Privacy Policy for Personal Data of "Liontransbel" Limited Liability Company
This Privacy Policy for personal data of "Liontransbel" Limited Liability Company (hereinafter – the "Privacy Policy") is developed in accordance with the Law of the Republic of Belarus No. 99-Z of May 7, 2021, "On Personal Data Protection," with the purpose of protecting personal data, rights, and freedoms of individuals during the processing of their personal data.

1. OPERATOR
1.1. The Operator is "Liontransbel" Limited Liability Company (hereinafter – the "Company").
The Company is registered in the Unified State Register of Legal Entities and Individual Entrepreneurs by the Minsk City Executive Committee, UNP (Taxpayer's Account Number) 193586831, legal address: 220030, Republic of Belarus, Minsk, ul. Myasnikova 27, 4th floor, office 25.
1.2. The Company uses the Website: https://liontrans.by.

2. TERMS AND DEFINITIONS
2.1. The following terms are used in this Privacy Policy:

• Website – the website https://liontrans.by.
• User – an individual whose personal data is being processed, who has access to the Website and uses the Website via the Internet.
• Personal Data – any information relating to an identified individual or an individual who can be identified.
• Processing of Personal Data – any action or set of actions performed regarding personal data, including collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, deletion of personal data.
• Confidentiality of Personal Data – a mandatory requirement for the Company or any other person who has gained access to personal data to prevent their distribution without the consent of the personal data subject or the existence of another legal basis.
• Cookies – a small piece of data sent by a web server and stored on the User's computer, which the web client or web browser sends back to the web server in an HTTP request each time an attempt is made to open a page of the corresponding site.
• IP Address – a unique network address identifying a device on the internet or a local network.
• 2.2. Other terms and concepts used in the text of the Privacy Policy are used in the meanings applied by the current legislation of the Republic of Belarus.

3. GENERAL PROVISIONS
3.1. The scope of this Privacy Policy covers the Company's processes involving the collection, processing, and storage of Users' personal data.
3.2. The processing of the User's personal data is carried out by the Operator.
3.3. This Privacy Policy applies only to the Website. The Website does not control and is not responsible for third-party websites that the User may access via links available on the Website.
3.4. The Company does not verify the accuracy of the personal data provided by the User. Consequently, any negative consequences (including liability of any kind) that may arise due to the provision of inaccurate information are the responsibility of the User.

4. PURPOSES OF USING PERSONAL DATA
4.1. The Company may use the User's personal data for the following purposes:

• Establishing feedback with the User, including sending notifications, requests related to the use of the Website, provision of services, processing requests and applications from the User;
• Use in mailings (postal, email, using SMS, other messaging services (e.g., Viber, Telegram, etc.)) to provide the User with information about new products, promotions, bonus programs, special offers, advertising and other similar events, as well as other news of the Company, for receiving which the Subject has given his/her consent in a form not prohibited by law. The Subject can always refuse these mailings via his/her contact information;
• Improving the quality of the Company's services, providing and promoting the Company's services;
• Sending technical notifications (notifications about orders, etc.);
• Confirming the accuracy and completeness of personal data provided by the User;
• Processing statistical information;
• Sending notifications, information, and requests related to the collection, storage, and processing of personal data;
• Providing the User, via email or other available means, with his/her consent, with other information/notifications on behalf of the Website.
• 4.2. Consent to the processing of personal data may be withdrawn by the User in the manner stipulated in clause 7.2. of this Privacy Policy.

