POLICY LIMITED LIABILITY COMPANY «COSWICK» (OPERATOR) REGARDING THE PROCESSING OF PERSONAL DATA ON COSWICK.COM WEBSITE
1. GENERAL TERMS
1.1 The policy regarding the processing of personal data (hereinafter referred to as the Policy) in the Limited Liability Company «Coswick» (hereinafter referred to as the enterprise, company, «Coswick») on the website https://coswick.com (hereinafter referred to as the website) explains the subjects of personal data, how and for what purposes their personal data is collected, used or otherwise processed, and also reflects the rights and enforcement mechanisms of the subjects of personal data in this regard.
1.2 The policy is one of the measures taken by the enterprise to protect personal data, provided for in Article 17 of the Law of the Republic of Belarus dated May 7, 2021 № 99-З “On the protection of personal data” (hereinafter referred to as the Law).
1.3 «Coswick» postal address: 223034, Republic of Belarus, Minsk region, Zaslavl, str. Y. Kolas, 2B; Internet address: https:/coswick.com.
1.4 This Policy uses terms and their definitions in the meaning defined by the Law.
1.5 The company processes only those personal data that are necessary for the stated purposes and does not allow their excessive processing.
1.6 Personal data may be used by «Coswick» for scientific or other research purposes after the mandatory anonymization of such personal data, in particular for:
– preparation and publication of annual reports on its activities;
– preparing and giving explanations on the application of the legislation on personal data;
– preparation and implementation of publications and speeches related to the performance by employees of the enterprise of their official duties.
1.7 Personal data is not to be transferred to third parties, except in cases related to the implementation of the current legislation.
2. PURPOSES, CATEGORIES OF PERSONAL DATA SUBJECTS WHOSE DATA IS PROCESSED, LIST OF PERSONAL DATA PROCESSED, LEGAL GROUNDS AND TIME FOR PROCESSING PERSONAL DATA
2.1 The company processes the personal data of individual managers and specialists, as well as site visitors (only in case they are filled out and/or sent by the visitor independently through special forms located on the website https://www.coswick.com).
2.2 «Coswick» can process the following personal data:
– employees of the enterprise: photo, last name, first name, position, office telephone numbers and email addresses;
– sent by a website visitor:
Full Name;
email address;
phone numbers;
mail/postal address;
as part of applicants’ resumes (formulas, autobiographies, personnel records sheets, applications, references, etc.);
as part of appeals.
2.3 Purposes, legal grounds and periods of storage of personal data:
2.3.1 preparation, conclusion and execution of civil contracts (including pre-sale, post-sale, warranty and claim support) – on the basis of paragraph 15 of Article 6 of the Law; storage period – 3 years after the expiration of the contract and the tax authorities verifying compliance with tax legislation. If the tax authorities did not check compliance with tax legislation – 10 years after the termination of the employment contract;
2.3.2 posting information on the activities of the enterprise and in relation to employees whose duties include active contact with the external circuit, on the website, social networks and messengers – on the basis of paragraph 8 of Article 6 of the Law; storage period – 10 days after the amendment or termination of the employment contract;
2.3.3 consideration of resumes (questionnaires) of applicants for vacant positions in order to conclude an employment contract, as well as the formation and maintenance of a personnel reserve – on the basis of consent (Article 5 of the Law – when sending a resume (questionnaire) in electronic form), based on paragraph 16 of Article 6 of the Law (when sending (providing) a resume (questionnaire) in writing or in the form of an electronic document); storage period – no more than 1 year (in case of non-hiring) or 1 month (in case of hiring);
2.3.4 consideration of appeals – on the basis of paragraph 20 of Article 6 of the Law (Article 12 of the Law of the Republic of Belarus dated July 18, 2011 No. 300-3 “On Appeals of Citizens and Legal Entities”); storage period – 5 years.
3. AUTHORIZED PERSONS. CROSS-BORDER DATA TRANSFER
3.1 The Company has the right to entrust the processing of personal data on behalf of «Coswick» or in its interest to an authorized person on the basis of the contract concluded with this person.
3.2 The company carries out cross-border transfer of personal data to ensure continuous communication with users of social networks and messengers (Facebook, X, LinkedIn, Instagram, Viber, Telegram, YouTube, WeChat, WhatsApp, VK, Vimeo, Pinterest, Houzz).
Cross-border personal data transfer to the territory of a foreign state can be carried out by a company if:
3.2.1 on the territory of a foreign state, an appropriate level of protection of the subjects` personal data rights is ensured – without restrictions if there are legal grounds provided by the Law;
3.2.2 on the territory of a foreign state, the appropriate level of protection of the subjects` personal data rights is not provided – in the cases provided in Article 9 of the Law, including:
– when the consent of the subject of personal data is given, provided that the subject of personal data is informed about the risks arising from the lack of an adequate level of protection;
– when posting information about your activities on the global computer network Internet;
– when the processing of personal data is necessary to fulfill the duties (powers) provided for by legislation.
4. RIGHTS OF PERSONAL DATA SUBJECTS
4.1 The subject of personal data has the right:
4.1.1 to withdraw your consent, if «Coswick» contacted the subject of personal data to obtain consent in order to process personal data. The right to withdraw consent cannot be exercised when the processing is carried out on other legal grounds;
4.1.2 to obtain information regarding the processing of your personal data by the enterprise, containing:
location of the company;
confirmation of the fact of processing of personal data of the applicant «Coswick»;
personal data and the source of receipt;
legal grounds and purposes of processing personal data;
the period for which consent is given (if the processing of personal data is based on consent);
name and location of the authorized person (authorized persons);
other information required by law;
4.1.3 to require the company to change its personal data if the personal data is incomplete, out of date or inaccurate. For these purposes, the subject of personal data attaches the relevant documents and (or) their duly certified copies confirming the need to make changes to personal data;
4.1.4 to receive information from the company about the provision of personal data processed by «Coswick» to third parties once a calendar year free of charge, unless otherwise provided by the Law and other legislative acts;
4.1.5 to require the company to stop processing its personal data free of charge, including its deletion, if there are no grounds for processing personal data provided for by the Law and other legislative acts;
4.1.6 to appeal against actions (inaction) and decisions of the company that violate its rights when processing personal data, in the manner established by law.
4.2 To exercise its rights related to the processing of personal data by «Coswick», the subject of personal data submits an application to the company in writing to the postal address specified in subclause 1.3 of clause 1 of this Policy, and in the case of exercising the right to withdraw consent – in the form in which such consent was obtained.
Such an application must contain:
Last name, first name, patronymic (if any) of the subject of personal data, address of his place of residence (place of stay);
date of birth of the subject of personal data;
statement of the essence of the requirements of the subject of personal data;
identification number of the subject of personal data, in the absence of such number
– the number of the document identifying the subject of personal data, in cases where this information was indicated by the subject of personal data when giving his consent or the processing of personal data is carried out without the consent of the subject of personal data;
personal signature (for a written application) or electronic digital signature (for an electronic document application) of the subject of personal data.
The company does not consider applications from personal data subjects received by other means (e-mail, telephone, etc.).
4.3 For assistance in exercising the rights related to the processing of personal data by «Coswick», the subject of personal data can contact the person responsible for internal control over the processing of personal data in the company by sending a message to popov@coswick.org.