1.What personal data (hereinafter referred to as PD) do we1 collect?

We collect and process the following PD:

  1. personal and contact information (your name, surname, patronymic (if any), citizenship, date and place of birth, place of residence, date of issue of the passport or other identity document, e-mail address, other data obtained when checking personal and contact data);
  2. data (information) about financial transactions and transactions (operations) with digital tokens (tokens) that are not financial transactions using the Application;
  3. data (information) about your payment instruments, including data of bank payment cards and virtual wallets;
  4. communication with you, including sound and video recording of communication (telephone and video calls, correspondence by e-mail and in chats);
  5. IP address;
  6. your device ID;
  7. ID of the operating system you have installed;
  8. documents and other materials (information) obtained in the course of determining the level of knowledge (competence) for making transactions (operations) for the acquisition of digital tokens (tokens) for money or electronic money (only for citizens of the Republic of Belarus);
  9. information required to be recognized as a qualified investor (annual income, work experience, education, experience in transactions with securities and (or) derivative financial instruments, transactions with non-deliverable Over-The-Counter financial instruments, etc.);
  10. information about how you use the Application (for example, connection type, session data);
  11. any other information that you provide to us (in particular, when communicating with our technical support service).

2. Why do we collect PD?

The processing of your PD specified in letters (a), (b), (c), (d), (h) and (i) of the paragraph 1 is subject to the requirements of the legislation of the Republic of Belarus and the acts of the Supervisory Board of the Hi-Tech Park, which are mandatory for us.

We are obliged to collect the specified PD so that we can provide you with Services.

Thus, if you do not provide us with the above data, we do not have the right to allow you to make transactions with digital tokens (tokens)

The processing of your PD specified in letters (e), (f), (g) and (j) of the paragraph is necessary in connection with our legitimate interests2.

3. Can you refuse to process PD?

You have the right to refuse processing:

  1. data required for marketing attribution and analytics;
  2. information about how you use the Application;
  3. the email address used to send you advertising materials. You can refuse to process this data by sending an appropriate letter to [email protected].

4. What rights do you have in relation to our Privacy Policy?

You have the right to:

  1. at any time, without giving any reason, withdraw your consent to the processing of PD specified in the paragraph 3;
  2. receive information regarding the processing of your PD;
  3. require us to amend our PD if the PD is incomplete, outdated or inaccurate;
  4. receive information from us about the provision of their PD to third parties;
  5. require us to stop processing your PD, including their deletion, in the absence of grounds for processing PD provided for by the legislation of the Republic of Belarus and (or) acts of the Supervisory Board of the Hi-Tech Park;
  6. to appeal against our actions (inaction) and decisions that violate your rights when processing PD, to the authorized body for the protection of the rights of subjects of PD in the manner prescribed by the legislation of the Republic of Belarus on appeals of citizens and legal entities.

5. How can you exercise the above rights?

In order to exercise the right to revoke the consent of the personal data subject, the right to receive information concerning the processing of PD and the modification of PD, the right to receive information about the provision of PD to third parties, the right to demand the termination of the processing of PD and (or) their deletion, you need to submit an application to us in writing at the address Republic of Belarus, 220030, Minsk, 36-1 Internatsionalnaya str., office 625, room 2, or send such an application to us by e-mail [email protected].

Your application must contain:

  1. surname, proper name, patronymic (if any), address of residence (place of stay);
  2. date of birth;
  3. identification number, in the absence of such a number – the number of the identity document, in cases where this information was indicated by you when giving your consent to us or the processing of PD is carried out without your consent;
  4. statement of the essence of the requirements;
  5. personal signature or electronic digital signature.

More information is available in the current Privacy Policy. Any suggestions, questions regarding this Privacy Policy, please send to [email protected].

1 “We”, “us” means the “Dzengi.com” CJSC, registered in accordance with the legislation of the Republic of Belarus (TIN 193665666), legal address: 220030, Minsk city, Internatsionalnaya street, 36-1, office 625, room 2. More detailed information about us is available at the link: https://dzengi.com/general-informationn.

2A complete list of our legitimate interests is in Clause 2.2. of Privacy Policy.