Processing of Personal Data
Last Updated: January 31, 2024
1.1. This Personal Data Processing Policy (hereinafter referred to as the Policy):
1.1.1. Defines the activities of the Limited Liability Company “MotoVeloZavod”, located at: Republic of Belarus, Minsk, Partizansky Ave, 8, bldg. 3, room 5 (hereinafter referred to as the Seller or Operator) regarding the processing of personal data, aimed at ensuring the protection of personal data, rights, and freedoms of individuals when processing their personal data;
1.1.2. Applies to relationships related to the processing of personal data by LLC “MotoVeloZavod”:
1.1.3. Applies to all personal data processed by the Operator within the relationships mentioned in clause 1.1.2;
1.1.4. Developed in accordance with the current legislation of the Republic of Belarus, including Presidential Decree of the Republic of Belarus No. 422 “On Measures to Improve the Protection of Personal Data” dated October 28, 2021, Law of the Republic of Belarus No. 99-Z “On the Protection of Personal Data” dated May 7, 2021, Law No. 455-Z “On Information, Informatization and Protection of Information” dated November 10, 2008, and other regulatory legal acts governing the activities of the Operator;
1.1.5. Published in open access on the information and telecommunication network Internet on the Site, as well as available in the stores of www.aist-bike.by;
1.1.6. Effective from the moment of its approval.
STORAGE PERIOD OF PERSONAL DATA
2.1. The legal basis for the processing of personal data is the consent of the personal data subject, except in cases established by the legislation of the Republic of Belarus when the processing of personal data is carried out without such consent and is based on other legal grounds.
2.2. The content and scope of personal data are determined by the necessity to achieve specific processing purposes, as well as the need for the Operator to exercise its rights and obligations, as well as the rights and obligations of the corresponding subject.
2.3. The Operator may process the following personal data for established purposes:
Purpose | Processed Personal Data | Basis | Retention Period | |
2.3.1. | Conclusion, performance, amendment, and termination of the contract with clients | Last name, first name, patronymic (optional); phone number; email address (optional); delivery address (optional); residential address (optional); bank details (optional); recording of telephone conversation (optional); other data provided by the client (or their representative) during the conclusion and execution of the contract. | Contract (Clause 15, Article 6 of the Law of the Republic of Belarus No. 99-Z “On the Protection of Personal Data” dated May 7, 2021) | 3 years after the expiration of the contract, or 10 years after the expiration of the contract if tax authorities do not conduct a tax compliance audit — Clause 70 of the Resolution of the Ministry of Justice of the Republic of Belarus No. 140 “On the List of Typical Documents” dated May 24, 2012 (hereinafter referred to as the List) |
2.3.2 | To create and use a personal account on the Site and/or in the application (adding items to favorites, creating a shopping list, etc.), identification of the subject | Email address | Contract (Clause 15, Article 6 of the Law of the Republic of Belarus No. 99-Z “On the Protection of Personal Data” dated May 7, 2021) | 3 years from the date of the subject’s last login to the personal account |
2.3.3 | To store personal data in the personal account, analyze data | Last name, first name, patronymic (optional); phone number (optional); delivery address (optional); date of birth (optional); gender (optional); order list | Consent Retention | 3 years from the moment of obtaining consent |
2.3.4. | To process an application on the Site for attracting bank funds for purchase, providing installment plans for purchases | Last name, first name, patronymic; phone number | Consent Retention | 3 years from the moment of obtaining consent |
2.3.5. | To receive information about the order, delivery of goods to the pickup point via electronic communication, SMS, Viber, E-mail, and other communication means; for delivery of goods to the customer’s address | Name (optional); email address and/or phone number; delivery address (optional) | Contract (Clause 15, Article 6 of the Law of the Republic of Belarus No. 99-Z “On the Protection of Personal Data” dated May 7, 2021) | 3 years after the expiration of the contract, or 10 years after the expiration of the contract if tax authorities do not conduct a tax compliance audit — Clause 70 of the List |
