This Regulation of the organization establishes the Policy regarding the procedure for processing personal data on the Sites in order to perform Morozproduct JLLC functions as a personal data operator.
The requirements of the Regulations are mandatory for application in all structural divisions of Morozproduct JLLC.
This standard uses references to the following documents:
Law of the Republic of Belarus “On the Protection of Personal Data” dated 05/07/2021 No. 99-Z.
3.1 blocking of personal data: Termination of access to personal data without deleting it;
3.2 confidentiality of personal data: Mandatory for responsible persons or other persons who have access to personal data to comply with the requirement not to allow their dissemination without the consent of the subject of personal data or the presence of another legal basis;
3.3 depersonalization of personal data: Actions as a result of which it becomes impossible, without the use of additional information, to determine the ownership of personal data to a specific subject of personal data;
3.4 processing of personal data: Any action or set of actions performed with personal data, including collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, deletion of personal data;
3.5 operator: A state body, a legal entity of the Republic of Belarus, another organization, an individual, including an individual entrepreneur (hereinafter, unless otherwise specified, an individual), independently or jointly with other specified persons organizing and (or) carrying out the processing of personal data;
3.6 personal data: Any information relating to an identified or identifiable individual;
3.7 provision of personal data: Actions aimed at becoming familiar with the personal data of a certain person or group of persons;
3.8 dissemination of personal data: Actions aimed at familiarizing with personal data of an indefinite number of persons;
3.9 subject of personal data: An individual in respect of whom personal data is processed;
3.10 cross-border transfer of personal data: Transfer of personal data to the territory of a foreign state;
3.11 deletion of personal data: Actions as a result of which it becomes impossible to restore personal data in information resources (systems) containing personal data and (or) as a result of which material media of personal data are destroyed;
3.12 authorized person: A state body, a legal entity of the Republic of Belarus, another organization, an individual who, in accordance with an act of legislation, a decision of a state body that is an operator, or on the basis of an agreement with an operator, processes personal data on behalf of the operator or in his interests;
3.13 natural person who can be identified: An individual who can be directly or indirectly identified, in particular through his surname, first name, patronymic, date of birth, identification number or through one or more signs characteristic of his physical, psychological, mental , economic, cultural or social identity;
3.2 other terms used in the text of the Policy are used in the meanings applied in the current legislation.
The following abbreviations are used in these Regulations:
Law: Law of the Republic of Belarus “On the Protection of Personal Data” dated 05/07/2021 No. 99-Z,
Operator: Joint Limited Liability Company "Morozproduct",
Policy: Policy regarding the processing of personal data of Morozproduct JLLC on the Sites,
Website: Internet sites: http://moroz.by, http://e-moroz .by, all other domain addresses of Morozproduct JLLC in case of their creation and registration.
4.1 Morozproduct JLLC pays special attention to the protection of personal data during its processing and respects the rights of personal data subjects.
Approval of the Policy regarding the processing of personal data on the Sites is one of the measures taken by Morozproduct JLLC to protect personal data provided for in Article 17 of the Law of the Republic of Belarus of May 7, 2021 No. 99-Z “On the Protection of Personal Data.”
4.2 This Policy regarding the processing of personal data of JLLC “Morozproduct” explains to subjects of personal data how and for what purposes their personal data is collected, used or otherwise processed, and also determines the rights that subjects of personal data have in this regard and the mechanism for their implementation .
The policy does not apply to the processing of personal data in the course of employment and during administrative procedures (in relation to employees and former employees), during video surveillance, as well as when processing cookies on the Morozproduct JLLC Sites.
4.3 The policy regarding the processing and protection of personal data was developed taking into account the requirements of the Constitution of the Republic of Belarus, in accordance with the Law of the Republic of Belarus dated 05/07/2021 No. 99-Z “On the Protection of Personal Data”, and other legislation of the Republic of Belarus.
4.4 When processing and protecting personal data, responsible employees of the organization are guided by the current legislative acts of the Republic of Belarus, this Policy, and other local acts of the organization.
4.5 This Policy defines the organization’s concept regarding the processing and protection of personal data of subjects.
4.6 JLLC “Morozproduct” is registered at the address: 222810 Minsk region, Pukhovichi district, Maryina Gorka, st. Oktyabrskaya, 133, building 5, and is the Operator processing personal data. Operator's postal address: 220056, Minsk, st. Heroes of the 120th Division, 3 A. Email: office@moroz.by, phone +375 17 3000099.
