Limited Liability Company IrisDev (IrisDev LLC)
Order of the Director of IrisDev LLC dated 06.08.2025 No 15-PD
POLITICS video surveillance in IrisDev LLC
1. GENERAL PROVISIONS
1.1. This Video Surveillance Policy (hereinafter referred to as the Policy) has been developed in accordance with the Regulation on Video Surveillance, approved by the order of the Director of IrisDev LLC, in order to explain to personal data subjects who are in the viewing areas of video surveillance cameras installed at the facilities of IrisDevLLC, the purposes of processing their images and reflects the rights of personal data subjects in this regard and the mechanism for their implementation.
1.2. The Policy is freely available on the Internet at https://irisdev.tech/ (hereinafter referred to as the Website), and is also available for review by clicking on the link in the QR code posted on the warning information plates on the implementation of video surveillance at the facilities of IrisDev LLC.
1.3. In IrisDev LLC, video surveillance is carried out on the basis of paragraph twenty of Article 6 of the Law of the Republic of Belarus of May 7, 2021 No 99-Z "On the Protection of Personal Data" (hereinafter referred to as the Law), in accordance with the Decree of the President of the Republic of Belarus of November 28, 2013 No 527 "On the Creation and Use of a Video Surveillance System in the Interests of Ensuring Public Order", the Decree of the President of the Republic of Belarus of October 25, 2007 No 534 "On Measures to Improve Security Activities", the Labor Code of the Republic of Belarus, the Law of the Republic of Belarus of November 8, 2006 No. 175-Z "On Security Activities in the Republic of Belarus", the Resolution of the Council of Ministers of the Republic of Belarus of December 30, 2013 No. 1164 "On the Criteria for Classifying Objects as Subject to Mandatory Equipment by Means of a Video Surveillance System for the State of Public Safety".
1.4. 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.
1.5. This Policy is effective from the moment of its approval.

2. PROCEDURE AND PURPOSES OF VIDEO SURVEILLANCE
2.1. In IrisDev LLC, video surveillance is carried out in the administrative building at the address: Republic of Belarus, 220012, Minsk, Tolbukhina Street, 3A, office 401-420 (4th floor), in the administrative building at the address: Minsk, ul. F. Skaryny, 2, pomeshch. № 6-24; 6-37; 6-53 (hereinafter referred to as the administrative building) for the purpose of: ensuring public order, including prevention, detection and suppression of offenses; protection of individuals (visitors, employees), facilities of IrisDev LLC, including material values and other property; control of visitor access to the facilities of IrisDev LLC; ensuring production and technological, executive and labor discipline.
2.2. In IrisDev LLC, video surveillance is carried out around the clock using open video surveillance cameras, while a constant recording mode is used.
2.3. IrisDev LLC informs personal data subjects about the implementation of video surveillance by placing warning information plates containing a QR code with a link to the text of this Policy inside the premises of the facilities of IrisDev LLC, where video surveillance is carried out.
2.4. IrisDev LLC carries out video surveillance without the involvement of authorized persons.
2.5. IrisDev LLC does not use a video surveillance system: in premises intended for personal needs of employees; offices, with the exception of offices of employees whose labor functions involve work with inventory; to record the working hours actually worked by the employees of IrisDev LLC; to uniquely identify persons who are in the areas of view of CCTV cameras.
2.6. CIrisDev LLC does not use video surveillance with the function of recording sound:
2.7. IrisDev LLC installed cameras in the area near the elevators, corridors (passages), server rooms, storage areas for inventory; Storage period of video materials: 30 days.
2.8. In case of receipt of information about the possible recording by video surveillance cameras of situations that have signs of committing a disciplinary offense, an administrative offense, a criminal offense, on the oral instruction of the director, deputy director for legal and economic security, the head of the internal control department (persons performing their duties) for such video recordings, the storage period may be extended for the period of the relevant measures provided for by the legislation of the Republic of Belarus.
2.9. IrisDev LLC establishes restrictions on the access rights of employees to CCTV recordings in accordance with their job duties. Access of employees to the settings of video cameras, recording modes is prohibited, with the exception of employees of IrisDev LLC. The procedure for access to personal data, including recordings of CCTV cameras, is carried out in accordance with the Regulation on the procedure for access to personal data, including those processed in the information resource (system), approved by the order of the director of IrisDev LLC. Employees of IrisDev LLC are prohibited from using access to video recordings for personal and other purposes not related to the performance of official duties. Video recordings are not subject to modification, use, distribution and provision, except as provided for by legislative acts.
2.10.IrisDev LLC has the right to use CCTV recordings as evidence in civil, criminal, administrative proceedings to confirm the fact(s) of the commission of an unlawful act, as well as to establish other circumstances subject to proof.
2.11. The information recorded by the video surveillance system at the facilities of IrisDev LLC can be provided to state bodies (organizations) only on the basis of a written request in cases provided for by the current legislation.

3. RIGHTS OF PERSONAL DATA SUBJECTS, THE MECHANISM OF THEIR IMPLEMENTATIONS
3.1. Personal data subjects have the following rights:

Law

Table of Contents

Aftermath

1

Right to be informed regarding the processing of personal data

The personal data subject has the right to receive information regarding the processing of his personal data, containing:

name and location of IrisDev LLC;

confirmation of the fact of personal data processing by IrisDev LLC; a list of processed personal data and the source of their receipt;

legal grounds and purposes of personal data processing;

the period for which consent to the processing of personal data was given;

name and location of the authorized person(s), if the processing of personal data by IrisDev LLC is entrusted to such person(s);

other information provided for by law

IrisDev LLC will provide the requested information within 5 working days after receiving the application or notify of the reasons for the refusal to provide it


2

Right to be informed about the provision of personal data to third parties

The personal data subject has the right to receive information from IrisDev LLC about the provision of his personal data to third parties once a calendar year free of charge

Within 15 calendar days from the date of receipt of the request, IrisDev LLC will provide information on what personal data and to whom was provided during the year preceding the date of filing the application, or notify of the reasons for refusal to provide it

3

The right to appeal against actions (inaction) and decisions of IrisDev 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

The complaint is considered in accordance with the procedure established by the legislation on appeals of citizens and legal entities

3.2. In order to exercise one or more of the rights specified under No 1-2 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, in person, by mail) at the address: Republic of Belarus, 220012, Minsk, Tolbukhina Street, 3A, of. 401-420 (4th floor); in the form of an electronic document containing the electronic digital signature of the personal data subject to the e-mail address dpo@irisdev.tech
3.3. 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 residence (place of stay); statement of the essence of the requirements; personal signature or electronic digital signature of the personal data subject. Due to the fact that IrisDev LLC does not use video surveillance for unique identification of persons, and the storage period for video recordings is up to 30 days, unless otherwise specified in paragraph 2.9. of this Policy, the statement of the essence of the requirements of the personal data subject must contain the date and time period of recording the image of the personal data subject. The time period is determined within an hour interval.
3.4. 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.
3.5. 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

4. FINAL PROVISIONS
4.1. 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.
4.2. Issues related to the processing of personal data not covered by this Policy are regulated by the legislation of the Republic of Belarus.
Telephone:
Email:
Limited Liability Company "IrisDev"
UNP 193075200
Postal address: 220012, Minsk, Tolbukhin str., 3A
Legal address: 220012, Minsk, Tolbukhin str., 3A, office 401-420 (4th floor)
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