COOKIE PROCESSING POLICY

Individual Entrepreneur
Volha Charkasava

POLICY
dated June 24, 2026
Minsk

on the processing of cookie files


1. General Provisions

1.1. The issuance of this Cookie Processing Policy (the “Policy”) is one of the mandatory measures adopted by Individual Entrepreneur Volha Charkasava (the “Operator”) to ensure the protection of personal data, as provided for by Article 17 of the Law of the Republic of Belarus No. 99-Z dated May 7, 2021 “On Personal Data Protection” (the “Law”).

This Policy explains to users of the information resource https://powerful.by/ (the “Website”), which is owned and operated by the Operator, how, for what purposes and on what legal basis their personal data are collected, used or otherwise processed.

1.2. For the purposes of this Policy, cookie files (“cookies”) mean text files stored in the web browser of a user’s device, such as a computer, mobile phone or other device, when visiting websites, in order to reflect and/or remember the user’s actions.

Other terms used in this Policy have the meanings assigned to them by the Law.


2. Categories of Cookies Processed

2.1. The following categories of cookies are distinguished:

By purpose:
- necessary cookies;
- targeted cookies, including analytical, advertising and performance cookies.

By retention period:
- persistent cookies;
- session cookies.

2.2. The Operator’s Website processes the following categories of cookies:

Necessary cookies

Purpose:
To ensure the correct functioning of the Website.

Retention period:
During the session.
Up to 1 year from the first visit to the Website.

Targeted cookies
(analytical, advertising and performance cookies)

Purpose:
To collect and subsequently process analytical and statistical information in aggregated form.

Retention period:
6 months from the date consent is obtained.

The Operator does not use cookies to identify Website users personally.


3. Legal Grounds for Processing Cookies

3.1. Necessary cookies are used to ensure the full and correct functioning of the Website and are processed regardless of whether the user has given consent.

If the user blocks the loading of necessary cookies, the Operator cannot guarantee the functionality and security of the Website.

This category of cookies is not transferred to third-party analytical systems.

3.2. Targeted cookies are processed on the basis of consent to the processing of personal data. Such consent is requested when the user first visits the Website: the user is offered, through a pop-up window, the option to consent to the use of cookies or refuse their use.

Analytical, advertising and performance cookies do not include information that directly identifies the Website user. However, the Operator may receive the following information:
- information about the user’s device, including device type, browser type and settings, operating system, request source URL and similar technical data;
- content preferences, including the Website pages visited, date and time of the visit and similar information.

This category of cookies helps the Operator improve the quality of the Website, understand what interests users on the Website and assess how useful the Website content is to users.

Disabling analytical, advertising and performance cookies will prevent the Operator from taking measures to improve the Website based on user preferences.

3.3. The user may change cookie settings, including withdrawing previously given consent to cookie processing, by clicking the “Cookie Settings” button at the bottom of the Website’s main page.


4. Cross-Border Transfer of Cookies

4.1. When using third-party targeted services for cookie processing, the Operator carries out cross-border transfer of cookies to the following persons:

Yandex LLC
Address: 16 Lev Tolstoy Street, Moscow, Russian Federation, 119021.

According to the legislation of the Republic of Belarus, this country ensures an adequate level of protection of the rights of personal data subjects.

Google, Inc.
Address: 1600 Amphitheatre Parkway, Mountain View, California 94043, USA.

The servers used by this person may be located in countries which, according to the legislation of the Republic of Belarus, do not ensure an adequate level of protection of the rights of personal data subjects.


5. Disabling Cookies in Browser Settings

5.1. Most browsers are initially set to accept cookies.

The user may delete previously stored cookies by selecting the relevant option in the browser history.

In addition, some browsers allow users to visit websites in “incognito” mode in order to limit the amount of information stored on the computer and automatically delete certain types of cookies.

5.2. The user may also disable cookies by changing the settings of their browser.

More information about cookie management settings is available on the official websites of the relevant browsers:
- Cookie settings in Internet Explorer;
- Cookie settings in Firefox;
- Cookie settings in Chrome;
- Cookie settings in Safari;
- Cookie settings in Opera;
- Cookie settings in Microsoft Edge.


6. Rights of Personal Data Subjects and the Mechanism for Exercising Them

Right:
To withdraw consent to the processing of personal data.

Operator’s obligation:
Within 15 days, to stop the processing and notify the data subject.

Notes:
Consent may be withdrawn at any time without giving reasons, except where personal data are processed on a legal basis other than consent.


