PERSONAL DATA PROCESSING POLICY
Individual Entrepreneur Volha Charkasava
Minsk
24 June 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 of 7 May 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 basis their personal data are collected, used, or otherwise processed. It also sets out the rights of personal data subjects in connection with such processing and the procedure for exercising those rights.
This Policy does not apply to the processing of personal data in connection with the use of cookies on the Operator’s website.
1.3. Operator’s contact details:
Location: Apt. 51, Bldg. 1, 43 Yesenina St., Minsk.
Email: info@powerful.by.
Phone: +375295662488.
Website: https://powerful.by/.
1.4. The terms and definitions used in this Policy have the meanings assigned to them by the Law.
1.5. The following abbreviations are used in this Policy:
Operator — Individual Entrepreneur Volha Charkasava;
Full name — surname, first name, and patronymic, if any;
Individual — a natural person;
Legal entity — a legal entity;
IE — individual entrepreneur;
Consent — consent to the processing of personal data;
Social media — the Operator’s pages on social networks and platforms:
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 PERSONAL DATA PROCESSING
2.1. Personal data are processed both with and without the use of automated means by way of 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 retention periods is set out in Appendix 1 to this Policy.
2.3. The Operator disseminates personal data in the following cases:
2.3.1. Surname, first name, photo and/or video image, social media profile data, and other information may be disseminated for the purpose of generating and maintaining interest by posting 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 made public by the personal data subject) or on the basis of consent.
2.3.2. Surname, first name, other information, photo and/or video image, social media page/blog address, and other information may be disseminated for the purpose of posting advertising information and news content on Social Media pages and/or on the Website, on the basis of consent.
2.4. Retention periods for personal data are determined in accordance with legislation on archiving and records management.
Upon expiry of the established retention periods, documents containing personal data are destroyed in accordance with the procedure established by legislation on archiving and records management, and personal data contained in the Operator’s information systems and resources are deleted.
3. AUTHORIZED PERSONS
3.1. In the course of 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 Article 7 of the Law.
To ensure that personal data processed by authorized persons are protected at a level no lower than that provided by the Operator, the Operator:
— periodically monitors authorized persons’ compliance with measures aimed at protecting the rights of personal data subjects when processing personal data on behalf of the Operator;
— does not authorize authorized persons to engage sub-authorized persons / permits authorized persons to engage sub-authorized persons only subject to the Operator’s prior written permission / written notification to the Operator.
3.3. List of the Operator’s authorized persons involved in personal data processing in the course of business activities:
Authorized person: Tilda Publishing Bel LLC
Location: Office 307, 71 Lenina St., Baranovichi, Brest Region, 225404
Privacy policy: https://tilda.by/ru/privacy/
Reason for processing: Use of the https://tilda.by/ platform for the creation and operation of the Website through remote access.
Actions with personal data: storage, access, and use for incident resolution; deletion upon termination of the contractual relationship.
Authorized person: Nadezhnye Programmy LLC
Location: 4th Floor, Block 1, 8 Aranskaya St., Minsk, 220006
Privacy policy: https://hoster.by/downloads/pd_processing-policy.pdf
Reason for processing: Ensuring the availability of the Website on the Internet.
Actions with personal data: storage, access, and use for incident resolution; deletion upon termination of the contractual relationship.
Authorized person: Telegram Messenger Inc.
Location: Geneva Place, Waterfront Drive, Tortola VG1110, British Virgin Islands
Privacy policy: https://telegram.org/privacy/by
Reason for processing: Provision of services using Telegram.
Actions with personal data: collection, systematization, storage, use, provision, and deletion of personal data.
Authorized person: Sistema Getcourse LLC
Location: Premises 1122, Bldg. 1, 42 Bolshoy Boulevard, Skolkovo Innovation Center, Moscow
Privacy policy: https://getcourse.ru/privacy_policy
Reason for processing: Use of the https://getcourse.ru/ service for educational activities and for sending promotional and informational mailings.
Actions with personal data: storage, access, and use for incident resolution; deletion upon termination of the contractual relationship.
Authorized person: Zoom Video Communications, Inc.
Location: 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113
Privacy policy: https://www.zoom.com/en/trust/privacy/privacy-statement/
Reason for processing: Use of the https://www.zoom.com/ service for the provision of services.
