1. GENERAL PROVISIONS
1.1. This Personal Data Processing Policy of IrisDev LLC (hereinafter referred to as the Policy) has been developed in pursuance of the requirements of the Law of the Republic of Belarus dated May 7, 2021 No 99-Z "On the Protection of Personal Data" (hereinafter referred to as the Law) in order to protect personal data, the rights and freedoms of individuals when processing their personal data.
1.2. The Policy explains to personal data subjects for what purposes and how their personal data is collected, used or otherwise processed, as well as determines the rights of personal data subjects in this regard and the mechanism for their implementation.
1.3. The Policy applies to relations related to the processing by IrisDev LLC of personal data of users of the https://irisdev.tech/ website (hereinafter referred to as the Site), customers when purchasing services, works, other programs and services, job seekers (job candidates), counterparties of IrisDev LLC (individuals with whom IrisDev LLC concludes civil law contracts, representatives of business entities authorized to sign the contract and (or) performance of actions within the framework of its execution), persons who sent appeals to IrisDev LLC, affiliates of IrisDev LLC (hereinafter, unless otherwise specified, referred to as personal data subjects).
1.4. This Policy does not apply to the processing of personal data in the course of employment and administrative procedures (in relation to employees and former employees), in relation to the processing of cookies on the Website, as well as in the implementation of video surveillance by IrisDev LLC. 1.5. Contacts of IrisDev LLC: Location address: Republic of Belarus, 220012, Minsk, Tolbukhina str., 3A, of. 401-420 (4th floor); e-mail address info@irisdev.tech; Phone +375 29 133-21-33, +375 29 625-58-28. 1.6. This Policy is published in free access on the Internet at the address https://irisdev.tech/, and is also freely available at the location of IrisDev LLC. 1.7. This Policy is effective from the moment of its approval.

2. TERMS AND DEFINITIONS
2.1. Personal data means any information relating to an identified natural person or an identifiable natural person.
2.2. Operator is a state body, a legal entity of the Republic of Belarus, another organization, an individual, including an individual entrepreneur, independently or jointly with other specified persons, organizing and (or) carrying out the processing of personal data.
2.3. Authorized person – a state body, a legal entity of the Republic of Belarus, another organization, an individual who, in accordance with an act of legislation, a decision of a state body that is the operator, or on the basis of an agreement with the operator, carry out the processing of personal data on behalf of the operator or in its interests. 2.4. Personal data subject is an individual in respect of whom personal data is processed.
2.5. Personal data processing is any action or set of actions performed with personal data, including: collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, deletion of personal data.
2.6. Provision of personal data – actions aimed at familiarizing yourself with the personal data of a certain person or a group of persons.
2.7. Dissemination of personal data is actions aimed at familiarizing an indefinite number of persons with personal data.
2.8. Deletion of personal data shall mean 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 tangible media of personal data are destroyed.
2.9. Cross-border transfer of personal data is the 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.

3. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA
3.1. The processing of personal data by IrisDev LLC is carried out on the basis of the consent of the personal data subjects, as well as on other legal grounds provided for by the legislation on personal data.
3.2. IrisDev LLC establishes the purposes of personal data processing, the categories of personal data subjects whose personal data are processed, the list of personal data to be processed, the legal grounds for personal data processing, the period of their storage and the list of persons to whom and to what extent personal data are provided in accordance with the Appendix, which is an integral part of this Policy.
3.3. IrisDev LLC processes personal data both with and without the use of automation tools with the following actions with personal data depending on the purpose (purposes) of processing: collection, systematization, storage, modification, use, provision (including cross-border transfer), deletion. In cases where the processing of personal data involves their distribution, then IrisDev LLC indicates the specific conditions under which such an action is possible.
3.4. IrisDev LLC limits the processing of personal data to the achievement of specific, pre-stated processing purposes, and the storage of personal data is carried out in a form that allows identifying the subject of personal data no longer than required by the stated purposes of processing.
3.5. The terms of storage of personal data of personal data subjects are determined in accordance with the legislation on archiving and records management. When determining the terms of storage of personal data, IrisDev LLC is guided by the terms determined by the List of standard documents generated in the course of the activities of state bodies, other organizations and individual entrepreneurs, with an indication of the 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 period of storage of personal data of personal data subjects is not determined by the legislation on archiving and records management, then the storage period of personal data of these persons is set by IrisDev LLC independently, based on the purposes of personal data processing and the specifics of the activities of IrisDev LLC. Upon expiration of the established storage periods, documents containing personal data shall be destroyed in accordance with the procedure established by the legislation in the field of archiving and records management, personal data contained in the information systems (resources) of IrisDev LLC shall be deleted.
3.6. IrisDev LLC processes only those personal data that are necessary to achieve the stated goals and does not allow their excessive processing.
3.7. In order to ensure the correct operation and improve the functioning of the Website, the convenience of its use, the creation of personalized advertising and the collection of analytical information in a generalized form, IrisDev LLC uses cookies. The procedure for processing cookies is defined in the Cookie Processing Policy of IrisDev LLC, posted on the Internet at https://irisdev.tech/
3.8. In order to ensure public order, protection of individuals, objects of IrisDev LLC, including material values and other property, IrisDev LLC carries out video surveillance in the administrative building at the address: Minsk, Tolbukhin Street, 3A, floor 4., in the administrative building at the address: Minsk, ul. F. Skaryny, 2, pomeshch. № 6-24; 6-37; 6-53. The procedure for processing personal data when using video surveillance systems installed at the facilities of IrisDev LLC is defined in the Video Surveillance Policy posted on the Internet at https://irisdev.tech/

