Company policy regarding the processing of personal data

2021 YEAR
1. GENERAL PROVISIONS
The personal data processing policy (hereinafter referred to as the Policy) has been developed in accordance with the Legislation of the Republic of Belarus.
This Policy defines the procedure for processing personal data and measures to ensure the security of personal data in IE Antonchenko Tatyana Aleksandrovna (hereinafter referred to as the Operator) in order to protect the rights and freedoms of a person and citizen when processing his personal data, including protecting the rights to privacy, personal and family secret.
The Policy uses the following basic concepts:
automated processing of personal data — processing of personal data using computer technology;
blocking of personal data - temporary termination of the processing of personal data (except for cases where processing is necessary to clarify personal data);
information system of personal data - a set of personal data contained in databases, and providing their processing of information technologies and technical means;
depersonalization of personal data - actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific subject of personal data;
processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
operator - a state body, a municipal body, a legal entity or an individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data;
personal data - any information relating directly or indirectly to a specific or identifiable individual (subject of personal data);
provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons;
dissemination of personal data - actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at acquaintance with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunication networks or providing access to personal data in any other way;
cross-border transfer of personal data - the transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign individual or foreign legal entity.
destruction of personal data - actions as a result of which it is impossible to restore the content of personal data in the information system of personal data and (or) as a result of which material carriers of personal data are destroyed;
The company is obliged to publish or otherwise provide access to
this Policy for the processing of personal data in accordance with the Legislation of the Republic of Belarus.

2 PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING
2.1 Principles of processing personal data
The processing of personal data by the Operator is carried out on the basis of the following principles:
- legality and fair basis;
restrictions on the processing of personal data to achieve specific, predetermined and legitimate goals;
- preventing the processing of personal data incompatible with the purposes of collecting personal data;
- preventing the unification of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
- processing only those personal data that meet the purposes of their processing;
compliance of the content and volume of processed personal data with the stated processing objectives;
- preventing the processing of personal data that is redundant in relation to the stated purposes of their processing;
- ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
- destruction or depersonalization of personal data upon reaching the goals of their processing or in case of loss of the need to achieve these goals, if the Operator cannot eliminate the violations of personal data, unless otherwise provided by the Legislation of the Republic of Belarus.


2 PRINCIPLES AND CONDITIONS OF PERSONAL DATA PROCESSING
2.1 Principles of processing personal data
The processing of personal data by the Operator is carried out on the basis of the following principles:
- legality and fair basis;
restrictions on the processing of personal data to achieve specific, predetermined and legitimate goals;
- preventing the processing of personal data incompatible with the purposes of collecting personal data;
- preventing the unification of databases containing personal data, the processing of which is carried out for purposes incompatible with each other;
- processing only those personal data that meet the purposes of their processing;
compliance of the content and volume of processed personal data with the stated processing objectives;
- preventing the processing of personal data that is redundant in relation to the stated purposes of their processing;
- ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of processing personal data;
- destruction or depersonalization of personal data upon reaching the goals of their processing or in case of loss of the need to achieve these goals, if the Operator cannot eliminate the violations of personal data, unless otherwise provided by the Legislation of the Republic of Belarus.
2.2 Conditions for processing personal data
The operator processes personal data if at least one of the following conditions is met:
- processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data;
- the processing of personal data is necessary to achieve the goals provided for by an international treaty of the Republic of Belarus or by law, for the implementation and implementation of the functions, powers and duties imposed by the legislation of the Republic of Belarus on the operator;
- the processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Republic of Belarus on enforcement proceedings;
- processing of personal data is necessary for the execution of a contract, to which the subject of personal data is either a party or a beneficiary or a guarantor, as well as for concluding an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data will be a beneficiary or guarantor;
- processing of personal data is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of the subject of personal data;
- processing of personal data is carried out, access to an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter - publicly available personal data);
- processing of personal data subject to publication or mandatory disclosure in accordance with the Legislation of the Republic of Belarus.
2.3 Confidentiality of personal data
The operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data, unless otherwise provided by the Legislation of the Republic of Belarus.
2.4 Publicly available sources of personal data
In order to provide information, the Operator may create publicly available sources of personal data of subjects, including directories and address books. The publicly available sources of personal data, with the written consent of the subject, may include his last name, first name, patronymic, date and place of birth, position, contact phone numbers, e-mail address and other personal data provided by the subject of personal data.
Information about the subject must at any time be excluded from publicly available sources of personal data at the request of the subject or by decision of a court or other authorized state bodies.

