POLICY ON THE PROCESSING OF PERSONAL DATA
INDIVIDUAL ENTREPRENEUR
Volha Charkasava
24.06.2026
Minsk
APPROVED BY
Individual Entrepreneur
Volha Charkasava
24.06.2026
1. GENERAL PROVISIONS
1.1. The adoption of this Policy is one of the mandatory measures taken by Individual Entrepreneur Volha Charkasava (hereinafter referred to as 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” (hereinafter referred to as the “Law”).
1.2. This Policy has been developed in accordance with the Law and explains to personal data subjects how, for what purposes and on what legal grounds their personal data are collected, used or otherwise processed, and also sets out the rights available to personal data subjects in connection with such processing and the mechanism for exercising those rights.
This Policy does not apply to the processing of personal data in connection with the processing of cookie files on the Operator’s website.
1.3. Operator’s contact details:
Minsk.
Email: info@powerful.by.
Telephone: +375295662488.
Website: https://powerful.by/.
1.4. The terms used in this Policy shall have the meanings assigned to them by the Law.
1.5. The following abbreviations are used throughout this Policy:
Operator – Individual Entrepreneur Volha Charkasava;
Full Name – surname, first name and patronymic (if any);
Individual – natural person;
Legal Entity – legal entity;
IE – individual entrepreneur;
Consent – consent to the processing of personal data;
Social Media – the Operator’s pages on social media:
https://www.instagram.com/olga.cherkasova.power
https://www.pinterest.com/olga_cherkasova_power/
linkedin.com/in/olgacherkasova
https://t.me/olgacherkasova_BA
https://www.youtube.com/@OlgaCherkasova
https://x.com/cherkasova_pro.
2. PROCEDURE AND CONDITIONS FOR THE PROCESSING OF PERSONAL DATA
2.1. Personal data are processed both by automated means and without the use of automated means through the collection, systematization, storage, modification, use, anonymization, dissemination, provision and deletion of personal data.
2.2. Information on the purposes of personal data processing, the list of personal data processed, the legal grounds for processing and the applicable retention periods is contained in Appendix 1 to this Policy.
2.3. The Operator disseminates personal data in the following cases:
2.3.1. Surname, first name, photographic and/or video images, social media profile data and other information for the purpose of generating and maintaining interest by publishing reviews of the Operator’s activities on Social Media pages, on the basis of paragraph 19 of Article 6 of the Law (processing of personal data previously disseminated by the personal data subject) or on the basis of Consent.
2.3.2. Surname, first name, other information, photographic and/or video images, the address of a social media page (blog), and other information for the purpose of publishing advertising information, as well as information as part of news content, through dissemination on Social Media pages and/or on the Website, on the basis of Consent.
2.4. The retention periods for personal data of personal data subjects are determined in accordance with legislation governing archives and records management.
Upon expiration of the established retention periods, documents containing personal data are destroyed in accordance with the procedure established by legislation governing archives and records management, and personal data contained in the Operator’s information systems (resources) are deleted.
3. AUTHORIZED PERSONS
3.1. When processing personal data in the course of its business activities, the Operator may entrust the processing of personal data to authorized persons.
3.2. The Operator enters into personal data processing agreements with authorized persons in accordance with the requirements of Article 7 of the Law.
In order to ensure that personal data processed by authorized persons are protected at a level no lower than that maintained by the Operator, the Operator:
periodically monitors compliance by authorized persons with measures intended to protect the rights of personal data subjects when processing their personal data on the Operator’s instructions;
does not authorize authorized persons to engage sub-processors / permits authorized persons to engage sub-processors only subject to the Operator’s prior written authorization / written notification to the Operator.
3.3. List of the Operator’s authorized persons involved in the processing of personal data in the course of business activities:
TILDA PUBLISHING BEL LLC
Location: 225404, Brest Region, Baranovichi, 71 Lenina St., Office 307
Privacy Policy: https://tilda.by/ru/privacy/
Reason for processing personal data by the authorized person: Use of the https://tilda.by/ platform for the creation and operation of the Website by means of remote access.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
NADEZHNYE PROGRAMMY LLC
Location: 220006, Minsk, 8 Aranskaya St., Block 1, 4th Floor
Privacy Policy: https://hoster.by/downloads/pd_processing-policy.pdf
Reason for processing personal data by the authorized person: Ensuring the availability of the Website on the Internet.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
TELEGRAM MESSENGER INC.
Location: Geneva Place, Waterfront Drive, Tortola VG1110, British Virgin Islands
Privacy Policy: https://telegram.org/privacy/by
Reason for processing personal data by the authorized person: Provision of services using Telegram.
Actions performed with personal data by the authorized person: Collection, systematization, storage, use, provision and deletion of personal data.
WHATSAPP IRELAND LIMITED – META PLATFORMS, INC.
Location: 1601 Willow Road, Menlo Park, CA 94025, USA
Privacy Policy: https://www.whatsapp.com/legal/privacy-policy-eea?lang=ru
Reason for processing personal data by the authorized person: Provision of services using WhatsApp.
Actions performed with personal data by the authorized person: Collection, systematization, storage, use, provision and deletion of personal data.
SISTEMA GETCOURSE LLC
Location: Moscow, Skolkovo Innovation Center, 42 Bolshoy Boulevard, Building 1, Premises 1122
Privacy Policy: https://getcourse.ru/privacy_policy
Reason for processing personal data by the authorized person: Use of the https://getcourse.ru/ service for educational activities and for sending advertising and informational communications.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
ZOOM VIDEO COMMUNICATIONS, INC.
Location: 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA
Privacy Statement: https://www.zoom.com/en/trust/privacy/privacy-statement/
Reason for processing personal data by the authorized person: Use of the https://www.zoom.com/ service for the provision of services.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
GOOGLE, INC.
Location: 1600 Amphitheatre Parkway, Mountain View, California 94043, USA
Privacy Policy: https://policies.google.com/privacy?hl=ru
Reason for processing personal data by the authorized person: Provision of services using Google Meet.
Actions performed with personal data by the authorized person: Collection, systematization, storage, use, provision and deletion of personal data.
BOTHELP LLC
Location: 241050, Russian Federation, Bryansk, 65 Duki St., Office 404
Privacy Policy: https://bothelp.io/ru/policy
Reason for processing personal data by the authorized person: Use of the https://bothelp.io/ service for submitting an application to enter into an agreement and for sending advertising and informational communications.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
SALEBOT LLC
Location: Russian Federation, Penza Region, Penza, 39V Stroiteley Avenue, Premises No. 251
Privacy Policy: https://salebot.pro/policy_ooo.pdf
Reason for processing personal data by the authorized person: Sending advertising and informational communications.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
UNISENDER LLC
Location: 127015, Moscow, 23 Bolshaya Novodmitrovskaya St., Premises 2/46
Privacy Policy: https://crm.unisender.com/politika_obrabotki_personalnyh_dannyx
Reason for processing personal data by the authorized person: Sending advertising and informational communications.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
SENDPULSE INC.
Location: 220 E 23rd St #401, New York, NY 10010, USA
Privacy Policy: https://sendpulse.com/ru/legal/pp?_gl=1*100r63t*_up*MQ..*_gs*MQ..
Reason for processing personal data by the authorized person: Sending advertising and informational communications.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
ICOMCHARGE LLC
UNP: 191670289
Location: 104 Dzerzhinskogo Ave., Office 1801, Minsk
Privacy Policy: https://bepaid.by/sites/default/files/privacy-policy_2.0.pdf
Reason for processing personal data by the authorized person: Providing the technical capability to process payments using bank payment cards and other payment methods.
Actions performed with personal data by the authorized person: Collection, systematization, storage, use, provision and deletion of personal data.