4. AUTHORIZED PERSONS, OTHER PERSONS INVOLVED IN THE PROCESSING OF PERSONAL DATA. CROSS-BORDER TRANSFER OF PERSONAL DATA.
4.1. IrisDev LLC processes personal data with the involvement of authorized persons for the purposes in accordance with the Appendix, including those who provide information technology (IT) support for information resources (systems) of IrisDev LLC, maintain accounting and tax accounting of the economic activities of IrisDev LLC, provide legal services (legal assistance), etc.
4.2. Authorized persons process personal data on the basis of an agreement concluded with IrisDev LLC on the processing of personal data (instructions of IrisDev LLC) and undertake to comply with the principles, rules for the processing and protection of personal data provided for by the Law. For each authorized person, the personal data processing agreement (instruction of IrisDev LLC) defines the list of permissible actions with personal data that will be performed by such a person, the purposes of processing, establishes the obligation of such a person to maintain confidentiality and ensure the security of personal data during their processing, indicates the necessary measures and requirements for the protection of processed personal data in accordance with the Law. IrisDev LLC regularly monitors the implementation of measures by authorized persons to ensure the protection of personal data processed on behalf of IrisDev LLC.
4.3. IrisDev LLC provides personal data to other persons for the purposes in accordance with the Appendix, in particular: RUE "Belpochta" – for the purpose of sending postal correspondence; Google LLC (Google Gmail) – for the purpose of sending and receiving emails; When providing personal data to Google LLC, IrisDev LLC carries out cross-border transfer of personal data. Google LLC communication servers (Google Gmail) are located outside the Republic of Belarus, including in foreign countries, on the territory of which an adequate level of protection of the rights of personal data subjects is not provided, due to the location of communication servers of a number of mail services in these states. In connection with the above, IrisDev LLC additionally informs personal data subjects about the existence of risks arising from the lack of an adequate level of personal data protection in the following foreign countries: o the absence of special legislation governing the processing of personal data, including requirements for compliance with such standards; o the absence of an independent authorized state body for the protection of the rights of personal data subjects; o a limited range of rights of personal data subjects; o use of improper methods of obtaining personal data, o illegal processing of personal data, as a result of which personal data may become available to an unlimited number of persons. Additional information on the procedure for processing personal data of Google LLC can be found on the official website of the company, located on the Internet at https://policies.google.com/privacy?hl=ru LLC "Successful Management Company" - to provide access to the office; state bodies (organizations) if there are legal grounds established by the legislation of the Republic of Belarus on personal data.

5. WAYS TO OBTAIN THE CONSENT OF THE PERSONAL DATA SUBJECT TO THE PROCESSING OF PERSONAL DATA
5.1. The consent of the personal data subject is a free, unambiguous, informed expression of his/her will, through which he/she authorizes the processing of his/her personal data.
5.2. The consent of the personal data subject may be obtained by IrisDev LLC in writing, in another electronic form. In another electronic form, IrisDev LLC obtains the consent of the personal data subject by putting a mark ("tick" in the checkbox) on the Website by the personal data subject.
5.3. Prior to obtaining consent, IrisDev LLC provides the personal data subject with information about the conditions for processing his personal data, namely: location of IrisDev LLC; the purpose of processing personal data; a list of processed personal data necessary to achieve the stated purpose of processing; a list of actions performed with personal data necessary to achieve the stated purpose of processing, as well as the method of their processing (with or without the use of automation tools); authorized persons involved, if they are involved; in case of cross-border transfer of personal data to foreign countries, on the territory of which an adequate level of protection of the rights of personal data subjects is not ensured, IrisDev 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 period for which the personal data subject gives consent. Prior to obtaining consent, IrisDev LLC shall also explain to the personal data subject his/her rights related to the processing of personal data, the mechanism for their implementation, as well as the consequences of giving or refusing to give such consent.

6. RIGHTS OF PERSONAL DATA SUBJECTS, MECHANISM FOR THEIR IMPLEMENTATION
6.1. Personal data subjects have the following rights:

6.2. In order to exercise one or more of the rights specified under No 1 – 4 of the above table, it is necessary to send a corresponding application to IrisDev LLC in one of the following ways: in writing (by courier, mail, in person) at the address: Republic of Belarus, 220012, Minsk, Tolbukhina str., 3A, of. 401-420 (4th floor); in the form of an electronic document containing an electronic digital signature of the personal data subject to the e-mail address dpo@irisdev.tech.
6.3. To exercise the right to withdraw consent, it is necessary to send a corresponding application to IrisDev LLC in the manner prescribed by clause 6.2 of the Policy. If the consent was provided by the personal data subject in another electronic form, the right to withdraw consent can be exercised by sending an electronic message to the e-mail address dpo@irisdev.tech. The right to withdraw consent cannot be exercised when the processing of personal data is carried out on the basis of a contract or other legal grounds provided for by the legislation on personal data.
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/her place of residence (place of stay); statement of the essence of the requirements; personal signature or electronic digital signature of the personal data subject. 6.5. The response to the application shall be sent to the personal data subject in the form corresponding to the application form, unless otherwise specified in the application itself.
6.6. The information security service is a structural subdivision of IrisDev LLC responsible for internal control over the processing of personal data in IrisDev LLC. The personal data subject has the right to apply for assistance in exercising his rights to the information security service by sending an e-mail message to the e-mail address dpo@irisdev.tech

7. FINAL PROVISIONS
7.1. IrisDev 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.

Appendix to the Personal Data Processing Policy of IrisDev LLC
List of purposes of personal data processing in IrisDev LLC, categories of personal data subjects whose personal data are processed, volume of personal data processed, legal grounds for personal data processing, retention periods, list of persons to whom and to what extent personal data is provided