Privacy policy

The Privacy Policy is developed in accordance with the requirements of the Law of the Republic of Belarus No. 99-Z of May 7, 2021, “On Personal Data Protection” (hereinafter referred to as the Law), is adopted and in force within the Administration, which is the personal data processing operator (hereinafter referred to as the Administration, we), and determines its approach to the processing of personal data.

1. General Provisions of the Privacy Policy

1.1. This Privacy Policy determines the obligations of the Administration regarding non-disclosure and ensuring the protection of the confidentiality of personal data that personal data subjects (hereinafter referred to as the PD Subject) provide at the request of the Administration, including during registration on the Site “savaniukgroup.by” (hereinafter referred to as the Site) and during interaction with the Platform.

1.2. The Privacy Policy applies to all information that the Site may collect about the User while using the Site’s services. By registering on the Site, the User agrees to all the terms of the Privacy Policy.

1.3. The Privacy Policy may be amended by the Administration without prior notice to the User. The current version of the Privacy Policy is always available on the Internet at: https://savaniukgroup.by/privacy-policy-ru

2. Purposes of Personal Data Processing

2.1. For each purpose of personal data processing (hereinafter also referred to as PD), the Administration determines the categories and list of processed personal data, the methods and terms of their processing and storage, and the procedure for destroying personal data upon achieving the purposes of their processing or upon the occurrence of other legal grounds.

2.2. The Administration has determined the following purposes for processing the User’s personal data:

2.2.1. For the User’s personal data:

• 1) providing access to the Site (registration);
• 2) ensuring the security of the Site and its proper functioning;
• 3) providing access under paid tariffs when paying by bank card;
• 4) providing access under paid tariffs when making a bank transfer from a legal entity;
• 5) ensuring the reliability of the Site’s functioning and the ability to recover data after failures using data backup and recovery technologies;

2.2.2. For the personal data of persons contacting the Administration with various requests:

• 1) considering appeals from PD Subjects regarding the processing of their PD by Users on the Site;
• 2) considering other appeals.

2.2.3. To analyze Site visit statistics.

2.3. Legal grounds for personal data processing.

2.3.1. Purpose of processing — providing access to the Site (registration)

Processed PD:
Name;
Phone number.

Processing is carried out automatically/with User participation:
IP;
City/Country (by IP);
Browser version;
Language;
UTM parameters;
Address of the site page from which the User navigated to the Site;
Cookie data used to identify the User without applying technical measures.

Grounds for PD processing — processing is carried out as part of the execution of contractual obligations.

Types of PD processing:
Collection, recording, systematization, accumulation, storage of PD;
Clarification (updating, modification) is carried out by the PD subject via the profile management form, as well as automatically during the User’s interaction with the Site;
Deletion of PD is performed by the User independently, on the page, or automatically upon the expiration of the storage period for automatically collected data;
Anonymization, blocking, destruction of PD is carried out via the Administrative panel for user management.

PD storage period — PD is stored throughout the validity period of the contract/during the periods established by the current legislation of the Republic of Belarus

2.3.2. Purpose of processing — ensuring the security of the Site and its proper functioning.

Processed PD — phone number.

Grounds for PD processing — processing is carried out as part of the execution of contractual obligations.

Types of PD processing:
Collection, recording, systematization, accumulation, storage;
If fraudulent actions, spam, or mass registration are suspected, the User provides the Administration with a contact phone number to confirm their independent actions on the Site pages;
Viewing, anonymization, blocking via the Administrative panel for user management.

PD storage period — PD is stored throughout the validity period of the contract/during the periods established by the current legislation of the Republic of Belarus.

Deletion of PD — PD is deleted by the User in their personal account via the page. The fact of deletion is recorded in the Site’s logs and stored for a period determined by the current legislation of the Republic of Belarus.

2.3.3. Purpose of processing — ensuring the reliability of the Site’s functioning and the ability to recover data after failures

Processed PD — all data processed by the Administration.

Grounds for PD processing — processing is carried out as part of the execution of contractual obligations.

Types of PD processing:
Storage;
Use for recovering PD in the event of failures;
Distribution (provision) to implement geo-distributed storage of backups;
Deletion occurs automatically upon the expiration of backup data storage periods.

PD storage period — PD is stored throughout the validity period of the contract/during the periods established by the current legislation of the Republic of Belarus.

Deletion of PD — PD is deleted automatically upon the expiration of backup data storage periods, as part of the current backup and recovery process.

2.3.4. Purpose of processing — providing access under paid tariffs when paying by bank card

Payment for the Tariff, in accordance with which the User utilizes the Platform’s services, is carried out using the Bepaid and WebPay payment systems. The specified payment systems collect and store financial information in accordance with their user agreements and privacy policies.

The Administration does not store full card details and does not process payments, receiving from the payment system only a notification about the fact of successful payment.