3.4. The Operator provides personal data to other persons for the purposes specified in Appendix 1, including, in particular, RUE Belpochta for the purpose of sending postal correspondence.
4. CROSS-BORDER TRANSFER OF PERSONAL DATA
4.1. The Operator carries out cross-border transfers of personal data for the following purposes:
4.1.1. For the publication of advertising information, as well as information as part of news content, through dissemination on Social Media pages: surname, first name, other information, photographic and/or video images, address of a social media page (blog), and other information are transferred to Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA; Telegram Group Inc., Geneva Place, Waterfront Drive, Tortola VG1110, British Virgin Islands; Google, Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, USA.
4.1.2. For the publication of reviews of the Operator’s activities through dissemination on Social Media pages: surname, first name, photographic and/or video images, social media profile data and other information are transferred to Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA.
4.1.3. For the provision of services using https://www.zoom.com/ru: image (photo and video), a person’s voice, surname, first name, patronymic, and other personal data communicated by the subject and obtained during the period in which the services are provided are transferred to Zoom Video Communications, Inc., 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA.
4.1.4. For the provision of services using Telegram: image (photo and video), a person’s voice, surname, first name, patronymic, Telegram username, mobile telephone number and other personal data communicated by the subject are transferred to Telegram Messenger Inc., Geneva Place, Waterfront Drive, Tortola VG1110, British Virgin Islands.
4.1.5. For the provision of services using WhatsApp: image (photo and video), a person’s voice, surname, first name, patronymic, mobile telephone number and other personal data communicated by the subject are transferred to WhatsApp Ireland Limited – Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA.
4.1.6. For sending advertising and informational communications: surname, first name, patronymic, mobile telephone number, photographic image and other information communicated by the personal data subject are transferred to SendPulse Inc., 220 E 23rd St #401, New York, NY 10010, USA.
4.1.7. For submitting an application to enter into an agreement: surname, first name, patronymic, mobile telephone number, Telegram username and other information are transferred to Bothelp LLC, 241050, Russian Federation, Bryansk, 65 Duki St., Office 404.
4.1.8. For sending advertising and informational communications by email: surname, first name, patronymic, email address and other information communicated by the personal data subject are transferred to UniSender LLC, 127015, Moscow, 23 Bolshaya Novodmitrovskaya St., Premises 2/46.
4.1.9. For sending advertising and informational communications: surname, first name, patronymic, mobile telephone number, photographic image and other information communicated by the personal data subject are transferred to Bothelp LLC, 241050, Russian Federation, Bryansk, 65 Duki St., Office 404; SaleBot LLC, Russian Federation, Penza Region, Penza, 39V Stroiteley Avenue, Premises No. 251.
4.1.10. For the provision of services using https://getcourse.ru/: image (photo and video), a person’s voice, surname, first name, patronymic, and other personal data communicated by the subject and obtained during the period in which the services are provided are transferred to Sistema GetCourse LLC, Moscow, Skolkovo Innovation Center, 42 Bolshoy Boulevard, Building 1, Premises 1122.
4.2. In the cases of cross-border transfer of personal data specified in Clauses 4.1.7–4.1.10 of this Policy, personal data are transferred to the territory of foreign states that ensure an adequate level of protection of the rights of personal data subjects.
In the case of the cross-border transfer of personal data specified in Clause 4.1.6 of this Policy, the personal data subject may, at their discretion and in order to avoid a cross-border transfer of personal data, use alternative methods of communication with the Operator to submit an application to enter into an agreement: telephone communication, submission of requests through feedback forms on the Website, or an in-person visit to the Operator’s location.
In the cases of cross-border transfer of personal data specified in Clauses 4.1.1–4.1.6, personal data are transferred to the territory of foreign states that do not ensure an adequate level of protection of the rights of personal data subjects. Since it is not possible to determine the state to which the cross-border transfer of personal data is made, there is a possibility that such state may not provide conditions ensuring adequate protection of the rights of personal data subjects. In this regard, the Operator informs personal data subjects of the following possible risks associated with cross-border transfers of personal data:
absence of personal data legislation;
a limited range of information concerning an individual being recognized as personal data;
absence of an authorized body responsible for protecting the rights of personal data subjects;
a limited list of rights of personal data subjects or the absence of such rights;
other possible risks of violations of the rights of personal data subjects arising in connection with cross-border transfers of personal data.
4.3. The Operator may carry out cross-border transfers of personal data where personal data subjects use the Instagram social network, as well as Telegram/Viber/WhatsApp messengers, to communicate with the Operator, including communication with customers for the purpose of ensuring the receipt of services by means of telephone and video communication, email and messengers; creating and operating communities/groups/chats for customers in messengers for the receipt of services, provision/receipt of information and receipt of feedback; and sending informational communications.
In such cases, the purpose of the cross-border transfer of personal data is to respond to requests from the personal data subject, ensure prompt communication between the Operator and the personal data subject, and ensure the proper provision of services.
In the situation described above, because the data transmission servers are beyond the Operator’s control, the Operator is unable to guarantee that the personal data subject’s personal data will be transferred exclusively within the territories of foreign states that ensure an adequate level of protection of the rights of personal data subjects.
Since it is not possible to determine the state to which the cross-border transfer of personal data is made, there is a possibility that such state may not provide conditions ensuring adequate protection of the rights of personal data subjects. In this regard, the Operator informs personal data subjects of the following possible risks associated with cross-border transfers of personal data:
absence of personal data legislation;
a limited range of information concerning an individual being recognized as personal data;
absence of an authorized body responsible for protecting the rights of personal data subjects;
a limited list of rights of personal data subjects or the absence of such rights;
other possible risks of violations of the rights of personal data subjects arising in connection with cross-border transfers of personal data.
The personal data subject may, at their discretion and in order to avoid a cross-border transfer of personal data, use alternative methods of communication with the Operator: telephone communication or an in-person visit to the Operator’s location.
5. RIGHTS OF PERSONAL DATA SUBJECTS
RIGHT: Withdraw* consent to the processing of personal data.
OPERATOR’S OBLIGATION**: Within 15 days***, cease processing and notify the personal data subject.
NOTES**: This right may be exercised at any time without stating reasons, except where personal data are processed on a legal ground other than consent.
RIGHT: Obtain* information about the processing of their 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 applicable;
– the name and location of the authorized person;
– other information provided for by law.
OPERATOR’S OBLIGATION**: Within 5 business days***, provide the information in an accessible form or notify the personal data subject of the reasons for refusing to provide it.
NOTES**: The personal data subject is not required to justify their interest in the requested information.
RIGHT: Request* amendments to their personal data.
OPERATOR’S OBLIGATION**: Within 15 days***, make the relevant amendments and notify the personal data subject accordingly, or notify the personal data subject of the reasons for refusing to make such amendments.
NOTES**: This right applies where the personal data are incomplete, outdated or inaccurate. Documents or information confirming the need for the amendments must be submitted together with the request.
RIGHT: Obtain information about the provision of their personal data to third parties.
OPERATOR’S OBLIGATION**: Within 15 days***, provide information regarding which of the personal data subject’s personal data were provided, and to whom, during the year preceding the date on which the request was submitted, or notify the personal data subject of the reasons for refusing to provide such information.
NOTES**: Free of charge once per calendar year.
RIGHT: Request* the cessation of processing of their personal data free of charge, including deletion of such data.
OPERATOR’S OBLIGATION**: Within 15 days***, cease processing the personal data, delete (block) such data and notify the personal data subject accordingly.
NOTES**: Where there are no legal grounds for processing the personal data.
RIGHT: Appeal against the Operator’s actions.
Such appeals may be made to the courts in accordance with the procedure established by civil procedural legislation.
You also have the right to contact the regulatory authority:
National Center for Personal Data Protection of the Republic of Belarus
220004, Minsk, 24-3 K. Tsetkin St.
