CHAPTER 1

GENERAL PROVISIONS

1.1. Personal data processing policy in LLC "Number of Good Luck" (hereinafter referred to as the "Policy") defines the basic principles, objectives, conditions and methods of personal data processing, lists of subjects and personal data processed, functions of LLC " Number of Good Luck" in processing personal data, rights of subjects of personal data, as well as requirements for personal data protection implemented in LLC "Number of Good Luck".

1.2. The policy was developed taking into account the requirements of the Constitution of the Republic of Belarus, legislative and other regulatory legal acts of the Republic of Belarus in the field of personal data.

1.3. The provisions of the Policy serve as the basis for the development of local legal acts regulating the processing of personal data of visitors to the virtual gambling institution of Grandcasino.by, employees of LLC "Number of Good Luck" and other subjects of personal data in LLC "Number of Good Luck".

1.4. The text of this Policy is posted by LLC "Number of Good Luck” on the Internet on the website Grandcasino.by.

CHAPTER 2

LEGISLATIVE AND OTHER REGULATORY LEGAL ACTS OF THE REPUBLIC OF BELARUS, ACCORDING TO WHICH THE POLICY OF PROCESSING PERSONAL DATA IN LLC "NUMBER OF GOOD LUCK" IS DETERMINED

2.1. The personal data processing policy in LLC "Number of Good Luck" is determined in accordance with the following regulatory legal acts:

Constitution of the Republic of Belarus;

Labour Code of the Republic of Belarus;

Law of the Republic of Belarus of 07.05.2021 N 99-Z "On the Protection of Personal Data" (hereinafter referred to as the Law on the Protection of Personal Data);

Law of the Republic of Belarus of 21.07.2008 N 418-Z "On the population register";

Law of the Republic of Belarus of 10.11.2008 N 455-Z "On Information, Informatization and Information Protection";

other regulatory legal acts of the Republic of Belarus and regulatory documents of authorized state authorities.

2.2. In order to implement the provisions of the Policy, LLC "Number of Good Luck" develops relevant local legal acts and other documents, including:

Regulation on processing and protection of personal data in LLC "Number of Good Luck" (Appendix 1 to this Policy);

Provision on the procedure for ensuring confidentiality when processing information containing personal data (Appendix 2 to this Policy);

other local legal acts and documents regulating the processing of personal data in LLC "Number of Good Luck."

CHAPTER 3

MAIN TERMS AND DEFINITIONS USED IN LOCAL LEGAL ACTS OF LLC "NUMBER OF GOOD LUCK" REGULATING THE PROCESSING OF PERSONAL DATA

3.1. Blocking personal data - stopping access to personal data without deleting it.

3.2. Processing of personal data - any action or set of actions taken with personal data, including collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, deletion of personal data.

3.3. Publicly available personal data - personal data distributed by the personal data subject himself or with his consent or distributed in accordance with the requirements of legislative acts.

3.4. Personal Data means any information relating to an identified individual or individual that may be identified.

3.5. Provision of personal data - actions aimed at familiarization with personal data of a certain person or circle of persons.

3.6. Distribution of personal data - actions aimed at familiarization with personal data of an indefinite range of persons.

3.7. Personal data subject - an individual in respect of whom personal data is processed.

3.8. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state.

3.9. Deletion of personal data - actions that make it impossible to restore personal data in information resources (systems) containing personal data, and (or) as a result of which material media of personal data are destroyed.

3.10. An individual who can be identified is an individual who can be directly or indirectly determined, in particular, through a surname, proper name, middle name, date of birth, identification number.

3.11. Information - information (messages, data) about persons, subjects, facts, events, phenomena and processes, regardless of the form of their presentation.

3.16. Automated processing of personal data - processing of personal data using computer equipment.

CHAPTER 4

PRINCIPLES AND OBJECTIVES OF PERSONAL DATA PROCESSING

4.1. LLC "Number of Good Luck", being a personal data operator, processes personal data of visitors to the virtual gambling institution Grandcasino, employees of LLC "Number of Good Luck" and other personal data subjects who are not members of LLC "Number of Good Luck" in labor relations.