Actions with personal data: storage, access, and use for incident resolution; deletion upon termination of the contractual relationship.
Authorized person: Bothelp LLC
Location: Office 404, 65 Duki St., Bryansk, Russian Federation, 241050
Privacy policy: https://bothelp.io/ru/policy
Reason for processing: Use of the https://bothelp.io/ service for submitting applications to conclude a contract and for sending promotional and informational mailings.
Actions with personal data: storage, access, and use for incident resolution; deletion upon termination of the contractual relationship.
3.4. The Operator provides personal data to other persons for the purposes set out in Appendix 1, including to RUE “Belpochta” for 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. Posting advertising information and news content on Social Media pages: surname, first name, other information, photo and/or video image, social media page/blog address, 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; and Google, Inc., 1600 Amphitheatre Parkway, Mountain View, California 94043, USA.
4.1.2. Posting reviews of the Operator’s activities on Social Media pages: surname, first name, photo and/or video image, social media profile data, and other information are transferred to Meta Platforms, Inc., 1601 Willow Road, Menlo Park, CA 94025, USA.
4.1.3. Provision of services using https://www.zoom.com/ru: image (photo/video), voice, surname, first name, patronymic, and other personal data provided by the data subject and obtained during the provision of services are transferred to Zoom Video Communications, Inc., 55 Almaden Boulevard, 6th Floor, San Jose, CA 95113.
4.1.4. Provision of services using Telegram: image (photo/video), voice, surname, first name, patronymic, Telegram username, mobile phone number, and other personal data provided by the data subject are transferred to Telegram Messenger Inc., Geneva Place, Waterfront Drive, Tortola VG1110, British Virgin Islands.
4.1.5. Submission of an application to conclude a contract: surname, first name, patronymic, mobile phone number, Telegram username, and other information are transferred to Bothelp LLC, Office 404, 65 Duki St., Bryansk, Russian Federation, 241050.
4.1.6. Sending promotional and informational mailings: surname, first name, patronymic, mobile phone number, Telegram username, photo image, and other information specified in the Telegram account are transferred to Bothelp LLC, Office 404, 65 Duki St., Bryansk, Russian Federation, 241050.
4.1.7. Provision of services using https://getcourse.ru/: image (photo/video), voice, surname, first name, patronymic, and other personal data provided by the data subject and obtained during the provision of services are transferred to Sistema Getcourse LLC, Premises 1122, Bldg. 1, 42 Bolshoy Boulevard, Skolkovo Innovation Center, Moscow.
4.2. In the cases of cross-border transfer of personal data specified in clauses 4.1.5–4.1.7 of this Policy, personal data are transferred to foreign states that ensure an adequate level of protection of the rights of personal data subjects.
In the case of cross-border transfer of personal data specified in clause 4.1.5 of this Policy, the personal data subject may, at their discretion and in order to avoid such cross-border transfer, use alternative methods of contacting the Operator to submit an application to conclude a contract: by telephone, through feedback forms on the Website, or by visiting the Operator’s location in person.
In the cases of cross-border transfer of personal data specified in clauses 4.1.1–4.1.4, personal data are transferred to 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 specific state to which the cross-border transfer of personal data is made, there is a possibility that such state may not provide the conditions necessary to ensure 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 transfer of personal data:
— absence of personal data legislation;
— classification of only a limited scope of information about an individual as personal data;
— absence of an authorized body for the protection of the rights of personal data subjects;
— limited list of rights, or absence of rights, of personal data subjects;
— other possible risks of infringement of the rights of personal data subjects arising in connection with cross-border transfer of personal data.
4.3. The Operator may carry out cross-border transfer of personal data when personal data subjects use the social network Instagram and the Telegram/Viber/WhatsApp messengers to communicate with the Operator, including for communication with clients to ensure the provision of services by telephone, video calls, email, and messengers; for creating and operating client communities, groups, or chats in messengers for receiving services, exchanging information, and obtaining feedback; and for sending informational mailings.
In such cases, the purpose of the cross-border transfer of personal data is to respond to inquiries from the personal data subject, ensure prompt communication between the Operator and the personal data subject, and properly provide services.