+375 (17) 367-07-90
info@cpd.by
However, if you have concerns that we may in any way be violating your rights, we ask that you contact us. Direct interaction with personal data subjects enables us to develop and improve the protection of your rights and interests.
* To exercise the rights listed above, the personal data subject shall submit an application to the Operator in writing (Individual Entrepreneur Volha Charkasava Minsk) or in the form of an electronic document (email: info@powerful.by). Legislative acts may require the personal presence of the personal data subject and presentation of an identity document when submitting an application to the Operator in writing.
The personal data subject’s application must contain:
the full name of the personal data subject and the address of their place of residence (place of stay);
the personal data subject’s date of birth;
the personal identification number of the personal data subject or, if no such number exists, the number of an identity document, where such information was provided by the personal data subject when giving consent to the Operator or where the personal data are processed without the personal data subject’s consent;
a statement describing the substance of the personal data subject’s request;
the personal signature or electronic digital signature of the personal data subject.
** Unless otherwise provided by legislative acts.
*** The periods for performance of the obligations are calculated from the day following receipt of the relevant application from the personal data subject, unless another period is established by legislative acts.
For any questions or assistance in exercising rights related to the processing of personal data by the Operator, please contact Individual Entrepreneur Volha Charkasava by email at info@powerful.by or at: Minsk.
INDIVIDUAL ENTREPRENEUR
Volha Charkasava
24.06.2026
Minsk
APPROVED BY
Individual Entrepreneur
Volha Charkasava
24.06.2026
1. GENERAL PROVISIONS
1.1. The adoption of this Policy is one of the mandatory measures taken by Individual Entrepreneur Volha Charkasava (hereinafter referred to as 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” (hereinafter referred to as the “Law”).
1.2. This Policy has been developed in accordance with the Law and explains to personal data subjects how, for what purposes and on what legal grounds their personal data are collected, used or otherwise processed, and also sets out the rights available to personal data subjects in connection with such processing and the mechanism for exercising those rights.
This Policy does not apply to the processing of personal data in connection with the processing of cookie files on the Operator’s website.
1.3. Operator’s contact details:
Minsk.
Email: info@powerful.by.
Telephone: +375295662488.
Website: https://powerful.by/.
1.4. The terms used in this Policy shall have the meanings assigned to them by the Law.
1.5. The following abbreviations are used throughout this Policy:
Operator – Individual Entrepreneur Volha Charkasava;
Full Name – surname, first name and patronymic (if any);
Individual – natural person;
Legal Entity – legal entity;
IE – individual entrepreneur;
Consent – consent to the processing of personal data;
Social Media – the Operator’s pages on social media:
https://www.instagram.com/olga.cherkasova.power
https://www.pinterest.com/olga_cherkasova_power/
linkedin.com/in/olgacherkasova
https://t.me/olgacherkasova_BA
https://www.youtube.com/@OlgaCherkasova
https://x.com/cherkasova_pro.
2. PROCEDURE AND CONDITIONS FOR THE PROCESSING OF PERSONAL DATA
2.1. Personal data are processed both by automated means and without the use of automated means through the collection, systematization, storage, modification, use, anonymization, dissemination, provision and deletion of personal data.
2.2. Information on the purposes of personal data processing, the list of personal data processed, the legal grounds for processing and the applicable retention periods is contained in Appendix 1 to this Policy.
2.3. The Operator disseminates personal data in the following cases:
2.3.1. Surname, first name, photographic and/or video images, social media profile data and other information for the purpose of generating and maintaining interest by publishing reviews of the Operator’s activities on Social Media pages, on the basis of paragraph 19 of Article 6 of the Law (processing of personal data previously disseminated by the personal data subject) or on the basis of Consent.
2.3.2. Surname, first name, other information, photographic and/or video images, the address of a social media page (blog), and other information for the purpose of publishing advertising information, as well as information as part of news content, through dissemination on Social Media pages and/or on the Website, on the basis of Consent.
2.4. The retention periods for personal data of personal data subjects are determined in accordance with legislation governing archives and records management.
Upon expiration of the established retention periods, documents containing personal data are destroyed in accordance with the procedure established by legislation governing archives and records management, and personal data contained in the Operator’s information systems (resources) are deleted.
3. AUTHORIZED PERSONS
3.1. When processing personal data in the course of its business activities, the Operator may entrust the processing of personal data to authorized persons.
3.2. The Operator enters into personal data processing agreements with authorized persons in accordance with the requirements of Article 7 of the Law.
In order to ensure that personal data processed by authorized persons are protected at a level no lower than that maintained by the Operator, the Operator:
periodically monitors compliance by authorized persons with measures intended to protect the rights of personal data subjects when processing their personal data on the Operator’s instructions;
does not authorize authorized persons to engage sub-processors / permits authorized persons to engage sub-processors only subject to the Operator’s prior written authorization / written notification to the Operator.
3.3. List of the Operator’s authorized persons involved in the processing of personal data in the course of business activities:
TILDA PUBLISHING BEL LLC
Location: 225404, Brest Region, Baranovichi, 71 Lenina St., Office 307
Privacy Policy: https://tilda.by/ru/privacy/
Reason for processing personal data by the authorized person: Use of the https://tilda.by/ platform for the creation and operation of the Website by means of remote access.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
NADEZHNYE PROGRAMMY LLC
Location: 220006, Minsk, 8 Aranskaya St., Block 1, 4th Floor
Privacy Policy: https://hoster.by/downloads/pd_processing-policy.pdf
Reason for processing personal data by the authorized person: Ensuring the availability of the Website on the Internet.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
TELEGRAM MESSENGER INC.
Location: Geneva Place, Waterfront Drive, Tortola VG1110, British Virgin Islands
Privacy Policy: https://telegram.org/privacy/by
Reason for processing personal data by the authorized person: Provision of services using Telegram.
Actions performed with personal data by the authorized person: Collection, systematization, storage, use, provision and deletion of personal data.
WHATSAPP IRELAND LIMITED – META PLATFORMS, INC.
Location: 1601 Willow Road, Menlo Park, CA 94025, USA
Privacy Policy: https://www.whatsapp.com/legal/privacy-policy-eea?lang=ru
Reason for processing personal data by the authorized person: Provision of services using WhatsApp.
Actions performed with personal data by the authorized person: Collection, systematization, storage, use, provision and deletion of personal data.
SISTEMA GETCOURSE LLC
Location: Moscow, Skolkovo Innovation Center, 42 Bolshoy Boulevard, Building 1, Premises 1122
Privacy Policy: https://getcourse.ru/privacy_policy
Reason for processing personal data by the authorized person: Use of the https://getcourse.ru/ service for educational activities and for sending advertising and informational communications.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
ZOOM VIDEO COMMUNICATIONS, INC.
Location: 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA
Privacy Statement: https://www.zoom.com/en/trust/privacy/privacy-statement/
Reason for processing personal data by the authorized person: Use of the https://www.zoom.com/ service for the provision of services.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
GOOGLE, INC.
Location: 1600 Amphitheatre Parkway, Mountain View, California 94043, USA
Privacy Policy: https://policies.google.com/privacy?hl=ru
Reason for processing personal data by the authorized person: Provision of services using Google Meet.
Actions performed with personal data by the authorized person: Collection, systematization, storage, use, provision and deletion of personal data.
