Privacy police
1. Limited Liability Company “GrandPerfid” (hereinafter referred to as the “Company”) places special emphasis on the protection of personal data during its processing and respects the rights of data subjects.
1.1. The adoption of the Personal Data Processing Policy (hereinafter referred to as the “Policy”) is one of the measures taken by the Company in accordance with Article 17 of the Law of the Republic of Belarus dated May 7, 2021, No. 99-Z “On the Protection of Personal Data” (hereinafter referred to as the “Law”).
1.2. The Policy explains to data subjects how and for what purposes their personal data is collected, used, or otherwise processed, as well as outlines the rights of data subjects in this regard and the mechanisms for exercising these rights.
1.3. The Policy does not apply to the processing of personal data in the course of employment activities and administrative procedures (concerning employees and former employees), as well as website users (with regard to cookie files).
2. The Company processes personal data in the following cases:
| Purposes of Personal Data Processing | Categories of Data Subjects Whose Data is Processed | List of Processed Personal Data | Legal Grounds for Personal Data Processing | Personal Data Retention Period |
|
Handling inquiries, including those submitted in the book of complaints and suggestions |
Individuals who submitted the inquiry |
Last name, first name, patronymic or initials, residential (or temporary) address, the subject of the inquiry, and other personal data provided in the inquiry |
The processing of personal data is necessary for the fulfillment of duties (powers) provided by legislative acts (Paragraph 20 of Article 6 and Paragraph 16 of Section 2 of Article 8 of the Law, Section 1 of Article 3 of the Law of the Republic of Belarus "On Appeals of Citizens and Legal Entities") |
5 years from the date of the last inquiry; 5 years after the end of maintaining the book of comments and suggestions |
|
Organization of legal services |
Authorized signatories of the contract |
Last name, first name, patronymic or initials of the person, personal signature, and other personal data (if necessary) |
In the case of concluding a contract with an individual: processing is based on the contract with the data subject (paragraph 15, Article 6 of the Law). |
3 years after the expiration of the contract, or after the tax authorities conduct an audit of compliance with tax legislation. If no audit is conducted by the tax authorities, then 10 years after the expiration of the contract |
| Conclusion and execution of civil law contracts not related to the provision of legal services |
Authorized signatories of the contract
|
Surname, first name, patronymic or initials of the person, position of the person who signed the contract, and other details in accordance with the contract conditions (if necessary) |
If the contract is concluded with an individual, data processing is based on the contract with the data subject (paragraph 15, Article 6 of the Law). If the contract is concluded with a legal entity, data processing is necessary to fulfill obligations (powers) provided by legislative acts (paragraph 20, Article 6 of the Law, Article 49, paragraph 5, Article 186 of the Civil Code). |
3 years after the expiration of the contract, following a tax authority's audit of compliance with tax legislation. If no such audit is conducted by the tax authorities, then 10 years after the expiration of the contract |
|
Organization and implementation of feedback with interested users (applicants), appointment scheduling on the Company’s official website in the global Internet network |
Individuals who submitted the inquiry
|
Surname, first name, patronymic (if applicable), and contact details (email address, e-mail, contact phone number) |
Paragraph 8, 15 of Part 1, Article 6 of the Law |
5 years from the date of the last request |
| Interaction with potential clients of the Company through the call center, via telephone calls, electronic messaging (receiving and sending emails), chat in messengers, official correspondence, and distribution of promotional information |
Individuals who submitted the inquiry
|
Surname, first name, patronymic (if applicable), contact details (email address, e-mail, contact phone number), and position |
Paragraph 8, 15 of Part 1, Article 6 of the Law
|
5 years from the date of the last request |
3. The Company processes only those personal data that are necessary for achieving the stated purposes and does not allow excessive processing of such data.
4. The Company does not transfer personal data to third parties, except in cases provided for by legal acts.
5. The data subject has the right to:
5.1. Withdraw their consent if the Company requested consent from the data subject for processing their personal data. Consequently, the right to withdraw consent cannot be exercised if the processing is based on a contract or in accordance with legal requirements (e.g., during audits or when reviewing a received inquiry);
5.2. Obtain information regarding the processing of their personal data, including:
- The location of the Company;
- Confirmation of the fact that their personal data is being processed by the Company;
- Their personal data and the source of its collection;
- The legal grounds and purposes of processing their personal data;
- The period for which their consent is given (if the processing of personal data is based on consent);
- The name and location of the authorized person(s);
- Other information required by law.
5.3. Request the Company to make changes to their personal data if the data is incomplete, outdated, or inaccurate. For this purpose, the data subject must provide relevant documents and/or their certified copies that confirm the need for changes in their personal data.
5.4. Receive information from the Company about the provision of their personal data processed by the Company to third parties. This right can be exercised once per calendar year, and the information provided is free of charge.
5.5. Demand the Company to cease processing their personal data, including deletion, if there are no grounds for processing personal data as provided by the Law and other legal acts.
5.6. Appeal against the Company’s actions (or lack thereof) and decisions that violate their rights in the processing of personal data to the court in accordance with civil procedural law.
6. To exercise their rights related to the processing of personal data by the Company, the data subject submits a request to the Company in writing or as an electronic document (and, if withdrawing consent, also in the form in which consent was obtained) to the postal address or the Internet address specified in part five of section 1 of this Policy. Such a request must include:
- The surname, first name, patronymic (if available), and contact details (address, email, phone number) of the data subject;
- The date of birth of the data subject;
- The essence of the data subject’s request;
- The identification number of the data subject, or if such a number is not available, the document number verifying the identity of the data subject, if this information was provided when consent was given or if the processing of personal data is conducted without consent;
- A personal signature (for a written request) or an electronic digital signature (for an electronic document) of the data subject.
The Company does not consider requests from data subjects sent by other means (e.g., email, phone, fax, etc.).
7. For assistance in exercising their rights, data subjects may also contact the person responsible for internal control of personal data processing in the Organization by sending a message.