In the situation described above, because data transmission servers are beyond the Operator’s control, the Operator cannot guarantee that the personal data of the data subject will be transferred exclusively to foreign countries that ensure an adequate level of protection of the rights of personal data subjects.
Since it is not possible to determine the specific state to which the cross-border transfer of personal data is made, there is a possibility that such state may not provide the conditions necessary to ensure 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 transfer of personal data:
— absence of personal data legislation;
— classification of only a limited scope of information about an individual as personal data;
— absence of an authorized body for the protection of the rights of personal data subjects;
— limited list of rights, or absence of rights, of personal data subjects;
— other possible risks of infringement of the rights of personal data subjects arising in connection with cross-border transfer of personal data.
The personal data subject may, at their discretion and in order to avoid cross-border transfer of personal data, use alternative methods of communication with the Operator: telephone communication or a personal visit to the Operator’s location.
5. RIGHTS OF PERSONAL DATA SUBJECTS
5.1. The personal data subject has the right to withdraw their consent to the processing of personal data.
Operator’s obligation: within 15 days, the Operator shall cease the processing and notify the personal data subject.
Note: consent may be withdrawn at any time without giving reasons, except where personal data are processed on a legal basis other than consent.
5.2. The personal data subject has the right to receive 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 legislation.
Operator’s obligation: within 5 business days, the Operator shall provide the information in an accessible form or notify the personal data subject of the reasons for refusal.
Note: the personal data subject is not required to justify their interest in the requested information.
5.3. The personal data subject has the right to request changes to their personal data.
Operator’s obligation: within 15 days, the Operator shall make the relevant changes and notify the personal data subject, or notify them of the reasons for refusing to make such changes.
Note: this right applies where the personal data are incomplete, outdated, or inaccurate. Documents or information confirming the need for the changes must be submitted together with the request.
5.4. The personal data subject has the right to receive information about the provision of their personal data to third parties.
Operator’s obligation: within 15 days, the Operator shall provide information on which personal data of the subject were provided and to whom during the year preceding the date of submission of the request, or notify the personal data subject of the reasons for refusal.
Note: this information is provided free of charge once per calendar year.
5.5. The personal data subject has the right to request the free-of-charge cessation of the processing of their personal data, including deletion.
Operator’s obligation: within 15 days, the Operator shall cease the processing of personal data, delete or block such data, and notify the personal data subject.
Note: this right applies where there are no grounds for processing personal data.
5.6. The personal data subject has the right to appeal against the actions of the Operator.
Appeals are made to the courts in accordance with civil procedural legislation.
The personal data subject also has the right to contact the regulator:
National Center for Personal Data Protection of the Republic of Belarus
24-3 K. Zetkin St., Minsk, 220004
+375 (17) 367-07-90
info@cpd.by
If you have concerns that we are violating your rights in any way, please contact us. Direct interaction with data subjects helps us improve the protection of your rights and interests.
5.7. To exercise the rights marked above, the personal data subject shall submit a written request to the Operator at the following address: Individual Entrepreneur Volha Charkasava, Apt. 51, Bldg. 1, 43 Yesenina St., Minsk, or submit it in the form of an electronic document by email to info@powerful.by.
Legislative acts may require the personal presence of the personal data subject and the 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 address 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, where this information was provided 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;
— a statement of the essence of the personal data subject’s requirements;
— the personal signature or electronic digital signature of the personal data subject.
Unless otherwise established by legislative acts, the time limits for 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: Apt. 51, Bldg. 1, 43 Yesenina St., Minsk.
APPENDIX 1
TO THE PERSONAL DATA PROCESSING POLICY
PURPOSES OF PERSONAL DATA PROCESSING, CATEGORIES OF DATA SUBJECTS, LIST OF PERSONAL DATA PROCESSED, LEGAL GROUNDS, AND RETENTION PERIODS
A. PERSONNEL RECRUITMENT
A.1. Search for and evaluation of job applicants; communication with them
Categories of data subjects: job applicants.
Personal data processed: personal data contained in resumes, application forms, autobiographies, personnel records, applications, letters of recommendation, and similar documents.
