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Personal Data Processing Policy

1. GENERAL PROVISIONS

1.1. Company Art Industria, LLC (hereinafter – the Operator) pays special attention to the protection of personal data of individuals and respects the rights of personal data subjects.

1.2. This Personal Data Processing Policy of Company Art Industria, LLC (hereinafter – the Policy) has been developed in accordance with the requirements of the Law of the Republic of Belarus of May 7, 2021 No. 99‑Z “On Personal Data Protection” (hereinafter – the Law) for the purpose of protecting personal data, as well as the rights and freedoms of personal data subjects during processing, and is aimed at ensuring transparency in the processing of personal data.

1.3. The Policy explains to personal data subjects for what purposes and in what manner their personal data is collected, used, or otherwise processed, and also defines the rights of personal data subjects related to such processing and the mechanism for exercising these rights.

1.4. The Policy applies to relations connected with the processing by Company Art Industria, LLC of personal data of users of the website https://temp.chemie-armor.com, buyers of goods, customers of services, job applicants, individuals with whom Company Art Industria, LLC concludes civil law contracts, visitors of trainings who provided Company Art Industria, LLC with personal data by filling out registration forms for trainings, and representatives of business entities (counterparties of Company Art Industria, LLC).

1.5. This Policy does not apply to the processing of personal data of employees in the course of employment activities and administrative procedures (regarding employees and former employees), to the processing of cookies on the Operator’s website, or to video surveillance carried out by Company Art Industria, LLC.

1.6. The Policy is publicly available and is posted on the Operator’s website https://temp.chemie-armor.com on the global Internet.

1.7. Contact details of Company Art Industria, LLC:

registered address: 223050, Belarus, Minsk region, Kolodishchi village, Chkalova street, 56/3-40;

email address: info@armor-chemie.com;

phone: +375 44 541-14-11.

1.8. The person responsible at the Operator for internal control over personal data processing, who may be contacted for assistance in exercising the rights of a personal data subject, is the specialist for internal control over personal data processing appointed by the order of the director of Company Art Industria, LLC (postal address: 223050, Belarus, Minsk region, Kolodishchi village, Chkalova street, 56/3-40), e-mail: info@armor-chemie.com).

1.9. This Policy is effective from the moment of its approval.

2. SCOPE AND PURPOSES OF PERSONAL DATA PROCESSING. LEGAL GROUNDS FOR PROCESSING AND RETENTION PERIOD OF PERSONAL DATA

2.1. Company Art Industria, LLC processes personal data on the basis of the consent of personal data subjects, as well as on other legal grounds provided for by legislation.

2.2. Company Art Industria, LLC determines the purposes of personal data processing, the categories of personal data subjects whose data is processed, the list of processed data, the legal grounds for processing, and the retention period.

2.3. The Operator processes personal data for the following purposes:

Purpose of personal data processingCategories of personal data subjects whose data is processedList of processed personal dataLegal grounds for personal data processingPersonal data retention period
Conclusion, execution, amendment and termination of contracts

Buyers/Customers – individuals;

 

representatives
of legal entities;

individual entrepreneurs

Clients – individuals:
Last name, first name, patronymic;
phone number;
e-mail (optional);
delivery address (optional) 

Representatives of legal entities:
Last name, first name, patronymic;
phone number;
e-mail; job title

Individual entrepreneurs: 
Last name, first name, patronymic;
phone number;
e-mail;
delivery address (optional)

 
Individuals and Individual Entrepreneurs – Contract conclusion – para. 15 art. 6 of the Law of the Republic of Belarus of May 7, 2021 No. 99‑Z “On Personal Data Protection” (hereinafter – the Law);

Representatives of legal entities – Processing of personal data in the course of employment activities – para. 8 art. 6 of the Law
3 years after the expiration of the contract, agreement, and completion of tax inspections regarding compliance with tax legislation. If no tax inspection was conducted – 10 years after the expiration of the contract, agreement (para. 70 of the List of standard documents approved by Resolution No. 140 of the Ministry of Justice of the Republic of Belarus dated 24.05.2012)
Processing a quick order on the Operator’s website BuyersLast name, first name, patronymic,
phone number
Contract conclusion – para. 15 art. 6 of the Law   3 years after the expiration of the contract, agreement, and completion of tax inspections regarding compliance with tax legislation. If no tax inspection was conducted – 10 years after the expiration of the contract, agreement (para. 70 of the List)
Establishing feedback with visitors of the Operator’s website who filled out the feedback form

