Personal Data Processing Policy
OOO «Future Reality»
Chapter 1. General Provisions
1.1. This Personal Data Processing Policy of OOO «Future Reality» (hereinafter — the Policy) has been developed in fulfilment of the requirements of the Law of the Republic of Belarus of 7 May 2021 No. 99-Z "On Personal Data Protection" (hereinafter — the Law) and explains to data subjects the purposes, legal grounds and procedure for processing their personal data, as well as the rights available to data subjects in this regard and the mechanism for exercising them.
1.2. Contacts of OOO «Future Reality»: UNP 193846830, registered address: Republic of Belarus, 220004, Minsk, Pobediteley Ave., 7A, office 8, information resource: ceo@ftr.by (hereinafter — the Website).
1.3. The Policy does not apply to the processing of personal data:
- in the course of employment and when carrying out administrative procedures (in respect of employees and former employees);
- when processing cookie files on the Website (the Cookie Processing Policy is published on the Internet at: https://ftr.by/cookies).
1.4. The Policy is published in open access on the Internet at https://ftr.by/privacy.
1.5. For the purposes of this Policy, terms are used in the meanings defined in Article 1 of the Law of the Republic of Belarus "On Personal Data Protection".
1.6. The Policy may be amended by OOO «Future Reality» at any time unilaterally without prior notice to data subjects. The new version of the Policy enters into force from the moment of its approval.
Chapter 2. Procedure and Conditions for Personal Data Processing
2.1. OOO «Future Reality» processes only those personal data that are necessary to achieve the stated purposes and does not allow their excessive processing.
2.2. Personal data processing by OOO «Future Reality» is carried out on the basis of consent of data subjects, as well as on other legal grounds provided for by the Law, namely:
- on the basis of a contract concluded (being concluded) with the data subject;
- fulfilment of duties (powers) provided for by legislative acts;
- processing in the course of employment;
- processing of previously disseminated personal data.
2.3. OOO «Future Reality» establishes the purposes of personal data processing, categories of data subjects whose personal data are processed, the list of processed personal data, legal grounds for personal data processing, their storage period and the list of persons to whom and to what extent personal data are provided in accordance with the Appendix to the Policy.
2.4. OOO «Future Reality» processes personal data both with and without automation by performing the following actions with personal data depending on the processing purpose: collection, systematization, storage, modification, use, provision (including cross-border transfer), deletion.
2.5. OOO «Future Reality» does not disseminate personal data.
2.6. OOO «Future Reality» limits personal data processing to the achievement of specific, pre-declared processing purposes, and personal data storage is carried out in a form that allows identification of the data subject no longer than required by the stated processing purposes.
2.7. When determining personal data storage periods, OOO «Future Reality» is guided by the periods defined in the List of standard documents generated in the course of activities of state bodies, other organizations and individual entrepreneurs, with indication of storage periods, approved by Resolution of the Ministry of Justice of the Republic of Belarus of 24 May 2012 No. 140 "On the List of Standard Documents" (hereinafter — the List). If the personal data storage period is not defined by the List, OOO «Future Reality» independently determines such period based on the purposes of personal data processing and the specifics of OOO «Future Reality» activities, while excluding excessive personal data processing.
Upon expiry of established storage periods, documents containing personal data are destroyed in the manner established by legislation on archival affairs and record keeping, and personal data contained in information systems (resources) of OOO «Future Reality» are deleted.
Chapter 3. Authorized Persons. Provision of Personal Data to Third Parties
3.1. OOO «Future Reality» entrusts the processing of personal data on its own behalf and in its own interests to authorized persons providing services:
3.1.1. for searching and reviewing job applicants for employment at OOO «Future Reality» (review of resumes, application forms, autobiographies, personnel records, applications, recommendation letters, references of applicants for vacant positions), communication with them:
- OOO "VSE RABOTA" (220004, Minsk, K. Tsetkin St., 24-76);
3.1.2. for access control and internal facility security, provision of maintenance and technical support services:
- Landlord Limited Liability Company "PORTEKA" (220013, Minsk, P. Brovki St., 30, bldg. 1, office 15A);
- Homeowners Association "Royal Plaza" (Minsk, 220004, Pobediteley Ave., 7A);
3.1.3. for development and technical support of computer programs (platforms) and information resources:
- OOO "Reliable Programs" (220006, Minsk, Aranskaya St., 8, block 1, 4th floor);
3.1.4. for posting offers to participate in electronic tenders:
- RUE "National Export Support Centre" (220030, Minsk, Svobody Sq., 17);
- JSC "Belarusian Universal Commodity Exchange" (Republic of Belarus, 220099, Minsk, Kazintsa St., 2, office 200).
