Cookie processing policy

Chapter 1. General provisions

This Policy on the processing of cookie files (hereinafter — the Policy) has been developed in compliance with the requirements of the Law of the Republic of Belarus No. 99-Z of 7 May 2021 "On Personal Data Protection" (as amended) (hereinafter — the Law). Its application is one of the measures taken to protect the personal data of users of the website owned by FLLC "NATUSANA" (20/11 Olshevskogo St., office 22, 220073 Minsk, Belarus) (hereinafter — the Operator).

The Policy explains to website users how and for what purposes the Operator processes cookie files and how users can control the processing.

Terms and definitions

• Cookie file — a small text file placed by the website on the user's device.
• IP address — a unique address that identifies a device on the Internet.
• Browser — application software for viewing web pages.
• Web analytics tools — services for collecting and analysing data on user behaviour.
• Website user — an individual using the Internet who has visited the website to perform any actions.
• Website session — the time interval during which the user interacts with the website, from the moment they open the website until the browser session ends.
• Device — a computer, mobile phone or other device of the user from which the website is accessed.

The terms "personal data" and "personal data subject" are used as defined in the Law.

The Operator processes cookie files for the following purposes:

• to ensure the security of website users;
• to ensure the correct functioning of the website;
• to collect analytical information about user interaction with the websites in order to improve the user experience.

Chapter 2. Cookie files used and user information

The Operator processes the following types of cookie files on the website:

Type	Description
Technical	Required for the correct operation of the website. Processed without the user's consent.
Analytical	Collect anonymised statistics on user behaviour (Yandex.Metrica, Google Analytics).
Marketing	Used to display relevant advertising. Processed only with the user's consent.

The following information may be obtained when processing cookie files:

• information about the website pages visited by the user;
• the number of the user's visits to the website during a month;
• information about the operating system and browser used by the user's device;
• the duration of the session when visiting the website.

Chapter 3. Legal grounds for processing cookie files

Technical cookie files are necessary to ensure the full and correct functioning of the website and its safe use. The Operator processes them regardless of whether the user has given consent. Such cookie files cannot be disabled using the website's functionality. However, the user can do so through the browser settings. If technical cookie files are disabled, the Operator does not guarantee the correct operation of the website.

For other cookie files (marketing and analytical), the Operator requests the user's consent to their processing. For this purpose, an information banner pops up on the website with the following options:

• accept all cookie files — the user also consents to the processing of functional and analytical cookie files;
• decline all cookie files — the user prohibits the Operator from processing any cookie files other than technical ones.

Once the cookie storage period expires, the information banner will be shown to the user again. The user has the right to change their choice regarding consent to the processing of cookie files at any time.

The user can also manually clear their device and (or) opt out of the use of cookie files through the browser configuration settings. More details on cookie management settings can be found on the pages of the major browsers (Chrome / Firefox / Safari / Yandex Browser / Edge).

When visiting the website in incognito mode, some types of cookie files are not saved.

Chapter 4. Cross-border transfer of cookie files

Based on the user's consent, the Operator carries out cross-border transfer of the information collected by means of analytical cookie files.

The processing of cookie files for the provision of information and analytics services is entrusted to:

• YANDEX LLC — Address: 16 Lva Tolstogo St., Moscow, 119021, Russian Federation.
• Google LLC — Address: 1600 Amphitheatre Parkway, Mountain View, California 94043, USA.
• VKontakte JSC — Address: 26 Pravdy St., Moscow, 125124, Russian Federation.

In accordance with clause 1 of Order No. 14 of the National Personal Data Protection Center of the Republic of Belarus dated 15 November 2021, the above organisations are located in a country included in the list of foreign states whose territory ensures an adequate level of protection of the rights of personal data subjects.

Chapter 5. Assistance in exercising rights related to the processing of cookie files

The user may contact the Operator for assistance in exercising their rights on matters related to the processing of cookie files in one of the following ways:

• in person;
• by sending a written application by post to: 20/11 Olshevskogo St., office 22, 220073 Minsk, Belarus;
• by sending an application in the form of an electronic document containing the electronic digital signature of the personal data subject to the e-mail address: yom@natusana.by.

For assistance in exercising their rights, the personal data subject may also contact the person responsible for internal control over the processing of personal data at the Operator by sending a message to the e-mail address: yom@natusana.by.

Chapter 6. Final provisions

The Policy comes into force on the date of its approval by the Operator's director. The current version of the Policy is publicly available on the website.

The Operator has the right to unilaterally amend and supplement the Policy at any time.

Matters concerning the processing of personal data that are not regulated by the Policy shall be resolved in accordance with the legislation of the Republic of Belarus.