POLICY ON THE PROCESSING OF PERSONAL DATA
 
1. GENERAL PROVISIONS
 
1.1. Natalia Krukovskaya, registered as a payer of the tax on professional income on August 03, 2026 (Taxpayer ID No. AH0008570) (hereinafter referred to as the "Operator"), pays special attention to the protection of personal data during its processing and respects the rights of personal data subjects.
The adoption of the Policy on the Processing of Personal Data (hereinafter referred to as the "Policy") constitutes one of the measures for the protection of personal data implemented by the Operator, as provided for in Article 17 of the Law of the Republic of Belarus No. 99-Z dated May 7, 2021, "On Personal Data" (hereinafter referred to as the "Law").
1.2. The Policy explains to personal data subjects how and for what purposes their personal data is being collected, used, or otherwise processed, and outlines the rights held by personal data subjects in this regard as well as the mechanism for exercising those rights.
The Policy also applies to the processing of personal data and cookies on the website https://www.languageconnect.by (hereinafter referred to as the "Site").
1.3. Operator’s address: Email: languageconnect7@gmail.com
1.4. Terms and definitions used in this Policy carry the meanings ascribed to them by the Law.
1.5. The Operator may use personal data for research purposes—specifically, to analyze its activities and to prepare and publish reports and materials regarding its operations—provided that such personal data is first anonymized.
1.6. The Operator processes only the personal data necessary to achieve the stated purposes and avoids excessive processing.
1.7. The processing of personal data is carried out by the Operator with the consent of the personal data subjects, as well as on other legal grounds.
1.8. The Operator determines the purposes of personal data processing, the categories of personal data subjects whose personal data are subject to processing, the list of personal data being processed, and the legal grounds for personal data processing.
1.9. Consent to the processing of personal data, as well as the withdrawal thereof, is provided on the Website by checking the box indicating acknowledgment of this Policy and clicking the "I agree" button. Consent may be withdrawn by sending a corresponding request to the Operator’s Email address, specifying the demand to cease the processing of personal data and providing details (or partial details) regarding the person who granted consent that are sufficient to identify said person.

2. PURPOSES, CATEGORIES OF PERSONAL DATA SUBJECTS WHOSE DATA ARE PROCESSED, LIST OF PROCESSED PERSONAL DATA, LEGAL GROUNDS, AND RETENTION PERIODS FOR PERSONAL DATA

2.1. The Operator processes the personal data of personal data subjects both with and without the use of automation tools (provided that such processing enables the retrieval of and/or access to personal data based on specific criteria—such as card indexes, lists, databases, logs, etc.) for the purposes, to the extent, on the legal grounds, and within the timeframes applicable to each category of personal data subjects as set forth in the following table:

Purposes of personal data processing

 

Categories of data subjects whose data are being processed

 

List of processed personal data

 

Legal grounds for the processing of personal data

 

Personal data retention period

 

Provision of services by the Operator

 

Individuals who contact the Operator for the purpose of entering into a service provision agreement with the Operator

 

Surname, first name, patronymic, Email address, phone number

 

The processing of personal data is necessary for the performance of obligations arising from a contract concluded (or being concluded) with the data subject, for the purpose of carrying out actions stipulated by that contract

(Paragraph 15 of Article 6 of the Law)


- If a contract is concluded:

3 years after the expiration of the contract term, provided the tax authorities have conducted an audit of compliance with tax legislation.

If the tax authorities have not conducted an audit of compliance with tax legislation – 10 years after the expiration of the contract term.

- If a contract is not concluded:

1 year from the date negotiations regarding the conclusion of the contract ended

 

Sending promotional communications regarding other services provided by the Operator

 

Individuals who have subscribed to the relevant newsletter

 

Name, Email address (for Email newsletters), and/or phone number / messenger account name (for messaging service notifications)

 

Consent

 

Validity period of the consent, or until the withdrawal of the consent, depending on which occurs earlier

 

 

 



2.2. The content and scope of the personal data being processed must correspond to the stated purposes of its processing. The personal data being processed must not be excessive in relation to the stated purposes of its processing.
2.3. The Operator is required to take measures to ensure the accuracy of the personal data it processes and to update it when necessary.

3. AUTHORIZED PARTIES.
CROSS-BORDER TRANSFER OF PERSONAL DATA
 
3.1. The Operator may entrust the processing of personal data to authorized parties.
The list of authorized parties processing personal data on behalf of the Operator is set out in the following table:

No.

