Privacy policy

Personal Data Processing Policy

This Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been prepared by the Site Administration in accordance with the provisions and requirements of the current legislation of the Republic of Belarus and is aimed at defining the conditions for obtaining (collecting) information about Users and Respondents, using and transmitting information about Users and Respondents, providing access to information about Users and Respondents to third parties.

This Policy is a legally binding document for Users and Respondents using the Site in accordance with its main purpose.
Each User and Respondent undertakes to familiarize themselves with this Policy before using the Site.

An integral part of this Policy are other documents, including, but not limited to, the User Agreement .

The Site Administration and the User/Respondent are referred to collectively as the “Parties” and separately as the “Party” in the text of the Policy.

Terms used in the Policy
1. For the purposes of this Policy, the following terms are used in the following meaning:
  1. Website – the result of intellectual activity, which is a composite work located in the Internet information and telecommunications network under a specific network address (domain, domain name) and includes computer programs (software) that ensure its technological and technical functioning, a graphic solution (design, the order of elements, the color scheme used, etc.), content, namely text information, photographic images, pictures, videos, audio recordings, etc., united by a single purpose and meaning and presented in the form of web pages. The Site in the text of this Agreement means a Site belonging to the Site Administration located on the Internet information and telecommunications network under a domain name (domain, address) – www.en.target-group.by, as well as the derived web pages included in it.
  2. The Site Administration is IP Romanenko D.M., who has the rights to use, manage and dispose of the Site, provides the Site for use by Users and provides Users with the services provided for in this Agreement, described directly on the Site itself or defined by the technical functionality of the Site. On behalf of the Site Administration, its authorized representative (moderator), appointed directly by the Site Administration, acts on the Site.
  3. The User is an individual, an individual entrepreneur or a legal entity represented by its representative who uses it in accordance with the main purpose of the Site.
  4. Respondent – an individual who is taking a Survey and provides answers to the questions posed in the Survey, or performs tasks set in the Survey.
  5. A survey is a set of questions and/or tasks on a particular topic with answer options (if any) published by the User on the Site in order to find out the opinion of Respondents and get answers to them from Respondents.
  6. Information (data) – any information about the User/Respondent or concerning the User/Respondent.
  7. E-mail (E-mail) is a special technology that ensures the forwarding and receipt of electronic messages, letters, files, documents, etc. through the use of the Internet information and telecommunications network.
  8. Personal data processing – any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2. The Policy may use terms not defined in clause 1.1. of this Policy. In these cases, the interpretation of the terms is carried out in accordance with the text and meaning of this Policy. In the absence of an unambiguous interpretation of the term in the text of the Policy, one should be guided, firstly, by the interpretation of the terms used on the Site, including, but not limited to, specified in other legal documentation posted on the Site; secondly, by the customs of business practice in the relevant field of activity; thirdly, by the provisions of the current legislation of the Republic of Belarus.
3. All definitions provided for in paragraph 1.1. of this Policy can be used both in the singular and plural, without prejudice
  to their meaning.
4. All definitions of this Policy are formulated only for convenience and cannot affect the legal significance of individual provisions of the Policy.
Acceptance of the Policy
1. Acceptance of the Policy means reading, familiarization, understanding of all the terms of the Policy in aggregate and in interrelation, as well as each of them individually, full, unconditional, unconditional and irrevocable consent of the User or Respondent with all the terms, conditions and requirements defined in the Policy.
2. By submitting their acceptance of the Policy, the User/Respondent undertakes to strictly comply with all the rules set out in the Policy. Acceptance of the Policy indicates the intention, will, desire and consent of the User/Respondent to comply with and comply with the terms of this Policy
3. From the moment of acceptance of this Policy, it is considered that the User/Respondent has accepted the rules set out in the Policy and entered into legal relations with the Site Administration.
4. Acceptance of the Policy is carried out by the User/Respondent performing concrete (actual) actions indicating that he has read and accepted the terms of the Policy. Within the framework of this Policy and when using the Site, the acceptance of the Policy is the actual use of the Site (its technical capabilities and functionality), and/or registration of the User / Respondent on the Site. Additionally and separately from the above, the acceptance of the Policy is also recognized and considered payment for services provided by the Site Administration on a reimbursable basis.
Policy Objective
1. This Policy is aimed at ensuring proper protection of User Information, including their personal data, from unauthorized access to it by third parties, determining the procedure for obtaining, providing and using User Information.
2. This Policy is aimed at defining exclusively general provisions regarding the receipt and use of User Information. Certain features of obtaining and using Information may be established by other documents published on the Site, or may be determined by the technical device of the Site.
