This Privacy Policy explains how Limited Liability Company "Tvoya Kartina" (ООО «Твоя картина»), registration number (УНП) 491572045, registered at [REPLACE: full legal address] ("VotePromotion", "we", "us", "our"), collects, uses, stores, and shares personal data when you visit votepromotion.store or use our services.
We aim to comply with the EU General Data Protection Regulation (GDPR), the UK Data Protection Act 2018, the California Consumer Privacy Act (CCPA), and the applicable data protection laws of the Republic of Belarus.
1. Who we are
The data controller responsible for the personal data we process is:
| Controller | Limited Liability Company "Tvoya Kartina" (ООО «Твоя картина») |
|---|---|
| Registration (УНП) | 491572045 |
| Address | [REPLACE: full legal address] |
| Contact for privacy matters | info@votepromotion.store |
2. What data we collect
We collect only data necessary to operate the site and to deliver our services.
2.1 Data you provide directly
- Contact details: name, email, phone, messenger handle.
- Project details: contest information, goals, budget range, and any other information you share through our forms or in communication with us.
- Billing details: company name, VAT number (if applicable), billing address, and payment method information processed by our payment provider.
2.2 Data collected automatically
- Technical data: IP address, browser type, operating system, referrer URL, pages visited, and time spent on each page.
- Cookies: see Cookie Policy for a detailed breakdown.
2.3 Data we do not collect
We do not knowingly collect personal data from individuals under the age of 16. We do not collect special category data (race, religion, biometric data, health information, sexual orientation, etc.). We do not require account registration to browse the site.
3. Why we use your data
| Purpose | Legal basis (GDPR) |
|---|---|
| Responding to your inquiries and proposals | Consent / pre-contractual measures (Art. 6(1)(a)/(b)) |
| Delivering contracted services | Performance of contract (Art. 6(1)(b)) |
| Issuing invoices, keeping accounting records | Legal obligation (Art. 6(1)(c)) |
| Improving the website, analytics | Legitimate interest (Art. 6(1)(f)) |
| Marketing communications (only if you opt in) | Consent (Art. 6(1)(a)) |
| Compliance with anti-fraud and AML obligations | Legal obligation / legitimate interest |
4. Who we share data with
We share personal data only with the following categories of recipients and only as required to deliver our services or to comply with the law:
- Hosting and infrastructure providers (currently Beget) — host the website and store contact form submissions.
- Payment providers — process card payments. We do not store full card numbers ourselves.
- Advertising platforms (Meta, Google, TikTok, etc.) — receive campaign-related information necessary to operate campaigns on your behalf.
- Email and analytics services — for transactional email delivery and aggregated site analytics.
- Accountants and auditors — for legally required reporting.
- Public authorities — only when legally required, e.g. in response to a valid legal request.
We do not sell personal data. We do not share personal data for purposes unrelated to the service.
5. International transfers
Some of our service providers are located outside Belarus and the European Economic Area. When we transfer personal data internationally we rely on appropriate safeguards, including Standard Contractual Clauses approved by the European Commission, where applicable.
6. How long we keep your data
| Category | Retention |
|---|---|
| Contact form submissions (no contract signed) | 12 months from last activity |
| Client records (active contracts) | Duration of contract + 6 years for accounting |
| Invoices and tax records | As required by Belarusian tax law (currently up to 10 years) |
| Site analytics logs (raw) | 14 months |
| Marketing consents | Until consent is withdrawn + 12 months |
7. Your rights
Depending on your jurisdiction, you have the following rights regarding your personal data:
- Access — request a copy of the data we hold about you.
- Rectification — request that inaccurate data be corrected.
- Erasure — request deletion of data, subject to legal retention requirements.
- Restriction — request that we limit how we process your data.
- Portability — request a machine-readable copy of data you provided.
- Objection — object to processing based on legitimate interest.
- Withdraw consent — at any time, without affecting prior lawful processing.
- Complain — lodge a complaint with the supervisory authority in your country.
To exercise any of these rights, write to info@votepromotion.store. We respond within 30 days.
8. Security
We use industry-standard technical and organizational measures to protect personal data, including TLS encryption in transit, encryption at rest where applicable, access controls, audit logs, and staff training. No system is perfectly secure; if a personal data breach affecting you occurs and is likely to result in a high risk, we will notify you in line with applicable law.
9. Cookies and similar technologies
See our separate Cookie Policy for full information on the cookies we use.
10. Children
Our services are not directed at children under the age of 16, and we do not knowingly collect personal data from anyone under that age. If you believe we have inadvertently collected such data, please contact us so we can delete it.
11. Updates to this policy
We may update this Privacy Policy from time to time. The "Last updated" date at the top reflects when the policy was last revised. Material changes will be notified to active clients by email.
12. Contact
For any privacy question, write to info@votepromotion.store or to our postal address listed at the top of this document.