5. LIST OF PERSONAL DATA PROCESSED AND THEIR RETENTION PERIOD
5.1. Personal data permitted for processing under this Privacy Policy are provided by the User by filling out the feedback form, as well as when placing an order or subscribing to news, and may include the following information:

• User's last name, first name, patronymic (if any);
• User's contact phone number;
• Email address (e-mail), other accounts in electronic information exchange services.
• 5.2. The Company may also collect information of a technical and other nature:
• Information from "cookies" files;
• Browser information (Mozilla Firefox, Opera, Internet Explorer, etc.);
• Operating system used (Mac OS, Windows, etc.);
• Access time;
• Type of device used;
• Name of the website from which the User accessed the Website;
• Products that the User compares or selects;
• Purchase history.
• Disabling statistical cookies prevents the determination of the website User's preferences, including the most and least popular pages, and taking measures to improve the website's operation based on the User's preferences.
• 5.3. The User, by providing personal data to the Company, grants the Company the right to receive, store, process, use, and disclose personal data under the terms of this Privacy Policy.
• 5.4. The User's personal data will be processed until the consent is withdrawn.

6. METHODS OF PROCESSING PERSONAL DATA
6.1. The Company carries out collection (receipt), processing (recording, systematization, accumulation, updating, modification, retrieval, use), storage, transfer (distribution, provision of access), destruction (depersonalization, blocking, deletion) of personal data for the purposes specified in this Privacy Policy.
6.2. The processing of the User's personal data is carried out in personal data information systems using automation tools or without using such tools, as well as in a mixed manner, including via information and telecommunication networks, for the purposes specified in this Privacy Policy.
6.3. The Company takes necessary measures to delete or clarify incomplete or inaccurate data.
6.4. The Company has the right to transfer personal data to third parties, in particular, courier services, postal organizations, telecommunications operators, solely for the purpose of fulfilling the User's order placed on the Website.
6.5. The User's personal data may be transferred to authorized state bodies of the Republic of Belarus and other persons only on the grounds and in the manner established by the legislation of the Republic of Belarus.
6.6. In case of loss or disclosure of personal data, the Company informs the User about the loss or disclosure of personal data.
6.7. The Company takes necessary organizational and technical measures to protect the User's personal information from unlawful or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions by third parties.
6.8. Personal data is stored in the Company's specialized systems that ensure automatic processing and storage of information.

7. USER'S RIGHTS
7.1. The User exercises his/her rights within the scope and procedure established by the legislation of the Republic of Belarus.
7.2. The User has the right at any time, without giving reasons, to withdraw his/her consent to the processing of his/her personal data or request the termination of the processing of his/her personal data, including their deletion, by sending a written application to the Company's address (via registered mail or in person): 220030, Republic of Belarus, Minsk, ul. Myasnikova 27, 4th floor, office 25.
The application must contain:

• User's last name, first name, patronymic (if any), address of his/her place of residence (stay);
• User's date of birth;
• User's identification number, in the absence of such a number – the number of the identity document of the User, in cases where this information was provided by the User when giving consent to the Company or if the processing of personal data is carried out without the consent of the personal data subject;
• Statement of the essence of the User's requirements;
• User's personal signature.
• Within fifteen days after receiving the User's application, the Company, in accordance with its content, terminates the processing of personal data, carries out their deletion, and notifies the User thereof, unless there are other grounds for such actions with personal data provided for by the legislative acts of the Republic of Belarus. In the absence of the technical possibility to delete personal data, the Company takes measures to prevent further processing of personal data, including their blocking, and notifies the User thereof within the same period.
• 7.3. The User has the right to submit an application to the Company in the manner specified in clause 7.2. of this Privacy Policy, for the purpose of obtaining information related to the processing of his/her personal data, containing:
• Name and location of the operator;
• Confirmation of the fact of processing of personal data by the operator (authorized person);
• User's personal data and the source of their obtaining;
• Legal grounds and purposes of personal data processing;
• The term for which his/her consent was given;
• Name and location of the authorized person, which is a state body, legal entity of the Republic of Belarus, or another organization, if the processing of personal data is entrusted to such a person;
• Other information provided for by law.
• Within five working days after receiving the corresponding application, the Company provides the User with the requested information or notifies him/her of the reasons for refusing to provide it.
• 7.4. The User has the right to submit an application to the Company in the manner specified in clause 7.2. of this Privacy Policy, for the purpose of making changes to his/her personal data if the personal data are incomplete, outdated, or inaccurate.
• Within fifteen days after receiving the application of the personal data subject, the Company makes the corresponding changes to the User's personal data and notifies the User thereof or informs about the reasons for refusing to make such changes.
• 7.5. The User has the right to submit an application to the Company in the manner specified in clause 7.2. of this Privacy Policy, for the purpose of obtaining from the Company information about the provision of his/her personal data to third parties once per calendar year free of charge.
• Within fifteen days after receiving the application, the Company provides the User with the corresponding information or notifies the User of the reasons for refusing to provide it.
• 7.6. The User's right to access his/her personal data may be restricted in accordance with the legislation of the Republic of Belarus.
• 7.7. The User has the right to receive from the Company the composition of the personal data of this User held by the Company and the source of their obtaining.
• 7.8. In case the User gives consent to the processing of his/her personal data, the Company will be able to provide the services requested by the User (place an order, send informational and advertising mailings).
• If the User withdraws or does not provide consent to the use of his/her personal data, the Company will not be able to provide the services requested by the User (place an order, send informational and advertising mailings, provide technical support and others, according to the purposes outlined in Section 4 of this Privacy Policy) – in full or in part.