3.1.5. for accounting and personnel records:
- OOO "Keep in Law" (220004, Republic of Belarus, Minsk, Frunzensky District, Kalvariyskaya St., 16, office 277).
3.1.6. for providing information about products and services, as well as for other requests and proposals:
- OOO "MTS" (220008, Minsk, Nezavisimosti Ave., 95-4).
3.2. Authorized persons process personal data on the basis of an agreement on personal data processing concluded with OOO «Future Reality» (instruction of OOO «Future Reality») and undertake to comply with the principles, rules of processing and protection of personal data provided for by the Law. For each authorized person, the personal data processing agreement defines the list of permitted actions with personal data to be performed by such person, processing purposes, establishes the obligation of such person to maintain confidentiality and ensure security of personal data during their processing, and specifies the necessary measures and requirements for the protection of processed personal data in accordance with the Law or the legislation of the foreign state where the authorized person is located.
OOO «Future Reality» regularly monitors compliance by authorized persons with measures to ensure protection of personal data processed on behalf of OOO «Future Reality».
3.3. OOO «Future Reality» provides personal data to third parties for purposes according to the Appendix, in particular:
- RUE "Belpost" (220050, Minsk, Nezavisimosti Ave., 10) — for the purpose of sending postal correspondence;
- state bodies and other organizations where legal grounds established by the legislation of the Republic of Belarus on personal data exist.
Chapter 4. Cross-Border Transfer of Personal Data
4.1. OOO «Future Reality» carries out cross-border transfer of personal data to foreign states where an adequate level of protection of data subjects' rights is not ensured for the purpose of informing about products, services, promotions and events.
OOO «Future Reality» may process Users' personal data (including name and phone number) to send informational messages about products, services, promotions and events via messengers and social networks, including but not limited to Viber, WhatsApp, Telegram, Instagram only with the consent of the data subject.
The first message sent to the client contains a request for informed consent to receive messages. The User can always agree or refuse.
The Company undertakes to use data only within the scope of consent and in accordance with personal data protection legislation.
The User may unsubscribe from messages at any time by writing "Unsubscribe" in the messenger or sending an e-mail with the subject "Unsubscribe from mailing list". After unsubscribing, the Company stops sending messages within a reasonable period.
In this regard, OOO «Future Reality» additionally informs data subjects of the risks arising from the lack of an adequate level of personal data protection in such foreign states:
- absence of special legislation regulating personal data processing, including requirements for compliance with such norms;
- absence of an independent authorized state body for the protection of data subjects' rights;
- limited scope of data subjects' rights;
- use of improper methods of obtaining personal data;
- unlawful processing of personal data, as a result of which personal data may become available to an unlimited number of persons.
Chapter 5. Rights of Data Subjects and Their Implementation
5.1. Data subjects have the following rights:
| No. | Legal action | Content | Action of OOO «Future Reality» |
|---|---|---|---|
| 1 | Withdraw the provided consent to the processing of their personal data | If the basis for personal data processing was consent provided by the subject, the subject has the right to withdraw their consent at any time without giving reasons. This will not affect the lawfulness of processing of this subject's personal data based on their consent prior to withdrawal of such consent. | Within 15 calendar days after receiving an application from the Subject, OOO «Future Reality» stops processing their personal data, deletes them and notifies the subject thereof, unless other grounds for such actions with personal data provided for by legislation exist. |
| 2 | Receive information regarding personal data processing | The subject has the right to receive information regarding the processing of their personal data, containing: the name and location of the Company; confirmation of personal data processing by the Company (authorized person); their own personal data and the source of their receipt; legal grounds and purposes of processing their personal data; the period for which consent to processing of their personal data was given; the name and location of the authorized person entrusted with processing the subject's personal data; provision of their personal data to third parties (once per calendar year free of charge). | OOO «Future Reality» is obliged within fifteen days after receiving an application from the data subject to provide the requested information (information on transfer of personal data to third parties is provided for the period within the year preceding the date of application) or notify the data subject of the reasons for refusal to provide the requested information. |
| 3 | Amend the provided personal data | The subject has the right to amend their personal data if their personal data are incomplete, outdated or inaccurate. | Within 15 calendar days after receiving an application from the subject, OOO «Future Reality» is obliged to make appropriate amendments to such subject's personal data and notify the subject thereof, or notify the subject of the reasons for refusal to make such amendments. |
| 4 | Demand cessation of processing of their personal data and/or their deletion | The subject has the right to demand free cessation of processing of their personal data, including their deletion, in the absence of grounds for personal data processing. | Within 15 calendar days after receiving an application from the subject, OOO «Future Reality» is obliged to stop processing this subject's personal data and delete them (including by the authorized person), and notify the subject thereof within the same period, except in cases where OOO «Future Reality» is entitled to continue processing the subject's personal data if grounds provided for by legislation exist. |
| 5 | Right to appeal actions (inaction) and decisions of OOO «Future Reality» related to personal data processing | If a data subject believes that processing of their personal data is carried out in violation of the legislation of the Republic of Belarus, the data subject may file a complaint with the National Centre for Personal Data Protection. | The complaint is considered in the manner established by legislation on appeals of citizens and legal entities. |
5.2. To exercise their rights related to personal data processing, a data subject may apply to OOO «Future Reality» with an application in written form (in person, by mail) at the legal address of OOO «Future Reality».
