1.1. This document (hereinafter referred to as the "Policy") defines the procedure for processing personal data by "Client Solutions" LLC (hereinafter referred to as the "Company") in accordance with the legislation of the Republic of Belarus.
1.2. The Company pays special attention to the protection of personal data during their processing and strictly complies with the rights of personal data subjects.
1.3. The Policy is one of the measures taken by the Company, provided for in Article 17 of the Law of the Republic of Belarus No. 99-Z dated May 7, 2021 "On Personal Data Protection" (hereinafter referred to as the "Personal Data Law") and the Law of the Republic of Belarus No. 455-Z dated November 10, 2008 "On Information, Informatization and Information Protection". The Company complies with the provisions of Article 6 of Federal Law No. 152-FZ concerning the processing of data of citizens of the Russian Federation.
1.4. The Policy explains to personal data subjects how and for what purposes their personal data is collected, used, or otherwise processed, as well as reflects their rights and the mechanism for their implementation.
1.5. The Policy applies to users of the websites https://helloclient.app/ (hereinafter referred to as the "Site"), https://my.helloclient.app and other services, programs, and products of the Company, the use of which may require the provision of personal data (hereinafter referred to as the "Company's Products").
1.6. The Policy defines the purposes, procedure, and conditions for performing actions with personal data, measures to ensure the protection of personal data applied by the Company both as an operator and as an authorized person.
1.7. The Policy is mandatory for familiarization and execution by all persons admitted to the processing of personal data in the Company, as well as persons involved in organizing processing processes and ensuring the protection of personal data.
1.8. The Policy is drawn up in accordance with the provisions of the Personal Data Law and the Law on Information, Informatization and Information Protection.
1.9. In case of changes in the legislation of the Republic of Belarus on personal data, the Policy is subject to updating.
1.10. Ensuring unlimited access to the Policy is carried out by its publication on the Company's website on the Internet at the address: https://helloclient.app/documents/privacy-policy-for-personal-information .
2.1. Purposes and grounds for processing personal data. The Company, acting as an operator, processes the specified personal data of subjects for the purposes and on the grounds specified in the table:
| Purposes of personal data processing | Categories of personal data subjects whose data is processed | List of processed personal data | Legal grounds for processing personal data | Storage period of personal data |
|---|---|---|---|---|
| Organization of services for using the CRM system | Persons using the Company's Products | * Full name, * Email address, * Phone number, * IP address, * Geolocation, * Device identifiers, * Other data obtained through cookies. |
1. In case of concluding a contract - processing based on the
contract (paragraph fifteen of Article 6 of Law No. 99-3). 2. For unauthorized users - consent (Article 5 of Law No. 99-3). | Until the expiration of the contract or withdrawal of consent, but not more than 10 years after termination of use of the Company's Products. |
| Formation of statistics on the use of the Company's Products and audience analysis | Users of the Company's Products | * IP address, * Geolocation, * Device identifiers, * Other data obtained through cookies. | Processing is necessary to achieve the purposes specified in the Usage Policy (paragraph twenty of Article 6 of Law No. 99-3). | 3 years after termination of use of the Company's Products. |
| Display of interest-based advertising on the Internet | Site visitors | * IP address, * Geolocation, * Device identifiers, * Other data obtained through cookies. | Consent of the personal data subject (Article 5 of Law No. 99-3). | Not more than 1 year after the last interaction with the advertisement. |
| Providing the user with Site services, including sending notifications and responses to requests | Registered Site users | * Email address, * Other personal data that the user may specify in their profile (e.g., full name, phone number, position). |
1. In case of concluding a contract - processing based on the
contract. 2. For unauthorized users - consent (Article 5 of Law No. 99-3). | Until the expiration of the contract or withdrawal of consent, but not more than 10 years after termination of use of the Company's Products. |
| Consideration of applications, appeals, and claims |
* Individuals - site visitors, users of the company's products, * Representatives of counterparties, * Counterparties - individuals. | * Full name, * Date of birth (if necessary), * Education information (if necessary), * Work experience information (if necessary), * Residential address (if necessary), * Contact phone number, * Email address, * Other data provided by the personal data subject. | Article 5 of Law No. 99-3 (consent) or paragraph twenty of Article 6 of Law No. 99-3 (necessity for fulfilling obligations). | During the period of consideration of the appeal and not more than 3 years after its completion. |
Processing does not include:
2.2. If any of the above purposes of personal data processing changes, if such change is not provided for by legislation, the Company requests renewed consent from the personal data subject.
2.3. By providing consent to the processing of personal data for the purposes of receiving informational and advertising mailings, the subject also provides consent to receive advertising in accordance with the Law of the Republic of Belarus No. 225-Z dated May 10, 2007 "On Advertising". Detailed conditions for receiving advertising and informational materials, methods of distribution, purposes of data processing, and the procedure for opting out of mailings are set out in the Agreement on Receiving Advertising Materials.