BOTHELP LLC
Location: 241050, Russian Federation, Bryansk, 65 Duki St., Office 404
Privacy Policy: https://bothelp.io/ru/policy
Reason for processing personal data by the authorized person: Use of the https://bothelp.io/ service for submitting an application to enter into an agreement and for sending advertising and informational communications.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
SALEBOT LLC
Location: Russian Federation, Penza Region, Penza, 39V Stroiteley Avenue, Premises No. 251
Privacy Policy: https://salebot.pro/policy_ooo.pdf
Reason for processing personal data by the authorized person: Sending advertising and informational communications.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
UNISENDER LLC
Location: 127015, Moscow, 23 Bolshaya Novodmitrovskaya St., Premises 2/46
Privacy Policy: https://crm.unisender.com/politika_obrabotki_personalnyh_dannyx
Reason for processing personal data by the authorized person: Sending advertising and informational communications.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
SENDPULSE INC.
Location: 220 E 23rd St #401, New York, NY 10010, USA
Privacy Policy: https://sendpulse.com/ru/legal/pp?_gl=1*100r63t*_up*MQ..*_gs*MQ..
Reason for processing personal data by the authorized person: Sending advertising and informational communications.
Actions performed with personal data by the authorized person: Storage; access and use for incident resolution; deletion upon termination of the contractual relationship.
ICOMCHARGE LLC
UNP: 191670289
Location: 104 Dzerzhinskogo Ave., Office 1801, Minsk
Privacy Policy: https://bepaid.by/sites/default/files/privacy-policy_2.0.pdf
Reason for processing personal data by the authorized person: Providing the technical capability to process payments using bank payment cards and other payment methods.
Actions performed with personal data by the authorized person: Collection, systematization, storage, use, provision and deletion of personal data.
3.4. The Operator provides personal data to other persons for the purposes specified in Appendix 1, including, in particular, RUE Belpochta for the purpose of sending postal correspondence.
4. CROSS-BORDER TRANSFER OF PERSONAL DATA
4.1. The Operator carries out cross-border transfers of personal data for the following purposes:
4.1.1. For the publication of advertising information, as well as information as part of news content, through dissemination on Social Media pages: surname, first name, other information, photographic and/or video images, address of a social media page (blog), and other information are transferred to Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA; Telegram Group Inc., Geneva Place, Waterfront Drive, Tortola VG1110, British Virgin Islands; Google, Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, USA.
4.1.2. For the publication of reviews of the Operator’s activities through dissemination on Social Media pages: surname, first name, photographic and/or video images, social media profile data and other information are transferred to Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA.
4.1.3. For the provision of services using https://www.zoom.com/ru: image (photo and video), a person’s voice, surname, first name, patronymic, and other personal data communicated by the subject and obtained during the period in which the services are provided are transferred to Zoom Video Communications, Inc., 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113, USA.
4.1.4. For the provision of services using Telegram: image (photo and video), a person’s voice, surname, first name, patronymic, Telegram username, mobile telephone number and other personal data communicated by the subject are transferred to Telegram Messenger Inc., Geneva Place, Waterfront Drive, Tortola VG1110, British Virgin Islands.
4.1.5. For the provision of services using WhatsApp: image (photo and video), a person’s voice, surname, first name, patronymic, mobile telephone number and other personal data communicated by the subject are transferred to WhatsApp Ireland Limited – Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA.
4.1.6. For sending advertising and informational communications: surname, first name, patronymic, mobile telephone number, photographic image and other information communicated by the personal data subject are transferred to SendPulse Inc., 220 E 23rd St #401, New York, NY 10010, USA.
4.1.7. For submitting an application to enter into an agreement: surname, first name, patronymic, mobile telephone number, Telegram username and other information are transferred to Bothelp LLC, 241050, Russian Federation, Bryansk, 65 Duki St., Office 404.
4.1.8. For sending advertising and informational communications by email: surname, first name, patronymic, email address and other information communicated by the personal data subject are transferred to UniSender LLC, 127015, Moscow, 23 Bolshaya Novodmitrovskaya St., Premises 2/46.
4.1.9. For sending advertising and informational communications: surname, first name, patronymic, mobile telephone number, photographic image and other information communicated by the personal data subject are transferred to Bothelp LLC, 241050, Russian Federation, Bryansk, 65 Duki St., Office 404; SaleBot LLC, Russian Federation, Penza Region, Penza, 39V Stroiteley Avenue, Premises No. 251.
4.1.10. For the provision of services using https://getcourse.ru/: image (photo and video), a person’s voice, surname, first name, patronymic, and other personal data communicated by the subject and obtained during the period in which the services are provided are transferred to Sistema GetCourse LLC, Moscow, Skolkovo Innovation Center, 42 Bolshoy Boulevard, Building 1, Premises 1122.
4.2. In the cases of cross-border transfer of personal data specified in Clauses 4.1.7–4.1.10 of this Policy, personal data are transferred to the territory of foreign states that ensure an adequate level of protection of the rights of personal data subjects.
In the case of the cross-border transfer of personal data specified in Clause 4.1.6 of this Policy, the personal data subject may, at their discretion and in order to avoid a cross-border transfer of personal data, use alternative methods of communication with the Operator to submit an application to enter into an agreement: telephone communication, submission of requests through feedback forms on the Website, or an in-person visit to the Operator’s location.
In the cases of cross-border transfer of personal data specified in Clauses 4.1.1–4.1.6, personal data are transferred to the territory of foreign states that do not ensure an adequate level of protection of the rights of personal data subjects. Since it is not possible to determine the state to which the cross-border transfer of personal data is made, there is a possibility that such state may not provide conditions ensuring adequate protection of the rights of personal data subjects. In this regard, the Operator informs personal data subjects of the following possible risks associated with cross-border transfers of personal data:
absence of personal data legislation;
a limited range of information concerning an individual being recognized as personal data;
absence of an authorized body responsible for protecting the rights of personal data subjects;
a limited list of rights of personal data subjects or the absence of such rights;
other possible risks of violations of the rights of personal data subjects arising in connection with cross-border transfers of personal data.
4.3. The Operator may carry out cross-border transfers of personal data where personal data subjects use the Instagram social network, as well as Telegram/Viber/WhatsApp messengers, to communicate with the Operator, including communication with customers for the purpose of ensuring the receipt of services by means of telephone and video communication, email and messengers; creating and operating communities/groups/chats for customers in messengers for the receipt of services, provision/receipt of information and receipt of feedback; and sending informational communications.
In such cases, the purpose of the cross-border transfer of personal data is to respond to requests from the personal data subject, ensure prompt communication between the Operator and the personal data subject, and ensure the proper provision of services.
In the situation described above, because the data transmission servers are beyond the Operator’s control, the Operator is unable to guarantee that the personal data subject’s personal data will be transferred exclusively within the territories of foreign states that ensure an adequate level of protection of the rights of personal data subjects.
Since it is not possible to determine the state to which the cross-border transfer of personal data is made, there is a possibility that such state may not provide conditions ensuring adequate protection of the rights of personal data subjects. In this regard, the Operator informs personal data subjects of the following possible risks associated with cross-border transfers of personal data:
absence of personal data legislation;
a limited range of information concerning an individual being recognized as personal data;
absence of an authorized body responsible for protecting the rights of personal data subjects;
a limited list of rights of personal data subjects or the absence of such rights;
other possible risks of violations of the rights of personal data subjects arising in connection with cross-border transfers of personal data.
The personal data subject may, at their discretion and in order to avoid a cross-border transfer of personal data, use alternative methods of communication with the Operator: telephone communication or an in-person visit to the Operator’s location.
5. RIGHTS OF PERSONAL DATA SUBJECTS
RIGHT: Withdraw* consent to the processing of personal data.
OPERATOR’S OBLIGATION**: Within 15 days***, cease processing and notify the personal data subject.
NOTES**: This right may be exercised at any time without stating reasons, except where personal data are processed on a legal ground other than consent.
RIGHT: Obtain* information about the processing of their 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 applicable;
– the name and location of the authorized person;
– other information provided for by law.
OPERATOR’S OBLIGATION**: Within 5 business days***, provide the information in an accessible form or notify the personal data subject of the reasons for refusing to provide it.