8. PRINCIPLES OF PROCESSING PERSONAL DATA
8.1. The processing of personal data in the Company is carried out in accordance with the following principles:

• Personal data are processed on a lawful basis;
• The processing of personal data is limited to achieving specific, explicitly defined, predetermined, and lawful purposes. Processing of personal data incompatible with the purposes of personal data collection is not permitted;
• Combining databases containing personal data processed for incompatible purposes is not permitted;
• Only those personal data that correspond to the purposes of their processing are subject to processing;
• The content and volume of processed personal data correspond to the stated purposes of processing. The processed personal data are not excessive in relation to the stated purposes of processing;
• During the processing of personal data, the accuracy of personal data, their sufficiency, and, where necessary, their relevance in relation to the stated purposes of their processing are ensured;
• Storage of personal data is carried out in a form that allows identification of the personal data subject no longer than required by the purposes of personal data processing, unless a different retention period for personal data is established by law or contract. Personal data are subject to destruction upon achieving the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided by law;
• The provided personal data remain in their original form and are not changed during the process of data collection and processing;
• Personal data are processed in a manner that ensures proper security of personal data, including protection against unauthorized or unlawful processing, as well as accidental loss, destruction, or damage, using appropriate technical or organizational measures;
• The Company does not transfer personal data to non-residents of the Republic of Belarus;
• The Company has the right to process publicly available personal data, and to process personal data subject to mandatory disclosure in accordance with the legislation of the Republic of Belarus;
• The Company has the right to entrust the processing of personal data to another authorized person. The Company is liable to the User for the actions of the authorized person;
• The Company does not have the right to receive and process the User's personal data concerning his/her race, nationality, political views, religious or philosophical beliefs, and intimate life;
• The User's personal data belong to the category of confidential information.
• 8.2. The Company undertakes to comply with the above principles not only during the current processing of personal data but also when implementing new methods and systems of processing.

9. LIABILITY OF THE PARTIES
9.1. For failure to perform or improper performance of the terms of this Privacy Policy, the Company and the User shall be liable as provided for by the legislation of the Republic of Belarus.
9.2. In case of loss or disclosure of Confidential Information, the Company shall not be liable if this Confidential Information:

• Became public domain before its loss or disclosure;
• Was received from a third party before it was received by the Company;
• Was disclosed with the User's consent.

10. FINAL PROVISIONS
10.1. The current legislation of the Republic of Belarus applies to this Privacy Policy and the relations between the User and the Company.
10.2. The Company has the right, at its sole discretion, to unilaterally change and/or supplement the terms of this Privacy Policy without prior notice to the User by posting a new version of the Policy on the Website.
10.3. The new version of the Privacy Policy comes into force from the moment of its placement on the Website, unless otherwise provided by the new version of the Privacy Policy.