Personal Data Processing Policy

CHAPTER 1

GENERAL PROVISIONS

1.1. This Personal Data Processing Policy of BLS Solutions LLC (hereinafter referred to as the "Policy") is developed in compliance with the requirements of the Law of the Republic of Belarus dated May 7, 2021, No. 99-Z "On Personal Data Protection" (hereinafter referred to as the "Law") to protect personal data, as well as the rights and freedoms of individuals during the processing of their personal data.

1.2. The Policy explains to personal data subjects for what purposes and in what manner their personal data is collected, used, or otherwise processed, and defines the rights available to personal data subjects in this regard and the mechanism for their implementation.

1.3. The Policy applies to relations related to the processing of personal data by BLS Solutions LLC of users of the websites «blsspainbelarus.by» and «blsslovakiavisa.by» (hereinafter referred to as the "Website", "Websites") during user account registration, applicants during pre-booking for submitting visa application documents, as well as purchasing services provided by the visa center, job applicants (candidates for employment), individuals with whom BLS Solutions LLC concludes civil law contracts, representatives of business entities authorized to sign contracts and/or perform actions within their execution, persons who have sent inquiries to BLS Solutions LLC (hereinafter, unless otherwise specified, "personal data subjects").

1.4. This Policy does not apply to the processing of personal data in the course of labor activities and during administrative procedures (regarding employees and former employees), to the processing of cookies on the Website, as well as to video surveillance conducted by BLS Solutions LLC.

1.5. Contacts of BLS Solutions LLC:
location address: Republic of Belarus, 220007, Minsk, Tolstogo St., 8-2, office 204;
email address: info.minsk@blshelpline.com;
phone: +375 (44) 732 23 39.

1.6. This Policy is published in free access on the Internet on the organization's websites and is also posted in free access on the information stand of BLS Solutions LLC.

CHAPTER 2

TERMS AND DEFINITIONS

2.1. Personal data - any information relating to an identified physical person or a physical person who can be identified.

2.2. Operator - a state body, legal entity of the Republic of Belarus, other organization, individual, including an individual entrepreneur, who independently or jointly with other specified persons organizes and/or carries out the processing of personal data.

2.3. Authorized person - a state body, legal entity of the Republic of Belarus, other organization, individual who, in accordance with a legislative act, a decision of a state body that is an operator, or based on a contract with the operator, processes personal data on behalf of the operator or in its interests.

2.4. Personal data subject - a physical person in respect of whom personal data processing is carried out.

2.5. Processing of personal data - any action or set of actions performed with personal data, including: collection, systematization, storage, alteration, use, depersonalization, blocking, distribution, provision, deletion of personal data.

2.6. Provision of personal data - actions aimed at familiarizing specific persons or a circle of persons with personal data.

2.7. Distribution of personal data - actions aimed at familiarizing an indefinite circle of persons with personal data.

2.8. Deletion of personal data - actions as a result of which it becomes impossible to restore personal data in information resources (systems) containing personal data and/or as a result of which the material carriers of personal data are destroyed.

2.9. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state.

2.10. Other terms used in the text of the Policy are used in the meanings adopted in the current legislation of the Republic of Belarus.

CHAPTER 3

PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA

3.1. BLS Solutions LLC is an authorized person and processes personal data on behalf of other entities that are operators of personal data (Consulates/Embassies) [hereinafter referred to as "personal data operators"].

3.2. Personal data operators establish the purposes of personal data processing, categories of personal data subjects whose personal data is processed, the list of processed personal data, legal grounds for processing personal data, their storage period, and the list of persons to whom personal data is provided and in what volume, according to the Appendix, which is an integral part of this Policy.

3.3. BLS Solutions LLC processes personal data on behalf of the operator based on the consent of personal data subjects, as well as on other legal grounds provided for by personal data legislation.

3.4. BLS Solutions LLC processes personal data on behalf of the operator both using automation tools and without their use, performing the following actions with personal data depending on the purpose(s) of processing: collection, systematization, storage, alteration, use, provision (including cross-border transfer of personal data), deletion. In cases where the processing of personal data involves their distribution, BLS Solutions LLC specifies the specific conditions under which such an action is possible.

3.5. BLS Solutions LLC limits the processing of personal data to achieving specific, pre-defined processing purposes, and the storage of personal data is carried out in a form that allows the identification of the personal data subject no longer than required by the stated processing purposes.

