STATEMENT
on Personal Data Processing Policy

CHAPTER 1. GENERAL PROVISIONS

1.1. Lawyer City Law Firm LLC (hereinafter referred to as "Lawyer City Law Firm" or the "Company") pays special attention to the protection of personal data when processed by the Company and respects the rights of data subjects.

1.2. The adoption of this Personal Data Processing Policy (hereinafter referred to as the "Policy") is one of the measures taken by the Company, as provided for in Article 17 of the Law of the Republic of Belarus No. 99-Z of May 7, 2021, "On the Protection of Personal Data" (hereinafter referred to as the "Law").

1.3. The terms and definitions contained in Article 1 of the Law are used in the Policy with the same meaning.

1.4. The Policy is developed in accordance with the requirements of the Law and defines the activities of Lawyer City Law Firm (UNP 192481625, address: 220012, Republic of Belarus, Minsk, Platonova St., 49, room 46-15) in relation to the processing of personal data of data subjects.

1.5. The Policy explains to data subjects how and for what purposes their personal data is collected, used, or otherwise processed, and also reflects the rights of data subjects in this regard and the mechanism for their realization.

1.6. The Policy does not apply to the processing of personal data in the course of employment and in the implementation of administrative procedures (in relation to employees and former employees of the Company), as well as users of the Company's website (in terms of cookies).

1.7. The Policy applies in cases where Lawyer City Law Firm acts as both a data controller and a processor.

1.8. When processing personal data, the Company is guided by: the Law of the Republic of Belarus No. 99-Z of May 7, 2021, "On the Protection of Personal Data"; the Decree of the President of the Republic of Belarus No. 422 of October 28, 2021, "On Measures to Improve the Protection of Personal Data"; the Rules for the Provision of Legal Services, approved by the Ministry of Justice of the Republic of Belarus on December 16, 2022, No. 153; and the Company's local regulatory documents.

1.9. The Policy regulates the processing of personal data both with and without the use of automated means, if such processing ensures the search for and/or access to personal data according to specific criteria (files, lists, databases, logs, etc.).

1.10. The mailing address of Lawyer City Law Firm is: 220012, Republic of Belarus, Minsk, Platonova St., 49, building B, floor 9, office 907; website: https://Lcity.by/; e-mail: info@Lcity.by.

CHAPTER 2. PURPOSES AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA. CATEGORIES OF DATA SUBJECTS. LIST AND STORAGE PERIOD OF PERSONAL DATA.

2.1. Lawyer City Law Firm processes personal data in the following cases:

Purposes of personal data processing

Categories of data subjects whose data is processed

List of personal data being processed

Legal grounds for processing personal data

Retention period for personal data

Review of appeals, including those in the suggestion box

Citizens (Individuals), including representatives of companies

Last name, first name, address, reason for the appeal, and any other personal information provided

абз. 20 ст. 6 Закона (ст. 12 Закона Республики Беларусь  от 18  июля  2011  г. № 300-З ”Об обращениях граждан и юридических лиц“)

5 лет (п. 85 Перечня типовых документов Национального архивного фонда Республики Беларусь, утв. постановление Министерства юстиции Республики Беларусь от 24 мая 2012 г. № 140  (далее – Перечень)

Review of appeals left on the Company's website via the "Contact Us" feedback form

 

Users of the Company's website who have left an appeal

 

Data provided by the website user when filling out the "Contact Us" form located at the link: https://lcity.by/en/contact/#contact-us, namely: first name, last name, phone number, email address, and any other information provided by the User at their discretion

 

Consent

1 year from the date of consent

Recruitment and selection of candidates for employment in the Company.

 

Website users are considered candidates for employment within the Company.

 

Data provided by candidates when filling out forms located at: https://lcity.by/careers/, namely: first name, last name, email address, contact phone number, and any other information the candidate may include in their attached resume (including date of birth, residential address, citizenship, education, work experience, and military service record)

 

Consent

If not hired, data will be retained for 1 year. If hired, data will be retained for 1 month

Conclusion, performance, amendment and termination of agreements with clients

Clients and their representatives

Data provided by the client (or their representative) in the context of the conclusion and performance of the agreement 

Paragraph 15, Article 6 of the Law (processing based on an agreement with the data subject)

3 years after the expiration of the agreement or completion of a tax audit, whichever is later; if no tax audit is conducted, 10 years after the expiration of the agreement

Conclusion and performance of civil law agreements not related to the main types of activities (e.g., supply, purchase and sale, contracting, etc.)