 
Buyers,
other persons browsing the Operator’s website
Name,
phone number,
e-mail (optional)
Consent of the personal data subject – para. 1 art. 5 of the Law (placing the corresponding mark on the Operator’s website)3 years from the date the personal data subject submits the feedback form
“Request a Call” function on the Operator’s website
Buyers,
other persons browsing the Operator’s website
Name,
phone number 
Consent of the personal data subject – para. 1 art. 5 of the Law (placing the corresponding mark on the Operator’s website)3 years from the date the personal data subject uses the “Request a Call” function
“Ask a Question” function on the Operator’s website
Buyers,
other persons browsing the Operator’s website
Name,
phone number,
e-mail (optional)
Consent of the personal data subject – para. 1 art. 5 of the Law (placing the corresponding mark on the Operator’s website)3 years from the date the personal data subject uses the “Ask a Question” function
“Leave a product review”, “Leave a company review” functions on the Operator’s website
Buyers,
other persons browsing the Operator’s website
Name,
e-mail (optional)
Consent of the personal data subject – para. 1 art. 5 of the Law (placing the corresponding mark on the Operator’s website)Data is not stored
“Subscribe to newsletter” function on the Operator’s website
Buyers,
other persons browsing the Operator’s website
e-mailConsent of the personal data subject – para. 1 art. 5 of the Law (placing the corresponding mark on the Operator’s website)2 years from the date the Operator receives the Consent, or until the moment of unsubscribing 
“Order a service” function on the Operator’s websiteCustomers
Name,
phone number,
e-mail (optional)
Contract conclusion – para. 15 art. 6 of the Law   3 years after the expiration of the contract, agreement, and completion of tax inspections regarding compliance with tax legislation. If no tax inspection was conducted – 10 years after the expiration of the contract, agreement (para. 70 of the List)
Placing an order via a phone call Buyers/Customers – individuals;

representatives
of legal entities;

individual entrepreneurs

Clients – individuals: Last name, first name, patronymic;
phone number;
e-mail (optional);
delivery address (optional)

Representatives of legal entities: Last name, first name, patronymic;
phone number; e-mail (optional); job title;

Individual entrepreneurs:
Last name, first name, patronymic;
phone number; e-mail (optional)
Individuals and Individual Entrepreneurs – Contract conclusion – para. 15 art. 6 of the Law;

Representatives of legal entities – Processing of personal data in the course of employment activities – para. 8 art. 6 of the Law
3 years after the expiration of the contract, agreement, and completion of tax inspections regarding compliance with tax legislation. If no tax inspection was conducted – 10 years after the expiration of the contract, agreement (para. 70 of the List)
Audio recording of a phone conversationBuyers/Customers – individuals;

representatives
of legal entities;

individual entrepreneurs;
other persons who made a phone call 
Audio recording of the phone conversation,
phone number,
other
personal data provided during the phone call
Consent of the personal data subject – para. 1 art. 5 of the Law1 year from the moment the audio recording is made.
In the virtual PBX provided by A1, personal data is stored in a form that allows identification of the personal data subject no longer than required for the purposes of processing within the virtual PBX service

Reviewing resumes (applications) of job candidates for the purpose of concluding an employment contract.

 

Formation and maintenance of a talent pool

Individuals who submitted resumesLast name, first name, patronymic,
year of birth, information about education
and work experience, contact phone number,
e-mail address
Consent – art. 5 of the Law – when submitting a resume (application) electronically via the form on the Website https://temp.chemie-armor.com, or by sending an e-mail to: info@armor-chemie.com ;

Document addressed to the operator – para. 16 art. 6 of the Law when submitting a resume (application) in writing or as an electronic document;

Processing of previously disseminated personal data – para. 19 art. 6 of the Law when the applicant posts a resume (application) on job search platforms (rabota.by; praca.by; by.linkedin.com etc.)
If not hired – 1 year;

If hired – 1 month.

2.4. Company Art Industria, LLC processes personal data both with and without the use of automation tools, performing the following actions with personal data depending on the purpose of processing: collection, systematization, storage, modification, use, provision (including cross‑border transfer), anonymization, blocking, deletion.

2.5. Personal data processing is terminated upon achieving the purposes of processing, upon expiration of the processing period, upon withdrawal of consent by the personal data subject or submission of a request to cease processing, in the absence of grounds for processing personal data, upon detection of unlawful processing, as well as in other cases provided for by personal data protection legislation.

2.6. Company Art Industria, LLC takes the necessary legal, organizational, and technical measures to protect personal data during processing from unauthorized or accidental access, alteration, blocking, copying, dissemination, provision, deletion, as well as from other unlawful actions involving personal data.

3. RIGHTS OF PERSONAL DATA SUBJECTS AND THE MECHANISM FOR THEIR EXERCISE

3.1. Personal data subjects are granted the following rights:

RightConsequences
1Withdraw consent to the processing of one’s personal data at any time without giving reasonsCompany Art Industria, LLC will, within 15 calendar days from the date of receiving the withdrawal, cease processing the subject’s personal data, delete it, and notify the personal data subject, except in cases where the Operator is entitled to continue processing on other legal grounds
2

Receive information related to the processing of one’s personal data, which includes:

 

– the name and location of the Operator;
– confirmation of the fact that the Operator processes personal data;
– the list of processed personal data and the source from which it was obtained;
– the legal grounds and purposes of personal data processing;
– the period for which consent to personal data processing was given;
– the name and location of the authorized person(s), if personal data processing is entrusted to such person(s);
– other information provided for by law.