4.2. The processing of personal data in LLC "Number of Good Luck" is carried out taking into account the need to ensure the protection of the rights and freedoms of visitors to the virtual gambling institution Grandcasino, employees of LLC "Number of Good Luck" and other subjects of personal data, including the protection of the right to privacy, personal and family secrets, on the basis of the following principles:

the processing of personal data is carried out on a legal and fair basis;

the processing of personal data is carried out in proportion to the stated goals of its processing and ensures at all stages of such processing a fair balance of interests of all interested parties;

processing of personal data is carried out with the consent of the personal data subject, except for cases stipulated by legislative acts;

the processing of personal data is limited to the achievement of specific, previously stated legitimate goals. It is not allowed to process personal data that is not compatible with the initially stated purposes of its processing;

content and volume of personal data processed correspond to the stated purposes of their processing. The personal data being processed are not redundant to the stated purposes of their processing;

processing of personal data is transparent. The personal data subject may be provided with relevant information relating to the processing of his personal data;

the operator takes measures to ensure the reliability of the personal data processed by him, updates them if necessary;

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 personal data.

4.3. Personal data is processed in the LLC "Number of Good Luck" in order to:

ensuring compliance with the Constitution of the Republic of Belarus, legislative and other regulatory legal acts of the Republic of Belarus, local legal acts of LLC "Number of Good Luck";

exercising the functions, powers and duties entrusted by the legislation of the Republic of Belarus to LLC "Number of Luck," including the provision of personal data to state authorities, to the Fund for Social Protection of the Population of the Ministry of Labor and Social Protection of the Republic of Belarus, as well as to other state bodies;

regulation of labor relations with employees of LLC "Number of Good Luck" (assistance in employment, training and promotion, ensuring personal safety, control of the quantity and quality of work performed, ensuring the safety of property);

protection of life, health or other vital interests of personal data subjects;

preparation, conclusion, execution and termination of contracts with counterparties;

ensuring access and intra-facility modes at the facilities of LLC "Number of Good Luck";

formation of reference materials for internal information support of the activities of LLC "Number of Good Luck";

execution of judicial acts, acts of other bodies or officials to be executed in accordance with the law of the Republic of Belarus on enforcement proceedings;

exercising the rights and legitimate interests of LLC "Number of Good Luck" within the framework of carrying out the types of activities stipulated by the Charter and other local legal acts of LLC "Number of Good Luck", or achieving socially significant goals;

provision of services to visitors of the Grandcasino virtual gambling establishment;

sending notifications to visitors of the Grandcasino virtual gambling institution regarding the services provided;

preparing and sending responses to requests from visitors to the Grandcasino virtual gambling institution;

sending information to the visitors of the Grandcasino virtual gambling institution, including advertising, about the events/works of the Number of LLC "Number of Good Luck" and the above-mentioned third parties;

identifying the visitor of the Grandcasino virtual gambling establishment with the personal data provided to them, as well as with the unique identifier assigned to them;

ensuring the implementation of the functions of state control over activities in the field of gambling business using a special computer cash register system (SCCRS);

ensuring compliance with legislation to prevent the legalization of proceeds of crime, the financing of terrorist activities and the financing of the proliferation of weapons of mass destruction;

ensuring protection of individuals from negative consequences associated with participation in gambling.

CHAPTER 5

LIST OF SUBJECTS WHOSE PERSONAL DATA ARE PROCESSED IN LLC "NUMBER OF GOOD LUCK"

5.1. In LLC "Number of Good Luck" personal data of the following categories of subjects are processed:

visitors to the virtual gambling establishment Grandcasino;

employees of structural subdivisions of LLC "Number of Good Luck";

other subjects of personal data (to ensure the implementation of the processing goals specified in Chapter 4 of the Policy).

for other legitimate purposes.