Legal grounds:
1. For personal data previously disseminated, for example on the state employment service portal or rabota.by — paragraph 19 of Article 6 of the Law.
2. Where a resume is submitted in writing or in the form of 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. In the event of refusal of employment — no more than 1 year.
2. In the event of hiring — 1 month.
3. Until withdrawal of consent.
B. BUSINESS ACTIVITIES
(CONCLUSION AND PERFORMANCE OF CIVIL LAW CONTRACTS, ETC.)
B.1. Conclusion, performance, and termination of civil law contracts for the provision of services under a fee-based educational program in simple written form, including on the basis of a public offer
Categories of data subjects: clients — individuals and individual entrepreneurs; authorized representatives of legal entities.
Personal data processed:
For the student who is an individual or individual entrepreneur, and for the payer: surname, first name, patronymic; registered address and/or actual residential address; identification number, or, if absent, details of the identity document (series, if any; number; date of issue; name or code of the issuing authority); phone number; email address; duration of training; educational program; start date of the educational process; form of education; signature.
For an employee of a legal entity or individual entrepreneur sent for training: surname, first name, patronymic; registered address and/or actual residential address; identification number, or, if absent, details of the identity document (series, if any; number; date of issue; name or code of the issuing authority); phone number; email address; signature; surname, first name, and patronymic of the individual entrepreneur; registered address of the individual entrepreneur; details of the individual entrepreneur’s registration certificate; bank details; surname, first name, and patronymic of the person signing the contract; details of the power of attorney, if the contract is signed under a power of attorney.
Legal grounds:
1. For individuals and individual entrepreneurs — contract, 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 a tax audit; if no audit was conducted, 10 years after termination of the contract.
B.2. Submission of applications to conclude a contract for the provision of services under fee-based educational programs, as well as other types of civil law contracts, through Social Media accounts, using https://bothelp.io/, using Telegram/Viber/WhatsApp messengers, and on the Website
Categories of data subjects: potential clients.
Personal data processed: name, phone number, email address, and other information.
Legal grounds:
1. For individuals and individual entrepreneurs — contract, 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 a tax audit; if no audit was conducted, 10 years after termination of the contract.
B.3. Conclusion, performance, and termination of civil law contracts in simple written form, including on the basis of a public offer
Categories of 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, phone number, payment-related information.
2. For representatives of legal entities: full name, position, work email address, work phone number.
Legal grounds:
1. For individuals and individual entrepreneurs — contract, 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 a tax audit; if no audit was conducted, 10 years after termination of the contract.
B.4. Conclusion, performance, and termination of civil law contracts related to material and technical support of the organization’s activities, including supply, sale and purchase, contracting, and paid services
Categories of 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, phone number, payment-related information.
2. For representatives of legal entities: full name, position, work email address, work phone number.
Legal grounds:
1. For individuals and individual entrepreneurs — contract, 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 a tax audit; if no audit was conducted, 10 years after termination of the contract.
B.5. Provision of services using Telegram
Categories of data subjects: clients/students.
Personal data processed: image (photo/video), voice, surname, first name, patronymic, Telegram username, mobile phone number, and other personal data provided by the data subject.
Legal ground: contract, paragraph 15 of Article 6 of the Law.
Retention period: for the term of the contract.
B.6. Provision of services using https://www.zoom.com/ru
Categories of data subjects: clients/students.
Personal data processed: image (photo/video), voice, surname, first name, patronymic, and other personal data provided by the data subject and obtained during the provision of services.
Legal ground: contract, paragraph 15 of Article 6 of the Law.
Retention period: for the term of the contract.
B.7. Provision of services using https://getcourse.ru/
Categories of data subjects: clients/students.
Personal data processed: image (photo/video), voice, surname, first name, patronymic, and other personal data provided by the data subject and obtained during the provision of services.
Legal ground: contract, paragraph 15 of Article 6 of the Law.
Retention period: for the term of the contract.
C. EDUCATIONAL ACTIVITIES
C.1. Posting information about students on the Website
Categories of data subjects: clients/students.
Personal data processed: surname, first name, patronymic, and other information.
Legal grounds: contract, 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 contract.
C.2. Organization and implementation of service provision, including issuing orders and instructions concerning the provision of services
Categories of data subjects: clients/students.