2.3.6. | To receive information on the availability of goods in stock, price reductions via electronic communication, SMS, Viber, E-mail, and other communication means | Name; email address; phone number (optional) | Contract (Clause 15, Article 6 of the Law of the Republic of Belarus No. 99-Z “On the Protection of Personal Data” dated May 7, 2021) | 3 years — Clause 71 of the List |
2.3.7. | To conduct marketing, advertising, news mailings, data analysis | Last name, first name, patronymic (optional); phone number and/or email address (optional); order list | Consent Retention | 3 years from the moment of obtaining consent |
2.3.8. | To conduct marketing and/or advertising activities (promotions, contests, games, and other events), identification of the personal data subject, data analysis | Last name, first name, patronymic (optional); passport data (optional); phone number; email address; date of birth | Consent Retention | 3 years from the moment of obtaining consent |
2.3.9. | To establish feedback with the user of the Site, application www.aist-bike.by, via feedback form (contact management; suggest an idea; request a callback; ask a question) | Name; phone number; email address | Consent Retention | 3 years from the moment of obtaining consent |
2.3.10 | To review, publish, and analyze reviews, and the “question-answer” form on the Site | Name, patronymic (optional); email address (optional); contact phone number (optional) | Consent Retention | 3 years from the moment of obtaining consent |
2.3.11. | To review an application for employment, internships, practice, maintaining a personnel reserve | Last name (optional), patronymic (optional), first name; phone number; other data specified by the subject in the application form | Consent or Clause 16, Article 6 of the Law of the Republic of Belarus No. 99-Z “On the Protection of Personal Data” (when submitting an application form in writing or as an electronic document) | 1 year from the moment of application If not hired, 1 year from the moment of receiving the resume (application form) according to Clause 680 of the List |
2.3.12 | To review complaints, including those recorded in the book of comments and suggestions | Last name, first name, patronymic (or initials); residential address (temporary residence); content of the complaint; other personal data specified by the subject in the complaint | Fulfillment of duties (powers) provided by legislative acts (Clause 20, Article 6, and Clause 16, Item 2, Article 8 of the Law of the Republic of Belarus No. 99-Z “On the Protection of Personal Data”, Clause 1, Article 3 of the Law of the Republic of Belarus “On Appeals of Citizens and Legal Entities”) | 5 years from the date of the last complaint; 5 years after the end of keeping the book of comments and suggestions — Clause 89 of the List |
2.3.13 | For the purpose of video surveillance at order pickup points to ensure public order, protect individuals and property of LLC “MVZ” | Video images of the personal data subject | Video Surveillance System Regulations of LLC “MVZ”, Clause 20, Article 6 of the Law, Presidential Decree of the Republic of Belarus No. 527 dated November 28, 2013 “On the Issues of Creation and Application of the Video Surveillance System in the Interests of Public Order”; Law of the Republic of Belarus No. 175-Z dated November 8, 2006 “On Security Activities in the Republic of Belarus” | 30 days from the date of video recording — Subclause 5.3, Clause 5 of Decree No. 527 dated November 28, 2013 “On the Issues of Creation and Application of the Video Surveillance System in the Interests of Public Order” |
2.3.14 | For the provision of maintenance and repair services of goods, and other related support | Last name, first name, patronymic;
Residential address (place of residence); Phone number (optional); Email address (optional); Other personal data provided by the subject |
Fulfillment of duties (powers) provided by legislative acts (Clause 20, Article 6, and Clause 16, Item 2, Article 8 of the Law of the Republic of Belarus No. 99-Z “On the Protection of Personal Data” dated May 7, 2021, Article 22 of the Law of the Republic of Belarus No. 90-Z “On the Protection of Consumer Rights” dated January 9, 2002) | 3 years after the expiration of the contract, or 10 years after the expiration of the contract if tax authorities do not conduct a tax compliance audit — Clause 70 of the List of the Resolution of the Ministry of Justice of the Republic of Belarus No. 140 “On the List of Typical Documents” dated May 24, 2012 (hereinafter referred to as the List) |
*By consenting to the processing of personal data by the Operator, the personal data subject agrees to the Operator performing the following actions with the data: collection, systematization, storage, modification, use, anonymization, blocking, provision, deletion, both using automation tools and without them.