Persons authorized to sign the agreement

Фамилия, собственное имя, отчество либо инициалы лица,  должность лица, подписавшего договор, иные данные в соответствии с условиями договора (при необходимости)

Paragraph 15, Article 6 of the Law (processing based on an agreement with the data subject)

3 years after the expiration of the agreement or completion of a tax audit, whichever is later; if no tax audit is conducted, 10 years after the expiration of the agreement

Review of resumes (applications) of job candidates for vacant positions for the purpose of concluding an employment contract

Individuals who submitted resumes

Surname, given name, patronymic, year of birth, education and work experience, contact phone number, email address, and other information provided by the data subject in the resume at their discretion

Paragraph 16, Article 6 of the Law – processing of personal data when they are contained in a document addressed to the controller and signed by the data subject, in accordance with the content of such document

If not hired, data will be retained for 1 year. If hired, data will be retained for 1 month

Employment (hiring)

Job applicants and their family members

In accordance with Article 26 of the Labor Code of the Republic of Belarus and other legislative acts

Paragraph 8 of Article 6 of the Law (Article 26 of the Labor Code, clause 11 of Presidential Decree No. 5 of December 15, 2014, and other legislative acts)

After dismissal – 55 years (item 673 of the List)

Ensuring compliance with laws and other regulatory legal acts

Members of the Company and affiliated persons of the Company

Surname, given name, patronymic of the member of the Company, date of birth, data of the identity document, actual residential address; surname, given name, patronymic of the spouse, parents (guardians), adult children who are emancipated or married before reaching the age of eighteen and their spouses, adoptive parents, adult adopted children and their spouses, grandparents, adult grandchildren and their spouses, brothers and sisters, parents of the spouse of a natural person who is an affiliated person of the Company

Paragraph 20 of Article 6 of the Law – processing of personal data when it is necessary for the performance of duties (powers) provided for by legislative acts (Article 56 of the Law of the Republic of Belarus of 09.12.1992 N 2020-XII (as amended on 18.07.2022) "On Commercial Companies")

For a period of five years after leaving the membership

Рассмотрение обращений, оставленных на сайте Общества через «Форму обратной связи»

Пользователи сайта Общества, оставившие обращение — клиенты и их представители

Данные, которые Пользователь сайта оставляет при заполнении на сайте «Формы обратной связи» по ссылке: https://lcity.by/feedback/, а именно: наименование клиента, адрес электронной почты, номер телефона и иные данные, указанные Пользователем в обращении по своему усмотрению

Consent

1 year from the date of consent

 2.2. Lawyer City Law Firm processes only the personal data necessary to fulfill the stated purposes and does not allow excessive processing. 

2.3.  Сроки обработки, в том числе хранения, персональных данных субъектов персональных данных на бумажных и иных материальных носителях, а также в информационных системах определяются Обществом в соответствии с законодательством Республики Беларусь. 

2.4. If the terms of processing of personal data are not established by law, their processing and storage shall be carried out no longer than is required for the purposes of processing, including storage, of personal data. 

2.5. Upon achievement of the goals of Lawyer City Law Firm as an Operator and as an Authorized Person under a processing agreement, as well as in the event of withdrawal of consent by the data subject, the Company erases personal data within the time period provided for by the legislation of the Republic of Belarus. 

CHAPTER 3. ORDER AND CONDITIONS OF PERSONAL DATA PROCESSING

3.1. The basis for processing personal data is the consent of the data subject, except in cases provided for by the legislation of the Republic of Belarus, when personal data is processed without consent. 

3.2. The consent of the data subject is a free, specific, informed expression of his will, by which he permits the processing of his personal data. 

Refusal to give consent to the processing of personal data entails the impossibility for the Company to perform actions aimed at such processing.

3.3. Consent is given until it is revoked. 

3.4. Lawyer City Law Firm performs actions carried out with personal data (including collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, erasure) of personal data for the purposes specified in the Policy. 

3.5. The Company processes personal data using automated means and without using such means, as well as in a mixed manner, including in information and telecommunication networks, for the purposes specified in the Policy. 