3.6. The storage periods for personal data of personal data subjects are determined in accordance with the legislation of the Republic of Belarus on archives and records management. When determining the storage periods for personal data, BLS Solutions LLC is guided by the terms defined by the List of Standard Documents Generated in the Activities of State Bodies, Other Organizations and Individual Entrepreneurs, Indicating Storage Periods, approved by the Resolution of the Ministry of Justice of the Republic of Belarus dated May 24, 2012, No. 140 "On the List of Standard Documents". If the storage period for personal data of personal data subjects is not defined by legislation on archives and records management, then the storage period for personal data of these persons is established by BLS Solutions LLC independently, based on the purposes of personal data processing and the specifics of BLS Solutions LLC's activities. Upon expiration of the established storage periods, documents containing personal data are destroyed in the manner prescribed by legislation in the field of archives and records management; personal data contained in the information systems (resources) of BLS Solutions LLC are deleted.

3.7. BLS Solutions LLC processes only those personal data that are necessary to achieve the stated purposes and does not allow their excessive processing.

3.8. For the purpose of ensuring the correct operation and improving the functioning of the Website, the convenience of its use, and collecting analytical information in a generalized form, BLS Solutions LLC uses cookies. The procedure for processing cookies is defined in the Cookie Processing Policy of BLS Solutions LLC, posted on the Internet on the organization's websites.

3.9. For the purpose of ensuring public order, protection of individuals, material assets and other property, as well as ensuring executive and labor discipline, monitoring compliance with document storage procedures, in particular the safety of documents transferred to consulates (including identity documents, travel documents, etc.), BLS Solutions LLC conducts video surveillance in the visa center located at: Minsk, Tolstogo St., 8-2, office 204. The procedure for processing personal data when using the video surveillance system installed in BLS Solutions LLC is defined in the Video Surveillance Policy, posted on the Internet on the organization's websites.

CHAPTER 4

PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA

AUTHORIZED PERSONS, OTHER PERSONS INVOLVED IN THE PROCESSING OF PERSONAL DATA. CROSS-BORDER TRANSFER OF PERSONAL DATA.

4. BLS Solutions LLC processes personal data with the involvement of authorized persons for the purposes according to the Appendix, including those providing information and technical support for the information resources (systems) of BLS Solutions LLC, maintaining accounting and tax records of the economic activities of BLS Solutions LLC, maintaining personnel records, delivering documents to consulates for consideration of Schengen visa issuance, delivering passports to the specified addresses of applicants.

4.1. For the purpose of maintaining personnel, accounting, and tax records of the economic activities of BLS Solutions LLC, the processing of personal data is entrusted to the authorized person - Center for Accounting Support EXPERT LLC (location address: Minsk, Nezavisimosti Ave., 117a, room 4V).

4.2. For the purpose of subscriber maintenance of the information system, to the authorized person, individual entrepreneur Roman G. Kanterman (location address: Minsk, Lozhinskaya St., 19, apt. 36).

4.3. For the purpose of courier delivery of passports to the specified addresses of applicants, BLS Solutions LLC entrusts the processing of applicants' personal data to AVTOLIGHT EXPRESS Limited Liability Company (location address: Republic of Belarus, 220015, Minsk, Odoyevskogo St., 117, room 23).

4.4. For the purpose of communication with Website users through the personal account, conducting pre-booking (reserving the date and time of the appointment by the Applicant for a visit to the visa center), verification of the Applicant at the entrance to the visa center, BLS Solutions LLC provides access to applicants' personal data to the parent company "BLS International Services Ltd", which is the operator in relation to this processing process (location address: BLS International 912, Indra Prakash Building, 21, Barakhamba Road, New Delhi – 110001 (India)).

4.5. For the purpose of informing citizens about the procedure for submitting documents for obtaining a visa, the visa center's working hours, as well as informing citizens about the status of submitted documents, BLS Solutions LLC entrusts the processing of personal data to the authorized person - LKT-SECUR LLC (location address: Russian Federation, 109028, Moscow, Pevcheskiy Pereulok, 4, building 4). During such processing, the provisions of the personal data processing agreement define the requirements for the protection of personal data, in particular, the implementation by LKT-SECUR LLC of organizational, technical, and cryptographic measures to ensure the security of personal data in the manner established by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data", Order of the Federal Service for Technical and Export Control of Russia No. 21 of February 18, 2013 "On Approval of the Composition and Content of Organizational and Technical Measures for Ensuring the Security of Personal Data during their Processing in Personal Data Information Systems".

