Personal Data Processing Policy

Publication Date: November 1, 2024

1. GENERAL PROVISIONS

1.1. PINFUD Service Limited Liability Company (hereinafter referred to as PINFUD Service LLC) pays special attention to the protection of personal data during its processing and respects the rights of personal data subjects.

The text of this Policy is posted by PINFUD Service LLC on its website at https://ronin.by/privacy-policy 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. This Policy explains to personal data subjects how and for what purposes their personal data is collected, used, or otherwise processed, and also describes the rights available to personal data subjects in this regard and the mechanism for exercising them.

This Policy does not apply to the processing of personal data in the course of employment or administrative procedures (regarding employees and former employees), video surveillance, or the processing of cookies on the PINFUD Service LLC website.

1.3. PINFUD Service LLC's postal address: 220030, Belarus, Minsk, Komsomolskaya St., 15, 3rd floor;

Website address: https://ronin.by

Email: minskronin@gmail.com

1.4. This Policy uses terms and definitions as defined by law.

1.5. Personal data may be used by PINFUD Service LLC for the following purposes:

• Creating analytical and reference materials, maintaining databases for internal information support of PINFUD Service LLC's activities;
• Communicating with personal data subjects, including through remote communication channels, to provide services and send (provide) notifications (messages, proposals, requests) for reference, information, complaints, and other purposes.

1.6. PINFUD service LLC processes only the personal data necessary to achieve the stated purposes and does not allow excessive processing.

2. PURPOSES, CATEGORIES OF PERSONAL DATA SUBJECTS WHOSE DATA IS PROCESSED, LIST OF PERSONAL DATA PROCESSED, LEGAL BASIS, AND PERIODS FOR PROCESSING PERSONAL DATA

PINFUD service LLC processes the personal data of personal data subjects for the purposes, scope, legal basis, and timeframes applicable to each category of personal data subjects in accordance with Appendix 1 to this Policy.

3. AUTHORIZED PERSONS.

CROSS-BORDER TRANSFER OF PERSONAL DATA

3.1. PINFUD service LLC does not delegate the processing of personal data to authorized persons.

3.2. PINFUD service LLC does not carry out cross-border transfers of personal data.

Cross-border transfers of personal data to the territory of a foreign state may be carried out by (Name of Organization) if:

3.2.1. an adequate level of protection of the rights of personal data subjects* is ensured in the territory of the foreign state – without restrictions, provided there are legal grounds stipulated by the Law;

3.2.2. an adequate level of protection of the rights of personal data subjects is not ensured in the territory of the foreign state – in cases stipulated by Article 9 of the Law, including:

when the consent of the personal data subject is given, provided that the personal data subject is informed of the risks arising from the lack of an adequate level of protection;

When posting information about their activities on the Internet;

When the processing of personal data is necessary to fulfill duties (powers) stipulated by legislation.

* The list of foreign countries in whose territory an adequate level of protection of the rights of personal data subjects is ensured is defined by Order No. 14 of the National Center for Personal Data Protection of the Republic of Belarus dated November 15, 2021, "On the Cross-Border Transfer of Personal Data."

4. RIGHTS OF PERSONAL DATA SUBJECTS

4.1. The personal data subject has the right:

4.1.1. To revoke their consent if PINFOOD Service LLC has requested consent from the personal data subject for the processing of personal data. The right to revoke consent cannot be exercised if the processing is carried out on other legal grounds (e.g., in accordance with legal requirements or under a contract);

4.1.2. To receive information regarding the processing of their personal data by PINFUD Service LLC, including:

• location of PINFUD Service LLC;
• confirmation of the processing of the applicant's personal data by PINFUD Service LLC;
• personal data and the source thereof;
• legal grounds and purposes for processing personal data;
• the period for which consent is given (if personal data is processed based on consent);
• name and location of the authorized person(s);
• other Information required by law;

4.1.3. Request that PINFOOD Service LLC amend their personal data if such data is incomplete, outdated, or inaccurate. For this purpose, the personal data subject shall attach relevant documents and/or their duly certified copies confirming the need to amend their personal data;

4.1.4. Receive information from PINFOOD Service LLC regarding the provision of their personal data processed by PINFOOD Service LLC to third parties once per calendar year free of charge, unless otherwise provided by the Law and other legislative acts;

4.1.5. Request that PINFOOD Service LLC cease processing their personal data free of charge, including deletion, if there are no grounds for processing the personal data stipulated by the Law and other legislative acts;

4.1.6. To appeal actions (inactions) and decisions of PINFUD Service LLC that violate their rights in the processing of personal data, in accordance with the procedure established by law.

4.2. To exercise their rights related to the processing of personal data by PINFUD Service LLC, as well as in the event of exercising the right to revoke consent, the personal data subject shall submit a written application to PINFUD Service LLC to the postal address or by email specified in subparagraph 1.3 of paragraph 1 of this Policy.

Such application must contain:

• the last name, first name, patronymic (if any) of the personal data subject, and their residential address (place of stay);

• the date of birth of the personal data subject;

• a statement of the essence of the personal data subject's demands;

• The identification number of the personal data subject, or, if such number is not available, the number of the personal data subject's identity document, if this information was provided by the personal data subject when providing consent or if the personal data is processed without the personal data subject's consent;

• The personal signature (for written applications) or electronic digital signature (for applications submitted electronically) of the personal data subject.

PINFUD Service LLC does not consider applications from personal data subjects received by other means (telephone, website feedback form, etc.).

Appendix 1

to the Policy on Personal Data Processing

Purposes, Scope, Legal Basis, and Timeframes for Processing Personal Data by PINFUD Service LLC