CHAPTER 6

LIST OF PERSONAL DATA PROCESSED IN LLC "NUMBER OF GOOD LUCK"

6.1. The list of personal data processed in LLC "Number of Good Luck" is determined in accordance with the legislation of the Republic of Belarus and local legal acts of LLC "Number of Good Luck", taking into account the purposes of processing personal data specified in Chapter 4 of the Policy.

6.2. Processing of special personal data concerning race or nationality, political views, membership in trade unions, religious or other beliefs, health or intimate life, bringing to administrative or criminal liability, as well as biometric and genetic personal data is not allowed in LLC " Number of Good Luck".

CHAPTER 7

FUNCTIONS OF LLC "NUMBER OF GOOD LUCK" WHEN PROCESSING PERSONAL DATA

7.1. LLC "Number of Good Luck" in the processing of personal data:

takes measures necessary and sufficient to ensure compliance with the requirements of the legislation of the Republic of Belarus and local legal acts of LLC "Number of Good Luck" in the field of personal data;

takes legal, organizational and technical measures to protect personal data from unlawful or accidental access to it, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;

appoints a structural unit or a person responsible for internal control over the processing of personal data;

issues local legal acts defining the policy and issues of processing and protection of personal data in LLC "Number of Good Luck";

familiarizes employees of LLC "Number of Good Luck," directly processing personal data, with the provisions of the legislation of the Republic of Belarus and local legal acts of LLC "Number of Good Luck" in the field of personal data, including requirements for the protection of personal data, and trains these employees;

publishes or otherwise provides unlimited access to this Policy;

informs the subjects of personal data or their representatives in accordance with the established procedure about the presence of personal data related to the relevant subjects, provides an opportunity to familiarize themselves with these personal data when contacting and (or) receiving requests from these subjects of personal data or their representatives, unless otherwise established by the legislation of the Republic of Belarus;

stops processing and destroys personal data in cases stipulated by the legislation of the Republic of Belarus in the field of personal data;

performs other actions stipulated by the legislation of the Republic of Belarus in the field of personal data.

CHAPTER 8

CONDITIONS FOR PROCESSING PERSONAL DATA IN LLC "NUMBER OF GOOD LUCK"

8.1. Personal data processing in LLC "Number of Good Luck" is carried out with the consent of the personal data subject to the processing of his personal data, unless otherwise provided by the legislation of the Republic of Belarus in the field of personal data.

8.2. LLC "Number of Good Luck" without the consent of the subject of personal data does not disclose to third parties and does not distribute personal data, unless otherwise provided by the legislation of the Republic of Belarus.

8.4. For the purposes of internal information support, LLC " Number of Good Luck" may create internal reference materials, which, with the written consent of the personal data subject, unless otherwise provided by the legislation of the Republic of Belarus, may include his surname, first name, middle name, place of work, position, year and place of birth, address, subscriber number, email address, other personal data reported by the personal data subject.

8.5. Access to personal data processed in LLC "Number of Good Luck" is allowed only to employees of LLC "Number of Good Luck", who hold positions included in the list of positions of structural divisions of LLC "Number of Good Luck", when replacing which personal data is processed.

CHAPTER 9

LIST OF ACTIONS WITH PERSONAL DATA AND METHODS OF THEIR PROCESSING

9.1. LLC "Number of Good Luck" processes personal data (any action or set of actions taken with personal data, including collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, deletion of personal data).

9.2. Processing of personal data in LLC "Number of Good Luck" is carried out:

using automation tools;

without the use of automation tools, if the search for personal data and (or) access to them according to certain criteria (file cabinets, lists, databases, logs, etc.) is provided.

CHAPTER 10

RIGHTS OF PERSONAL DATA SUBJECTS

10.1. Personal data subjects have the right to:

revoking the consent of the personal data subject;

obtaining information concerning the processing of personal data and changing personal data;

demand for termination of processing of personal data and (or) their deletion;

appeal against actions (inaction) and decisions of the operator related to the processing of personal data.