4.6. For the purpose of transferring applicants' documents to/from the General Consulate of the Kingdom of Spain, BLS Solutions LLC entrusts the processing of personal data to BLS INTERNATIONAL RU LLC (location address: Russian Federation, 115054, Moscow, Kosmodamianskaya Embankment, 52, building 7). During such processing, the provisions of the personal data processing agreement define the requirements for the protection of personal data, in particular, the implementation by BLS INTERNATIONAL RU LLC of organizational, technical, and cryptographic measures to ensure the security of personal data in the manner established by Federal Law No. 152-FZ of July 27, 2006 "On Personal Data", Order of the Federal Service for Technical and Export Control of Russia No. 21 of February 18, 2013 "On Approval of the Composition and Content of Organizational and Technical Measures for Ensuring the Security of Personal Data during their Processing in Personal Data Information Systems". The delivery of applicants' documents to BLS INTERNATIONAL RU LLC is carried out by the following transport companies:
Murud Logistic LLC (location address: Republic of Belarus, 220007, Minsk, Vuzovskiy Pereulok, 3a, office 2);
Semar ExpressBel LLC (location address: Republic of Belarus, 220005, Minsk, Platonova St., 34);
SDEK Global LLC (location address: Russian Federation, 630007, Novosibirsk, Krivoshchekovskaya St., 15, building 1, floor 1,2).
These legal entities directly deliver the cargo (documents located in a closed and sealed container) and do not process the personal data of applicants.

4.7. For the purpose of considering applicants' documents for obtaining Schengen visas, BLS Solutions LLC carries out cross-border transfer of personal data to: General Consulate of the Kingdom of Spain (location address: Russian Federation, 115054, Moscow, Stremyanniy Pereulok, 31/1);
Embassy of the Slovak Republic (location address: Republic of Belarus, 220030, Minsk, Volodarskogo St., 6).
In accordance with the Order of the National Center for Personal Data Protection of the Republic of Belarus dated November 15, 2021, No. 14 "On Cross-Border Transfer of Personal Data", the Kingdom of Spain and the Slovak Republic are included in the list of foreign states on whose territory an adequate level of protection of the rights of personal data subjects is ensured, namely: regulatory legal acts defining the procedure for ensuring the protection of personal data have been adopted, and a regulator in the field of personal data protection has been designated.

4.8. Authorized persons process personal data on the basis of contracts concluded with BLS Solutions LLC and undertake to comply with the principles, rules of processing and protection of personal data provided for by the Law. For each authorized person, a list of permissible actions with personal data that they will perform, the purposes of processing, are defined, the obligation to maintain confidentiality and ensure the security of personal data during their processing is established, and the necessary measures and requirements for the protection of processed personal data in accordance with the Law are specified. BLS Solutions LLC monitors the implementation by authorized persons of measures to ensure the protection of processed personal data on behalf of the operator.

4.9. BLS Solutions LLC provides personal data to other persons for the purposes according to the Appendix, in particular:
RUE "Belpochta" - for the purpose of sending postal correspondence;
state bodies (organizations) if there are legal grounds established by the legislation of the Republic of Belarus on personal data.

CHAPTER 5

METHODS OF OBTAINING CONSENT OF THE PERSONAL DATA SUBJECT FOR THE PROCESSING OF PERSONAL DATA

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

5.2. The consent of the personal data subject can be obtained by BLS Solutions LLC in written form, in another electronic form. In another electronic form, BLS Solutions LLC obtains the consent of the personal data subject by pressing a button on the Website confirming the choice.

5.3. Before obtaining consent, BLS Solutions LLC provides the personal data subject with information about the conditions for processing his personal data, namely:
locatio of BLS Solutions LLC;
purpose of personal data processing;
list of processed personal data necessary to achieve the stated processing purpose;
list of actions performed with personal data necessary to achieve the stated processing purpose, as well as the method of their processing (using automation tools or without using automation tools);
involved authorized persons (if it is necessary to involve them);
in case of cross-border transfer of personal data to foreign states on whose territory an adequate level of protection of the rights of personal data subjects is not ensured, BLS Solutions LLC additionally informs the personal data subject about the risks arising from the lack of an adequate level of protection of his personal data in such states;
the term for which the personal data subject gives consent.
BLS Solutions LLC also, before obtaining consent, explains to the personal data subject his rights related to the processing of personal data, the mechanism for their implementation, as well as the consequences of giving consent or refusing to give such consent.

CHAPTER 6

RIGHTS OF PERSONAL DATA SUBJECTS, MECHANISM FOR THEIR IMPLEMENTATION

6.1. Personal data subjects have the following rights:

6.1.1. Right to amend their personal data.
The personal data subject has the right to demand from BLS Solutions LLC to amend his personal data if they are incomplete, outdated, or inaccurate. For this, the personal data subject must provide the relevant documents and/or their duly certified copies confirming the need for changes, or independently make the relevant changes on the Website by deleting the personal account and creating a new one. BLS Solutions LLC, within 15 calendar days from the date of receipt of the request, makes changes to the personal data if they are incomplete, outdated, or inaccurate.