2.5 Special categories of personal data
The processing by the Operator of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, health status, intimate life is allowed in cases where:
- the subject of personal data has given his consent in writing to the processing of his personal data;
- personal data is made publicly available by the subject of personal data;
- the processing of personal data is carried out in accordance with the legislation on state social assistance, labor legislation, the Legislation of the Republic of Belarus on pensions for state pensions, on labor pensions;
- the processing of personal data is necessary to protect the life, health or other vital interests of the subject of personal data or the life, health or other vital interests of others and obtaining the consent of the subject
The processing of special categories of personal data should be immediately terminated if the reasons due to which their processing was carried out are eliminated, unless otherwise provided by the Legislation of the Republic of Belarus.
The processing of personal data on criminal records can be carried out by the Operator only in cases and in the manner that are determined in accordance with the Legislation of the Republic of Belarus.
2.6 Biometric personal data
Information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity - biometric personal data - can be processed by the Operator only with the consent in writing of the subject.
2.7 Ordering the processing of personal data to another person
The operator has the right to entrust the processing of personal data to another person with the consent of the subject of personal data, unless otherwise provided by the legislation of the Republic of Belarus, on the basis of an agreement concluded with this person.
The person carrying out the processing of personal data on
on behalf of the Operator, is obliged to comply with the principles and rules for the processing of personal data provided for by the Legislation of the Republic of Belarus.
2.8 Cross-border transfer of personal data
The operator is obliged to make sure that the foreign state, to whose territory it is supposed to transfer personal data, provides adequate protection of the rights of subjects of personal data, prior to the start of such transfer.
Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of subjects of personal data can be carried out
in cases:
- availability of written consent of the personal data subject to - cross-border transfer of his personal data;
execution of an agreement to which the subject of personal data is a party.
3 RIGHTS OF THE PERSONAL DATA SUBJECT
3.1 Consent of the subject of personal data to the processing of his personal data
The subject of personal data decides on the provision of his personal data and agrees to their processing freely, of his own free will and in his interest. Consent to the processing of personal data can be given by the subject of personal data or his representative in any form that allows to confirm the fact of its receipt, unless otherwise
established by the Legislation of the Republic of Belarus.

The obligation to provide proof of receipt of the consent of the subject of personal data to the processing of his personal data or proof of the existence of the grounds specified in the Legislation of the Republic of Belarus rests with the Operator.
3.2 Rights of the personal data subject
The subject of personal data has the right to receive information from the Operator regarding the processing of his personal data, if such a right is not limited in accordance with the Legislation of the Republic of Belarus. The subject of personal data has the right to demand that the Operator clarify his personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights ...
The processing of personal data in order to promote goods, works, services on the market by making direct contacts with a potential consumer using communication means, as well as for the purpose of political campaigning, is allowed only with the prior consent of the subject of personal data.
The specified processing of personal data is recognized as carried out without the prior consent of the subject of personal data, if the Company does not
proves that such consent has been obtained.
The operator is obliged to immediately stop, at the request of the personal data subject, the processing of his personal data for the above purposes.
It is prohibited to make decisions on the basis of solely automated processing of personal data that give rise to legal consequences in relation to the subject of personal data or otherwise affect his rights and legitimate interests, with the exception of cases provided for by the Legislation of the Republic of Belarus, or if there is consent in
written form of the subject of personal data.
If the subject of personal data believes that the Operator is processing his personal data in violation of the requirements of the Legislation of the Republic of Belarus or otherwise violates his rights and freedoms, the subject of personal data has the right to appeal against the actions or inaction of the Operator to the Authorized body for the protection of the rights of subjects of personal data or in court ...
The subject of personal data has the right to protect his rights and legitimate interests, including compensation for damages and (or) compensation for moral damage in court.
4 ENSURING THE SECURITY OF PERSONAL DATA
The security of personal data processed by the Operator is ensured by the implementation of legal, organizational and technical measures necessary to meet the requirements of the Legislation of the Republic of Belarus in the field of personal data protection.
To prevent unauthorized access to personal data, the Operator applies the following organizational and technical measures:
- appointment of officials, if necessary, responsible for organizing the processing and protection of personal data;
- limiting the composition of persons with access to personal data;
familiarization of subjects with the requirements of the Legislation of the Republic of Belarus and the Operator's regulatory documents on the processing and protection of personal data;
- organization of accounting, storage and circulation of information carriers;
identification of threats to the security of personal data during their processing, the formation of threat models on their basis;
- development of a personal data protection system based on the threat model;
checking the readiness and effectiveness of the use of information security tools;
- differentiation of user access to information resources and
software and hardware for information processing;
- registration and accounting of actions of users of information systems of personal data;
- use of anti-virus tools and means of restoring the personal data protection system;
- the use of firewalling, intrusion detection, security analysis and cryptographic information protection means, if necessary;
organization of access control to the territory of the Operator, protection of premises with technical means for processing personal data.
5 FINAL PROVISIONS
Other rights and obligations of the Operator as an operator of personal data are determined by the Legislation of the Republic of Belarus in the field of personal data.
Operator's officials guilty of violating the rules governing the processing and protection of personal data will bear material, disciplinary, administrative, civil or criminal liability in the manner prescribed by the legislation of the Republic of Belarus.
The Company has the right to make changes to this Privacy Policy without the consent of the User.
All suggestions or questions about this Privacy Policy should be reported in the "Contacts" section of the site.

The current Privacy Policy is posted on the page at:https://antinteriordevelopment.com/confidentiality...

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