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Privacy policy of Arzinger Legal LLC

1. General provisions.

1.1. This Privacy Policy (hereinafter referred to as the Policy) was developed in compliance with the requirements of the Law of the Republic of Belarus of May 7, 2021 No. 99-Z “On Personal Data Protection” (hereinafter –the Law) and explains to personal data subjects the purposes, legal grounds, procedure for processing their personal data, as well as the rights that personal data subjects have in this regard and the mechanism for their implementation.

1.2. Contacts of Arzinger LegalLLC (hereinafter – Arzinger or we): PIN 193265850, 220030, Minsk, Sovetskaya str., 12, office 29, information resource: https://arzinger.by (hereinafter – the Site), phone number: +375 29 304 34 11, email address: dpo@arzinger.by.

1.3. The following basic terms are used in the Policy:

The services – legal and other services provided by Arzinger.
Personal data – any information that can directly or indirectly identify an individual and that is processed by Arzinger during the provision of services, in the process of interaction with potential and existing customers, when using the Site, in the process of hiring employees or as part of other necessary business processes.
Personal data subject – an individual in respect of whom personal data is processed (hereinafter also – the Site user and/or the Client).
Other terms and their definitions in the meaning determined by the Law.

1.4. The policy does not apply to the processing of personal data:

in the course of employment and administrative procedures (in relation to employees and former employees);
when processing cookies on the Site (The Cookie Policy is available on the Internet at https://arzinger.by/cookie ).

2. Procedure and conditions for processing personal data.

2.1. Arzinger processes only those personal data that are necessary to achieve the declared goals and does not allow their excessive processing.

2.2. The processing of personal data is carried out on the basis of the consent of personal data subjects, as well as on other legal grounds provided for by the Law, namely:

on the basis of a contract concluded (being concluded) with the subject of personal data;
performance of duties (powers) stipulated by legislative acts;
processing of previously disseminated personal data.

2.3. We may use personal data for the following purposes and on the following grounds:

Purpose	Actions performed	Ground	Duration
Provision of Services	We collect, use and store information that Clients voluntarily provided to us through the use of the Site and/or in other ways that allow us to provide Services.	Processing of personal data is carried out on the basis of a contract concluded (being concluded) with the subject of personal data (paragraph fifteen of Article 6 of the Law)	3 years after the tax authorities verify compliance with tax legislation. If the tax authorities have not verified compliance with the tax legislation-10 years after the termination of the contract
Request for Information about Services	We process personal data of Clients and Site users who made a request for Services through the Site, by phone, in social networks, by email or otherwise. Contact information and other data required to complete the request are used by us exclusively for preparing and providing a response to the request.	The processing of personal data is carried out on the basis of the consent of the personal data subject (Article 5 of the Law)	3 years from the moment of receiving the request
Advertising and newsletters	We use the personal data of Clients and Site users to send news materials, information about our products and services, special offers and events. We will only send a newsletter if the subject consents to receiving such a newsletter.	ОProcessing of personal data is carried out on the basis of the consent of the personal data subject (Article 5 of the Law)	3 years from the date of termination of the contract for the provision of services, and if the contract was not concluded – from the date of receipt of consent to the distribution.
Processing of personal data in connection with events held	With the consent of the Site user and/or the Client, for the purposes of holding events, Arzinger may use personal data to perform the following actions: registration of participants, confirmation of participation, creation of lists of participants; sending the event program, logistics information (time, venue, requirements for participants), technical instructions for online events; providing access to platforms for webinars and online conferences, sending out connection links, passwords and instructions; sending surveys for quality assessment collect suggestions for improvement; informing about the results of events, provide additional materials, recordings of sessions (if there is consent). other actions commensurate with the declared goal.	Processing of personal data is carried out on the basis of the consent of the personal data subject (Article 5 of the Law) or on the basis of a contract concluded (being concluded) with the personal data subject (paragraph fifteen of Article 6 of the Law)	3 years from the date of termination of the contract for the provision of services, and if the contract was not concluded – from the date of obtaining consent.
Client database analysis	We analyze contact data and other personal information that we receive as a result of the personal data subject's interaction with the Site, as well as communication with it via email and/or in connection with the provision of Services.	Processing of personal data is carried out on the basis of the consent of the personal data subject (Article 5 of the Law)	3 years from the date of receiving consent
Business administration and legal compliance	The processing of personal data by us may be related to: fulfilling our obligations established by law. For example, the transfer of personal data to the relevant state authorities in cases where this is expressly required in the legislation; the exercise of our legal rights. For example, checking for conflicts of interest; protecting the rights of third parties	The processing of personal data is necessary to fulfill the obligations stipulated by legislative acts (paragraph 20 of Article 6 of the Law).	3 years from the date of termination of the service contract or sending a request
Employment	We use personal data for the purpose of hiring and evaluating the suitability of a person who wants to get a job in Arzinger, for any position, including the positions of a partner, lawyer, trainee or apprentice for the summer period, as well as administrative positions to support the business and provision of services if we received such a request online, by e-mail, in paper form, or by personal request.	When sending a CV (questionnaire) in electronic form by e-mail to the email address mail@arzinger.by – processing of personal data is carried out on the basis of the consent of the personal data subject (Article 5 of the Law);	3 years from the date of receipt of the CV (questionnaire)

