1. General Provisions

1.1. This Personal Information Privacy Policy (hereinafter referred to as the Policy) applies to all information that the company Clik.by may obtain about the Customer during their use of the website https://clik.by/ (including all subdomains of the *.clik.by format) and during the performance of any agreements and contracts between Clik.by and the Customer.

1.2. The purpose of the Policy is to communicate to the individuals providing their personal data the necessary information allowing them to assess what personal data and for what purposes are processed by Clik.by, and what methods of ensuring their security are implemented.

1.3. Information about the Operator
The personal data operator of the Clik.by service is Proactive Technology LLC (Registration number/UNP: 193648169, registered on September 22, 2022, by the Minsk City Executive Committee), located at: Republic of Belarus, Minsk, Olesheva St., 9, premises 5.

To ensure compliance with the General Data Protection Regulation (GDPR) and to facilitate communication with our users in the European Economic Area, the Operator maintains a physical office and designates its EU representative at the following address: Av. Diagonal, 468, Gràcia, 08006 Barcelona, Spain.
Email for data protection and privacy inquiries: info@clik.by.

1.4. The Policy ensures the protection of the rights and freedoms of data subjects during the processing of their personal data, whether using automation tools or without the use of such tools, and establishes the liability of persons having access to personal data for non-compliance with the requirements governing the processing and protection of personal data.

1.5. The Policy applies to data obtained both before and after the Policy enters into force.

1.6. Clik.by reserves the right to make changes to this Privacy Policy at any time and may amend the Policy without prior notice.

1.7. This Policy has been developed in accordance with the Law of the Republic of Belarus dated May 7, 2021, No. 99-Z "On Personal Data Protection", the General Data Protection Regulation (GDPR), and other legislative acts.

1.8. The Agreement is a publicly available document.

1.9. Disclaimer regarding the processing of third-party data: If you are not a direct Customer (user of a personal account) of Clik.by, but have clicked on a link processed by our service (for example, from an email), this Policy applies to you subject to certain limitations. In such cases, Clik.by processes your technical data (IP address, cookies) solely on behalf of the link sender (our Customer). Clik.by acts as an Authorized Person (Data Processor), whereas the Data Operator (Data Controller) is the sender of the link. For matters concerning the deletion of data or withdrawal of consent, you should contact the sender of the link.

2. Concept and Composition of Personal Data

2.1. Within the framework of the Policy, "Customer's personal information" means personal information that the Customer provides about themselves independently when creating an account in the personal account or obtained automatically in the process of using the website https://clik.by/.

The received personal data may include:

• Surname, first name, patronymic;
• Registration data of a sole proprietor or legal entity, current account, date and number of registration;
• Contact telephone numbers, email address;
• Data automatically transmitted via the website in the course of its use through the software installed on the Customer's device, including IP address, cookie data, information about the User's browser, access time, and the address of the requested page.

2.2. Depending on the personal data subject, Clik.by may process the personal data of the following categories of subjects:

• Personal data of the employees of Proactive Technology LLC — information required in connection with labor relations;
• Personal data of the Customer — information necessary for Clik.by to fulfill its obligations within the framework of contractual relations and to comply with legal requirements.

2.3. The specified list is not exhaustive and may be subject to amendments.
2.4. Clik.by does not verify the accuracy of the data provided by the Customer and does not monitor their legal capacity. The responsibility for the accuracy, relevance, and sufficiency of the data rests entirely with the Customer who provided them.

3. Grounds and Purposes of Processing the Customer's Data

3.1. Clik.by collects and retains the Customer's personal data necessary for the provision of services, execution of agreements and contracts, and fulfillment of obligations to the Customer.

3.2. Clik.by may also use the Customer's data for the following purposes:

• Conclusion and execution of a contract with the Customer. Legal basis: paragraph 15, Article 6 of the Law (processing is necessary for the execution of a contract). Processed data: full name, contact details, payment details;
• Sending advertising and marketing newsletters. Legal basis: Article 5 of the Law (consent of the personal data subject). Processed data: email, phone number;
• Analytics of website performance and service improvement. Legal basis: Article 5 of the Law (consent of the personal data subject) or paragraph 19, Article 6 of the Law (processing for statistical purposes, provided that the personal data are strictly anonymized). Processed data: IP address, cookie data.

4. Terms and Methods of Personal Data Processing

4.1. The terms of personal data processing are determined based on the processing purposes in the information systems of Clik.by, in accordance with the validity period of the contract or agreement with the personal data subject.
4.2. In the course of providing services and carrying out its activities, Clik.by uses automated and non-automated processing of personal data.
4.3. The set of processing operations includes collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of data.

5. Processing of Personal Information Using Cookies

5.1. To enhance the efficiency and security of the website https://clik.by/, cookies are used.
5.2. The Customer manages their cookie preferences via the cookie banner on the Website. The Customer is also aware that they can use their browser settings to prohibit operations with cookies.
5.3. Clik.by reserves the right to stipulate that the provision of certain functions is possible only provided that the acceptance and receipt of cookies are permitted by the Customer.
5.4. The structure of the cookie, its content, and technical parameters are determined by Clik.by and may be modified. Detailed information regarding cookies is provided below in Appendix 1.