5.3. If consent was provided by the data subject in another electronic form (by checking a checkbox on the Website), the right to withdraw consent may be exercised by:
- completing the electronic form on the Website "Withdrawal of Consent" located at https://ftr.by/privacy;
- sending an electronic message to ceo@ftr.by.
The right to withdraw consent cannot be exercised if personal data processing is carried out not on the basis of the data subject's consent, but on other legal grounds provided for by personal data legislation, for example, on the basis of a contract concluded with the data subject.
5.4. An application to exercise one or more of the above rights must contain:
- surname, name, patronymic (if any), date of birth of the data subject, address of their place of residence (stay);
- statement of the essence of the requirements;
- personal signature or signature of the authorized/legal representative of the data subject.
5.5. When completing the electronic form on the Website "Withdrawal of Consent" or sending an electronic message on exercising the right to withdraw consent that was provided by the data subject in another electronic form, such message must contain:
- a list of personal data for the processing of which the data subject provided their consent in another electronic form;
- statement of the essence of the requirements.
5.6. A response to the application is sent to the data subject in a form corresponding to the form of submission of the application, unless otherwise specified in the application itself.
Appendix to the Personal Data Processing Policy of OOO «Future Reality»
| Purposes of personal data processing | Categories of data subjects | List of personal data | Legal grounds for personal data processing | Personal data storage period |
|---|---|---|---|---|
| List of persons to whom and to what extent personal data are provided | ||||
| Review of resumes (application forms) of applicants (candidates for employment), including searching, assessing compliance of applicants with established requirements, communication with applicants | Candidates for employment | Surname, name, patronymic (if any), date of birth, phone numbers, email address, information about education, seniority and work experience, other personal data specified by the applicant (candidate for employment) in the resume (application form) | When sending a resume (application form) electronically to the corporate email address — personal data processing is carried out on the basis of the data subject's consent; when sending (providing) a resume in writing — processing of personal data specified in the document addressed to the operator and signed by the data subject; when reviewing a resume posted on job search websites — processing of previously disseminated personal data | 1 year — if not employed; 1 month — if employed |
| To achieve this purpose, OOO «Future Reality» entrusts personal data processing to the authorized person OOO "VSE RABOTA". | ||||
| Formation of a talent pool | Candidates for employment | Personal data specified by the applicant (candidate for employment) in the resume (application form) | Personal data processing is carried out on the basis of the data subject's consent | 3 years from the date consent is given |
| Review of candidates for a position (conducting an interview) | Candidates who have passed preliminary selection and are applying for a position (employment) | Personal data specified by the applicant (candidate for employment) in the resume (application form) | Processing of previously disseminated personal data. For the purpose of organizing and conducting an interview with a candidate, processing is carried out on the basis of the data subject's consent | 1 year — if not employed; 1 month — if employed |
| Employment (hiring) | Candidates for employment | In accordance with Article 26 of the Labour Code of the Republic of Belarus | Processing of personal data when establishing employment relations | After dismissal — 55 years |
| To achieve this purpose, OOO «Future Reality» entrusts personal data processing to the authorized person OOO "Keep in Law". | ||||
| Accounting and tax records of business activities | Customers, counterparties of OOO «Future Reality» (representatives of the parties to the contract authorized to sign the contract and/or perform actions within its execution, individuals who are a party to a civil law contract) | The list of processed personal data is limited to the content of primary accounting documents necessary for recording business transactions | Personal data processing is necessary to fulfil duties provided for by legislative acts (Law of the Republic of Belarus of 12 July 2013 No. 57-Z "On Accounting and Reporting") | 3 years after tax authorities conduct an inspection of compliance with tax legislation. If tax authorities did not conduct such inspection — 10 years after expiry of the contract |
| To achieve this purpose, OOO «Future Reality» entrusts personal data processing to the authorized person OOO "Keep in Law". | ||||
| Conclusion, execution and termination of contracts with Partners (legal entities) | Partners (individual entrepreneurs, legal entities) and their representatives | Surname, given name, patronymic, contact phone number, other information necessary for concluding a contract | Individual entrepreneurs (hereinafter — IE): personal data processing is carried out on the basis of a contract concluded (being concluded) with the data subject. Representatives of legal entities (hereinafter — LE): personal data processing in the course of employment. | 3 years after tax authorities conduct an inspection of compliance with tax legislation. If tax authorities did not conduct such inspection — 10 years after expiry of the contract |