4.7 This Policy applies to personal data processed by the Operator, which can be obtained:
4.8 The collection, processing and storage of personal data are based on the principles of ensuring the protection of human and civil rights and freedoms, including the protection of the rights to privacy, personal and family secrets.
4.10 This policy is publicly available and is posted on the Internet on the Operator’s Websites.
4.11 This Policy is valid from the moment of its approval.
5.1 Processing of personal data is carried out with the consent of the subjects of personal data, as well as on other legal grounds provided for by the legislation of the Republic of Belarus.
5.2 The operator processes personal data both using automation tools (including in information systems and resources) and without the use of such tools, if this provides search for personal data and (or) access to it according to certain criteria (card files, lists , databases, logs, etc.).
5.3 The operator establishes the purposes of processing personal data, categories of personal data subjects whose personal data are processed, a list of personal data processed, legal grounds for processing personal data and storage periods in accordance with Appendix No. 1, which is an integral part of this Policy.
5.4 The processing of personal data is carried out by the Operator by any actions (including their combination), including collection, systematization, storage, modification, use, depersonalization, blocking, provision, and deletion of personal data.
5.5 By providing their consent to the processing of personal data to the Operator, subjects of personal data agree to the Operator performing the following actions with personal data in accordance with this Policy, both with and without the use of automation tools: collection, systematization, storage, modification, use, depersonalization, blocking , provision (including to authorized persons, as well as cross-border transfer to authorized persons), deletion of personal data.
5.6 Refusal to provide consent for one or more purposes of processing personal data, as well as withdrawal of previously provided consent makes it impossible for the Operator to process personal data for the relevant purposes, and, as a result, entails the impossibility of providing the subject of personal data with services corresponding to the purposes of such processing, the provision of which presupposes the possession by the Operator of certain personal data of the subject.
5.7 The Operator limits the processing of personal data to the achievement of specific, pre-declared legitimate purposes.
5.8 The operator processes only those personal data that are necessary to fulfill the stated purposes and does not allow their excessive processing.
5.9 The processing of personal data is transparent. The subject of personal data, in cases provided for by the Law, is provided with relevant information regarding the processing of his personal data.
5.10 The Operator takes measures to ensure the accuracy of the personal data it processes and updates it if necessary.
5.11 The processing of special personal data is carried out with the adoption of a set of measures aimed at preventing risks that may arise during the processing of such personal data for the rights and freedoms of personal data subjects.
5.12 The Operator processes personal data with the involvement of authorized persons for the purposes specified in Appendix No. 1 to this Policy.
5.13 Name and location of authorized persons to whom the Operator has the right to entrust the processing of personal data on behalf of the Operator or in his interests:
5.13.1 When sending information, advertising and other messages via Viber/Email messages, the Operator carries out cross-border transfer of personal data:
5.13.2 Taking into account the above, the Operator additionally informs personal data subjects about the existence of risks arising from the possible lack of an adequate level of personal data protection in such foreign countries, namely:
With additional information on the procedure for processing personal data Viber Media S.à r.l. can be found on the company’s official website located on the Internet at https://www.viber.com/ ru/terms/viber-privacy-policy/.
Additional information about the procedure for processing personal data by postal services can be found on the official websites of companies that own such services.
5.14 Authorized persons processing personal data on the basis of a contract (agreement) concluded with the Operator on the processing of personal data (instructions of the Operator) undertake to comply with the principles, rules for the processing and protection of personal data provided for by the Law. For each authorized person, the contract (agreement) on the processing of personal data defines: the purposes of processing, a list of actions with personal data that will be performed by such person, establishes his obligations to maintain confidentiality and ensure the protection of personal data in the process of their processing, and indicates the necessary measures for ensuring the protection of personal data in accordance with the Law.
5.15 If the processing of personal data on behalf of the Operator requires obtaining the consent of the subject of personal data, such consent is obtained by the Operator.
The Operator bears responsibility to the subject of personal data for the actions of an authorized person to whom the Operator has entrusted the processing of personal data.
5.16 Personal data may be transferred to third parties, including government bodies and organizations, only on the grounds and in the manner established by the legislation of the Republic of Belarus.
