This document defines the policy of JV TRANSIT LLC (legal address: 148 Krasnogvardeyskaya St., Brest, 224024, Republic of Belarus (hereinafter referred to as TRANSIT) regarding the processing of personal data (hereinafter referred to as the Policy).
CHAPTER 1. TERMS, DEFINITIONS AND ABBREVIATIONS USED IN THE POLICY
1. This Policy uses the terms and definitions enshrined in the Law of the Republic of Belarus No. 99-З dated May 7, 2021 "On Personal Data Protection" (hereinafter – the Law), as well as the following terms and definitions:
- blocking of personal data - termination of access to personal data without their deletion;
- depersonalization of personal data - actions as a result of which it becomes impossible to determine the identity of personal data to a specific personal data subject without using additional information;
- provision of personal data - actions aimed at familiarizing with the personal data of a certain person or group of persons;
- dissemination of personal data - actions aimed at familiarizing with the personal data of an indefinite circle of persons;
- deletion of personal data is an action 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 electronic documents, computer files, and material carriers of personal data are destroyed.
CHAPTER 2. GENERAL PROVISIONS
2. The purpose of the Policy is to comply with the requirements of the legislation of the Republic of Belarus on personal data and protect the interests of personal data subjects.
3. The Policy applies to all personal data:
- processed by TRANSIT during the execution of concluded (planned to be concluded) contracts;
- processed by TRANSIT in the process of registering users on TRANSIT Internet resources;
- processed by TRANSIT in information systems (resources); TRANSIT workers;
- obtained in a different way.
4. TRANSIT processes personal data in accordance with the legislation of the Republic of Belarus and the Policy with the purpose of:
- implementation of the functions assigned to TRANSIT by regulatory legal acts of the Republic of Belarus;
- user identification;
- communications;
- provision of electronic services and improvement of the quality of their provision;
- sending notifications, commercial offers;
- providing information about the company activities;
- for other purposes.
5. The Policy applies to the processes in which personal data are processed, including using automation tools.
6. The current version of the Policy is available for unlimited access both on the TRANSIT website and at the TRANSIT location on the ground floor of the building at 148 Krasnogvardeyskaya Str., Brest, 224024, Republic of Belarus.
7. The policy is intended for familiarization by the subject of personal data, which may be an employee of TRANSIT, a consumer of electronic services provided by TRANSIT, another person providing TRANSIT with their personal data both in writing on paper and in electronic form in any available way, including, but not exclusively: by putting a mark in the field the TRANSIT Internet resource/service/system (resource) "Agree", with reference to the Policy, by visiting Internet resources and/or using services belonging to TRANSIT, using information systems (resources) owned and (or) operated by TRANSIT.
By submitting your personal data, the personal data subject expresses their consent to the processing of their personal data on the terms set out in the Policy and confirms that they are familiar with the Policy and agrees with its terms.
8. TRANSIT does not control and is not responsible for third-party websites to which the subject of personal data can click on links available on TRANSIT Internet resources, TRANSIT services, information systems (resources) owned and (or) operated by TRANSIT, or on third-party information systems (resources) hosted by on TRANSIT resources.
CHAPTER 3. PROCESSING OF PERSONAL DATA
9. TRANSIT processes personal data for the purposes specified in the Policy.
10. TRANSIT transmits personal data:
- to the subject of personal data in relation to themselves – without restrictions, except in cases expressly provided for by the requirements of the legislation of the Republic of Belarus;
- to third parties – in cases provided for by the requirements of the legislation of the Republic of Belarus.
11. Personal data are stored:
- on paper;
- in electronic documents;
- in computer files;
- in information systems (resources) that provide automatic processing and storage of information.
12. Processing of personal data is allowed only in compliance with the requirements of the legislation of the Republic of Belarus.
13. In cases provided for in Article 6 of the Law, in particular, in order to fulfill the powers assigned to TRANSIT by legislative acts (paragraph 7 of Decree of the President of the Republic of Belarus No. 460 dated 16.12.2019 "On a nationwide automated information system", sub-paragraph 5.1 of paragraph 5 of Decree of the President of the Republic of Belarus No. 515 dated 08.11.2011 "On certain issues of Information Society development in the Republic of Belarus"), TRANSIT processes personal data without obtaining the consent of the personal data subject.
