1. General Provisions1.1. This Personal Data Processing Policy (hereinafter — Policy) is prepared in accordance with the Law of the Republic of Belarus of May 7, 2021 No. 99-Z “On the Protection of Personal Data” (hereinafter — the Law) and defines the procedure for processing and protecting personal data by Sole Proprietor Daniela Denisovna Bauer (hereinafter — the Operator).
1.2. The purpose of this Policy is to ensure the protection of the rights and freedoms of individuals when processing their personal data, including the protection of the right to privacy and family secrecy.
1.3. This Policy applies to all information that the Operator may obtain about visitors to the website https://poda.by (hereinafter — the Website).
2. Key TermsTerms used herein are based on the Law of the Republic of Belarus No. 99-Z:

• Personal data — any information relating to an identified or identifiable natural person.
• Processing of personal data — any operation or set of operations performed on personal data, including collection, storage, modification, use, provision, anonymization, destruction.
• Operator — a natural or legal person who independently or jointly with others organizes and/or processes personal data.
• Data subject — an individual to whom the personal data relates.
• Consent of the data subject — a voluntary, specific, informed, and unambiguous indication of the data subject's will to allow the processing of their personal data.

3. Principles of Personal Data ProcessingThe Operator processes personal data based on the following principles:

• Lawfulness, fairness, and transparency;
• Data minimization;
• Accuracy and data relevance;
• Limited data retention;
• Security of personal data;
• Respect for data subject rights.

4. Rights of the Data SubjectThe data subject has the right to:

• Receive information about the processing of their personal data;
• Request the correction, blocking, or deletion of inaccurate or excessive data;
• Withdraw consent to data processing;
• Appeal to the National Center for Personal Data Protection of the Republic of Belarus or to the court;
• Exercise other rights as provided by Belarusian law.

5. Rights and Obligations of the OperatorThe Operator shall:

• Ensure the lawful processing of personal data;
• Develop and implement measures to protect personal data;
• Provide information to the data subject upon request;
• Notify the authorized body in the event of a data breach;
• Comply with the provisions of Belarusian legislation.

6. Purpose of Personal Data ProcessingThe Operator processes personal data for the following purposes:

• Conclusion and execution of contracts;
• Provision of services;
• Feedback communication;
• Sending informational messages;
• Compliance with legal obligations.

Data processed may include:
Full name, phone number, email address.
7. Legal Grounds for ProcessingThe Operator processes personal data on the following legal grounds:

• Consent of the data subject;
• Conclusion and execution of a contract;
• Compliance with legal obligations;
• Legitimate interests of the Operator, provided that the rights of the data subject are not violated.

8. Data Collection, Storage, Transmission, and Deletion8.1. Personal data is collected through online forms or via email.
8.2. Data is stored in a manner that allows identification of the data subject, for no longer than necessary for the purposes of processing.
8.3. Data may be transferred to third parties only:

• With the consent of the data subject;
• As required by government authorities;
• Under a contract, for the performance of obligations.

8.4. Personal data is destroyed upon achievement of processing purposes, withdrawal of consent, or at the data subject’s request, unless legal grounds for further processing exist.
9. Data Protection MeasuresThe Operator implements necessary organizational and technical measures to ensure the protection of personal data from unlawful access, alteration, disclosure, or destruction, including:

• Access control;
• Anti-virus protection;
• Data backup;
• Internal policies and training.

10. Cross-Border Data TransferCross-border transfer of personal data may occur only if:

• The data subject has provided consent; or
• The recipient country ensures adequate protection of personal data, in accordance with the list approved by the National Center for Personal Data Protection of the Republic of Belarus.

11. ConfidentialityPersons who have access to personal data must not disclose or disseminate such data without the consent of the data subject, unless otherwise required by law.
12. Final Provisions12.1. Users may contact the Operator for any questions regarding their personal data via email: souls.minsk@gmail.com.
12.2. This Policy is valid indefinitely until replaced by a new version.
12.3. The current version of the Policy is publicly available at:
https://poda.by/politics

• ⚖️ Legal References:Law of the Republic of Belarus No. 99-Z of May 7, 2021 “On the Protection of Personal Data”
• National Center for Personal Data Protection: https://www.pd.gov.by