Privacy Policy
This Privacy Policy describes how AddProcess collects, uses and discloses information from or about an identified or identifiable person, including information that we can associate with an individual person (“Personal Data”), as well as any choices you have with respect to your Personal Data.
1. GENERAL PROVISIONS
1.1. AddProcess places special emphasis on the protection of personal data during its processing and respects the rights of personal data subjects.
The approval of this Regulation on the Personal Data Processing Policy (hereinafter referred to as the "Policy") is one of the measures taken by Tour.Process to protect personal data, as provided for in Article 17 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").
1.2. The Policy explains to personal data subjects how and for what purposes their personal data is collected, used, or otherwise processed, as well as the rights they have in this regard and the mechanisms for exercising those rights.
The Policy does not apply to the processing of personal data in the course of employment relations and administrative procedures (regarding employees and former employees), video surveillance, or the processing of cookies on the website of Veronika Aleksandrovna Sotskaya.
1.3. Postal address of Tour.Process; website address: process.pro/travel_assistant
1.4. The terms used in this Policy shall have the meanings defined in the Law.
1.5. Personal data may be used by Tour.Process for scientific or other research purposes after mandatory anonymization of such data, in particular, for:
- preparing and publishing annual reports on its activities;
- preparing and providing clarifications on the application of personal data legislation;
- preparing and publishing materials and speeches related to the performance of duties by Tour.Process employees.
1.6. Veronica Aleksandrovna Sotskaya processes only the personal data necessary for achieving the stated purposes and does not allow excessive processing.
2. PURPOSES, CATEGORIES OF PERSONAL DATA SUBJECTS, LIST OF PROCESSED PERSONAL DATA, LEGAL BASES, AND PROCESSING PERIODS
Veronika Aleksandrovna Sotskaya processes personal data of personal data subjects for the purposes, scope, legal bases, and periods applicable to each category of personal data subjects, as specified in Appendix 1 to this Policy.
3. AUTHORIZED PERSONS. CROSS-BORDER TRANSFER OF PERSONAL DATA
3.1. AddProcess entrusts the processing of personal data to authorized persons.
The list of authorized persons processing personal data on behalf of Veronica Aleksandrovna Sotskaya is provided in Appendix 2 to this Policy.
3.2. AddProcess carries out cross-border transfers of personal data to ensure continuous communication with users of social networks and messengers (Instagram, TikTok, Telegram, YouTube).
Cross-border transfer of personal data to a foreign state may be carried out by Tour.Process if:
3.2.1. The foreign state ensures an adequate level of protection for the rights of personal data subjects—without restrictions, provided there are legal grounds under the Law;
3.2.2. The foreign state does not ensure an adequate level of protection for the rights of personal data subjects—in cases provided for by Article 9 of the Law, including:
- when the personal data subject has given consent, provided that the subject has been informed of the risks arising from the lack of adequate protection;
- when publishing information about its activities on the global Internet;
- when the processing of personal data is necessary for the fulfillment of duties (powers) stipulated by legislative acts.
4. RIGHTS OF PERSONAL DATA SUBJECTS
4.1. A personal data subject has the right to:
4.1.1. Withdraw their consent if Tour.Process has requested consent for the processing of personal data. The right to withdraw consent cannot be exercised if processing is based on other legal grounds (e.g., in accordance with legal requirements or under a contract);
4.1.2. Obtain information regarding the processing of their personal data by Tour.Process, including:
- the location of AddProcess;
- confirmation of the processing of their personal data by AddProcess;
- the personal data and the source of its collection;
- the legal basis and purposes of processing;
- the duration of consent (if processing is based on consent);
- the name and location of the authorized person(s);
- other information stipulated by law;
- 4.1.3. Request AddProcess to amend their personal data if the data is incomplete, outdated, or inaccurate. To do so, the subject must provide relevant documents and/or certified copies confirming the need for amendments;
- 4.1.4. Receive from AddProcess information about the disclosure of their processed personal data to third parties once per calendar year free of charge, unless otherwise provided by law;
- 4.1.5. Demand that AddProcess cease processing their personal data, including deletion, if there are no legal grounds for processing under the Law or other legislative acts;
- 4.1.6. Appeal against actions (inaction) and decisions of AddProcess that violate their rights in personal data processing, in accordance with the law.
4.2. To exercise their rights regarding the processing of personal data by AddProcess, a personal data subject must submit a written application to the postal address specified in clause 1.3 of this Policy or via the state unified (integrated) republican information system for recording and processing applications from individuals and legal entities. In case of withdrawing consent, the application must be submitted in the same form in which the consent was originally given.
The application must include:
- the full name (if applicable) and residential address of the subject;
- the subject’s date of birth;
- a description of the subject’s request;
- the subject’s identification number (or passport details if no ID number exists);
- a handwritten signature (for written applications) or an electronic digital signature (for electronic applications).
- AddProcess does not consider applications submitted via other means (e.g., email, phone).
4.3. For assistance in exercising rights related to the processing of personal data by Veronica Aleksandrovna Sotskaya, a personal data subject may contact the person responsible for internal control over personal data processing by sending a message to
veronica.sotskaya@addprocess.com.