CHAPTER 11

MEASURES TAKEN BY LLC "NUMBER OF GOOD LUCK" TO ENSURE PERFORMANCE OF OPERATOR'S DUTIES IN PROCESSING OF PERSONAL DATA

11.1. Measures necessary and sufficient to ensure that LLC "Number of Good Luck" fulfills the operator's duties stipulated by the legislation of the Republic of Belarus in the field of personal data include:

providing personal data subjects with the necessary information before obtaining their consent to the processing of personal data;

explaining to personal data subjects their rights related to the processing of personal data;

obtaining written consents of personal data subjects for the processing of their personal data, except for cases stipulated by the legislation of the Republic of Belarus;

appointment of a structural subdivision or person responsible for internal control over the processing of personal data in LLC " Number of Good Luck";

publication of documents defining the policy of LLC "Number of Good Luck" regarding the processing of personal data;

familiarization of employees directly processing personal data in LLC "Number of Good Luck" with the provisions of the legislation on personal data;

establishing the order of access to personal data, including those processed in the information resource (system);

implementation of technical and cryptographic protection of personal data in LLC "Number of Good Luck" in accordance with the procedure established by the Operational and Analytical Center under the President of the Republic of Belarus, in accordance with the classification of information resources (systems) containing personal data;

providing unlimited access, including using the global Internet, to documents defining the policy of LLC "Number of Good Luck" regarding the processing of personal data, before the start of such processing;

termination of processing of personal data in the absence of grounds for their processing;

immediate notification of the authorized body for the protection of the rights of personal data subjects about violations of personal data protection systems;

modification, blocking, deletion of false or illegally obtained personal data;

limiting the processing of personal data to the achievement of specific, pre-stated legitimate goals;

storing personal data in a form that allows identification of personal data subjects for no longer than the stated purposes of processing personal data require.

11.2. Measures to ensure the security of personal data during their processing in personal data information systems are established in accordance with local legal acts of LLC "Number of Good Luck" regulating the issues of ensuring the security of personal data during their processing in personal data information systems LLC "Number of Good Luck".

CHAPTER 12

CONTROL OVER COMPLIANCE WITH THE LEGISLATION OF THE REPUBLIC OF BELARUS AND LOCAL LEGAL ACTS OF LLC "NUMBER OF GOOD LUCK" IN THE FIELD OF PERSONAL DATA, INCLUDING REQUIREMENTS FOR THE PROTECTION OF PERSONAL DATA

12.1. Control over compliance of structural subdivisions of LLC "Number of Good Luck" with the legislation of the Republic of Belarus and local legal acts of LLC "Number of Good Luck" in the field of personal data, including requirements for the protection of personal data, is carried out in order to check the compliance of personal data processing in the structural divisions of LLC "Number of Good Luck" legislation of the Republic of Belarus and local legal acts of LLC "Number of Good Luck" in the field of personal data, including requirements for the protection of personal data, as well as measures taken to prevent and identify violations of the legislation of the Republic of Belarus in the field of personal data, identify possible channels of leakage and unauthorized access to personal data, eliminate the consequences of such violations.

12.2. Internal control over compliance by structural units of the administration of LLC "Number of Good Luck" with the legislation of the Republic of Belarus and local legal acts of LLC "Number of Good Luck" in the field of personal data, including requirements for the protection of personal data, is carried out by the person responsible for organizing the processing of personal data in LLC "Number of Good Luck."

12.3. Personal responsibility for compliance with the requirements of the legislation of the Republic of Belarus and local regulations of LLC "Number of Good Luck" in the field of personal data in the structural unit LLC "Number of Good Luck," as well as for ensuring the confidentiality and security of personal data in these divisions of LLC "Number of Good Luck" rests with their managers.

Цели обработки персональных данных, категории субъектов, перечни обрабатываемых данных, правовые основания, сроки их хранения в ООО «Число Удачи»