1. General Provisions
       This personal data processing policy has been drawn up 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 — the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure their protection by LLC "ElSiDi Group" (hereinafter — the Operator).
       1.1. The Operator considers the observance of the rights and freedoms of individuals in the processing of their personal data, including the protection of the right to privacy, personal and family confidentiality, to be its most important goal and condition for carrying out its activities.
       1.2. This Operator policy on the processing of personal data (hereinafter — the Policy) applies to all information that the Operator may obtain about visitors to the website lcd-group.info/page (hereinafter — the Website).
       1.3. The Operator's activities are related to the import of goods. The Website is used exclusively for informational purposes; payment for goods or services through the Website is not carried out.

2. Basic Concepts Used in the Policy
       2.1. Personal data — any information relating to an identified individual or an individual who can be identified.
       2.2. Subject of personal data (hereinafter — the User) — any individual whose personal data is processed by the Operator, including any visitor to the Website.
       2.3. Operator — a legal entity that independently or jointly with other persons organises and (or) carries out the processing of personal data, and also determines the purposes of processing personal data.
       2.4. Processing of personal data — any action or set of actions performed with personal data, including collection, systematisation, storage, modification, use, anonymisation, blocking, distribution, provision, and deletion of personal data.
       2.5. Automated processing of personal data — processing of personal data using computer technology.
       2.6. Distribution of personal data — actions aimed at making personal data available to an indefinite number of persons.        2.7. Provision of personal data — actions aimed at making personal data available to a specific person or a specific group of persons.
       2.8. Blocking of personal data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
       2.9. Deletion of personal data — actions as a result of which it becomes impossible to restore personal data and (or) as a result of which the physical carriers of personal data are destroyed.
       2.10. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state.
       2.11. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.

3. Basic Rights and Obligations of the Operator
       3.1. The Operator has the right to:
       - receive reliable information and (or) documents containing personal data from the subject of personal data;
       - in the event that the subject of personal data withdraws consent to their processing, continue processing personal data without such consent if there are grounds provided for by the Personal Data Law;
       - independently determine the composition and list of measures necessary and sufficient to ensure fulfilment of the obligations provided for by the Personal Data Law.
       3.2. The Operator is obliged to:
       - provide the subject of personal data, upon their request, with information concerning the processing of their personal data;
       - organise the processing of personal data in the manner established by the legislation of the Republic of Belarus;
       - respond to requests and inquiries from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
       - take legal, organisational and technical measures to protect personal data from unauthorised or accidental access, modification, blocking, distribution, provision, deletion, as well as from other unlawful actions with respect to personal data;
       - publish or otherwise ensure free access to this Policy;
       - cease processing and delete personal data in the manner and in the cases provided for by the Personal Data Law;
       - fulfil other obligations provided for by the Personal Data Law.

4. Basic Rights and Obligations of Personal Data Subjects
       4.1. Personal data subjects have the right to:
       - receive information concerning the processing of their personal data. Information is provided to the subject of personal data by the Operator in an accessible form;
       - require the Operator to modify their personal data if it is incomplete, outdated or inaccurate;
       - require the cessation of processing of their personal data, including its deletion, in the absence of grounds for processing provided for by the Personal Data Law;
       - withdraw consent to the processing of personal data; - appeal against the actions (inaction) of the Operator in the processing of personal data to the authorised body for the protection of the rights of personal data subjects or through legal proceedings;
       - exercise other rights provided for by the legislation of the Republic of Belarus.
       4.2. Personal data subjects are obliged to:
       - provide the Operator with reliable information about themselves;
       - inform the Operator of any changes to their personal data.
       4.3. Persons who have provided the Operator with false information about themselves or information about another personal data subject without the latter's consent shall bear liability in accordance with the legislation of the Republic of Belarus.

5. Principles of Personal Data Processing
       5.1. Processing of personal data is carried out on a lawful and fair basis.
       5.2. Processing of personal data is limited to achieving specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of their collection is not permitted.
       5.3. The merging of databases containing personal data, the processing of which is carried out for purposes incompatible with each other, is not permitted.
       5.4. Only personal data that corresponds to the purposes of their processing shall be subject to processing.
       5.5. The content and volume of personal data being processed correspond to the stated purposes of processing. Excessive processing of personal data in relation to the stated purposes is not permitted.
       5.6. When processing personal data, their accuracy, sufficiency, and where necessary, relevance in relation to the purposes of processing are ensured. The Operator takes the necessary measures to delete or clarify incomplete or inaccurate data.
       5.7. Storage of personal data is carried out in a form that allows identification of the personal data subject, for no longer than required by the purposes of processing, unless a different storage period is established by the legislation of the Republic of Belarus or by agreement. Upon achievement of the processing purposes, personal data are deleted or anonymised.

