APPROVED
Order of the Director of Aurora Support LLC No. 1-PD dated 03.03.2025

Limited Liability Company
"Aurora Support"
(Aurora Support LLC)

POLICY
processing of personal data by Aurora Support LLC

1. GENERAL PROVISIONS

1.1. This Policy for the processing of personal data of Aurora Support LLC (hereinafter referred to as the Policy) has been developed in compliance with 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, rights and freedoms of individuals when processing their personal data

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

1.3. The policy applies to relations related to the processing of personal data of users of the site by Aurora Support LLC https://avrorasupport.com/ (hereinafter referred to as the Site), customers when purchasing services, works, other programs and services, job seekers (job candidates), counterparties of Aurora Support LLC (individuals with whom Aurora Support LLC concludes civil law contracts, representatives of business entities authorized to sign the contract and (or) perform actions within the framework of its execution), persons who sent requests to Aurora Support LLC, affiliated persons of Aurora Support 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 work activities and in the implementation of administrative procedures (in relation to employees and former employees), in relation to the processing of cookies on the Site, as well as in the implementation of video surveillance by Aurora Support LLC.

1.5. Contacts of Aurora Support LLC:
location address: Republic of Belarus, 220012, Minsk, Tolbukhin St., 3A (floor 2);
email address info@avrorasupport.com ;
phone +375298457126.

1.6. This Policy is published in the public domain on the Internet at https://avrorasupport.com/policy, and is also freely available at the location of Aurora Support LLC.

1.7. This Policy shall be effective from the moment of its approval.

2. TERMS AND THEIR DEFINITIONS

2.1. Personal data – any information relating to an identified or identifiable natural person.

2.2. Operator – a government agency, 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 a legislative act, a decision of a state body that is an operator, or on the basis of an agreement with the operator, process personal data on behalf of the operator or in its interests.

2.4. Subject of personal data – an individual in relation to whom personal data is processed.

2.5. Processing of personal data – 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 oneself with the personal data of a certain person or group of persons.

2.7. Dissemination of personal data – actions aimed at familiarizing an indefinite number of persons with personal data.

2.8. Deletion of personal data – actions that make it impossible to restore personal data in information resources (systems) containing personal data, and (or) that result in the destruction of tangible media of personal data.

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 accepted in the current legislation of the Republic of Belarus.

3. ПОРЯДОК И УСЛОВИЯ ОБРАБОТКИ ПЕРСОНАЛЬНЫХ ДАННЫХ

3.1. The processing of personal data by Aurora Support LLC is carried out on the basis of the consent of the subjects of personal data, as well as on other legal grounds provided for by the legislation on personal data.

3.2. Aurora Support LLC establishes the purposes of personal data processing, categories of personal data subjects whose personal data are processed, a list of personal data processed, legal grounds for processing personal data, their storage period and a list of persons to whom and in what volume personal data are provided in accordance with the Appendix, which is an integral part of this Policy.

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

3.4. Aurora Support 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 identification of the subject of personal data for no longer than required by the stated processing purposes.

3.5. The storage periods for personal data of personal data subjects are determined in accordance with the legislation on archival affairs and records management.
When determining the storage periods for personal data, Aurora Support LLC is guided by the periods defined by the List of standard documents generated in the course of activities of government agencies, other organizations and individual entrepreneurs, indicating 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 storage period for personal data of personal data subjects is not determined by the legislation on archiving and office work, then the storage period for the personal data of the specified persons is established by Aurora Support LLC independently, based on the purposes of processing personal data and the specifics of the activities of Aurora Support LLC.
Upon expiration of the established storage periods, documents containing personal data are destroyed in accordance with the procedure established by legislation in the field of archival affairs and office work; personal data contained in the information systems (resources) of Aurora Support LLC are deleted.

3.6. Aurora Support 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 improvement of the functioning of the Site, the convenience of its use, the creation of personalized advertising and the collection of analytical information in a generalized form, Aurora Support LLC uses cookies.
The procedure for processing cookies is defined in the Cookie Processing Policy of Aurora Support LLC, located on the Internet at https://avrorasupport.com/cookies.

3.8. In order to ensure public order, protect individuals, objects of Aurora Support LLC, including material assets and other property, Aurora Support LLC carries out video surveillance in the administrative building at the address: Minsk, Tolbukhin St. 3A, floor 4.
The procedure for processing personal data when using video surveillance systems installed at the facilities of Aurora Support LLC is defined in the Video Surveillance Policy, posted on the Internet at https://avrorasupport.com/video.

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

4.1. Aurora Support LLC processes personal data with the involvement of authorized persons for the purposes specified in the Appendix, including those providing information technology (IT) support for the information resources (systems) of Aurora Support LLC, maintaining accounting and tax records of the business activities of Aurora Support LLC, providing legal services (legal assistance), etc.