NOTES**: The personal data subject is not required to justify their interest in the requested information.
RIGHT: Request* amendments to their personal data.
OPERATOR’S OBLIGATION**: Within 15 days***, make the relevant amendments and notify the personal data subject accordingly, or notify the personal data subject of the reasons for refusing to make such amendments.
NOTES**: This right applies where the personal data are incomplete, outdated or inaccurate. Documents or information confirming the need for the amendments must be submitted together with the request.
RIGHT: Obtain information about the provision of their personal data to third parties.
OPERATOR’S OBLIGATION**: Within 15 days***, provide information regarding which of the personal data subject’s personal data were provided, and to whom, during the year preceding the date on which the request was submitted, or notify the personal data subject of the reasons for refusing to provide such information.
NOTES**: Free of charge once per calendar year.
RIGHT: Request* the cessation of processing of their personal data free of charge, including deletion of such data.
OPERATOR’S OBLIGATION**: Within 15 days***, cease processing the personal data, delete (block) such data and notify the personal data subject accordingly.
NOTES**: Where there are no legal grounds for processing the personal data.
RIGHT: Appeal against the Operator’s actions.
Such appeals may be made to the courts in accordance with the procedure established by civil procedural legislation.
You also have the right to contact the regulatory authority:
National Center for Personal Data Protection of the Republic of Belarus
220004, Minsk, 24-3 K. Tsetkin St.
+375 (17) 367-07-90
info@cpd.by
However, if you have concerns that we may in any way be violating your rights, we ask that you contact us. Direct interaction with personal data subjects enables us to develop and improve the protection of your rights and interests.
* To exercise the rights listed above, the personal data subject shall submit an application to the Operator in writing (Individual Entrepreneur Volha Charkasava Minsk) or in the form of an electronic document (email: info@powerful.by). Legislative acts may require the personal presence of the personal data subject and presentation of an identity document when submitting an application to the Operator in writing.
The personal data subject’s application must contain:
the full name of the personal data subject and the address of their place of residence (place of stay);
the personal data subject’s date of birth;
the personal identification number of the personal data subject or, if no such number exists, the number of an identity document, where such information was provided by the personal data subject when giving consent to the Operator or where the personal data are processed without the personal data subject’s consent;
a statement describing the substance of the personal data subject’s request;
the personal signature or electronic digital signature of the personal data subject.
** Unless otherwise provided by legislative acts.
*** The periods for performance of the obligations are calculated from the day following receipt of the relevant application from the personal data subject, unless another period is established by legislative acts.
For any questions or assistance in exercising rights related to the processing of personal data by the Operator, please contact Individual Entrepreneur Volha Charkasava by email at info@powerful.by or at: Minsk.
APPENDIX 1
to the Personal Data Processing Policy
PURPOSES OF PERSONAL DATA PROCESSING
PERSONNEL RECRUITMENT
Purpose of processing:
Search for and evaluation of job applicants; communication with them.
Categories of personal data subjects:
Job applicants.
Personal data processed:
Personal data contained in resumes (questionnaires, autobiographies, personnel record forms, applications, letters of recommendation, etc.).
Legal grounds for processing:
1. With respect to personal data previously disseminated (for example, on the information portal of the state employment service or rabota.by) – paragraph 19 of Article 6 of the Law.
2. Where a resume is provided in writing or as an electronic document signed by the job applicant – paragraph 16 of Article 6 of the Law.
3. Where a resume is sent by email – Consent.
Retention period:
1. If employment is refused – no more than 1 year.
2. If the applicant is hired – 1 month.
3. Where processing is based on Consent – until Consent is withdrawn.
BUSINESS ACTIVITIES
(CONCLUSION AND PERFORMANCE OF CIVIL-LAW AGREEMENTS, ETC.)
Purpose of processing:
Conclusion of civil-law agreements for the provision of services in connection with the implementation of educational programs on a paid basis in simple written form, including on the basis of a public offer; performance and termination of such agreements.
Categories of personal data subjects:
Clients – Individuals and Individual Entrepreneurs.
Authorized representatives of Legal Entities.
Personal data processed:
With respect to a learner who is an Individual (Individual Entrepreneur) and/or payer: surname, first name, patronymic; registered address and/or actual residential address; personal identification number or, in its absence, identity-document details (series, if any; number; date of issue; name or code of the issuing authority); telephone number; email address; period of study; educational program; commencement date of the educational process; form of education; signature.
With respect to an employee of a Legal Entity or Individual Entrepreneur referred for training: surname, first name, patronymic; registered address and/or actual residential address; personal identification number or, in its absence, identity-document details (series, if any; number; date of issue; name or code of the issuing authority); telephone number; email address; signature.
With respect to an Individual Entrepreneur: surname, first name, patronymic; registered address of the Individual Entrepreneur; details of the certificate of state registration of the Individual Entrepreneur; bank details; surname, first name and patronymic of the person who signed the Agreement; details of the power of attorney where the Agreement is signed under a power of attorney.
Legal grounds for processing:
1. For Individuals and Individual Entrepreneurs – agreement (paragraph 15 of Article 6 of the Law).
2. For a representative of a Legal Entity – paragraph 8 of Article 6 of the Law (labor legislation, civil legislation).
Retention period:
3 years after an inspection by the tax authorities; if no inspection is conducted – 10 years after termination of the agreement.
Purpose of processing:
Submission of applications for entering into agreements for the provision of services in connection with the implementation of educational programs on a paid basis, as well as other types of civil-law agreements, through Social Media accounts, using https://bothelp.io/, using Telegram/Viber/WhatsApp messengers, and on the Website.
Categories of personal data subjects:
Potential clients.
Personal data processed:
First name, telephone number, email address, other information.
Legal grounds for processing:
1. For Individuals and Individual Entrepreneurs – agreement (paragraph 15 of Article 6 of the Law).
2. For a representative of a Legal Entity – paragraph 8 of Article 6 of the Law (labor legislation, civil legislation).
Retention period:
3 years after an inspection by the tax authorities; if no inspection is conducted – 10 years after termination of the agreement.
Purpose of processing:
Conclusion of civil-law agreements in simple written form, including on the basis of a public offer; performance and termination of such agreements.
Categories of personal data subjects:
Counterparties – Individuals and Individual Entrepreneurs.
Authorized representatives of counterparties that are Legal Entities.
Personal data processed:
1. For Individuals, including Individual Entrepreneurs: full name, registered address, email address, telephone number, payment-related information.
2. For representatives of Legal Entities: full name, position, business email address, business telephone number.
Legal grounds for processing:
1. For Individuals and Individual Entrepreneurs – agreement (paragraph 15 of Article 6 of the Law).
2. For representatives of Legal Entities – paragraph 8 of Article 6 of the Law (labor legislation, civil legislation).
Retention period:
3 years after an inspection by the tax authorities; if no inspection is conducted – 10 years after termination of the agreement.
Purpose of processing:
Conclusion, performance and termination of civil-law agreements related to the material and technical support of the organization’s activities (supply, sale and purchase, contracting, provision of services for consideration, etc.).
Categories of personal data subjects:
Counterparties – Individuals and Individual Entrepreneurs.
Authorized representatives of counterparties that are Legal Entities.
Personal data processed:
1. For Individuals, including Individual Entrepreneurs: full name, registered address, email address, telephone number, payment-related information.
2. For representatives of Legal Entities: full name, position, business email address, business telephone number.
Legal grounds for processing:
1. For Individuals and Individual Entrepreneurs – agreement (paragraph 15 of Article 6 of the Law).
2. For representatives of Legal Entities – paragraph 8 of Article 6 of the Law (labor legislation, civil legislation).
Retention period:
3 years after an inspection by the tax authorities; if no inspection is conducted – 10 years after termination of the agreement.
