Privacy Policy
1. GENERAL PROVISIONS
1.1. This Policy regarding the processing of personal data (hereinafter referred to as the Policy) determines the activities of the Limited Liability Company “Mollyflex”, registered at the address: Republic of Belarus, 220104, Minsk, st. Olshevsky 76A UNP 193645251 (hereinafter referred to as the Company or Operator) regarding 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 Personal Data Protection”.
1.3. The policy is determined in accordance with the following regulatory legal acts:
· Constitution of the Republic of Belarus;
· Labor Code of the Republic of Belarus;
· The Law of the Republic of Belarus of 07.05.2021 N 99-Z “On the protection of personal data” (hereinafter – the Law);
· Law of the Republic of Belarus No. 418-Z of 21.07.2008 “On the Population Register”;
· Law of the Republic of Belarus of 10.11.2008 N 455-Z “On information, informatization and information protection”;
· Other regulatory legal acts of the Republic of Belarus and regulatory documents of authorized state authorities.
1.4. The terms and definitions contained in Article 1 of the Law are used in this Policy with a similar meaning.
1.5. The following terms are used in this Policy:
Services are any services, products, programs, events, services of the Company.
Sites – https://vipmatras.by / and other Company-owned sites, as well as subdomains of these sites.
1.6. This Policy applies to all operations performed by the Operator with personal data using automation tools or without their use.
1.7. This Policy comes into force from the moment of its approval.
2. CATEGORIES OF PERSONAL DATA SUBJECTS
AND THE VOLUME OF PERSONAL DATA PROCESSED
2.1. The Operator processes personal data that can be obtained from the following personal data subjects: Company members and Company affiliates; Company employees, former employees, candidates for vacant positions; contractors and clients of the Company who are individuals; representatives and/or employees of contractors and clients of the Company who are legal entities or individual entrepreneurs; visitors to the Company’s Websites and Services; people who have provided personal data to the Company by subscribing to the newsletter, by sending feedback, appeals, by filling out questionnaires during advertising and other events conducted by the Company; people who have provided personal data to the Company in another way.
2.2. The operator processes the following personal data of the personal data subject:
surname, first name, patronymic; gender; date of birth; email address; phone number; place of residence; history of requests and views on the Company’s Websites and Services; other information (the specified list may be reduced or expanded depending on the specific case and processing purposes).
2.3. To analyze the operation of Sites and Services, the Operator processes such data as: IP address; browser information; cookie data; addresses of requested pages; access time.
2.4. The operator ensures that the content and volume of the processed personal data correspond to the stated processing purposes and, if necessary, takes measures to eliminate their redundancy in relation to the stated processing purposes.
2.5. The operator processes biometric personal data only with the consent of the subject of personal data 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 race, nationality, political views, membership in trade unions, religious and other beliefs, health, sexual life, bringing to administrative or criminal responsibility, except in cases when the subject of personal data independently provided such data to the Operator, or they became known to the Operator in accordance with with the legislation of the Republic of Belarus.
2.7. The operator, if necessary, in order 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. PURPOSES OF PERSONAL DATA COLLECTION
3.1. The Operator processes personal data for the following purposes:
carrying out communications with personal data subjects; making various transactions with personal data subjects, their subsequent execution, and, if necessary, modification and termination (termination); providing personal data subjects with Company Services; providing personal data subjects with information about the Company’s activities, about the Company’s development of new Sites and Services; sending notifications to personal data subjects, commercial offers, advertising and informational messages; The Company conducts promotions, surveys, interviews, tests on the Company’s Websites and Services; evaluation and analysis of the Company’s Services, monitoring and improving the quality of the Company’s Services; informing about the work of the Company’s Websites; registration and maintenance of accounts on the Company’s Websites and Services; processing appeals and requests received from personal data subjects; attracting candidates for occupation of vacant positions of the Company; conducting personnel work and organization of accounting of employees of the Company; formation of statistical reports, conducting research; implementation of economic activity; implementation of other powers and duties assigned to the Operator by the legislation of the Republic of Belarus.
4. BASIC RIGHTS AND OBLIGATIONS OF THE OPERATOR AND THE SUBJECT OF PERSONAL DATA
4.1. The operator has the right to:
receive reliable information and/or documents containing personal data from the subject of personal data; request information from the subject of personal data on the relevance and reliability of the personal data provided; refuse to satisfy the requirements of the subject of personal data to terminate the processing of his personal data and/or delete them if there are grounds for processing provided for by the legislation of the Republic of Belarus, in including if they are necessary for the stated purposes of their processing.