6.1.2. Right to receive information related to the processing of personal data.The personal data subject has the right to receive information related to the processing of his personal data, containing:
name and location of BLS Solutions LLC;
confirmation of the fact of personal data processing by BLS Solutions LLC;
list of processed personal data and the source of their receipt;
legal grounds and purposes of personal data processing;
the term for which consent to personal data processing was given;
name and location of the authorized person(s), if the processing of personal data by BLS Solutions LLC is entrusted to such person(s).

6.1.3. Right to receive information about the provision of personal data to third parties.The personal data subject has the right to receive from BLS Solutions LLC information about the provision of his personal data to third parties once a calendar year free of charge. BLS Solutions LLC, within 15 calendar days from the date of receipt of the request, will provide information about which personal data and to whom were provided during the year preceding the date of application, or will notify of the reasons for refusal to provide it.

6.1.4. Right to demand termination of personal data processing and/or their deletion. The personal data subject has the right to demand from BLS Solutions LLC free termination of the processing of his personal data, including their deletion, in the absence of other grounds for personal data processing established by the legislation of the Republic of Belarus. BLS Solutions LLC, within 15 calendar days from the date of receipt of the request, will terminate the processing of personal data, carry out their deletion and notify the personal data subject about this, except for cases where BLS Solutions LLC has the right to continue processing personal data if there are other grounds established by personal data legislation.

6.1.5. Right to withdraw previously given consent to the processing of personal data. If BLS Solutions LLC applied to the personal data subject to obtain consent for the processing of personal data, then the personal data subject can at any time, without giving reasons, withdraw his consent. In this regard, the right to withdraw consent cannot be exercised in cases where processing is carried out on other legal grounds for personal data processing. BLS Solutions LLC, within 15 calendar days from the date of receipt of the request, will terminate the processing of personal data, carry out their deletion and notify the personal data subject about this, except for cases where BLS Solutions LLC has the right to continue processing personal data if there are other grounds established by personal data legislation.

6.1.6. Right to appeal actions (inaction) and decisions of BLS Solutions LLC related to the processing of personal data.
If the personal data subject believes that the processing of his personal data is carried out in violation of the legislation of the Republic of Belarus, then the personal data subject can file a complaint with the National Center for Personal Data Protection of the Republic of Belarus. The complaint is considered in the manner established by the legislation on appeals of citizens and legal entities

6.2 To exercise one or more rights specified under No. 6.1.1. - 6.1.4, it is necessary to send BLS Solutions LLC a corresponding application in one of the following ways: in written form (by courier, mail, in person) to the address: Republic of Belarus, 220007, Minsk, Tolstogo St., 8-2, office 204 (2nd floor);
in the form of an electronic document containing the electronic digital signature of the personal data subject, to the email address info.minsk@blshelpline.com.

6.3. To exercise the right to withdraw consent, it is necessary to send BLS Solutions LLC a corresponding application in the manner established by clause 6.2 of the Policy. In case the consent was provided by the personal data subject in another electronic form, the realization of the right to withdraw consent is possible by deleting the personal account on the Website. The right to withdraw consent cannot be exercised in case the processing of personal data is carried out on the basis of a contract or other legal grounds provided for by personal data legislation.

6.4. An application for the exercise of one or more of the above rights must contain: surname, first name, patronymic (if any), date of birth of the personal data subject, address of his place of residence (stay); statement of the essence of the requirements; personal signature or electronic digital signature of the personal data subject.

6.5. In case of sending an electronic message about the exercise of the right to withdraw consent, which was provided by the personal data subject in another electronic form, such a message must contain: a list of personal data for the processing of which the personal data subject provided his consent in another electronic form; statement of the essence of the requirements.

6.6. The response to the application is sent to the personal data subject in a form corresponding to the form of submission of the application, unless otherwise stated in the application itself.

6.7. The personal data subject has the right to apply for assistance in realizing his rights to the person responsible for internal control over the processing of personal data in BLS Solutions LLC or by sending an electronic message to the email address alexander.shtelmakh@blsinternational.net.

CHAPTER 7

FINAL PROVISIONS

7.1. BLS Solutions LLC has the right, at its discretion, to unilaterally change and/or supplement the terms of this Policy without prior notice to personal data subjects by posting a new version of the Policy on the Website.

7.2. Issues related to the processing of personal data not covered by this Policy are regulated by the legislation of the Republic of Belarus.

7.3. This Policy comes into force from the moment of its approval by the Director of the organization.

Annex 1 To the personal data processing policy of BLS Solutions LLC

List of purposes of personal data processing in BLS Solutions LLC, categories of personal data subjects whose data are processed, list of processed personal data, legal grounds for personal data processing, personal data storage period.