Purpose of processing:
Provision of services using Telegram.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Image (photo/video), a person’s voice, surname, first name, patronymic, Telegram username, mobile telephone number, other personal data communicated by the subject.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Provision of services using WhatsApp.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Image (photo/video), a person’s voice, surname, first name, patronymic, mobile telephone number, other personal data communicated by the subject.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Provision of services using https://www.zoom.com/ru.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Image (photo/video), a person’s voice, surname, first name, patronymic, other personal data communicated by the subject and obtained during the provision of services.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Provision of services using Google Meet.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Image (photo/video), a person’s voice, surname, first name, patronymic, other personal data communicated by the subject and obtained during the provision of services.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Provision of services using https://getcourse.ru/.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Image (photo/video), a person’s voice, surname, first name, patronymic, other personal data communicated by the subject and obtained during the provision of services.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
EDUCATIONAL ACTIVITIES
Purpose of processing:
Publication of information about learners on the Website.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic, other information.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law); paragraph 20 of Article 6 of the Law (education legislation).
Retention period:
For the term of the agreement.
Purpose of processing:
Organization and implementation of the provision of services (issuance of orders and instructions relating to the provision of services).
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic; number and date of the order; other information contained in the documents.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
10 years.
Purpose of processing:
Refund to the customer or payer of funds for services not received, as well as funds credited in error; notification of the customer thereof.
Categories of personal data subjects:
Customers (learners); payers.
Personal data processed:
Surname, first name, patronymic; telephone number; email address; bank details (card account number).
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
3 years after expiration of the Agreement and completion of an inspection by the tax authorities regarding compliance with tax legislation. If no such inspection is conducted – 10 years after expiration of the Agreement.
Purpose of processing:
Communication with customers to enable receipt of services by telephone and video communication, email and messengers.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic; email address; telephone number.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Creation and operation of communities/groups/chats for customers in messengers for receipt of services, provision/receipt of information and receipt of feedback.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic, username, telephone number.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Sending informational communications.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic, telephone number, Telegram username.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Maintaining the register for recording and issuing education documents.
Categories of personal data subjects:
Customers (learners); persons to whom an education document is issued under a power of attorney.
Personal data processed:
Registration number of the education document; series (if any) and number of the education-document form; surname, first name, patronymic (if any) of the learner; learner’s personal identification number; identity-document details (series, if any; number; date of issue; name of the state authority that issued it, where the education document is received under a power of attorney); profile (field of activity) in which the educational program is implemented, if any; number and date of the expulsion order; information on dispatch by post (receipt number and dispatch date) or issue under a power of attorney (number and date thereof); signature of the person receiving the education document, where received in person; other information.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (education legislation).
Retention period:
55 years.
Purpose of processing:
Issuance of a certificate of training.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic; period of education; name of the educational program; its topic, if any; number of hours; registration number.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law); paragraph 20 of Article 6 of the Law (education legislation).
Retention period:
Not retained.
Purpose of processing:
Sending education documents by post.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic; postal address.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law); paragraph 20 of Article 6 of the Law (education legislation).
Retention period:
Not retained.
MARKETING
(EVENTS, MAILINGS AND OTHER ACTIVITIES FOR THE PROMOTION OF GOODS, WORKS AND SERVICES)
Purpose of processing:
Publication of advertising information, as well as information as part of news content, through dissemination on Social Media pages and on the Website.
Categories of personal data subjects:
Persons who participated in the creation of advertising information or news content.
Personal data processed:
Surname, first name, patronymic, photographic and/or video image, social media profile data.
Legal grounds for processing:
Consent.
Retention period:
Until Consent is withdrawn.
Purpose of processing:
Generating and maintaining interest through dissemination of reviews on Social Media.
Categories of personal data subjects:
Persons who have submitted reviews.
Personal data processed:
Surname, first name, photographic image (if any), other information.
Legal grounds for processing:
1. With respect to personal data previously disseminated – paragraph 19 of Article 6 of the Law.
2. With respect to other personal data – Consent.
Retention period:
3 years.
Purpose of processing:
Sending advertising and informational communications.
Categories of personal data subjects:
Persons who have given Consent to receive advertising and informational communications.
Personal data processed:
Surname, first name, patronymic, mobile telephone number, email address, Telegram username, photographic image, other information communicated by the personal data subject.
Legal grounds for processing:
Consent.
Retention period:
3 years.
COMMUNICATION
Purpose of processing:
Correspondence on matters related to the organization’s activities through feedback forms on the Website, Social Media and Telegram/Viber/WhatsApp messengers.
Categories of personal data subjects:
Clients – Individuals and Individual Entrepreneurs.
Authorized representatives of Legal Entities.
Personal data processed:
First name, email address, telephone number, other personal data contained in the correspondence.
Legal grounds for processing:
1. Where an agreement is concluded and performed with an Individual or Individual Entrepreneur – paragraph 15 of Article 6 of the Law.
2. Where an agreement is concluded and performed with a Legal Entity – paragraph 8 of Article 6 of the Law (labor legislation, civil legislation).
Retention period:
Where an agreement is concluded – 3 years after completion of the correspondence.
Purpose of processing:
Consideration of citizens’ appeals, including comments and proposals entered in the Book of Comments and Proposals.
Categories of personal data subjects:
1. Persons who submitted an appeal.
2. Other persons whose personal data are specified in the appeal.
Personal data processed:
Full name, address of residence (place of stay), content of the appeal, other personal data specified in the appeal.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (legislation on appeals of citizens and legal entities).
Retention period:
5 years from the date of the most recent appeal.
5 years after completion of the Book of Comments and Proposals.
Purpose of processing:
Consideration of applications from personal data subjects in accordance with personal data legislation.
Categories of personal data subjects:
1. Persons who submitted an application.
2. Other persons whose personal data are specified in the application.
Personal data processed:
Data specified in Article 14 of the Law.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (personal data legislation).
Retention period:
1 year.
Purpose of processing:
Consideration of consumer applications.
Categories of personal data subjects:
Clients – Individuals.
Personal data processed:
Full name, address of residence (place of stay), content of the application, other personal data specified in the application.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (consumer protection legislation).
Retention period:
5 years from the date of the most recent application.
PERFORMANCE OF LEGALLY SIGNIFICANT OBLIGATIONS
Purpose of processing:
Maintenance of tax records (performance of tax and other obligations).
Categories of personal data subjects:
1. Employees and former employees.
2. Clients – Individuals and Individual Entrepreneurs; authorized persons of Legal Entities.
3. Contractors – Individuals and Individual Entrepreneurs; authorized representatives of Legal Entities.
4. Partners – Individuals and Individual Entrepreneurs; authorized representatives of Legal Entities.
Personal data processed:
Full name and other data required for completing primary accounting documents necessary for business transactions.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (accounting and reporting legislation).
Retention period:
Determined by the Operator in accordance with the retention periods established by legislation on archives and records management for the relevant processing of personal data.
Purpose of processing:
Recording and storage of documents in accordance with legislation governing archives and records management.
Categories of personal data subjects:
Persons whose information is contained in documents registered in the document-management records system.
Personal data processed:
Full name, employee position (worker’s occupation), other information contained in the registered document.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (legislation on archives and records management).
Retention period:
In accordance with the retention periods established by applicable legislation on archives and records management.
Purpose of processing:
Completion and submission of required reporting forms to state authorities and other authorized organizations.
Categories of personal data subjects:
Depending on the reporting form.
Personal data processed:
In accordance with the reporting form submitted.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law.
Retention period:
In accordance with the retention periods applicable to the relevant reporting and records under applicable legislation.
Purpose of processing:
Provision of information in response to requests from state authorities and other organizations.
Categories of personal data subjects:
Persons in respect of whom information is requested.