6. Confidentiality and Protection of Personal Data

6.1. Access to the Customer's personal data may be granted to the employees of Clik.by solely within the scope of fulfilling their official duties. Clik.by requires its employees to strictly observe confidentiality.
6.2. Clik.by does not have the right to transfer personal data to third parties, except in cases where such an obligation is established by law or upon request from law enforcement authorities.
6.3. Clik.by shall not be liable for third-party websites to which the user has navigated via links available on the Clik.by Website.

7. Rights of the Personal Data Subject

7.1. The Customer, as a personal data subject, has the following rights concerning their personal data:

• 7.1.1. Right to withdraw consent. The Customer has the right to withdraw their consent to the processing of personal data at any time without explaining the reasons.
• 7.1.2. Right to obtain information regarding processing. The Customer has the right to obtain information from the Operator concerning what personal data are stored, the legal grounds, purposes, and retention periods.
• 7.1.3. Right to amend personal data. The Customer has the right to demand that the Operator amend their personal data if they are incomplete, outdated, or inaccurate.
• 7.1.4. Right to obtain information on the provision of personal data to third parties. The Customer is entitled, once per calendar year and free of charge, to receive information regarding the third parties to whom their personal data were transferred.
• 7.1.5. Right to demand the cessation of processing and/or deletion. The Customer has the right to demand that the Operator cease processing their personal data free of charge, including their deletion.
• 7.1.6. Right to appeal. If the Customer believes that their rights have been violated, they have the right to file a complaint with the authorized body for the protection of personal data subjects’ rights.

7.2. Mechanism for Exercising Rights

7.2.1. To exercise their rights specified in clauses 7.1.1 – 7.1.5, the personal data subject must submit an application to the Operator in one of the following forms:
1. In writing, by sending it to the mailing address: Republic of Belarus, Minsk, Olesheva St., 9, premises 5.
2. In the form of an electronic document signed with an electronic digital signature, by sending it to the email address: info@clik.by.

7.2.2. The application must contain: Surname, first name, patronymic; Residential address; Date of birth; Identification number (if applicable); Statement of the substance of the claims.
7.2.3. The Operator undertakes to review the application and provide a response within the time limits established by law:
– 5 (five) working days — for applications for the provision of information (clause 7.1.2);
– 15 (fifteen) calendar days — for all other applications (regarding deletion, withdrawal of consent, cessation of processing, or amendments).

8. Final Provisions

8.1. The Agreement and the relations between the Information User and the Customer shall be governed by and construed in accordance with the legislation of the Republic of Belarus. Matters not governed by the Agreement shall be subject to resolution in accordance with the legislation of the Republic of Belarus.
8.2. The Agreement constitutes a public offer in accordance with Part 2, Article 407 of the Civil Code of the Republic of Belarus. The act of ticking the consent box with the content of the Agreement by the Customer on the Website is a full and unconditional acceptance of this Agreement.
8.3. Clik.by reserves the right, at its sole discretion, to modify and/or supplement the Policy at any time without prior notice. The current version of the Policy is available in the Website's interface.
8.4. This Agreement enters into force from the moment the Customer performs the actions specified in clause 8.2 and remains in effect until the Customer deletes their account.

9. Cross-Border Transfer of Personal Data

9.1. In the course of conducting economic activities, as well as to ensure the operation of the Website and analytics (Google Analytics, Yandex.Metrica, etc.), Clik.by may carry out the cross-border transfer of personal data (technical data such as IP address and cookies) to the territory of foreign states.
9.2. Clik.by guarantees that the transfer of data is carried out to countries on the territory of which an adequate level of protection is ensured (e.g., EU countries, the Russian Federation), or to other countries subject to the availability of legal grounds.
9.3. When using analytics and advertising services (Google, Meta) or hosting providers (AWS), the servers of which may be located in jurisdictions with a different level of data protection (including the USA), the cross-border data transfer is carried out only upon obtaining explicit consent from the Customer.
9.4. The Customer is informed that when transferring data to countries that do not ensure an adequate level of protection, there may be risks associated with the absence of legislation in such countries protecting the rights at an adequate level. By providing active consent to the use of cookies on the banner, the Customer confirms that they have been notified of such risks.

10. Integration with Google Services

10.1. To provide core anti-fraud and advertising analytics features, the Clik.by service may require a connection to specific Google services (such as Google Ads) via Google APIs.

10.2. Clik.by's use and transfer to any other app of information received from Google APIs will strictly adhere to the Google API Services User Data Policy, including the Limited Use requirements.

10.3. When you authorize Clik.by to access your Google account data, we guarantee the following principles of data processing:

• The data is used exclusively to provide and improve user-facing features within the Clik.by interface.
• We do not use or transfer the data for serving ads, including retargeting, personalized, or interest-based advertising.
• We implement strict access controls. Human access to your data is prohibited unless we have your explicit affirmative agreement, it is necessary for security purposes (e.g., investigating abuse), it is required by applicable law, or the data has been fully aggregated and anonymized for internal operations.

Appendix 1. Clik.by Cookie Policy