Personal data processed: surname, first name, patronymic; order number and date; other information contained in documents.
Legal ground: contract, paragraph 15 of Article 6 of the Law.
Retention period: 10 years.
C.3. Refund of funds to the client or payer for services not received, as well as refund of funds credited in error; notification of the client thereof
Categories of data subjects: clients/students; payers.
Personal data processed: surname, first name, patronymic; phone number; email address; bank details/card account number.
Legal ground: contract, paragraph 15 of Article 6 of the Law.
Retention period: 3 years after expiry of the contract and completion of a tax compliance audit by tax authorities; if no such audit was conducted, 10 years after expiry of the contract.
C.4. Communication with clients to ensure the provision of services by telephone, video calls, email, and messengers
Categories of data subjects: clients/students.
Personal data processed: surname, first name, patronymic; email address; phone number.
Legal ground: contract, paragraph 15 of Article 6 of the Law.
Retention period: for the term of the contract.
C.5. Creation and operation of client communities, groups, and chats in messengers for receiving services, exchanging information, and obtaining feedback
Categories of data subjects: clients/students.
Personal data processed: surname, first name, patronymic; nickname; phone number.
Legal ground: contract, paragraph 15 of Article 6 of the Law.
Retention period: for the term of the contract.
C.6. Sending informational mailings
Categories of data subjects: clients/students.
Personal data processed: surname, first name, patronymic; phone number; Telegram username.
Legal ground: contract, paragraph 15 of Article 6 of the Law.
Retention period: for the term of the contract.
C.7. Maintaining the register for recording and issuing training documents
Categories of data subjects: clients/students; persons receiving a training document under a power of attorney.
Personal data processed: registration number of the training document; series, if any, and form number of the training document; surname, first name, and patronymic, if any, of the student; student identification number; details of the identity document (series, if any; number; date of issue; name of the issuing state authority) where the educational document is received under a power of attorney; profile/field of activity of the educational program, if any; number and date of the expulsion order; mailing details (receipt number and dispatch date) or details of issuance under a power of attorney (number and date of execution); signature of the person receiving the training document, if received in person; other information.
Legal ground: paragraph 20 of Article 6 of the Law (education legislation).
Retention period: 55 years.
C.8. Issuance of a training certificate
Categories of data subjects: clients/students.
Personal data processed: surname, first name, patronymic; period of education; name of the educational program; topic, if any; number of hours; registration number.
Legal grounds: contract, paragraph 15 of Article 6 of the Law; paragraph 20 of Article 6 of the Law (education legislation).
Retention period: not retained.
C.9. Mailing of training documents
Categories of data subjects: clients/students.
Personal data processed: surname, first name, patronymic; postal address.
Legal grounds: contract, paragraph 15 of Article 6 of the Law; paragraph 20 of Article 6 of the Law (education legislation).
Retention period: not retained.
D. MARKETING
(EVENTS, MAILINGS, AND OTHER ACTIVITIES PROMOTING GOODS, WORKS, AND SERVICES)
D.1. Posting advertising information and news content on Social Media pages and on the Website
Categories of data subjects: persons who participated in creating advertising information or news content.
Personal data processed: surname, first name, patronymic; photo and/or video image; social media profile data.
Legal ground: consent.
Retention period: until withdrawal of consent.
D.2. Generating and maintaining interest by posting reviews on Social Media
Categories of data subjects: persons who left reviews.
Personal data processed: surname, first name, photo image, if available, and other information.
Legal grounds:
1. For personal data previously disseminated — paragraph 19 of Article 6 of the Law.
2. For other personal data — consent.
Retention period: 3 years.
D.3. Sending promotional and informational mailings
Categories of data subjects: persons who consented to receive promotional and informational mailings.
Personal data processed: surname, first name, patronymic; mobile phone number; Telegram username; photo image; other information specified in the Telegram account.
Legal ground: consent.
Retention period: 3 years.
E. COMMUNICATION
E.1. Correspondence regarding the organization’s activities through Website feedback forms, Social Media, and Telegram/Viber/WhatsApp messengers
Categories of data subjects: clients — individuals and individual entrepreneurs; authorized representatives of legal entities.