2.4. The Company processes only those personal data that are necessary to achieve the stated purposes and does not allow their excessive processing.
2.5. The Company does not transfer personal data to third parties, except in cases provided for by legislative acts.
2.6. Personal data of visitors and users of the sites may be obtained by the Company from the following sources:
2.7. The Company has the right to perform the following actions with personal data: collection, recording, systematization, accumulation, storage, clarification, retrieval, use, anonymization, provision, deletion, destruction, as well as cross-border transfer of personal data, including transfer to the territory of the Russian Federation and other states where partner services are located, specified on the page https://helloclient.app/documents/partners .
Transfer of personal data to foreign states is carried out if one of the following grounds exists:
The personal data subject has the right to withdraw their consent to the cross-border transfer of personal data by sending a written notification to the Company.
2.8. Recipients of personal data in the territory of the Russian Federation are obliged to comply with the requirements of the legislation of the Russian Federation on personal data, as well as apply necessary organizational and technical measures for their protection. When transferring personal data to third parties in the territory of other foreign states, the Company takes measures to ensure their protection in accordance with the legislation of the Republic of Belarus. When transferring personal data to the territory of the Russian Federation, the Company ensures their localization in accordance with Part 1 of Article 18.1 of Federal Law No. 152-FZ.
2.9. Methods of processing personal data by the Company: using automation means, without their use, as well as by mixed method.
2.10. The terms of processing personal data by the Company are determined taking into account:
Processing is terminated upon expiration of the contract with the personal data subject, withdrawal of consent, by decision of the authorized body, or upon liquidation of the Company.
2.11. The Company processes special personal data of persons related to employee accidents (in particular, health status data). At the same time, the Company takes measures aimed at preventing risks that may arise during the processing of such personal data for the rights and freedoms of personal data subjects.
2.12. In cases where it is necessary for providing services/works/goods of the operator or providing other services/works related to the use of the Company's software Products, the Company may transfer personal data to one or more third parties, the list of which is posted on the Internet at the address https://helloclient.app .
2.13. The Company ceases processing personal data in the following cases:
3.1. The Company, acting as an authorized person, processes personal data of users of the Company's End Users under a personal data processing assignment.
3.2. With respect to personal data placed by the user or End User in the "HelloClient" program (cloud version)/Company's Products in accordance with its/their functionality, the End User is the operator or authorized person in relation to the specified personal data. In this case, the Company:
3.3. When placing personal data of third parties for storage purposes, the End User guarantees that they have obtained all necessary permissions and consents for such actions.
3.4. Storage of user content is carried out in accordance with the functional purpose of specific Company Products, technical documentation for them, as well as the license agreement for their use and the personal data processing assignment.
3.5. The Company is not responsible for the collection, storage, and processing of personal data by third-party developer software included in the Company's Products.
4.1. When a user visits the Site, data may be saved in their browser, or the browser may transmit such data, mainly in the form of cookie files. Such data usually does not directly identify the user but may provide the Company with personalized Internet browsing capabilities.
4.2. Cookies are small text files placed on a device to store data, readable by a web server in the domain where they were created. The Company uses cookies to store and support user preferences and settings for logging in, providing relevant advertising, combating fraud, analyzing the operation of the Company's Products, and performing other lawful procedures.
4.3. The Company uses the following types of cookies:
4.4. The Company uses the following services that process information using cookies:
Consequently, Yandex, Google, and Facebook companies process information about users' visits to the Site and actions that users perform on the Site pages.
The data processing policy of each of the above services is located at the following links:
4.5. You can refuse the processing of cookies (except for technical / necessary ones) using the functionality of the cookie banner placed on the site. You can also change cookie collection settings in your browser settings (Firefox, Google Chrome, Safari, Opera, Microsoft Edge, Internet Explorer).