The Operator, within 5 business days after receiving the request from the personal data subject, will provide the requested information or notify the subject of the reasons for refusal
3Once per calendar year, receive free information about the transfer of one’s personal data to third partiesThe Operator, within 15 calendar days from the date of receiving the request, will provide information on which personal data of the subject and to whom it was transferred during the year preceding the date of the request, or notify of the reasons for refusal
4Request cessation of processing and/or deletion of one’s personal data
 
The Operator, within 15 calendar days from the date of receiving the request, will cease processing the subject’s personal data, delete it, and notify the subject, except in cases where the Operator is entitled to continue processing on other legal grounds
5Request that the Operator make changes to one’s personal data if the data is incomplete, outdated, or inaccurateThe Operator, within 15 calendar days from the date of receiving the request, will make the necessary changes to the personal data if it is incomplete, outdated, or inaccurate, or notify the subject of the reasons for refusal
6Appeal the actions (inaction) and decisions of the Operator related to the processing of personal data to the National Center for Personal Data Protection of the Republic of Belarus in accordance with the procedure established by lawThe National Center for Personal Data Protection reviews complaints in accordance with the legislation on appeals of citizens and legal entities

3.2. To exercise the rights specified in clause 3.1 of this Policy, the personal data subject must submit an application to the Operator in one of the following ways:

– in writing (by mail/in person) to the address: 223050, Belarus, Minsk region, Kolodishchi village, Chkalova street, 56/3-40;

– as an electronic document containing the personal data subject’s digital signature, sent to the email address: info@armor-chemie.com.

3.3. To exercise the right to withdraw consent, the personal data subject may submit an application to Company Art Industria, LLC in the manner established in clause 3.2 of the Policy, to the legal address (223050, Belarus, Minsk region, Kolodishchi village, Chkalova street, 56/3-40). If the personal data subject provided consent in another electronic form, the right to withdraw consent may be exercised by sending an electronic message to info@armor-chemie.com.

3.4. The right to withdraw consent cannot be exercised if personal data is processed on the basis of a contract or other legal grounds provided for by the Law and other legislative acts.

3.5. An application from a personal data subject to exercise the rights specified in clause 3.1 of the Policy must contain the following information:

– last name, first name, patronymic (if applicable);

– residential (or temporary) address;

– date of birth;

– description of the essence of the request;

– personal signature or digital signature.

3.6. The response to the application is sent to the personal data subject in the same form in which the application was submitted, unless otherwise specified in the application.

3.7. Company Art Industria, LLC assumes that the personal data subject provides accurate information about their personal data and will assist in updating the data processed by the Operator if the subject’s personal data is incomplete, outdated, or inaccurate.

4. TRANSFER OF DATA TO AUTHORIZED PERSONS AND OTHER PARTIES INVOLVED IN PERSONAL DATA PROCESSING. CROSS‑BORDER TRANSFER OF PERSONAL DATA

4.1. The Operator, if necessary to achieve the purposes of processing, may transfer personal data to third parties in compliance with the legislation of the Republic of Belarus.

4.2. Authorized persons processing personal data on the basis of a contract and/or a personal data processing agreement (Operator’s assignment) are obliged to comply with the principles, rules of processing, and protection of personal data established by the Law. For each authorized person, the contract and/or agreement specifies the purposes of processing, the list of actions with personal data to be performed, the obligations to maintain confidentiality and ensure protection of personal data during processing, as well as the necessary measures to ensure personal data protection in accordance with the Law.

4.3. The Operator is responsible to the personal data subject for the actions of the Authorized Person when personal data processing is entrusted to such a person.

4.4. Company Art Industria, LLC provides personal data to other parties for the purposes specified in clause 2.3 of this Policy, namely: telecommunications operators, and the messenger operators Viber Media S.à r.l and Telegram Messenger, Inc.

4.5. When sending messages via Viber and Telegram, depending on the server of Viber Media S.à r.l and Telegram Messenger, Inc. where the data is stored, cross‑border transfer of personal data may occur to countries that do not ensure an adequate level of protection of personal data subjects’ rights.

Company Art Industria, LLC informs about possible risks associated with the inadequate level of protection of personal data subjects’ rights in such foreign states:

– absence of specific personal data protection legislation;

– absence of an independent supervisory authority for personal data protection;

– limited rights of personal data subjects;

– narrow definition of personal data, with only a limited set of information about an individual considered personal data;

– broad access to personal data by security agencies;

– use of improper methods of obtaining personal data.

4.6. Additional information on the processing of personal data by Viber Media S.à r.l. is available on the company’s official website at: https://www.viber.com/ru/terms/viber-privacy-policy/

4.7. Additional information on the processing of personal data by Telegram Messenger, Inc. is available on the company’s official website at: https://telegram.org/privacy/by/

4.8. Personal data may be transferred to state bodies (organizations) only if there are legal grounds established by the legislation of the Republic of Belarus on personal data.

5. FINAL PROVISIONS

5.1. Company Art Industria, LLC has the right, at its discretion, to unilaterally amend and/or supplement the provisions of this Policy without prior notice to personal data subjects by publishing a new version of the Policy on the Operator’s websites.

5.2. Issues related to personal data processing that are not covered by this Policy are regulated by the current legislation of the Republic of Belarus.