Personal data processed:
In accordance with the request received.
Legal grounds for processing:
1. Consent – where the personal data subject’s Consent is attached to the request.
2. Paragraph 20 of Article 6 of the Law, where processing is carried out for the performance of duties (powers) provided for by legislative acts.
Retention period:
In accordance with the retention periods applicable under the relevant legislation.
Purpose of processing:
Filing statements of claim, participation in court proceedings, enforcement proceedings.
Categories of personal data subjects:
Clients and counterparties of the organization (representatives of parties to an agreement authorized to sign the agreement and/or perform actions in connection with its performance; Individuals who are parties to a civil-law agreement).
Personal data processed:
For Individuals, including Individual Entrepreneurs: full name, telephone number, email address (optional), address of residence (place of registration).
For representatives of Legal Entities: full name, position, details from the document confirming authority.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (civil, civil procedural, commercial procedural legislation and legislation on enforcement proceedings).
Retention period:
In accordance with the retention periods established by the applicable legislation.
to the Personal Data Processing Policy
PURPOSES OF PERSONAL DATA PROCESSING
PERSONNEL RECRUITMENT
Purpose of processing:
Search for and evaluation of job applicants; communication with them.
Categories of personal data subjects:
Job applicants.
Personal data processed:
Personal data contained in resumes (questionnaires, autobiographies, personnel record forms, applications, letters of recommendation, etc.).
Legal grounds for processing:
1. With respect to personal data previously disseminated (for example, on the information portal of the state employment service or rabota.by) – paragraph 19 of Article 6 of the Law.
2. Where a resume is provided in writing or as an electronic document signed by the job applicant – paragraph 16 of Article 6 of the Law.
3. Where a resume is sent by email – Consent.
Retention period:
1. If employment is refused – no more than 1 year.
2. If the applicant is hired – 1 month.
3. Where processing is based on Consent – until Consent is withdrawn.
BUSINESS ACTIVITIES
(CONCLUSION AND PERFORMANCE OF CIVIL-LAW AGREEMENTS, ETC.)
Purpose of processing:
Conclusion of civil-law agreements for the provision of services in connection with the implementation of educational programs on a paid basis in simple written form, including on the basis of a public offer; performance and termination of such agreements.
Categories of personal data subjects:
Clients – Individuals and Individual Entrepreneurs.
Authorized representatives of Legal Entities.
Personal data processed:
With respect to a learner who is an Individual (Individual Entrepreneur) and/or payer: surname, first name, patronymic; registered address and/or actual residential address; personal identification number or, in its absence, identity-document details (series, if any; number; date of issue; name or code of the issuing authority); telephone number; email address; period of study; educational program; commencement date of the educational process; form of education; signature.
With respect to an employee of a Legal Entity or Individual Entrepreneur referred for training: surname, first name, patronymic; registered address and/or actual residential address; personal identification number or, in its absence, identity-document details (series, if any; number; date of issue; name or code of the issuing authority); telephone number; email address; signature.
With respect to an Individual Entrepreneur: surname, first name, patronymic; registered address of the Individual Entrepreneur; details of the certificate of state registration of the Individual Entrepreneur; bank details; surname, first name and patronymic of the person who signed the Agreement; details of the power of attorney where the Agreement is signed under a power of attorney.
Legal grounds for processing:
1. For Individuals and Individual Entrepreneurs – agreement (paragraph 15 of Article 6 of the Law).
2. For a representative of a Legal Entity – paragraph 8 of Article 6 of the Law (labor legislation, civil legislation).
Retention period:
3 years after an inspection by the tax authorities; if no inspection is conducted – 10 years after termination of the agreement.
Purpose of processing:
Submission of applications for entering into agreements for the provision of services in connection with the implementation of educational programs on a paid basis, as well as other types of civil-law agreements, through Social Media accounts, using https://bothelp.io/, using Telegram/Viber/WhatsApp messengers, and on the Website.
Categories of personal data subjects:
Potential clients.
Personal data processed:
First name, telephone number, email address, other information.
Legal grounds for processing:
1. For Individuals and Individual Entrepreneurs – agreement (paragraph 15 of Article 6 of the Law).
2. For a representative of a Legal Entity – paragraph 8 of Article 6 of the Law (labor legislation, civil legislation).
Retention period:
3 years after an inspection by the tax authorities; if no inspection is conducted – 10 years after termination of the agreement.
Purpose of processing:
Conclusion of civil-law agreements in simple written form, including on the basis of a public offer; performance and termination of such agreements.
Categories of personal data subjects:
Counterparties – Individuals and Individual Entrepreneurs.
Authorized representatives of counterparties that are Legal Entities.
Personal data processed:
1. For Individuals, including Individual Entrepreneurs: full name, registered address, email address, telephone number, payment-related information.
2. For representatives of Legal Entities: full name, position, business email address, business telephone number.
Legal grounds for processing:
1. For Individuals and Individual Entrepreneurs – agreement (paragraph 15 of Article 6 of the Law).
2. For representatives of Legal Entities – paragraph 8 of Article 6 of the Law (labor legislation, civil legislation).
Retention period:
3 years after an inspection by the tax authorities; if no inspection is conducted – 10 years after termination of the agreement.
Purpose of processing:
Conclusion, performance and termination of civil-law agreements related to the material and technical support of the organization’s activities (supply, sale and purchase, contracting, provision of services for consideration, etc.).
Categories of personal data subjects:
Counterparties – Individuals and Individual Entrepreneurs.
Authorized representatives of counterparties that are Legal Entities.
Personal data processed:
1. For Individuals, including Individual Entrepreneurs: full name, registered address, email address, telephone number, payment-related information.
2. For representatives of Legal Entities: full name, position, business email address, business telephone number.
Legal grounds for processing:
1. For Individuals and Individual Entrepreneurs – agreement (paragraph 15 of Article 6 of the Law).
2. For representatives of Legal Entities – paragraph 8 of Article 6 of the Law (labor legislation, civil legislation).
Retention period:
3 years after an inspection by the tax authorities; if no inspection is conducted – 10 years after termination of the agreement.
Purpose of processing:
Provision of services using Telegram.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Image (photo/video), a person’s voice, surname, first name, patronymic, Telegram username, mobile telephone number, other personal data communicated by the subject.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Provision of services using WhatsApp.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Image (photo/video), a person’s voice, surname, first name, patronymic, mobile telephone number, other personal data communicated by the subject.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Provision of services using https://www.zoom.com/ru.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Image (photo/video), a person’s voice, surname, first name, patronymic, other personal data communicated by the subject and obtained during the provision of services.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Provision of services using Google Meet.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Image (photo/video), a person’s voice, surname, first name, patronymic, other personal data communicated by the subject and obtained during the provision of services.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Provision of services using https://getcourse.ru/.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Image (photo/video), a person’s voice, surname, first name, patronymic, other personal data communicated by the subject and obtained during the provision of services.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
EDUCATIONAL ACTIVITIES
Purpose of processing:
Publication of information about learners on the Website.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic, other information.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law); paragraph 20 of Article 6 of the Law (education legislation).
Retention period:
For the term of the agreement.
Purpose of processing:
Organization and implementation of the provision of services (issuance of orders and instructions relating to the provision of services).
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic; number and date of the order; other information contained in the documents.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
10 years.
Purpose of processing:
Refund to the customer or payer of funds for services not received, as well as funds credited in error; notification of the customer thereof.
Categories of personal data subjects:
Customers (learners); payers.
Personal data processed:
Surname, first name, patronymic; telephone number; email address; bank details (card account number).
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
3 years after expiration of the Agreement and completion of an inspection by the tax authorities regarding compliance with tax legislation. If no such inspection is conducted – 10 years after expiration of the Agreement.