 

Authorized person

 

Location of the authorized person

 

Information resource (system)

 

Purpose of processing

 

1

YANDEX LLC

 

16 Lva Tolstogo Str., Moscow, 119021, Russia

 

Yandex Mail,

Yandex Disk,

Yandex Metrica

 

Email services,

Data storage,

Web analytics for the Operator's website

 

2

Google LLC

1600 Amphitheatre Parkway

Mountain View, California, 94043

USA

Gmail,

Google Drive,

Google Analytics

 

Email services,

Data storage,

Web analytics for the Operator's website

 

3

“Tilda Publishing Bel” LLC

 

Premises 433, 1 Borovaya Village, Borovlyany Village Council, Minsk District, Minsk Region, Republic of Belarus, 223053

 

Website

 

Data storage


Authorized persons process personal data on the basis of a contract concluded with the Operator.

3.2. The Operator carries out the cross-border transfer of personal data to facilitate communication with counterparties and clients (WhatsApp, Telegram, Viber, Instagram) and for data storage (Google and Yandex cloud storage services), as well as within the customer relationship management (CRM) system used by the Operator.
The cross-border transfer of personal data to the territory of a foreign state may be carried out by the Operator 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 as 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 a foreign state – in the cases provided for by Article 9 of the Law, including:
• when the personal data subject has given consent, provided that the personal data subject has been informed of the risks arising from the absence of an adequate level of protection;
• when publishing information about one’s activities on the global Internet;
• when the processing of personal data is necessary to fulfill duties (powers) prescribed by legislative acts.

4. USE OF COOKIES AND YANDEX METRICA / GOOGLE ANALYTICS SERVICES
 
4.1. The Site uses cookies (text files saved in the web browser of the user's device-computer, mobile phone, etc.—when visiting the Site, in order to reflect and/or remember the user's actions on the Site) and web analytics services (Yandex Metrica / Google Analytics) to:
- analyzing user actions on the Site
- improving the Site's performance
- evaluating the effectiveness of advertising campaigns.
4.2. Yandex.Metrica / Google Analytics collect and process anonymized data regarding visits to the Site in order to improve its performance and analyze user behavior.
4.3. Users may disable the use of cookies in their browser settings. Please note, however, that certain features of the Site may become unavailable as a result.
4.4. The Site may also use other web analytics services and analytical tools to:
- collect visit statistics;
- analyze user behavior;
- optimize advertising campaigns;
- improve the user experience.
These services collect anonymous information that does not allow for the identification of a specific Site user.

5. RIGHTS AND OBLIGATIONS OF PERSONAL DATA SUBJECTS

5.1. The personal data subject has the right:
5.1.1. to withdraw their consent, if the Operator obtained such consent from the personal data subject for the processing of personal data. The right to withdraw consent cannot be exercised where processing is carried out on other legal grounds (for example, in accordance with statutory requirements or on the basis of a contract);
5.1.2. to receive information regarding the processing of their personal data by the Operator, containing:
· the location of the Operator;
· confirmation of the fact that the Operator is processing the personal data of the inquiring person;
· the personal data and the source from which it was obtained;
· the legal grounds and purposes for processing the personal data;
· the period for which consent has been granted (if the processing of personal data is based on consent);
· the name and location of the authorized person(s);
· other information prescribed by law;
5.1.3. to require the Operator to amend their personal data if such personal data is incomplete, outdated, or inaccurate;
5.1.4. to receive information from the Operator, free of charge once per calendar year, regarding the disclosure to third parties of their personal data processed by the Operator, unless otherwise provided by the Law and other legislative acts;
5.1.5. to require the Operator to cease processing their personal data—including its deletion—free of charge, in the absence of grounds for processing personal data as provided for by the Law and other legislative acts;
5.1.6. to appeal against actions (inaction) and decisions of the Operator that violate their rights during the processing of personal data, in the manner prescribed by law.
5.2. To exercise their rights related to the processing of personal data by the Operator, the personal data subject shall submit a written request to the Operator via the postal or Email address specified in sub-clause 1.3 of clause 1 of this Policy; however, in the case of exercising the right to withdraw consent, the request shall be submitted in the same form in which such consent was originally obtained.
5.3. The personal data subject confirms the accuracy of the personal data provided and agrees to accept all adverse consequences in the event that the data provided is inaccurate.

6. FINAL PROVISIONS

6.1. The Operator reserves the right to unilaterally amend this Policy (in whole or in part) at any time.
6.2. The new version of the Policy enters into force upon its publication on the Website, unless otherwise specified in the new version of the Policy. The current version is always available on the Website at https://www.languageconnect.by.  


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