion of personal data, as well as from other illegal actions in relation to personal data.
5.11 The Company processes special personal data exclusively for the purposes specified in paragraph 3.1. of this Policy. The Company may also process biometric personal data for the purposes specified in paragraph 3.1. of this Policy.
5.12. The processing of special, including biometric, personal data is permitted only if a set of measures is taken to prevent risks that may arise during the processing of such personal data for the rights and freedoms of personal data subjects.
5.13. The Company does not carry out cross-border transfer of personal data if the territory of a foreign state does not ensure an adequate level of protection of the rights of personal data subjects, except in cases established by law.
6.1. The personal data subject has the right to revoke 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:
The operator, within 15 days after receiving the application, stops processing personal data (if there are no grounds for processing, according to the law), deletes them, and if there is no technical possibility of deleting them, takes measures to prevent further processing of personal data, including blocking them, and notifies the subject of personal data about this within the same period.
6.2. The personal data subject has the right to receive information from the Operator concerning the processing of his/her personal data by submitting an application to the Operator in the manner prescribed by clause 6.1 of these Rules. The Operator, within 5 working days after receiving the application, provides the personal data subject with the relevant information or notifies him/her of the reasons for refusing to provide such information.
6.3. The personal data subject has the right to demand that the Operator make changes to his/her personal data if they are incomplete, outdated or inaccurate by submitting an application to the Operator in the manner prescribed by clause 6.1 of these rules, with attached documents (copies certified in the established manner) confirming the need to make such changes. The Operator, within 15 days after receiving the application, makes changes to the personal data and notifies the personal data subject thereof or notifies of the reasons for refusing to make changes.
6.4. The personal data subject has the right to receive information from the Operator about the provision of his/her personal data to third parties once per calendar year free of charge, by submitting an application to the Operator in the manner prescribed by clause 6.1 of these Rules. The Operator, within 15 days after receiving the application, provides the personal data subject with information about which personal data of this subject and to whom were provided during the year preceding the date of filing the application, or notifies him/her of the reasons for refusing to provide such information.
6.5. The personal data subject has the right to demand that the Operator stop processing his/her personal data, including deleting them, if there are no grounds for processing, by submitting an application to the Operator in the manner prescribed by clause 6.1 of these Rules. Within 15 days after receiving the application, the Operator stops processing the personal data (if there are no grounds for processing, in accordance with the law), deletes them, and if there is no technical possibility of deleting them, takes measures to prevent further processing of the personal data, including blocking them, and notifies the personal data subject about this within the same period.
7.1. The Company is obliged to take legal, organizational and technical measures to ensure the protection of personal data from unauthorized or accidental access to them, modification, blocking, copying, distribution, provision, deletion of personal data, as well as from other illegal actions in relation to personal data.
7.2. To protect personal data, the Company takes the following measures:
7.3. The Company is obliged to provide unlimited access, including through the use of the global computer network Internet, to documents defining the Company’s policy regarding the processing of personal data, prior to the commencement of such processing.
7.4. The classification of information resources (systems) containing personal data, for the purpose of determining the requirements for technical and cryptographic protection of personal data, shall be established by the authorized body for the protection of the rights of personal data subjects.
8.1. Issues related to the processing of personal data that are not set out in this Policy are governed by the legislation of the Republic of Belarus.
8.2. If any provision of the Policy is recognized as contradicting the legislation, the remaining provisions that comply with the legislation shall remain in force and are valid, and any invalid provision will be considered deleted/modified to the extent necessary to ensure its compliance with the legislation.
8.3. The Operator has the right, at its own discretion, to change 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 always available at: 1ak-group.com/politika-konfidenczialnosti.html
8.4. The personal data subject can receive any clarifications on issues of interest related to the processing of his personal data by contacting the Site Administration via e-mail info@1ak-group.com.