6. Purposes of Personal Data Processing
       Purpose of processing: processing of incoming consultation requests; sending informational materials by email; conclusion, performance and termination of civil law contracts.
       Personal data:
       — email address;
       — phone numbers;
       — last name and first name.
       Legal grounds: consent of the personal data subject (Article 5 of the Personal Data Law); performance of a contract.
       Types of processing: collection, systematisation, storage, use, deletion and anonymisation of personal data; sending informational messages to an email address.

7. Conditions for the Processing of Personal Data
       7.1. Processing of personal data is carried out with the consent of the personal data subject, expressed in written or electronic form, unless otherwise provided by the Personal Data Law.
       7.2. Processing of personal data is permitted without the consent of the subject in cases provided for by Article 6 of the Law of the Republic of Belarus "On the Protection of Personal Data", including:
       - for the performance of a contract to which the personal data subject is a party;
       - for the exercise of the rights and legitimate interests of the Operator or third parties, provided that the rights and freedoms of the personal data subject are not violated;
       - in other cases provided for by the legislation of the Republic of Belarus.

8. Procedure for the Collection, Storage, Transfer and Other Types of Processing of Personal Data
       The security of personal data processed by the Operator is ensured through the implementation of legal, organisational and technical measures necessary to fully comply with the requirements of the legislation of the Republic of Belarus in the field of personal data protection.
       8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent access to personal data by unauthorised persons.
       8.2. The User's personal data shall under no circumstances be transferred to third parties, except in cases provided for by the legislation of the Republic of Belarus, or if the personal data subject has given the Operator consent to transfer data to a third party for the purpose of fulfilling obligations under a civil law contract.
       8.3. In the event of inaccuracies in personal data being identified, the User has the right to send the Operator a notification to the email address info@lcd-group.info marked "Personal Data Update".
       8.4. The period of personal data processing is determined by the achievement of the purposes for which they were collected, unless a different period is provided for by agreement or by the legislation of the Republic of Belarus. The User has the right at any time to withdraw consent to the processing of personal data by sending a notification to the email address info@lcd-group.info marked "Withdrawal of Consent to the Processing of Personal Data".
       8.5. Information collected by third-party services (including communication tools and other service providers) is stored and processed by such persons in accordance with their user agreements. The Operator is not responsible for the actions of third parties.
       8.6. The Operator ensures the confidentiality of personal data.
       8.7. The Operator stores personal data in a form that allows identification of the subject for no longer than required by the purposes of processing, unless a different storage period is established by the legislation of the Republic of Belarus or by agreement.
       8.8. The grounds for ceasing the processing of personal data are: achievement of the processing purposes, expiry of the consent period, withdrawal of consent by the personal data subject, a request from the subject to cease processing, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with Personal Data
       9.1. The Operator carries out the collection, systematisation, storage, modification, use, anonymisation, blocking, distribution, provision and deletion of personal data.
       9.2. The Operator carries out automated processing of personal data with the receipt and (or) transmission of the information obtained via information and telecommunication networks or without such transmission.

10. Cross-Border Transfer of Personal Data
       10.1. Cross-border transfer of personal data to the territory of foreign states is carried out by the Operator in accordance with the requirements of Article 10 of the Law of the Republic of Belarus "On the Protection of Personal Data".
       10.2. Cross-border transfer of personal data to the territory of foreign states that ensure an adequate level of protection of the rights of personal data subjects is carried out with the consent of the subject or on other lawful grounds.
       10.3. Cross-border transfer of personal data to the territory of foreign states that do not ensure an adequate level of protection of the rights of personal data subjects is permitted exclusively in cases provided for by the Personal Data Law, including with the written consent of the personal data subject.

11. Confidentiality of Personal Data
       The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by the legislation of the Republic of Belarus.

12. Final Provisions
       12.1. The User may obtain clarification on matters relating to the processing of their personal data by contacting the Operator at the email address: info@lcd-group.info.
       12.2. Any changes to this Policy are reflected in this document. The Policy is valid indefinitely until it is replaced by a new version.
       12.3. The current version of the Policy is published on the Website at: lcd-group.info/page.
       12.4. On matters relating to the application of personal data protection legislation, the personal data subject has the right to contact the National Centre for Personal Data Protection of the Republic of Belarus.
POLICY
on the Processing of Personal Data
of ООО «ЭлСиДи Групп»