3.6. Access of representatives of state authorities to personal data is regulated by the current legislation of the Republic of Belarus. 

3.7. Personal data may be processed by:

— employees of Lawyer City Law Firm holding positions specified in the List of divisions and positions authorized to process personal data within the Company;

— third parties processing personal data on behalf of the Company (authorized persons).

3.8. The Company may transfer personal data to the following third parties (authorized persons) for the following purposes:

— Reliable Programs LLC — stores data on its server. UNP: 100160363. Address: 220006, Minsk, Aranская St., 8 (block 1, 4th floor). Privacy policy: https://hoster.by/downloads/pd_processing-policy.pdf;

— Google Analytics – web analytics tool by Google, Inc. Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. Google's Privacy policy: https://policies.google.com/privacy?hl=ru#infocollect; 

— other services and advertising platforms engaged by the Company to fulfill its obligations under agreements with data subjects

3.9. Within the framework of the purposes of personal data processing established by this Policy, the Company does not carry out cross-border transfer of personal data

CHAPTER 4. RIGHTS OF DATA SUBJECTS AND THE MECHANISM FOR THEIR IMPLEMENTATION

4.1. A data subject has the right to:

4.1.1. withdraw their consent, if the Company sought the data subject's consent for the processing of personal data, by submitting a statement to the Company in the manner established by clause 4.2 of the Policy, or in the form in which their consent was obtained. 

4.1.2. obtain information regarding the processing of their personal data, including:

the location of the Company;

confirmation of the fact that the Company is processing the personal data of the applicant;

their personal data and the source of its receipt;

the legal basis and purposes of personal data processing;

the term for which their consent was given (if the processing of personal data is carried out on the basis of consent);

the name and location of the authorized person (authorized persons);

other information provided for by law;

4.1.3. demand that the Company make changes to their personal data if the personal data is incomplete, outdated or inaccurate. For these purposes, the data subject attaches the relevant documents and/or their certified copies, confirming the need to make changes to the personal data, in the manner established by clause 4.2 of the Policy;

4.1.4. obtain from the Company information about the provision of their personal data processed by the Company to third parties. This right may be exercised once a calendar year, and the provision of such information is free of charge;

4.1.5. demand that the Company cease processing their personal data free of charge, including erasing it, in the absence of grounds for processing personal data provided for by the Law and other legislative acts.

4.1.6. to appeal to a court of law any actions (or inaction) and decisions of the Company that violate their rights when processing personal data, in accordance with the procedure established by civil procedural law.

4.2. To exercise their rights related to the processing of personal data by the Company, the data subject submits a written statement to the Company at the mailing address indicated in clause 1.1 of this Policy. 

Regardless of the form and method of exercising the rights, such a statement must contain:

First name, last name , patronymic (if any) of the data subject, their residential address;

the date of birth of the data subject;

a statement of the essence of the data subject's claims;

the identification number of the data subject, or, in the absence of such a number, the number of the document certifying the identity of the data subject, in cases where this information was indicated by the data subject when giving their consent or personal data is processed without the consent of the data subject;

the personal signature of the data subject.

The Company does not consider statements from data subjects sent in other ways (e-mail, telephone, fax, etc.).

4.3. A statement from a data subject submitted in the prescribed form is considered by the Company within the time period established by law, and the subject is notified of the results of the consideration of the statement.

4.4. The right to appeal the actions (inaction) and decisions of the Company related to the processing of personal data is exercised in the manner prescribed by the legislation of the Republic of Belarus on appeals of citizens and legal entities.

4.5. The withdrawal of consent to the processing of personal data entails the impossibility of further processing of personal data in accordance with the purposes of processing, the termination of the processing of personal data, their erasion, and, in the absence of technical feasibility, their blocking. 

CHAPTER 5. FINAL PROVISIONS

5.1. Issues related to the processing of personal data not fixed in this Policy are regulated by the legislation of the Republic of Belarus. 

5.2. In the event that any provision of the Policy is found to be invalid or unenforceable, the other terms shall remain in full force and effect, to the extent permitted by applicable law. 

5.3. The Policy may be amended by the Company without notifying data subjects. The current version of the Policy is constantly available at the link https://lcity.by/privacy-policy/.

 
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