Personal data of users
1. The list of Information required for the use of the Site is set solely at the discretion of the Site Administration.
2. Purposes of personal data processing:
  - Fulfillment of its contractual obligations to Users/Respondents, in particular to provide the services of the Site for the use of Users/Respondents, providing services defined by the functionality of the Site;
  - Identification of Users/Respondents in accounting, systematization, accumulation and transmission of certain information about or for them, etc.;
  - Communication and correspondence with Users/Respondents, providing answers to questions from Users/Respondents in feedback mode, notifying Users/Respondents about significant circumstances when using the Site, etc.
3. An individual User places the following data on the Site: surname, first name, patronymic, email address, password, contact phone number, address and other data at the discretion of the Site Administration.
4. The Respondent places on the Site the data that are determined by the Site Administration and established by the technical functionality of the Site. The Respondent understands, gives his permission and agrees that by indicating his personal data on the Website, they will become available to the User conducting the corresponding Survey.
5. The posting of personal data of the User/Respondent on the Website is aimed at creating and conducting Surveys by Users among Respondents.
6. The User/Respondent has the right to delete personal information, as well as any other information about himself posted on the Site. To do this, the User /Respondent should contact the Site Administration by e-mail: marketing.target.group@ya.ru with a request to delete or change the personal data of the User/Respondent.
7. By using the Site, the User/Respondent agrees and accepts that the Site Administration reserves the right to use his personal data anonymously and in a generalized form for statistical purposes.
8. The Site Administration undertakes not to provide any personal data about Users /Respondents to individuals and organizations claiming possible misuse of such information (sending unauthorized advertising, spam, providing information to other persons, etc.).
9. The Site Administration is not responsible for the possible misuse of information posted on the Site by Users / Respondents or other persons, which occurred without notifying the Site Administration with a violation of the information security of the Site or in the absence of such a violation.
10. The User/Respondent undertakes to store data for the use of the Site in a place inaccessible to any third parties, as well as not to disclose or provide relevant information to third parties. The User/Respondent bears full responsibility and the risk of all possible potential and real negative consequences associated with non-compliance with this rule.
11. The Site Administration processes only those personal data of Users that have been posted on the Site. Personal data of Users is processed using the software, hardware and technical means of the Site.
Sources of information
1. The Site Administration receives information about Users/Respondents in the following ways (from the following sources):
  1. Information provided directly by Users/Respondents themselves, including, but not limited to the following:
    - Information about the User/Respondent received from another User/Respondent, in particular the email address for sending notifications and messages;
    - Information about the User /Respondent specified as part of the formation and creation of the Survey or providing answers to questions / tasks of the Survey.
    - Information about the User/Respondent provided at the motivated request of the Site Administration.
    1. The Site Administration has the right, at its discretion, to request or oblige the User/Respondent to provide any Information necessary for it to fulfill its obligations to Users/Respondents. The User/Respondent is hereby obligated
      to provide exclusively reliable, complete and up-to-date information about the User/Respondent.
  2. Information from software, technical and hardware services (software, etc.) used by the User/Respondent when viewing the Website pages, including, but not limited to the following:
    - Information about hardware and software devices used by Users/Respondents when visiting the Site, including the model and version of the operating system, unique device identifiers, as well as data about the mobile network and the phone number from which the User/Respondent visits the Site;
    - Information recorded in server logs, in particular information about User/Respondent search queries, cookies, IP address, system failures, cookie data, data about User/Respondent browsing of certain web pages of the Site;
    - Information about the territorial location of the User/Respondent provided via the Internet, etc.;
    - Information about the domain of the provider of the User/Respondent, the country of his location, etc.
Notifications and assurances
1. The User/Respondent hereby acknowledges and agrees that his/her posting of information on the Site, as well as its transfer to the Site Administration, including his/her personal data, is carried out independently, voluntarily and at the personal discretion of the User/Respondent. By posting their personal data on the Site, the User/Respondent confirms that he/she does this voluntarily, and also that he/she voluntarily provides them to the Site Administration for processing.
2. The User/Respondent hereby consents to the processing of his/her personal data in accordance with the provisions of the current legislation of the Republic of Belarus. The Site Administration has the right to use the personal data of the User / Respondent in order to fulfill its obligations to the User / Respondent, including those specified and defined in the User Agreement, in accordance with the terms of the current legislation on personal data.