In other cases, in order to process personal data, TRANSIT receives the consent of the personal data subject to such processing.
The subject of personal data may withdraw their consent to the processing of personal data at any time, in accordance with the procedure established by Law.
14. The assignment of personal data processing to a third party is carried out by TRANSIT only on the basis of a contract/agreement concluded between TRANSIT and the third party in accordance with the legislation of the Republic of Belarus. At the same time, TRANSIT specifies in the contract/agreement the obligation of the person processing personal data on behalf of TRANSIT to comply with the principles and rules of personal data processing provided for by the Policy and legislation of the Republic of Belarus.
15. If TRANSIT entrusts the processing of personal data to a third party, TRANSIT is responsible to the subject of personal data for the actions of the said person. The person who processes personal data on behalf of TRANSIT is liable to TRANSIT.
16. TRANSIT takes the necessary measures to ensure that third parties who have access to personal data do not disclose them to third parties and do not distribute them without the consent of the personal data subject, unless otherwise provided by the legislation of the Republic of Belarus.
17. The procedure for accessing personal data, including those processed in information systems (resources), in particular, the circle of persons entitled to access personal data and the period of their storage, is specified in the TRANSIT Register of Personal Data Processing.
18. The processed personal data are subject to deletion or depersonalization upon achievement of the processing goals or in case of loss of the need to achieve those goals, unless otherwise provided by the legislation of the Republic of Belarus.
CHAPTER 4 RIGHTS OF PERSONAL DATA SUBJECTS
19. Personal data subjects have the right: to withdraw consent to the processing of their personal data; to receive information regarding the processing of their personal data; to change their personal data; to receive information about the provision of their personal data to third parties; to demand the termination of the processing of their personal data; to demand the deletion of their personal data; to appeal against actions (inaction) and decisions of TRANSIT related to the processing of their personal data; 6 exercise other rights provided for by the legislation of the Republic of Belarus.
20. In order to exercise these rights, the subject of personal data submits an application in writing or in the form of an electronic document to the TRANSIT address in accordance with the procedure established by the legislation of the Republic of Belarus.
21. TRANSIT, within five working days after receiving the applicant's application, provides them with information in an accessible form regarding the processing of their personal data.
22. TRANSIT within fifteen days after receipt of the application:
- on termination of personal data processing – deletes them and notifies the applicant about it, if technically possible, and in the absence of technical possibility of deleting personal data – takes measures to prevent further processing of personal data, including their blocking, and notifies the applicant about it within the same period;
- on making changes to personal data – makes changes and notifies the applicant about it or notifies about the reasons for refusal to make such changes;
provides the applicant with information about what personal data was provided and to whom during the year preceding the date of filing the application, or notifies the applicant of the reasons for the refusal to provide such information.
23. TRANSIT has the right to refuse to satisfy the applicant's requirements to terminate the processing of their personal data and (or) delete them if there are grounds for processing personal data provided for by the Law on Personal Data Protection and other legislative acts, including if they are necessary for the stated purposes of their processing, with notification of the applicant within fifteen days after receipt of the application.
CHAPTER 5. CROSS-BORDER TRANSFER OF PERSONAL DATA
24. TRANSIT, prior to the start of the cross-border transfer of personal data, is obliged to ensure that the foreign state to whose territory the transfer of personal data is supposed to be carried out ensures reliable protection of the rights of personal data subjects.
The cross-border transfer of personal data on the territory of foreign states that do not meet the above requirement 7 may be carried out only in the cases provided for in article 9 of the Law.
CHAPTER 6. PROTECTION OF PERSONAL DATA
25. TRANSIT, when processing personal data, is guided by the legislation of the Republic of Belarus and takes the necessary legal, organizational and technical measures to protect personal data from unauthorized access to them, as well as from other illegal actions in relation to personal data.
CHAPTER 7. FINAL PROVISIONS
26. The Policy comes into force from the moment of its approval by the office order of the Director of TRANSIT