Personal data processed: name, email address, phone number, and other personal data specified in the correspondence.
Legal grounds:
1. Where a contract is concluded and performed with an individual or individual entrepreneur — paragraph 15 of Article 6 of the Law.
2. Where a contract is concluded and performed with a legal entity — paragraph 8 of Article 6 of the Law (labor legislation, civil legislation).
Retention period: where a contract is concluded, 3 years after the correspondence ends.
E.2. Review of citizens’ inquiries, including comments and suggestions entered in the book of comments and suggestions
Categories of data subjects: persons who submitted an inquiry; other persons whose personal data are specified in the inquiry.
Personal data processed: full name, residential address/address of stay, content of the inquiry, and other personal data specified in the inquiry.
Legal ground: paragraph 20 of Article 6 of the Law (legislation on inquiries from citizens and legal entities).
Retention period: 5 years from the date of the last inquiry; 5 years after the book of comments and suggestions is no longer maintained.
E.3. Review of requests from personal data subjects in accordance with personal data legislation
Categories of data subjects: persons who submitted an inquiry; other persons whose personal data are specified in the inquiry.
Personal data processed: data specified in Article 14 of the Law.
Legal ground: paragraph 20 of Article 6 of the Law (personal data legislation).
Retention period: 1 year.
E.4. Review of consumer claims and requests
Categories of data subjects: clients who are individuals.
Personal data processed: full name, residential address/address of stay, content of the inquiry, and other personal data specified in the inquiry.
Legal ground: paragraph 20 of Article 6 of the Law (consumer protection legislation).
Retention period: 5 years from the date of the last contact.
F. PERFORMANCE OF LEGALLY SIGNIFICANT OBLIGATIONS
F.1. Tax accounting, including fulfillment of tax and other obligations
Categories of data subjects: employees and former employees; clients who are individuals and individual entrepreneurs; authorized persons of legal entities; contractors who are individuals and individual entrepreneurs; authorized representatives of legal entities; partners who are individuals and individual entrepreneurs; authorized representatives of legal entities.
Personal data processed: full name and other data required to complete primary accounting documents necessary for business transactions.
Legal ground: paragraph 20 of Article 6 of the Law (accounting and financial reporting legislation).
Retention period: determined by the Operator in accordance with the time limits established by legislation on archiving and records management for the relevant processing of personal data.
F.2. Record-keeping and storage of documents in accordance with legislation on archiving and records management
Categories of data subjects: persons whose information is contained in documents registered in the document management system.
Personal data processed: full name, employee position/worker’s profession, and other information contained in the registered document.
Legal ground: paragraph 20 of Article 6 of the Law (legislation on archiving and records management).
Retention period: determined by the Operator in accordance with the time limits established by legislation on archiving and records management for the relevant processing of personal data.
F.3. Completion and submission of required reporting forms to government bodies and other authorized organizations
Categories of data subjects: depending on the reporting form.
Personal data processed: in accordance with the reporting form submitted.
Legal ground: paragraph 20 of Article 6 of the Law.
Retention period: determined by the Operator in accordance with the time limits established by legislation on archiving and records management for the relevant processing of personal data.
F.4. Provision of information in response to requests from government bodies and other organizations
Categories of data subjects: persons in respect of whom information is requested.
Personal data processed: in accordance with the received request.
Legal grounds:
1. Consent — if 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 to perform duties or powers provided for by legislative acts.
Retention period: determined by the Operator in accordance with the time limits established by legislation on archiving and records management for the relevant processing of personal data.
F.5. Filing lawsuits, participation in court proceedings, and enforcement proceedings
Categories of data subjects: clients and counterparties of the organization, including representatives of parties to a contract authorized to sign the contract and/or perform actions for its execution, and individuals who are parties to a civil law contract.
Personal data processed:
For individuals, including individual entrepreneurs: full name, phone number, email address, if available, residential/registered address.
For representatives of legal entities: full name, position, and details from the document confirming authority.
Legal ground: paragraph 20 of Article 6 of the Law (civil legislation, civil procedural legislation, economic procedural legislation, legislation on enforcement proceedings).
Retention period: determined by the Operator in accordance with the time limits established by legislation on archiving and records management for the relevant processing of personal data.