2.4. Arzinger processes personal data both with and without automation tools by performing the following actions with personal data, depending on the purpose of processing: collection, systematization, storage, modification, use, provision (including cross-border transfer), deletion.

2.5. Arzinger stores your personal data for the duration stipulated by the achievement of the legitimate purposes of their processing, or for a specified period, if such a period is stipulated by law. When determining the terms of storage of personal data, Arzinger is guided by the terms defined by the List of Standard documents formed in the course of the activities of state bodies, other organizations and individual entrepreneurs, indicating the storage periods approved by Resolution No. 140 of the Ministry of Justice of the Republic of Belarus of May 24, 2012 “On the list of standard documents”. Upon expiration of the established retention periods, documents containing personal data are destroyed in accordance with the procedure established by the legislation on archival affairs and office management, and personal data contained in information systems (resources) are deleted. In some cases, it is necessary to preserve a certain part of personal data for archival purposes or in order to exclude the subject of personal data from further communication, if necessary.

3. Provision of personal data to third parties. Cross-border transfer of personal data.

3.1. We may also share information with the following third parties if necessary:

our professional consultants, such as lawyers and accountants;
state or other regulatory authorities;
companies that provide civil liability insurance services for causing harm to third parties in the course of professional activities, or other insurance companies;
regulatory authorities, tax authorities, and state registration authorities;
third parties from whom we receive the following services, including, but not limited to, document processing, translation services, deletion of confidential materials, information system or software providers, technical support services, document and information storage services;
third parties involved in the provision of services to clients: lawyers, arbitrators, mediators, secretaries, witnesses, appraisers, the court, the opposing party and its lawyers, document review platforms, and tax or valuation experts.
third parties that provide customer base analysis services, such as Google Analytics, Yandex. Metrika.
to third parties that provide postal or courier services that provide services for the delivery of advertising newsletters, or the delivery of documents on a specific issue.
other persons, when contacting them is necessary in order to provide our Services most effectively.

3.2. In the event of data transfer to third parties, Arzinger guarantees an appropriate level of personal data protection, including, but not limited to, the conclusion of standard non-disclosure agreements with such third parties. Using this measure, Arzinger ensures that these persons (i) take the necessary measures to protect personal data; (ii) use the transmitted data exclusively in accordance with the instructions of Arzinger, and not for other purposes; and (iii) store the transmitted personal data in accordance with the provisions of the agreement.

3.3. Arzinger transfers personal data across borders to foreign countries where the rights of personal data subjects are not adequately protected by:

operators of the electronic message exchange service, mail services of electronic message exchange – for the purpose of sending informational, advertising and other messages;
social networks and operators of electronic messaging services (instant messengers) – for the purpose of communicating with persons who sent messages through social networks and instant messengers.