3. The Site Administration guarantees that only those actions are performed with respect to personal Users/Respondents that are necessary or desirable to achieve the above goals, including: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), blocking, deletion, destruction of personal data. The processing of personal data is carried out both with the use of automation tools and without the use of such tools.
4. The User/Respondent hereby agrees to be sent by the Site Administration (to e-mail, Personal Account, phone number, by other means) various SMS mailings, e-mail letters and other forms of sending/receiving information, including advertising and informational messages of any kind and content. At the same time, the User / Respondent has the right to independently determine (regulate) the frequency of receipt of advertising or informational messages to his address (e-mail address) (frequency of mailing). At the same time, despite the mailing restrictions set by the User / Respondent, the Site Administration has the right, at its discretion, to send any messages to him at any time.
5. The Site Administration does not verify the accuracy of the Information provided or received from Users /Respondents, does not monitor their legal and legal capacity. It is assumed and the Site Administration proceeds from the fact that the User / Respondent in all cases, without exception, provides complete and reliable information about himself and keeps this information up to date.
6. When processing personal data of Users/Respondents, the Site Administration undertakes to take all organizational and technical measures to protect them from unauthorized access in a way not provided for by the Site. However, it is possible that as a result of a malfunction of the Site, a virus or hacker attack, technical malfunctions and other circumstances, the personal data of Users / Respondents may become available to other persons.
7. The Site Administration undertakes not to post personal data of other persons on the Site, as well as not to use the personal data of other Users / Respondents in any way that does not comply with the requirements of the legislation of the Republic of Belarus, for illegal or illegal purposes, for profit and for any other purposes that do not correspond to the purposes of the Site.
Transfer of user information
1. The Site Administration has no right, except for the cases specified in paragraph 6.2. of this Policy, to transfer Information about the User/Respondent to third parties without the consent of the User/Respondent, both for a fee and free of charge.
2. The Site Administration has the right to transfer information about the User/Respondent without the consent of the User/Respondent and without prior notification in the following cases:
  - State bodies, including law enforcement agencies, bodies of inquiry and investigation, courts, local self-government bodies at their reasoned request;
  - On the basis of a judicial act to third parties;
  - To third parties and public organizations at their reasoned request in case of violation or alleged violation of their rights;
  - In other cases stipulated by the current legislation.
Information about the implemented requirements
for the protection of personal data
1. The Site Administration when providing the Site for use by Users/Respondents respect the privacy of personal data subjects. The Site Administration takes care of the protection of personal data provided to it by Users/Respondents.
2. Access to the information constituting personal data is restricted. Organizational, legal and technical measures have been taken to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, dissemination of personal data, as well as from other illegal actions with respect to personal data in accordance with the established requirements of authorized authorities.
3. The Website Administration fulfills the requirements for the protection of personal data during their processing, including in personal data information systems, established by the legislation of the Republic of Belarus
Dispute resolution procedure
1. Hereby, the Site Administration and the User/Respondent have established a claim-based pre-trial procedure for resolving disagreements and disputes arising from the application of this Policy. The deadline for responding to the submitted claim is 10 (ten) working days from the date of its receipt.
2. In case of failure to reach an agreement on disputed issues, the dispute arising from this Policy is subject to judicial review in accordance with the current legislation at the location of the Site Administration.
Policy Action
1. This Policy comes into force from the moment it is posted on the Internet on the Website specified in paragraph 1.1.1. of this Policy.
2. This Policy has been put into effect for an indefinite period and becomes invalid upon its cancellation by the Site Administration.
3. If changes are made to the Policy, such changes will take effect from the moment the new version of the Policy is published on the Website, unless another date for the changes to take effect is additionally determined at the time of its publication. The Site Administration has the right to unilaterally make changes to the text of the Policy.
4. The User/Respondent undertakes to independently monitor changes to the provisions of this Policy and is responsible for the negative consequences associated with non-compliance with this obligation.
5. If the User / Respondent does not agree with the relevant changes, the User / Respondent is obliged to stop using the Site and refuse the services provided by the Site Administration. Otherwise, the continued use of the Site by the User/Respondent means that the User/Respondent agrees to the terms of the new version of the Policy.
6. The current version of the Policy is available on the Website at: https://en.target-group.by/politika-konfidencialnosti/
7. This Policy has been compiled in Russian. Russian Russian version of the Policy should there be any inconsistencies between the Russian version of the Policy and the version of the Policy translated into another language, the provisions of the Policy drawn up in Russian will have priority and direct application.