Poehali.by Privacy Policy regarding the processing of personal data
In this Privacy Policy you will find information about the processing of your personal data. We undertake to be transparent and provide clear information about which of your personal data are processed, the purposes of processing, the storage periods, as well as the legal basis for data processing and other information we are required to provide under applicable legislation.
You have the right to give consent to the processing of your personal data, as well as to withdraw such consent at any time or amend the personal data provided.
Contents:
1.1. The Privacy Policy regarding the processing of personal data has been developed in order to protect personal data and the rights and freedoms of natural persons in the processing of their personal data. The Policy explains to data subjects for what purposes and in what manner their personal data are collected, used or otherwise processed, and also defines the rights of data subjects in this regard and the mechanism for their exercise (hereinafter – the Policy).
1.2. Limited Liability Company «Vadzhen trans» (hereinafter – the Organisation) is registered and located at the following address: Republic of Belarus, Minsk, Kazintsa Str. 33, office 2, TIN 193286041; website: https://poehali.by (hereinafter – the Website). The Organisation sells tickets for scheduled international passenger transportation via the Website.
1.3. The Website may contain links to other websites; we recommend reviewing the Privacy Policies of those pages before providing any data there. We are not responsible for any data provided when visiting other websites.
1.4. The Policy does not apply to the processing of personal data in the course of employment and the performance of administrative procedures (in relation to employees and former employees), video surveillance, or the processing of cookies.
1.5. The Organisation processes only those personal data that are necessary to achieve the stated purposes and does not allow their excessive processing.
1.6. This Policy uses terms and their definitions in the meaning established by the Law of the Republic of Belarus No. 99-З of 7 May 2021 "On Personal Data Protection", taking into account the additions set out in the Policy.
Personal data – any information relating to an identified natural person or a natural person who can be identified.
Processing of personal data – any action or set of actions performed with personal data, including the collection, organisation, storage, modification, use, anonymisation, blocking, distribution, provision, or deletion of personal data.
Data subject – a user of the Website whose personal data are being processed.
Website user – a person who visits the Website and performs any actions on it.
Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state.
Deletion of personal data – actions as a result of which it becomes impossible to restore personal data within the information resources containing such personal data.
Operator – a legal entity that organises and carries out the processing of personal data.
POEHALI.BY carrier – carriers of passengers and baggage using the Poehali.by trademark in their activities, in particular: Republic of Belarus – LLC «Vadzhen trans», LLC «Vadzhen plus»; Russian Federation – LLC «PTS-REGION»; Lithuania – UAB «Gromora».
Information resource (system) in which personal data are processed – the integrated software «BusSystem» (hereinafter – the System).
Integrated software «BusSystem» (hereinafter – the System) – a computer program for the purchase of tickets for international passenger transportation, representing a system of online access via the Internet to a unified database containing information about trips and allowing operations for the sale and refund of tickets and the generation of reports on tickets sold and refunded.
Purpose of using the System – the conclusion, performance, amendment and termination of contracts for the carriage of passengers and baggage, and the generation of reports on tickets sold and refunded.
1.7. The Policy is published publicly on the Internet at https://poehali.by. Use of the Website constitutes consent to the Policy and to the terms of processing of personal data.
2.1. The Organisation processes personal data of data subjects for the purposes, in the scope, on the legal grounds, and within the terms applicable to each category of data subjects:
| Purposes of personal data processing | Categories of data subjects whose data are processed | List of processed personal data | Storage period |
|---|---|---|---|
| Conclusion of contracts for scheduled international carriage of passengers and baggage | Persons purchasing tickets on the Website | Surname, given name, contact telephone number, e-mail address, citizenship | 1 year |
| Informing about changes in departure or arrival times, rescheduling, cancellation of trips and other changes in concluded carriage contracts | Persons who purchased tickets on the Website | Surname, given name, contact telephone number, e-mail address | 1 year |
| Provision of information for reporting to state statistical authorities | Persons who purchased tickets on the Website | Citizenship (anonymised) | 1 year |
| Appointment booking for in-person consultation | Persons requesting an in-person consultation | Surname, given name, patronymic, contact telephone number, subject of the enquiry | 1 year |
| Sending special offers (promotions, notifications) regarding trips | Persons purchasing tickets on the Website and listed in the CRS system | E-mail address, telephone number | 1 year |
| Provision of bonuses upon registration in the loyalty programme | Persons registered in the loyalty programme | Loyalty programme registration number | Until consent is withdrawn |
| Border crossing | Persons purchasing tickets on the Website | Passport series and number | Not stored |
2.2. Personal data that are not processed: when paying for a ticket through payment systems, payment data are not stored by the Operator. When paying for a ticket with a bank card, the payer's card details are not entered on the Website and are not stored; the payment is generated and authorised on the page of APK «WEBPAY» – a specialised hardware and software system for processing payment information that interacts with the Processing Centre of the acquiring bank and/or the AIS «Raschet» (ERIP). The Organisation does not transfer personal data to third parties for advertising purposes.
3.1. Since the Organisation sells tickets for scheduled international carriage of passengers and baggage operated by carriers registered in foreign countries, there is a need to transfer personal data cross-border to the territory of the Russian Federation and Lithuania in order for the carriers to fulfil their obligations under the concluded carriage contracts. Personal data are transferred to Poehali.by carriers for the performance of obligations and carriage operations for the purpose of contract performance.
3.2. The cross-border transfer of personal data is carried out by the Organisation to the territory of foreign states that ensure an adequate level of protection of the rights of data subjects.
4.1. A data subject has the right:
4.1.1. to withdraw their consent, if the Organisation approached the data subject to obtain consent for the processing of personal data. The right to withdraw consent cannot be exercised where the processing is carried out on other legal grounds (for example, in accordance with legal requirements or on the basis of a contract);
4.1.2. to receive information concerning the processing of their personal data by the Organisation, containing:
4.1.3. to require the Organisation to amend their personal data where such data are incomplete, outdated or inaccurate. For this purpose the data subject attaches the relevant documents and/or their duly certified copies confirming the need to amend the personal data;
4.1.4. to receive, free of charge and once per calendar year, information from the Organisation regarding the provision of their personal data, processed by the Organisation, to third parties, unless otherwise provided by legislation;
4.1.5. to require the Organisation to cease the processing of their personal data, including their deletion, free of charge, in the absence of grounds for the processing of personal data provided for by legislation;
4.1.6. to appeal against the actions (or inaction) and decisions of the Organisation that violate their rights in the processing of personal data, in the manner established by legislation.
4.2. A data subject is obliged:
4.2.1. to provide accurate personal data;
4.2.2. to inform the Operator of any changes to the personal data.
4.3. In order to exercise their rights related to the processing of personal data by the Organisation, a data subject shall submit a written application to the Organisation at the postal address specified in clause 1.2 of the Policy or by sending a message to the e-mail address vadjentrans7486666@gmail.com, and in the case of exercising the right to withdraw consent – in the form in which such consent was obtained.
Such application must contain the surname and given name of the data subject, telephone number, e-mail address, a statement of the essence of the data subject's requirements, and a personal signature (in the case of a written application).
The Organisation does not consider applications from data subjects received by any other means.
For assistance in exercising rights related to the processing of personal data, the data subject may contact us by sending a message to the e-mail address vadjentrans7486666@gmail.com.