5.17 The operator may transfer personal data to persons located in foreign countries (cross-border transfer of personal data), which ensures an adequate level of protection of the rights of personal data subjects
The list of foreign states on whose territory the appropriate level of protection of the rights of personal data subjects is ensured is established by order of the National Center for Personal Data Protection of the Republic of Belarus dated November 15, 2021 No. 14 “On cross-border transfer of personal data.”
5.18 Personal data is stored in a form that allows identification of the subject of personal data, no longer than required by the stated purposes of processing personal data.
5.19 The storage period for documents generated in the course of the Operator’s activities, which contain personal data of subjects, is established by Decree of the Ministry of Justice of the Republic of Belarus dated May 24, 2012 No. 140 “On the list of standard documents.”
5.20 In cases of loss or unauthorized disclosure (distribution) of personal data, the Operator informs the subject of personal data about the loss or unauthorized disclosure (distribution) of personal data.
5.21 In accordance with the Law, the Operator takes the necessary legal, organizational and technical measures to ensure the protection of personal data from unauthorized or accidental access to it, modification, blocking, copying, distribution, provision, deletion of personal data, as well as from other unlawful actions in relation to personal data. data.
6.1 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.
6.2 The consent of the subject of personal data can be obtained by the Operator in writing, in the form of an electronic document or in electronic form.
In another electronic form, the Operator receives the consent of the subject of personal data by:
7.1 Personal data subjects have the following rights:
7.1.1 The right to withdraw previously provided consent to the processing of personal data:
The subject of personal data has the right at any time, without giving reasons, to withdraw his consent to the processing of personal data previously provided to the Operator by submitting an application to the Operator in writing or in the form through which his consent was obtained. However, the right to withdraw consent cannot be exercised in cases where the processing of personal data is carried out on other legal grounds (for example, when receiving personal data on the basis of a contract in order to perform actions established by it or when legislative acts directly provide for the processing of personal data without consent subject).
7.1.2 The right to receive information regarding the processing of personal data:
The subject of personal data has the right to receive information regarding the processing of his personal data, containing:
7.1.3 The right to make changes to your personal data:
The personal data subject has the right to demand that the Operator make changes to his personal data if they are incomplete, outdated or inaccurate. For these purposes, the subject of personal data attaches to the application the relevant documents and (or) their duly certified copies confirming the need to make changes.
7.1.4 The right to receive information about the provision of personal data to third parties:
The subject of personal data has the right to receive from the Operator information about the provision of his personal data to third parties once a calendar year free of charge.
7.1.5 The right to demand termination of processing of personal data and (or) its deletion:
The subject of personal data has the right to demand from the Operator a free termination of the processing of his personal data, including its deletion, in the absence of grounds for processing personal data provided for by the legislation of the Republic of Belarus.
7.1.6 The right to appeal actions (inaction) and decisions of the Operator related to the processing of personal data:
The subject of personal data has the right to appeal actions (inaction) and decisions of the Operator that violate his rights when processing personal data to the National Center for Personal Data Protection of the Republic of Belarus (220003, Minsk, Klara Tsetkin St., 24-3), in the manner established legislation on appeals from citizens and legal entities.
7.2 To exercise the rights specified in clause 7.1. Policy, the subject of personal data must send a corresponding application to the Operator in the following way:
7.3 To exercise the right to withdraw consent, the subject of personal data must send a corresponding application to the Operator in the manner prescribed by clause 7.2. Politicians.
If the consent of the subject of personal data was provided in another form, the right to withdraw consent can also be exercised in the form through which such consent was obtained:
7.4 The personal data subject’s application for the exercise of one or more of the rights listed above must contain:
7.5 The Operator does not consider applications from personal data subjects sent by other means (e-mail, telephone, fax, etc.).
7.6 For assistance in exercising the rights related to the processing of personal data by the Operator, the subject of personal data can contact the person responsible for internal control over the processing of personal data at Morozproduct JLLC by sending a message to the email address office@moroz.by.
7.7 It is understood that the subject of personal data provides the Operator with reliable information about his personal data.
8.1 The Operator has the right, at its discretion, to unilaterally change and (or) supplement the terms of this Policy without prior notification of personal data subjects by posting a new version of the Policy on the Operator’s Websites.
8.2 The new version of the Policy comes into force from the moment it is posted on the Operator’s Website, unless otherwise provided by the new Policy.
8.3 Issues of processing personal data that are not reflected in this Policy are regulated by the legislation of the Republics
Appendix No. 1 to the Policy of JLLC "MOROZPRODUCT" regarding the processing of personal data
