Personal data processing policy
Date of update of the personal data processing policy: 22.09.2022
This Personal data processing policy (“Policy”) applies to all personal data of users that LLC “Civitta BY” receives through the website https://innovatebelarus.org (“our Website”). This Policy contains information about what personal data we collect when a person uses our website, how and for what we use it.
The words “we”, “us”, or “our” in this Policy mean Limited Liability Company “Civitta BY”, Taxpayer Identification Number (UNP) 191778178, legal address: 25A Internatsionalnaya St., office 322, Minsk, Republic of Belarus – hello@innovatebelarus.org.
The words “you”, “by you” or “your” in this Policy mean:
- People willing to create an account on our Website
- People willing to subscribe to our marketing emails in a section of our Website «Newsletter»
- People willing to contact us by email, telephone, through a section of our Website «Contact us», etc. for any request
Those people can include (non-exhaustive list) startup representatives, investors (business angels and representatives of investment companies/funds, representatives of ecosystem player organizations, etc.)
Unless expressly stated otherwise, all the following terms of the Policy apply to all the above-mentioned categories.
IF YOU DO NOT AGREE TO THE TERMS OF THIS PERSONAL DATA PROCESSING POLICY, PLEASE DO NOT USE OUR WEBSITE.
We reserve the right to make changes to this Policy at any time. We will notify you of the changes by indicating the latest update date each time we make any changes to this Policy. The changes come into force from the moment they are posted on our Website. If you do not agree with the current terms of processing your personal data in accordance with the current Policy, please do not use our Website.
WHICH PERSONAL DATA, FOR WHAT PURPOSES AND ON WHAT BASIS DO WE PROCESS?
We use your personal data for the purposes and on the legal basis set out below:
| Circumstances under which personal data is provided | Processed personal data | Purpose of processing | Processing basis |
| When you create an account on our Website | All users: | Registering your account on our Website | Terms of Use* |
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| Startup representatives provide additionally: | |||
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| Investors provide additionally: | |||
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| Representatives of Ecosystem Player Organizations provide additionally: | |||
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| When you contact us by email, telephone, through a section of our Website «Contact us», etc. for any request |
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To resolve the issue on which you contacted us | Consent** |
| When you subscribe to our marketing emails in a section of our Website «Newsletter» |
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To send you our news and offers | Consent ** |
| When you upload a startup presentation, startup documents to our Website | Data contained in the startup presentation, startup documents. | To post a startup presentation, startup documents on our Website and provide access to them for Investors. | Consent ** |
* Without providing this data, you will be still able to use our Website, but without the benefits that are provided to registered users.
** By giving us your consent to the processing of your personal data, you agree to the following actions with data: collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, deletion, both with and without the use of automation tools. Consent is given for a period until its withdrawal.
DATA THAT IS COLLECTED AUTOMATICALLY
Our Website may also automatically collect certain data when you interact with our Website using cookies – we collect data about your geolocation, data about your device that you use to access our Website (brand, model), your browser type, information about your use of our Website, URL of the previous page, etc. This data is collected using cookies and is used to analyze the performance of our Website, identify problems, troubleshoot technical issues, and continuously improve our Website. Read more about how we use cookies in the “Cookies” section of the Policy.
COOKIES
Cookies are small text files placed on a storage device and read by a web server in the domain in which they were created.
Cookies are used to:
- customize the content of the pages of our Website according to your preferences, as well as optimize our Website. In particular, these files allow to recognize your device and, accordingly, customize the viewing of the Website page to your personal needs;
- create statistics that help us understand how you use our Website, this allows us to improve the structure and content of our Website;
- maintain your session of our Website (after logging in), so that you do not have to re-enter your login and password on each page.
In this way, cookies do not harm your device and allow us to provide you with faster and better navigation on our Website. Cookies are present, as a rule, in significant numbers in each user’s browser and sometimes persist for a long time.
Our Website uses two different types of cookies: “temporary” (session cookies) and “permanent” (persistent cookies).
Temporary cookies are files that are stored on your device until you leave out Website or disable the software (web-browser).
Permanent cookie stored on your device for the time specified in the cookie settings or until you delete them.
List of cookies used by our Website during its operation:
Session Cookies
These cookies are necessary for our Website to function correctly. They allow to move around our Website and use its features. These files do not identify you as an individual. If you do not agree to use this type of files, it may affect the performance of our Website or its components.
Persistent Cookies
These cookies allow to “remember” the choices you have made (such as your username, language, and the region where you are located) in order to provide you with an efficient and personalized experience on our Website. The information collected from this type of file may include personal information that you have provided, such as your username or request information. We will always inform you about what information we collect, what we do with it and how we process it. If you block this type of file, it may affect the performance and functionality of our Website and may restrict access to content on our Website.
Third-Party Cookies
These cookies allow to provide advertising content that may be of interest to you. They may be used to deliver targeted advertisements or to limit the number of times an advertisement is viewed. They also help to measure the effectiveness of advertising campaigns on our Website and other companies’ web properties. We may use these cookies to record information about the websites you have visited, and we may share this information with other parties, including advertisers and agencies. The information collected from this type of file may include personal information that you have provided. We will always inform you about what information we collect, what we do with it and how we process it. If you block this type of file, it may affect the performance and functionality of our Website and may restrict access to content on our Website.
In addition, our Website uses web beacons (also referred to as pixels, pixel tags, or GIFs).
