1.1. This Personal Data Processing Policy (hereinafter referred to as the "Policy") defines the procedure and conditions for processing personal data by sole proprietor Al-Khatib A.F., registered at 20 Sologub Street, Stolbtsy, Republic of Belarus, UNP 692111656, state registration certificate No. 0883388, issued by the Stolbtsy District Executive Committee on March 12, 2025 (hereinafter referred to as the "Operator").

1.2. This Policy has been developed in accordance with the requirements of the Law of the Republic of Belarus dated May 7, 2021, No. 99-Z "On the Protection of Personal Data" (hereinafter referred to as the "Law"), as well as other regulatory legal acts governing the protection and processing of personal data.

1.3. The terms used in this Policy have the meanings defined in Article 1 of the Law.

1.4. The following terms apply to this Policy:

Services — any services, products, events, programs, and services provided by the Operator.

Website — https://eet.by and other websites owned by the Operator, including their subdomains.

1.5. This Policy applies to all transactions with personal data performed by the Operator, with or without the use of automated tools, including the collection, systematization, storage, modification, use, transfer, depersonalization, blocking, and deletion of data.

1.6. This Policy shall enter into force upon its approval and remain in effect until it is replaced by a new version.

2.1. The Operator processes personal data received from the following categories of personal data subjects:

• Operator participants and affiliates;
• Employees, former employees, and job applicants;
• Individual clients and contractors;
• Representatives and/or employees of legal entities and sole proprietors interacting with the Operator;
• Visitors to the Operator's Website and Services;
• Individuals who have provided personal data by subscribing to newsletters, sending reviews, inquiries, or filling out questionnaires as part of advertising and other events;
• Other individuals who have provided personal data in any way.

2.2. As part of its activities, the Operator may process the following categories of personal data:

• Surname, first name, patronymic;
• Gender;
• Date of birth;
• Email address;
• Phone number;
• Citizenship;
• History of searches and views on the Website and Services;
• Other information necessary to achieve the processing purposes (the list may be expanded or reduced depending on the specific situation).
• 2.3. To analyze the performance of the Website and Services, the Operator may process technical data:
• IP ​​address;
• Browser information;
• Cookie data;
• Addresses of requested pages;
• Access time.

2.4. The Operator ensures that the volume and content of processed personal data correspond to the stated processing purposes and takes measures to eliminate redundant data.

2.5. Biometric personal data is processed by the Operator only with the written consent of the subject or in cases stipulated by the legislation of the Republic of Belarus.

2.6. The Operator does not process special categories of personal data related to racial or ethnic origin, political views, religious or philosophical beliefs, health status, intimate life, trade union membership, or information about administrative or criminal liability, except in cases where such data was voluntarily provided by the subject or obtained in accordance with the law.

2.7. In order to perform its functions and achieve the purposes of processing, the Operator has the right to transfer personal data to third parties, subject to the requirements of the legislation of the Republic of Belarus.

3.1. The Operator processes personal data for the following purposes:

• Establishing and maintaining communication with personal data subjects;
• Concluding, executing, amending, and terminating agreements with personal data subjects;
• Providing access to the Operator's Services;
• Informing personal data subjects about the Operator's activities, including the launch of new Websites and Services;
• Sending notifications, commercial offers, and advertising and informational messages;
• Conducting marketing activities, including promotions, surveys, interviews, and testing;
• Analyzing and evaluating the performance of the Websites and Services, as well as improving their quality;
• Providing technical and informational support for the Websites and Services;
• Registering and maintaining user accounts;
• Processing inquiries, requests, and feedback from personal data subjects;
• Searching for and recruiting candidates for vacant positions;
• Maintaining personnel records and fulfilling job responsibilities;
• Preparing statistical reports and conducting analytical research;
• Carrying out business and entrepreneurial activities;
• performance of other duties and powers stipulated by the legislation of the Republic of Belarus.

4.1. The Operator has the right to:

receive from the personal data subject reliable information and/or documents containing personal data necessary to achieve the processing purposes;

request confirmation from the personal data subject of the relevance, completeness, and accuracy of the data provided;

refuse requests from the personal data subject to terminate processing and/or delete personal data in cases stipulated by the legislation of the Republic of Belarus, including situations where the data is necessary for the stated processing purposes, fulfillment of contractual obligations, or compliance with legal requirements.

4.2. The Operator is obligated to:

process personal data in accordance with the requirements of the legislation of the Republic of Belarus;

ensure appropriate protection of personal data during processing, including protection from unauthorized access, modification, blocking, or destruction;

take measures to ensure the relevance and accuracy of the personal data being processed, and make necessary changes if incomplete, outdated, or inaccurate data is identified;

review inquiries from personal data subjects regarding processing issues and provide reasoned responses within the established timeframes;

Provide the data subject with information about their personal data, as well as information about its transfer to third parties (if such transfer has occurred);

Stop processing, delete, or block personal data if there are no legal grounds for its further processing, including at the request of the data subject;

Fulfill other obligations stipulated by the legislation of the Republic of Belarus in the field of personal data protection.