2.4. The processing of the personal data subject’s data ceases when:
3.1. The Operator takes necessary organizational and technical measures to protect the personal information of the personal data subject from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, as well as other unlawful actions by third parties.
3.2. The Operator has the right to transfer personal data to third parties for the purposes specified in the Policy, under civil law contracts concluded with LLC “MVZ”.
Third parties to whom the Operator entrusts the processing of personal data are usually located in countries that provide an adequate level of protection of the rights of personal data subjects.
In the case of processing personal data in a country that does not ensure an adequate level of protection for the rights of personal data subjects, the subject is additionally informed of the risks associated with the lack of an adequate level of data protection in such countries before obtaining consent for processing, specifically:
4.1. The personal data subject has the right to:
Right | Consequences | |
4.1.1. | To demand the Operator to
make changes if personal data is outdated, incomplete, or inaccurate |
The Operator shall make changes to your personal data within 15 calendar days from the receipt of the request if
it is incomplete, outdated, or inaccurate. |
4.1.2. | To receive information
regarding the processing of personal data |
The Operator shall provide the requested information
within 5 working days after receiving your application or notify you of the reasons for the refusal. |
4.1.3. | To receive information once a calendar year for free about
the provision of their data to third parties |
The Operator shall provide information on what personal
data and to whom it was provided within the year preceding the application date, or notify you of the reasons for the refusal, within 15 calendar days from the receipt of your application. |
4.1.4. | To withdraw consent to the processing of personal data | |
4.1.5. | To demand the cessation of
data processing and its deletion |
The Operator shall cease processing your personal data
and delete it within 15 calendar days from the receipt of the request, except in cases where the Operator has the right to continue processing personal data on other legal grounds, and shall notify you of this. |
4.1.6. | To appeal the actions/inactions
and decisions of the Operator related to the processing of personal data to the authorized body for the protection of personal data subjects’ rights — the National Center for Personal Data Protection of the Republic of Belarus, in the manner prescribed by law |
4.2. To exercise the personal data subject’s rights, as set out in clauses 4.1.1. — 4.1.5., a written application must be submitted to the Operator by mail (Republic of Belarus, Minsk, Partizansky Ave, 8, bldg. 3, room 5).
4.3. To exercise the right to withdraw consent (clause 4.1.4.), the subject may either send a corresponding application to LLC “MVZ” at its legal address (Republic of Belarus, Minsk, Partizansky Ave, 8, bldg. 3, room 5), or withdraw consent on the Site in the personal account section “personal data”.
4.4. The application must include:
4.5. The right to appeal actions/inactions and decisions of the Operator related to the processing of personal data (clause 4.1.6.) is exercised by appealing to the authorized body for the protection of the personal data subjects’ rights — the National Center for Personal Data Protection of the Republic of Belarus, in the manner prescribed by the legislation of the Republic of Belarus on appeals of citizens and legal entities.
4.6. For assistance in exercising their rights, the personal data subject can also contact the person responsible for internal control over the processing of personal data at the Operator by sending a message to the email address: marketing01@mvz.by.
4.7. In the event that the personal data subject refuses to give consent for the processing of personal data, withdraws their provided consent for the processing of personal data, and/or requests the cessation of their processing, the Operator will be unable to process the personal data unless otherwise provided by law.
The cessation of personal data processing by the Operator may make it impossible to further provide goods and services to the personal data subject.
4.8. Any person who provides incomplete, outdated, or inaccurate information about themselves to the Operator, or information about another personal data subject without their consent, is responsible in accordance with the legislation of the Republic of Belarus.
5.1. Issues related to the processing of personal data not covered by this Policy are regulated by the legislation of the Republic of Belarus.
5.2. If any provision of the Policy is found to be contrary to the law, the remaining provisions that comply with the law remain in force and are valid, and any invalid provision will be considered removed/modified to the extent necessary to ensure its compliance with the law.
5.3. The Operator has the right, at its discretion, to unilaterally change and/or supplement the terms of this Policy without prior notice to the personal data subjects by posting a new version of the Policy on the Site.