Web beacons — are small graphic files (1×1 GIF files) that are embedded in HTML web pages or emails and are usually invisible to users. Typically, web beacons are used in conjunction with cookies to track user interactions with website content or newsletters. For example, we may use web beacons to determine whether email messages have been opened or certain links have been clicked on, to identify trends and individual usage patterns, and to generate usage statistics for our Website.
Management of sending and receiving cookies
You can disable tracking by cookies in the settings of your browser and mobile device, or by writing to us at hello@innovatebelarus.org. Please note that if you do not allow us to set cookies, you may limit the functionality of our Website, which may make some of our features unavailable to you.
TRANSFER OF YOUR PERSONAL DATA TO THIRD PARTIES
We may outsource the processing of your personal data to certain third parties listed below:
| Google Analytics | web analytics service provided by Google, Inc. | Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. | Google privacy policy. |
| Facebook Pixel | web analytics service provided by Meta Platforms, Inc. | Address: 1601 Willow Road, Menlo Park, CA 94025, USA | Meta privacy policy. |
| Google Ads | contextual advertising service provided by Google, Inc. | Address: Google, Google Data Protection Office, 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA. | Google privacy policy. |
| Sendpulse.com | mailing service provided by SendPulse, Inc. | Address: 220 E 23rd St #401, New York, NY 10010, USA. | Sendpulse privacy policy. |
| Circle.so | communication platform provided by CircleCo, Inc. | Address: 228 Park Ave S, PMB 52933, New York, NY 10003, USA. | CircleCo privacy policy. |
| Hotjar | web analytics service provided by Hotjar Ltd. | Address: Dragonara Business Centre, 5th Floor, Dragonara Road, Paceville St Julian’s STJ 3141, Malta. | Hotjar privacy policy. |
| Facebook Ads Manager | a tool for creating and managing Facebook ads provided by Meta Platforms, Inc. | Address: 1601 Willow Road, Menlo Park, CA 94025, USA. | Meta privacy policy.
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| Hoster.by | Hosting provider | Address: Aranskaya st., 8/1, Minsk 220006, Republic of Belarus |
Hoster.by privacy policy |
We may also share your personal data when we have reason to believe that (i) we are required to do it by law, or (ii) as necessary to detect, prevent and stop fraud and other illegal activities.
We do not sell your personal data, hence, we do not exchange it for a monetary reward. We may only disclose certain personal data to third parties, as described above, to make those parties achieve the purposes for which they were involved.
INTERNATIONAL DATA TRANSFER
We may have international partners i.e., your personal data may be exported outside the Republic of Belarus. Since other countries may have different data protection laws than those in your country, we take steps to ensure that your data is adequately safeguarded as described in this Policy. Our partners in their policy guarantee the use of standard contractual clauses approved by the laws of the states of which they are residents.
PERIOD OF STORAGE OF PERSONAL DATA
We keep your personal data for the period necessary for the purposes for which such data is processed, or for the period required by law.
After achieving the goals or in case of withdrawal of the consent of the subject of personal data, we will delete personal data within the period provided for by third-parties countries law in relation to personal data of users located in the third-parties countries and provided for by the legislation of the Republic of Belarus in relation to personal data of users located in the Republic of Belarus.
RIGHTS YOU HAVE AND HOW YOU CAN USE THEM
In some cases, and considering certain exceptions, you may be able to use certain rights in relation to your personal data, as set out in the table below.
| Rights | Description |
| 1. Right to access personal information | You may request what data we hold about you and receive a copy of it, as well as other additional information. |
| 2. Right to make amendments | At any time, you may request your personal data to be amended if you believe it is inaccurate or out of date. |
| 3. Right to erasure (“right to be forgotten”)
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You can request deleting all the data related to you at any time. Please note that we may retain your personal information as necessary to comply with our legal obligations or resolve disputes. If we have no reason to continue processing your personal data, we will delete or anonymize it and notify you of such deletion or anonymization. |
| 4. Right to restrict / suspend the processing of personal data | The right to restrict the processing of your personal data enter into force if (a) the accuracy of the personal data is disputed by you, (b) the processing is unlawful (c) we no longer need the personal data for the purposes of the processing, but you need it to establish, exercise or defend legal claims, and (d) you have objected to the processing prior to verification of the legal basis. |
| 5. Right to data transfer | You may have the right to receive your personal data in a structured, commonly used and machine-readable form. Please note that this right only applies to data that we process based on your permission. |
| 6. Right to withdraw consent | You may withdraw your consent at any time if we process your personal data based on agreement. Unless we have other grounds for processing your personal data, after you send us a request to withdraw your consent, we will stop processing your personal data that we processed based on your agreement. |
| 7. Right to lodge a complaint with a supervisory authority | If you believe that our processing of personal data violates applicable personal data protection laws, you may file a complaint with the competent authority. |
Your request to exercise one or more of the above rights must contain: full name; address; date of birth; essence of requirements; identification number or number of an identity document (in the absence of an identification number), if this information was indicated when giving consent or the processing of personal data is carried out without the consent of the subject, personal or electronic signature.
To exercise one or more of the rights indicated under No. 1 – 5, you need to send us a corresponding request:
- in writing form to the address: 25A Internatsionalnaya St., office 322, Minsk, Republic of Belarus or;
- in the form of an electronic document to an email address: hello@innovatebelarus.org
To exercise the right to withdraw consent (under No. 6), you may send us a corresponding request:
- in writing form to the address: 25A Internatsionalnaya St., office 322, Minsk, Republic of Belarus or;
- in the form of an electronic document to an email address: hello@innovatebelarus.org
Please note that the termination of the processing of your personal data may make it impossible for you to continue using our Website.