4.3. The data subject has the right to:

Receive information about the fact, purposes, legal grounds, and methods of processing their personal data;

Change their personal data if it is incomplete, inaccurate, or out of date;

Revoke previously provided consent to the processing of personal data;

Receive information about the transfer of their personal data to third parties;

Stop processing and/or delete their personal data if there are no legal grounds for storing and using it;

To appeal the Operator's actions (inactions) and decisions related to the processing of personal data to the authorized state body in accordance with the procedure established by law;

To exercise other rights stipulated by the legislation of the Republic of Belarus in the field of personal data protection.

4.4. The personal data subject is obligated to:

provide the Operator with only accurate and up-to-date information about themselves;

upon the Operator's request, provide documents containing personal data to the extent necessary to achieve the processing purposes;

promptly inform the Operator of any changes to their personal data.

4.5. Liability:

Any person who provides the Operator with inaccurate, incomplete, or outdated information about themselves, or the personal data of third parties, without their proper consent, shall be liable in accordance with the legislation of the Republic of Belarus.

5.1. The basis for processing personal data is the voluntary, informed consent of the personal data subject, except in cases expressly provided for by the legislation of the Republic of Belarus, when processing is permitted without such consent.

5.2. The consent of the personal data subject is a free, unambiguous, and informed expression of will by which the subject authorizes the processing of their personal data. Refusal to consent to the processing of personal data may serve as grounds for the Operator to deny access to the Website and/or Services.

5.3. The processing of personal data by the Operator includes, but is not limited to, the following actions: collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, deletion, as well as other actions carried out in accordance with the legislation of the Republic of Belarus.

5.4. The Operator processes personal data in the following ways:

manual processing;

automated processing with or without the transmission of information over information and telecommunications networks;

Mixed processing, combining elements of automated and non-automated processing.

5.5. Personal data is stored in a form that allows for the identification of the personal data subject for the period necessary to achieve the processing objectives, unless another period is established by the legislation of the Republic of Belarus, an agreement with the personal data subject, or other legal grounds.

5.6. Grounds for terminating the processing of personal data may include:

achievement of the processing objectives;

expiration of the established storage period;

revocation of consent by the personal data subject;

detection of unlawful processing.

5.7. The operator takes the necessary legal, organizational, and technical measures to ensure the security of personal data, including protection against unauthorized or accidental access, modification, blocking, copying, distribution, provision, deletion, and other illegal actions.

6.1. The personal data subject has the right to revoke their consent to the processing of their personal data by sending a written request to the Operator by registered mail or electronically. The request must include: last name, first name, and patronymic; date of birth; the essence of the request; and a personal signature or electronic digital signature. Within 15 calendar days of receiving the request, the Operator will cease processing the personal data (if there are no legal grounds for continuing), delete it, or, if deletion is impossible, take measures to block and prevent further processing, notifying the personal data subject accordingly within the same period.

6.2. The personal data subject has the right to receive information about the fact, purposes, and methods of processing their personal data by submitting a request in the manner prescribed in Section 6.1 of this Policy. The Operator will provide the requested information or a reasoned refusal within 5 business days of receiving the request.

6.3. If incomplete, outdated, or inaccurate personal data is discovered, the data subject has the right to request its updating by submitting a request in accordance with the procedure set forth in Section 6.1, along with supporting documents (certified copies). The operator will make the appropriate changes or provide a reasoned refusal within 15 calendar days.

6.4. The data subject has the right to receive information free of charge once per calendar year about the transfer of their personal data to third parties by submitting a request in accordance with the procedure set forth in Section 6.1. The operator will provide information about what data was transferred and to whom during the year preceding the request, or will provide a reasoned refusal within 15 calendar days.

6.5. The data subject has the right to request the cessation of processing and deletion of their personal data in the absence of legal grounds for its storage and use by submitting a request in accordance with the procedure set forth in Section 6.1. The operator will cease processing, delete, or block the data and notify the data subject thereof within 15 calendar days.

7.1. All matters related to the processing of personal data not regulated by this Policy are governed by the laws of the Republic of Belarus.

7.2. If any provision of this Policy is found to be inconsistent with the law, the remaining provisions shall remain in full force and effect. The invalid provision shall be deemed amended or deleted to the extent necessary to bring it into compliance with the law.

7.3. The Operator reserves the right to amend and/or supplement this Policy at any time without prior notice to personal data subjects.

7.4. For questions regarding this policy, please contact us by email at info@eet.by

7.5. This is an unofficial translation for illustrative purposes only. The official, legal version is available in Russian at https://eet.by/personal-data-processing-ru.