4.2. The operator is obliged to:
to process personal data in accordance to the procedure established by the legislation of the Republic of Belarus; to ensure the protection of personal data during their processing; to take measures to ensure the reliability of the personal data processed by them, to make changes to personal data that are incomplete, outdated or inaccurate; to consider the statements of personal data subjects on the processing of personal data and give motivated answers to them; to provide the subject of personal data with information about his personal data, about their provision to third parties; to terminate the processing of personal data, as well as to delete or block them in the absence of grounds for their processing, as well as at the request of the subject of personal data; to perform other duties provided for by the legislation of the Republic of Belarus.
4.3. The subject of personal data has the right to:
to receive information concerning the processing of his personal data by the Operator; to make changes to his personal data if the personal data is incomplete, outdated or inaccurate; to withdraw his consent to the processing of personal data; to receive information about the provision of his personal data to third parties; to terminate the processing of his personal data, including their removal, if there are no grounds for their processing; to appeal the actions/omissions and decisions of the Operator related to the processing of his personal data to the authorized body for the protection of the rights of personal data subjects in accordance with the procedure established by law; to exercise other rights provided for by the legislation of the Republic of Belarus.
4.4. The subject of personal data is obliged to:
provide the Operator with exclusively reliable information about yourself; if necessary, provide the Operator with documents containing personal data to the extent necessary for the purpose of their processing; inform the Operator about changes to your personal data.
4.5. A person who has provided the Operator with incomplete, outdated, unreliable information about himself or herself, or information about another personal data subject without the latter’s consent, is liable in accordance with the legislation of the Republic of Belarus.
5. PROCEDURE AND CONDITIONS OF PERSONAL DATA PROCESSING
5.1. The basis for the processing of personal data is the consent of the subject of personal data, except in 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, through which he authorizes the processing of his personal data.
Refusal to consent to the processing of personal data gives the Operator the right to refuse the subject of personal data to provide access to the Company’s Websites and Services.
5.3. 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, other actions, in accordance with the legislation of the Republic of Belarus.
5.4. Methods of processing personal data 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. The storage of personal data is carried out in a form that allows you to identify the subject of personal data for a period no longer than the purposes of personal data processing require, except in cases when the storage period of personal data is established by the legislation of the Republic of Belarus, an agreement concluded (concluded) with the subject of personal data for the purpose of performing the actions established by this agreement.
5.6. The condition for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiration of the personal data processing period, the withdrawal of the consent of the personal data subject to the processing of his personal data, as well as the identification of unlawful processing of personal data.
5.7. 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 unlawful actions with respect to personal data.
6. MECHANISM OF REALIZATION OF THE RIGHTS OF THE SUBJECT OF PERSONAL DATA
6.1. The subject of personal data has the right to withdraw his consent to the processing of personal data by submitting an application to the Operator in writing, sent by registered mail, or in the form of an electronic document. The application must contain: surname, first name, patronymic of the subject of personal data; address of residence (place of stay); date of birth; identification number (if indicated when giving consent or processing of personal data is carried out without the consent of the subject of personal data); statement of the essence of the requirement; personal signature or electronic digital signature.
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, in the absence of a technical possibility of deletion, takes measures to prevent further processing of personal data, including blocking them, and notifies the subject of personal data about it within the same period.
6.2. The subject of personal data has the right to obtain information from the Operator concerning the processing of his personal data by submitting an application to the Operator in accordance with the procedure provided for in 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 of the reasons for refusing to provide such information.
6.3. The subject of personal data has the right to require the Operator to make changes to his personal data if they are incomplete, outdated or inaccurate by submitting an application to the Operator in accordance with paragraph 6.1 of these rules, with the attachment of documents (duly certified copies) 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 about it or notifies about the reasons for refusing to make changes.
6.4. The subject of personal data has the right to receive information from the Operator about the provision of his personal data to third parties once a calendar year for free, by submitting an application to the Operator in accordance with paragraph 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 of the reasons for refusing to provide such information.
6.5. The subject of personal data has the right to demand from the Operator the termination of the processing of his personal data, including their deletion, in the absence of grounds for processing, by submitting an application to the Operator in accordance with paragraph 6.1 of these Rules. The operator stops processing personal data within 15 days after receiving the application (if there are no grounds for processing, according to the law), deletes them, in the absence of a technical possibility of deletion, takes measures to prevent further processing of personal data, including blocking them, and notifies the subject of personal data about it within the same period.
7. FINAL PROVISIONS
7.1. Issues related to the processing of personal data that are not fixed in this Policy are regulated by the legislation of the Republic of Belarus.
7.2. If any provision of the Policy is found to be contrary to the law, the remaining provisions that comply with the law remain in force and are valid, and any invalid provision will be considered deleted/changed to the extent necessary to ensure its compliance with the law.
7.3. The Operator has the right, at its 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.