3.4. In connection with the above, Arzinger additionally informs the subjects of personal data about the existence of risks arising from the lack of an adequate level of personal data protection in such foreign countries:

lack of specific 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 inappropriate 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.

4. The rights of subjects of personal data, the mechanism of their implementation.

4.1. Subjects of personal data have the following rights:

№	Right	Essence	Consequence
1	Right to make changes to your personal data	The personal data subject has the right to request changes to their personal data if it is incomplete, outdated or inaccurate. To do this, the personal data subject must provide relevant documents and (or) their duly certified copies confirming the need for making changes.	Arzinger will make changes to your personal data within 15 calendar days of receiving the request, if it is incomplete, outdated or inaccurate.
2	Right to receive information related to the processing of personal data	The personal data subject has the right to receive information related to the processing of his personal data, containing: name and location of Arzinger; confirmation of the fact of processing personal data by Arzinger; personal data and the source of their receipt; legal grounds and purposes of processing personal data; the period for which consent is given to the processing of personal data; name and location of the authorized person, if the processing of personal data by Arzinger is entrusted to such a person; other information provided by law.	Arzinger within 5 working days after receipt of the application will provide the information requested or notified of the reasons for the refusal to provide such information
3	Right to receive information on the provision of personal data to third parties	The personal data subject is entitled to obtain from Arzinger information about transferring their personal data to third parties 1 time in the calendar year	Arzinger within the term up to 15 calendar days from the moment of receipt of the request will provide information about what personal data and to whom was granted within the year preceding the date of filing of the application or notify the causes of refusal to provide such information
4	Right to require the cessation of processing of personal data and (or) their deletion	The personal data subject has the right to demand from Arzinger free termination of the processing of their personal data including their removal, in the absence of other grounds for processing personal data established by the legislation of the Republic of Belarus	Arzinger within the term up to 15 calendar days from the moment of receipt of the request will stop the processing of personal data, carry out their deletion and notify the personal data subject about it, with the exception of cases we are entitled to continue processing personal data in the presence of the other grounds, established by the Law
5	Right to withdraw previously granted consent to the processing of personal data	If the consent of the personal data subject has been granted for the processing of personal data by Arzinger, the personal data subject may withdraw his consent at any time without giving reasons. In this regard, the right to withdraw consent cannot be exercised in cases where processing is carried out on other legal grounds for processing personal data.	Аrzinger will stop processing personal data within 15 calendar days from the moment of receiving the request, delete them and notify the personal data subject about this, except for cases when Arzinger has the right to continue processing personal data if there are other grounds established by the Law.
6	Right to appeal actions (inaction), decisions of Arzinger related to the processing of personal data	If the personal data subject considers that the processing of their personal data is carried out in violation of the legislation of the Republic of Belarus, the personal data subject may file a complaint to 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.

4.2. In order to exercise one or more of the rights listed under №1-5 of the table in clause 4.1 of the Policy, you must send an appropriate application to Arzinger using one of the following methods:

in written form to the address: 12 Sovetskaya str., office 29, Minsk, 220030, Republic of Belarus
in the form of an electronic document containing the electronic digital signature of the personal data subject, to the e-mail addressdpo@arzinger.by

4.3. The application for exercising one or more of the above rights must contain:

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

4.4. The response to the application is sent to the personal data subject in the form corresponding to the application submission form, unless otherwise specified in the application itself.

4.5. The subject of personal data has the right to request assistance in the exercise of their rights by sending a letter to the e-mail dpo@arzinger.by.

5. Final provisions.

5.1. The Policy is published freely on the Internet on the Site and is valid from the moment of its approval.

5.2. Arzinger has the right to unilaterally change and / or supplement the terms of this Policy. The new version of the Policy comes into force from the moment it is posted on the Site, unless otherwise provided in such version.

5.3. Last updated: 08. 09. 2025