4.2. Authorized persons process personal data on the basis of an agreement on personal data processing concluded with Aurora Support LLC (Aurora Support LLC's instruction) and undertake to comply with the principles, rules for processing and protecting personal data stipulated by the Law. For each authorized person, the agreement on personal data processing (Aurora Support LLC's instruction) defines a list of permissible actions with personal data that will be performed by such person, the purposes of processing, establishes the obligation of such person to maintain confidentiality and ensure the security of personal data during their processing, specifies the necessary measures and requirements for the protection of processed personal data in accordance with the Law.
Aurora Support LLC regularly monitors the implementation by authorized persons of measures to ensure the protection of personal data processed on behalf of Aurora Support LLC.

4.3. Aurora Support LLC provides personal data to other persons for the purposes specified in 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 dataGoogle LLC Aurora Support LLC carries out cross-border transfer of personal data. Google LLC (Google Gmail) communication servers are located outside the Republic of Belarus, including in foreign countries, on the territory of which the proper level of protection of the rights of personal data subjects is not ensured, due to the location of communication servers of a number of mail services in these countries.
In connection with the above, Aurora Support LLC additionally informs personal data subjects about the existence of risks arising due to the lack of an adequate level of protection of personal data in the following foreign countries:

• the absence of special legislation regulating the processing of personal data, including requirements for compliance with such standards;
• the absence of an independent authorized state body for the protection of the rights of personal data subjects;
• limited range of rights of personal data subjects;
• use of improper methods of obtaining personal data,
• 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 processing of personal data by Google LLC can be found on the company's official website, located on the Internet at https://policies.google.com/privacy?hl=ru
LLC "Successful Management Company" - to provide access to the office;
government agencies (organizations)in the presence of legal grounds established legislation of the Republic of Belarus on personal data.

5. METHODS OF OBTAINING CONSENT FROM THE PERSONAL DATA SUBJECT TO THE PROCESSING OF PERSONAL DATA

5.1. The consent of the subject of personal data 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 may be obtained by Aurora Support LLC in writing, in another electronic form. In another electronic form, Aurora Support LLC obtains the consent of the personal data subject by the personal data subject placing a mark (a tick in the checkbox) on the Website.

5.3. Before receiving consent, Aurora Support LLC provides the subject of personal data with information on the terms of processing his personal data, namely:

• location of Aurora Support LLC; purpose of personal data processing;
• a list of personal data processed that is necessary to achieve the stated purpose of processing;
• a list of actions performed with personal data that are necessary to achieve the stated purpose of processing, as well as the method of processing them (using automation tools or without using automation tools);
• the authorized persons involved, if they are involved;
• in the event of cross-border transfer of personal data to foreign states, on the territory of which the appropriate level of protection of the rights of personal data subjects is not ensured, Aurora Support LLC additionally informs the personal data subject about the risks arising in connection with the absence of an appropriate level of protection of his personal data in such states;
• the period for which the personal data subject gives consent.

Aurora Support LLC also, prior to obtaining consent, explains to the subject of personal data 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.

6. RIGHTS OF PERSONAL DATA SUBJECTS, MECHANISM OF THEIR IMPLEMENTATION
6.1. Subjects of personal data have the following rights:

6.2. To exercise one or more rights specified under No. 1 – 4 of the table above, you must send a corresponding application to Aurora Support LLC in one of the following ways:

• in writing (by courier, mail, in person) to the address: Republic of Belarus, 220012, Minsk, Tolbukhin St., 3A, office 401-420 (4th floor);
• in the form of an electronic document containing an electronic digital signature of the personal data subject, to the email address info@avrorasupport.com.

6.3. To exercise the right to revoke consent, it is necessary to send a corresponding application to Aurora Support LLC in the manner prescribed by paragraph 6.2 of the Policy. If the consent of the personal data subject was provided in another electronic form, the right to revoke consent can be exercised by sending an electronic message to the e-mail address info@avrorasupport.com.
The right to revoke consent cannot be exercised in cases where the processing of personal data is carried out on the basis of an agreement 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:

• last name, first name, patronymic (if any), date of birth of the subject of personal data, address of his place of residence (place of stay);
• statement of the essence of the requirements;
• personal signature or electronic digital signature of the subject of personal data.

6.5. The response to the application shall be sent to the subject of personal data in a form corresponding to the application submission form, unless otherwise specified in the application itself.

6.6. The structural division of Aurora Support LLC responsible for the implementation of internal control over the processing of personal data in Aurora Support LLC is the information security service. The subject of personal data has the right to seek assistance in exercising his/her rights from the information security service by sending an e-mail to the e-mail address info@avrorasupport.com

7. FINAL PROVISIONS

7.1. Aurora Support LLC has the right, at its own 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 in this Policy are governed by the legislation of the Republic of Belarus.