APPROVED

By the order of the Director of Amber Media LLC

No. 12/23 dated 01.12.2023

"AMBER MEDIA" LLC POLICY REGARDING THE PERSONAL DATA PROCESSING OF THE VIDEO SERVICE USER

1. Terms and definitions

1.1. The Company is a Limited Liability Company "AMBER MEDIA" registered and operating in accordance with the Legislation of the Republic of Belarus, registration number 693204722.
1.2. Video Service – AtlantTV video service owned by the Company, intended for watching television channels, accessing VOD services (including online cinemas), as well as listening to online radio stations and other similar functions.
1.3. The User is an individual, the client of the Video Service, in respect of whom the Company processes Personal Data and who, in accordance with the Legislation, is the subject of Personal Data.
1.4. The Law on Personal Data - Law of the Republic of Belarus dated May 7, 2021 No. 99- З “On Personal Data Protection”.
1.5. Legislation – substantive and procedural laws of the Republic of Belarus, including the Law on Personal Data.
1.6. Policy – The Company’s Policy regarding the processing of Personal Data of the Video Service User, approved by the order of the Director of the Company No. 12/23 dated December 1, 2023.
1.7. Other terms and definitions are used in the Policy in the senses provided for by the Legislation.

2. General provisions

2.1. This Policy, developed by the Company in accordance with the Law on Personal Data and other acts of Legislation, regulates the Personal Data processing of the Video Service User.
2.2. The Policy applies exclusively to the Personal Data of the Video Service User processed by the Company and does not apply processing of the Personal Data of employees and clients (counterparties) of the Company.
2.3. The Policy applies to relations in the field of processing of Personal Data, including collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, deletion of personal data carried out using automation tools and without the use of such tools.
2.4. The Policy is intended to the subject of Personal Data – the Video Service User for familiarization.
2.5. Personal Data is provided by the User to the Company in electronic form, in any of the available means provided for by the functionality of the Video Service.
By transferring Personal Data to the Company, the User confirms his consent to the processing of his Personal Data on the terms set out in the Policy, and confirms that he has read the Policy and agrees with its terms.
2.6. The processing of by the Company is based on the principles of legality, respect for the rights and interests of individuals, and the inviolability of their private life.
2.7. The Policy is published in free access in the public domain on the Company’s website www.atlant.tv.
2.8. The Company does not control and is not responsible for third Parties’ websites that the Video Service User can access via links available on the Company’s Internet resources/services/systems.

3. Purposes of Personal Data processing

3.1. The Company processes Personal Data for the following purposes:
- concluding any types of contracts with the User (including user agreements) and their subsequent execution;
- use of Personal Data for advertising and marketing purposes, including sending the User notifications, commercial offers, informational and advertising mailings related to the activities of the Video Service and (or) the Company;
- providing technical support on the functioning of the Video Service and (or) the Company;
- processing messages and requests received from the User;
- analyzing the operation of Video Service resources, improving its functionality and (or) search capabilities, including through surveys and other research;
- provision of Video Service and (or) Company services to the User;
- fulfillment of other duties (powers) provided for by the Legislation.
3.2. The content and volume of Personal Data processed by the Company must correspond to the purposes of their processing stated in this section. The Personal Data processed should not be redundant in relation to the stated purposes of their processing.

4. Personal Data processing

4.1. The Personal Data processing is carried out by the Company in accordance with the requirements of the Legislation.
4.2. The Personal Data processing is carried out with the consent of the User of the Company's Video Service to process their Personal Data, as well as without such consent in cases provided for by the Legislation.
4.3. The Company carries out both automated and non-automated Personal Data processing.
4.4. The disclosure to third Parties and distribution of Personal Data without the consent of the User is not permitted, unless otherwise provided by the Legislation.
4.5. The Company stores personal data no longer than required by the purposes of Personal Data processing, unless the period for storing Personal Data is established by the Legislation and (or) the Contract (Agreement) concluded with the User.

5. Realization of Users’ rights

5.1. The User, as a subject of Personal Data, has the right:
5.1.1. To receive information regarding the processing of his Personal Data in the manner and under the conditions provided for by the Legislation. In this case, the Company, within 5 working days after receiving the application from the User, provides the relevant information or notifies him of the reasons for the refusal to provide such information.
5.1.2. To require the Company to clarify his Personal Data if the Personal Data is incomplete, outdated, or inaccurate. In this case, the User must attach to his application containing the relevant requirements, the relevant documents and (or) duly certified copies confirming the need to make changes in the Personal Data.
If the fact of inaccuracy of Personal Data is confirmed, the Company, based on the information provided by the User, clarifies (changes) the Personal Data within 15 days from the date of submission of such information.
5.1.3. To receive information about the provision of his Personal Data to third Parties once a calendar year free of charge. At the same time, the Company, within 15 days after receiving the request, provides the User with information about what Personal Data was provided and to whom it was provided during the year preceding the date of submission of the application, or notifies the reasons for refusal to provide it.
5.1.4. At any time, without giving reasons, withdraw the consent to the processing of Personal Data;
The exercise of the right is carried out by the User in the manner of submitting an application to the Company in accordance with Art. 10 of the Law on Personal Data, or in the form through which his consent was previously obtained.
The Company, within 15 days after receiving the User’s application in accordance with its content, stops processing personal data and also deletes it (ensures the termination of the Personal Data processing, as well as its deletion by authorized persons, if any) and notifies the User about this.
If the Company does not have the technical ability to delete Personal Data, the Company takes measures to prevent further processing of Personal Data, including blocking, and notifies the User about this.
The Company has the right to refuse to satisfy the User’s requests to stop processing his Personal Data and (or) delete them if there are grounds for processing Personal Data provided for by the Legislation.
5.1.5. To appeal actions (inactions) and decisions of the Company that violate the User’s rights during Personal Data processing in the authorized body for the protection of the rights of Personal Data subjects in the manner established by the Legislation.
5.2. To exercise the rights specified in clause 5.1. of this Policy, the User submits an application to the Company.
The application must contain:
- surname, first name, patronymic (if any) of the User, address of his place of residence (place of stay);
- date of birth of the User;
- identification number of the User, in the absence of such a number – the number of the identification document, in cases where this information was indicated by the User when giving his consent to the Company;
- statement of the essence of the User’s requirements;
- personal signature or electronic digital signature of the Client.
The application can be sent in writing or in the form of an electronic document signed in accordance with the Legislation.
If the User’s application does not reflect all the information required in accordance with the Legislation, or if the applicant does not have access rights to the requested information, then a reasoned refusal is sent to him.


AMBER MEDIA LLC
UNP 693204722
Legal address: 223610 Minsk region, Slutsk, st. Komsomolskaya, 5A