| Access control and internal facility security, provision of maintenance and technical support services at OOO «Future Reality» facilities | Individuals — company employees, individuals — visitors of OOO «Future Reality» (employees of third-party organizations, foreign citizens) | Surname, given name, patronymic (if any), photograph | Personal data processing is necessary to fulfil duties (powers) provided for by legislative acts (Law of the Republic of Belarus of 8 November 2006 No. 175-Z "On Security Activities in the Republic of Belarus") | Limited to the period of presence at the facility |
| To achieve this purpose, OOO «Future Reality» entrusts personal data processing to the authorized person Homeowners Association "Royal Plaza". | ||||
| Consultation of persons who contacted the Organization via phone call, feedback form on the Website, social networks, messengers | Persons who contacted the Organization | Minimum necessary list of personal data determined depending on the nature and content of the consultation | Personal data processing is carried out on the basis of a contract concluded (being concluded) with the data subject (paragraph fifteen of Article 6, paragraph three of paragraph 1 of Article 9 of the Law) | 1 year |
| To achieve this purpose, OOO «Future Reality» via phone calls entrusts data processing and provides the phone number and personal data contained in the message to the authorized person — OOO "MTS". For communication with website users via electronic messaging services, OOO «Future Reality» carries out cross-border transfer and entrusts personal data processing: on the Instagram social network — to the authorized person Meta Platforms, Inc., on the YouTube video hosting — to the authorized person YouTube, LLC, on the Telegram messenger — to the authorized person Telegram Group Inc. or Telegram FZ-LLC. | ||||
| Record keeping, storage and accounting of documents in accordance with legislation in the field of archival affairs and record keeping | Persons whose information is contained in documents registered in the document management system | Personal data of individuals contained in archival documents | Personal data processing is necessary to fulfil duties provided for by legislative acts (Law of the Republic of Belarus of 25 November 2011 No. 323-Z "On Archival Affairs and Record Keeping in the Republic of Belarus") | Determined depending on the period defined in the List of Standard Documents approved by Resolution of the Ministry of Justice of the Republic of Belarus of 24.05.2012 No. 140 |
| Review and response to applications (appeals) of data subjects received within the framework of exercising their rights in accordance with personal data legislation | Applicants, other persons whose personal data are specified in the application (appeal) | Surname, name, patronymic (if any), address of place of residence (stay), date of birth, other personal data specified in the appeal | Personal data processing is necessary to fulfil duties provided for by legislative acts (Law of the Republic of Belarus of 7 May 2021 No. 99-Z "On Personal Data Protection") | 1 year |
| Review and response to received appeals | Applicants; other persons whose personal data are specified in the appeal | Surname, name, patronymic (if any), phone number (optional), address of place of residence (registration), other personal data specified in the appeal | Personal data processing is necessary to fulfil duties provided for by legislative acts (paragraph 1 of Article 3 of the Law of the Republic of Belarus of 18 July 2011 No. 300-Z "On Appeals of Citizens and Legal Entities") | 5 years from the date of the last appeal; 5 years after completion of the book of comments and suggestions |
| Submission of required reporting forms to state bodies and other authorized organizations | Depending on the reporting form | In accordance with the form of the reporting provided | Personal data processing is necessary to fulfil duties provided for by legislative acts | — |
| Provision of information within the framework of fulfilling requests from state bodies and other organizations | Persons regarding whom information is requested | The volume of personal data transferred is determined depending on the content of the request | Legal grounds for personal data processing are determined depending on the content of the request | The storage period is determined depending on the content of the request in accordance with established storage periods for the corresponding type of correspondence, as a rule — 3 years |
| Conducting marketing research of User categories, as well as research aimed at processing received information, including the possibility of commercial use of results; conducting research to improve the quality of services provided | Users | Phone number, personal data, other personal data depending on the research purpose | Personal data processing is carried out on the basis of the data subject's consent | — |
Withdrawal of Consent
Use this form to withdraw consent to the processing of personal data that you previously provided electronically on the Website (for example, by checking a checkbox in a form).