Right:
To receive information about the processing of personal data, including:
- the name and location of the Operator;
- confirmation that personal data are being processed;
- the list of personal data being processed and the source from which they were obtained;
- the legal grounds and purposes of personal data processing;
- the period for which consent was given, if consent was given;
- the name and location of the authorized person;
- other information provided for by law.

Operator’s obligation:
Within 5 business days, to provide the information in an accessible form or notify the data subject of the reasons for refusal.

Notes:
The data subject is not required to justify their interest in the requested information.


Right:
To request changes to personal data.

Operator’s obligation:
Within 15 days, to make the relevant changes and notify the data subject, or notify the data subject of the reasons for refusing to make such changes.

Notes:
This applies where personal data are incomplete, outdated or inaccurate.

Documents or information confirming the need for the changes must be submitted together with the request.


Right:
To receive information about the provision of personal data to third parties.

Operator’s obligation:
Within 15 days, to provide information on which personal data of the data subject were provided and to whom during the year preceding the date of the request, or to notify the data subject of the reasons for refusing to provide such information.

Notes:
This information is provided free of charge once per calendar year.


Right:
To demand, free of charge, the cessation of personal data processing, including deletion of personal data.

Operator’s obligation:
Within 15 days, to stop the processing of personal data, delete or block the personal data and notify the data subject.

Notes:
This right applies where there are no grounds for processing personal data.


Right:
To appeal against the actions of the Operator.

Procedure:
Appeals are made to judicial authorities in the manner established by civil procedural legislation.

The data subject also has the right to contact the regulator:

National Center for Personal Data Protection of the Republic of Belarus
220004, Minsk, 24-3 K. Zetkin Street
+375 (17) 367-07-90
info@cpd.by

However, if you have concerns that we may be violating your rights in any way, please contact us first. Direct interaction with data subjects allows us to improve and become better at protecting your rights and interests.


How to Exercise These Rights

To exercise the rights listed above, the personal data subject must submit a written request to the Operator:

Individual Entrepreneur Volha Charkasava
Apt. 51, Bldg. 1, 43 Yesenina Street
Minsk

or submit the request in the form of an electronic document by email:
info@powerful.by

Legislative acts may require the personal presence of the personal data subject and presentation of an identity document when submitting a written request to the Operator.

The request of the personal data subject must contain:
- the full name of the personal data subject and their residential address or place of stay;
- the date of birth of the personal data subject;
- the identification number of the personal data subject, or, if there is no such number, the number of the identity document of the personal data subject, in cases where this information was indicated by the personal data subject when giving consent to the Operator or where personal data are processed without the consent of the personal data subject;
- the substance of the personal data subject’s request;
- the personal signature or electronic digital signature of the personal data subject.

Unless otherwise established by legislative acts, the time limits for fulfilling the Operator’s obligations are calculated from the day following receipt of the relevant request from the personal data subject.

For any questions regarding assistance in exercising rights related to the processing of personal data by the Operator, you may contact Individual Entrepreneur Volha Charkasava by sending an email to info@powerful.by or by writing to the following address:

Apt. 51, Bldg. 1, 43 Yesenina Street
Minsk



EXPLANATION ON HOW TO WORK WITH THE COOKIE PROCESSING POLICY

Based on the definition of personal data in the Law of the Republic of Belarus No. 99-Z dated May 7, 2021 “On Personal Data Protection”, cookie files are treated as personal data because they constitute information relating to an identified natural person or to a natural person who may be identified.

There is no special legal regulation dedicated specifically to the processing of cookie files. However, the position of the National Center for Personal Data Protection indicates that obtaining consent to the processing of cookie files is intended to ensure transparency in their use.

In view of the above, the Website should include functionality, such as a pop-up notification window, allowing the Website user, upon their first visit to the Website, to refuse the collection of cookie files or configure cookie collection individually.

Example wording for the pop-up notification window:

“To ensure the convenience of Website users, cookies are used.”

The pop-up may then include:
- an “Accept” button, which permits the collection of cookie files;
- a “Reject” button, which provides the option to disable or configure cookie files;
- a “Learn more” button, which opens the text of the Cookie Processing Policy.

According to the National Center for Personal Data Protection, a website developer may collect various types of information through cookies. Therefore, it is important that the Website user can clearly see what specific information is collected through cookies, why it is collected and whether it is transferred to third parties.

This can be done by placing a link to the Cookie Processing Policy on the Website.

The presence of such a Policy on the Website is viewed by the National Center for Personal Data Protection as a demonstration of respectful treatment of Website users and their personal data.

For a better understanding of how this may be implemented, you may visit the website of the National Center for Personal Data Protection and see how it is implemented there:
https://cpd.by/