Purpose of processing:
Communication with customers to enable receipt of services by telephone and video communication, email and messengers.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic; email address; telephone number.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Creation and operation of communities/groups/chats for customers in messengers for receipt of services, provision/receipt of information and receipt of feedback.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic, username, telephone number.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Sending informational communications.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic, telephone number, Telegram username.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law).
Retention period:
For the term of the agreement.
Purpose of processing:
Maintaining the register for recording and issuing education documents.
Categories of personal data subjects:
Customers (learners); persons to whom an education document is issued under a power of attorney.
Personal data processed:
Registration number of the education document; series (if any) and number of the education-document form; surname, first name, patronymic (if any) of the learner; learner’s personal identification number; identity-document details (series, if any; number; date of issue; name of the state authority that issued it, where the education document is received under a power of attorney); profile (field of activity) in which the educational program is implemented, if any; number and date of the expulsion order; information on dispatch by post (receipt number and dispatch date) or issue under a power of attorney (number and date thereof); signature of the person receiving the education document, where received in person; other information.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (education legislation).
Retention period:
55 years.
Purpose of processing:
Issuance of a certificate of training.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic; period of education; name of the educational program; its topic, if any; number of hours; registration number.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law); paragraph 20 of Article 6 of the Law (education legislation).
Retention period:
Not retained.
Purpose of processing:
Sending education documents by post.
Categories of personal data subjects:
Customers (learners).
Personal data processed:
Surname, first name, patronymic; postal address.
Legal grounds for processing:
Agreement (paragraph 15 of Article 6 of the Law); paragraph 20 of Article 6 of the Law (education legislation).
Retention period:
Not retained.
MARKETING
(EVENTS, MAILINGS AND OTHER ACTIVITIES FOR THE PROMOTION OF GOODS, WORKS AND SERVICES)
Purpose of processing:
Publication of advertising information, as well as information as part of news content, through dissemination on Social Media pages and on the Website.
Categories of personal data subjects:
Persons who participated in the creation of advertising information or news content.
Personal data processed:
Surname, first name, patronymic, photographic and/or video image, social media profile data.
Legal grounds for processing:
Consent.
Retention period:
Until Consent is withdrawn.
Purpose of processing:
Generating and maintaining interest through dissemination of reviews on Social Media.
Categories of personal data subjects:
Persons who have submitted reviews.
Personal data processed:
Surname, first name, photographic image (if any), other information.
Legal grounds for processing:
1. With respect to personal data previously disseminated – paragraph 19 of Article 6 of the Law.
2. With respect to other personal data – Consent.
Retention period:
3 years.
Purpose of processing:
Sending advertising and informational communications.
Categories of personal data subjects:
Persons who have given Consent to receive advertising and informational communications.
Personal data processed:
Surname, first name, patronymic, mobile telephone number, email address, Telegram username, photographic image, other information communicated by the personal data subject.
Legal grounds for processing:
Consent.
Retention period:
3 years.
COMMUNICATION
Purpose of processing:
Correspondence on matters related to the organization’s activities through feedback forms on the Website, Social Media and Telegram/Viber/WhatsApp messengers.
Categories of personal data subjects:
Clients – Individuals and Individual Entrepreneurs.
Authorized representatives of Legal Entities.
Personal data processed:
First name, email address, telephone number, other personal data contained in the correspondence.
Legal grounds for processing:
1. Where an agreement is concluded and performed with an Individual or Individual Entrepreneur – paragraph 15 of Article 6 of the Law.
2. Where an agreement is concluded and performed with a Legal Entity – paragraph 8 of Article 6 of the Law (labor legislation, civil legislation).
Retention period:
Where an agreement is concluded – 3 years after completion of the correspondence.
Purpose of processing:
Consideration of citizens’ appeals, including comments and proposals entered in the Book of Comments and Proposals.
Categories of personal data subjects:
1. Persons who submitted an appeal.
2. Other persons whose personal data are specified in the appeal.
Personal data processed:
Full name, address of residence (place of stay), content of the appeal, other personal data specified in the appeal.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (legislation on appeals of citizens and legal entities).
Retention period:
5 years from the date of the most recent appeal.
5 years after completion of the Book of Comments and Proposals.
Purpose of processing:
Consideration of applications from personal data subjects in accordance with personal data legislation.
Categories of personal data subjects:
1. Persons who submitted an application.
2. Other persons whose personal data are specified in the application.
Personal data processed:
Data specified in Article 14 of the Law.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (personal data legislation).
Retention period:
1 year.
Purpose of processing:
Consideration of consumer applications.
Categories of personal data subjects:
Clients – Individuals.
Personal data processed:
Full name, address of residence (place of stay), content of the application, other personal data specified in the application.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (consumer protection legislation).
Retention period:
5 years from the date of the most recent application.
PERFORMANCE OF LEGALLY SIGNIFICANT OBLIGATIONS
Purpose of processing:
Maintenance of tax records (performance of tax and other obligations).
Categories of personal data subjects:
1. Employees and former employees.
2. Clients – Individuals and Individual Entrepreneurs; authorized persons of Legal Entities.
3. Contractors – Individuals and Individual Entrepreneurs; authorized representatives of Legal Entities.
4. Partners – Individuals and Individual Entrepreneurs; authorized representatives of Legal Entities.
Personal data processed:
Full name and other data required for completing primary accounting documents necessary for business transactions.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (accounting and reporting legislation).
Retention period:
Determined by the Operator in accordance with the retention periods established by legislation on archives and records management for the relevant processing of personal data.
Purpose of processing:
Recording and storage of documents in accordance with legislation governing archives and records management.
Categories of personal data subjects:
Persons whose information is contained in documents registered in the document-management records system.
Personal data processed:
Full name, employee position (worker’s occupation), other information contained in the registered document.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (legislation on archives and records management).
Retention period:
In accordance with the retention periods established by applicable legislation on archives and records management.
Purpose of processing:
Completion and submission of required reporting forms to state authorities and other authorized organizations.
Categories of personal data subjects:
Depending on the reporting form.
Personal data processed:
In accordance with the reporting form submitted.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law.
Retention period:
In accordance with the retention periods applicable to the relevant reporting and records under applicable legislation.
Purpose of processing:
Provision of information in response to requests from state authorities and other organizations.
Categories of personal data subjects:
Persons in respect of whom information is requested.
Personal data processed:
In accordance with the request received.
Legal grounds for processing:
1. Consent – where the personal data subject’s Consent is attached to the request.
2. Paragraph 20 of Article 6 of the Law, where processing is carried out for the performance of duties (powers) provided for by legislative acts.
Retention period:
In accordance with the retention periods applicable under the relevant legislation.
Purpose of processing:
Filing statements of claim, participation in court proceedings, enforcement proceedings.
Categories of personal data subjects:
Clients and counterparties of the organization (representatives of parties to an agreement authorized to sign the agreement and/or perform actions in connection with its performance; Individuals who are parties to a civil-law agreement).
Personal data processed:
For Individuals, including Individual Entrepreneurs: full name, telephone number, email address (optional), address of residence (place of registration).
For representatives of Legal Entities: full name, position, details from the document confirming authority.
Legal grounds for processing:
Paragraph 20 of Article 6 of the Law (civil, civil procedural, commercial procedural legislation and legislation on enforcement proceedings).
Retention period:
In accordance with the retention periods established by the applicable legislation.
Operating hours
- Mon-Fri, 10:00-17:00
- info@powerful.by
Legal information
DETAILS
Individual Entrepreneur Volha Charkasava
Taxpayer Identification Number (UNP) 193451430,
The license issued by the Minsk City Executive Committee on July 30, 2020.
Taxpayer Identification Number (UNP) 193451430,
The license issued by the Minsk City Executive Committee on July 30, 2020.