5.1. The personal data subject has the following rights regarding their personal data:
| No. | Right | Content | Operator's Actions |
|---|---|---|---|
| 1. | Right to receive information regarding the processing of personal data | The subject has the right to receive information regarding the processing of their personal data, containing the name and location of the operator, confirmation of the fact of processing of personal data by the operator, the subject's personal data and the source of their receipt, legal grounds and purposes of processing personal data, the term for which the subject's consent is given, the name and location of the authorized person. | The operator, within 5 working days after receiving an application from the personal data subject, provides the requested information or notifies the personal data subject of the reasons for refusal to provide it. |
| 2. | Right to receive information about the provision of personal data to third parties | The personal data subject has the right to receive from the operator information about the provision of their personal data to third parties once per calendar year free of charge. | The operator, within up to 15 calendar days from the date of submission of the corresponding request by the subject, provides the personal data subject with information about which personal data of this subject and to whom were provided during the year preceding the date of submission of the application, or notifies the personal data subject of the reasons for refusal to provide it. |
| 3. | Right to make changes to their personal data | The personal data subject has the right to demand from the operator to make changes to their personal data if they are incomplete, outdated, or inaccurate. | The operator, within up to 15 calendar days from the date of submission of the corresponding request by the subject, makes changes to the personal data if they are incomplete, outdated, or inaccurate. |
| 4. | Right to demand termination of processing of personal data and/or their deletion | The personal data subject has the right to demand from the operator free termination of processing of their personal data, including their deletion, in the absence of grounds for processing personal data. | The operator, within up to 15 calendar days from the date of submission of the corresponding request by the subject, terminates the processing of personal data except in cases where the operator has the right to continue processing personal data if there are grounds established by the legislation of the Republic of Belarus. |
| 5. | Right to withdraw previously given consent to the processing of personal data | The personal data subject has the right at any time without giving reasons to withdraw their consent to the processing of personal data. | The operator, within up to 15 calendar days from the date of submission of the corresponding request by the subject, terminates the processing of personal data, carries out their deletion and notifies the personal data subject of this, except in cases where the operator has the right to continue processing personal data if there are grounds established by the legislation of the Republic of Belarus. |
| 6. | Right to appeal actions (inaction) and decisions of the operator related to the processing of personal data | The personal data subject has the right to appeal actions (inaction) and decisions of the operator that violate their rights during the processing of personal data to the authorized body. | The operator, within up to 15 calendar days from the date of submission, considers the complaint of the personal data subject and within the terms established by the legislation of the Republic of Belarus provides a response or takes measures to eliminate violations. |
5.2. Implementation of subjects' rights
5.2.1. The personal data subject has the right to send a request to the Company to implement one or more of the rights specified in clause 5.1. The request must contain: full name; address; date of birth; essence of requirements; identification number or number of the identity document (in the absence of an identification number), if this information was indicated when giving consent or processing of personal data is carried out without the subject's consent, personal signature or electronic signature.
5.2.2. To implement one or more of the rights specified under Nos. 1-4, the personal data subject must send the Company a corresponding request meeting the requirements of clause 5.2.1:
5.2.3. In case of withdrawal of consent, the Operator ceases processing within up to 15 days from the receipt of the application, except in cases where the Operator has the right to continue processing personal data if there are grounds established by legislation (Law of the Republic of Belarus No. 99-Z dated May 7, 2021 "On Personal Data Protection", Decree of the President of the Republic of Belarus No. 60 dated February 1, 2010 "On Measures to Improve the Use of the National Segment of the Internet" and others).
5.2.4. Any information (including personal data) that the personal data subject provides when registering an account or in their profile section may be used by the Operator in accordance with this Policy. The personal data subject can at any time view the provided information, independently change it in the personal account on the Site without sending a request to the Operator. Viewing and changing the provided information is available only to registered Site users.
5.2.5. To implement the right to withdraw consent (under No. 5), it is necessary to send the Company a corresponding request meeting the requirements of clause 5.2.1:
5.2.6. The right to appeal actions (inaction) and decisions of the Company (under No. 6) related to the processing of personal data is exercised in the manner established by the legislation of the Republic of Belarus on appeals of citizens and legal entities.
5.2.7. Termination of processing of the subject's personal data by the Operator may make it impossible to further provide goods/services/works of the Operator to this subject.
6.1. The Company takes necessary legal, organizational, and technical measures to ensure the protection of personal data from unauthorized or accidental access to them, alteration, blocking, copying, dissemination, provision, deletion of personal data, as well as from other unlawful actions regarding personal data.
6.2. Legal measures taken by the Company: The Company has developed and put into effect documents establishing the procedure for processing and ensuring the protection of personal data, which ensure compliance with the requirements of the Law of the Republic of Belarus No. 99-Z dated May 7, 2021 "On Personal Data Protection" and the Law of the Republic of Belarus No. 455-Z dated November 10, 2008 "On Information, Informatization and Information Protection" and other legislation regulating relations in the field of personal data.
6.3. Organizational measures taken by the Company include:
6.4. Technical measures taken by the Company include:
7.1. This Policy may be changed by the Company unilaterally.
7.2. Changes come into force from the date of placement of the new version of the Policy on the Internet on the website at the addresses https://helloclient.app/documents/personal-data-processing-policy and https://helloclient.app/ .
"Client Solutions" LLC
UNP 193782426
Registered by Minsk City Executive Committee on 13.08.2024
Working hours: Mon-Fri from 10:00 to 16:00,
E-mail:
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