In the process of receiving payment for the Tariff, the Administration may collect additional information related to the payment made by the User, including, among other things, the transaction number, transaction time, type and expiration date of the card used for payments, as well as the last four digits of the card number, the cardholder’s name, the country and city where the funds were debited from the card.

Processed PD:
First and last name on the card;
Masked bank card number;
Card expiration date.

Grounds for PD processing — processing is carried out as part of the execution of contractual obligations.

Types of PD processing:
Receipt of PD from third parties, recording, systematization, accumulation, storage of PD is carried out after payment of tariffs on the page;
Clarification (updating, modification) is not carried out;
Deletion, anonymization, blocking, destruction of personal data is carried out via the Administrative panel for user management.

PD storage period — PD is stored throughout the validity period of the contract/during the periods established by the current legislation of the Republic of Belarus.

Deletion of PD — PD is deleted after the expiration of the storage periods determined by the current legislation of the Republic of Belarus.

2.3.5. Purpose of processing — providing access under paid tariffs when making a bank transfer from a legal entity

Processed PD:
Full name of the director or authorized signatory;
Full name, email, phone number of the contact person.

Grounds for PD processing — processing is carried out as part of the execution of obligations under the agreement with the User (legal entity), under which the User (legal entity) undertakes to obtain all necessary consents from the PD subjects whose PD is processed by the Administration.

Types of PD processing:
Collection, recording, systematization, accumulation, storage, clarification (updating, modification), anonymization, and deletion of PD is carried out by the User on the page;
Clarification (updating, modification), destruction of PD is carried out via the Administrative panel for company management.

PD storage period — PD is stored throughout the validity period of the contract/during the periods established by the current legislation of the Republic of Belarus.

Deletion of PD — PD is deleted after the expiration of the storage periods determined by the current legislation of the Republic of Belarus.

2.3.6. Purpose of processing — considering other appeals

Processed PD:

For the applicant of the appeal:
Last name, first name of the applicant;
E-mail;
Personal data, the processing of which is the subject of the appeal (if present in the appeal).

For the applicant’s representative:
Last name, first name;
E-mail;
Personal data reflected in the documents confirming the authority of the applicant’s representative, the processing of which is carried out solely for the purpose of considering the appeal sent by such representative in the interests of the applicant (Full name, date of birth, address, and other data in accordance with the requirements of applicable law for documents).

Processing is carried out automatically when submitting via the web form:
IP;
City/Country (by IP);
Browser version;
Language;
UTM parameters;
Partner tag;
Address of the site page from which the User navigated to the Platform;
Cookie data used to identify the User.

Grounds for PD processing — processing is carried out on the basis of the Consent of the PD Subject.

Types of PD processing:
Collection, recording, accumulation, storage, anonymization, blocking, deletion;
Viewing via the User interaction system;
Transfer — data may be transferred to the User against whom the appeal is filed.

PD storage period — PD is stored for 3 (three) years after the response to the appeal.

Deletion of PD — PD is deleted by the Administration after the expiration of the storage period or earlier in the event of the withdrawal of consent to their processing.

2.3.7. Purpose of processing — participation in the Administration’s information projects and informing about them

Processed PD:
Participant’s name;
E-mail;
Messenger nickname.

Processing is carried out automatically when submitting via the web form:
IP;
City/Country (by IP);
Browser version;
Language;
UTM parameters;
Partner tag;
Address of the site page from which the User navigated to the Platform;
Cookie data used to identify the User.

Grounds for PD processing — processing is carried out on the basis of the Consent of the PD Subject.

Types of PD processing:
Collection, recording, accumulation, systematization, storage, extraction, use, anonymization, blocking, deletion;
Clarification (updating, modification) is not carried out.

PD storage period — PD is stored for 3 (three) years after registration for participation in the Administration’s information project.

Deletion of PD — PD is deleted by the Administration after the expiration of the storage period or earlier in the event of the withdrawal of consent to their processing.

2.3.8. Purpose of processing — analyzing visit statistics of the Administration’s sites

Processing is carried out automatically when visiting the Administration’s sites:
IP;
City/Country (by IP);
Browser version;
Language;
UTM parameters;
Address of the site page from which the User navigated to the Site;
Cookie data used to identify the User.

Grounds for PD processing — legitimate interest of the Administration.

Types of PD processing:
Collection, recording, accumulation, systematization, storage, extraction, use, blocking, deletion;
Clarification (updating, modification) is not carried out.

PD storage period — PD is stored for 3 (three) years after visiting the Administration’s site.

Deletion of PD — PD is deleted by the Administration after the expiration of the storage period or earlier in the event of an appeal by the PD Subject.

2.4. Polls and surveys

In order to collect feedback on the functional capabilities of the Platform and improve the user experience, the Administration may send requests, polls, as well as invitations to participate in research and surveys to the User’s email address specified in the Account. The User has the right to refuse to receive such messages at any time by sending a reply letter to the Administration’s email address.