Cookie Policy

COOKIE PROCESSING POLICY

1. GENERAL PROVISIONS

1.1. This Cookie Processing Policy (hereinafter – the “Policy”) governs the use of cookies on the website www.verkhovodko.com (hereinafter – the “Website”) owned by Verkhovodko & Partners LLC, Republic of Belarus, Minsk, 220012, 76B Nezavisimosti Avenue (hereinafter – the “Organization”). This Policy is developed in accordance with the requirements of the legislation of the Republic of Belarus on personal data processing and protection.

1.2. This Policy explains to Website users how and for what purposes the Organization processes cookies, and how users can control this processing.

1.3. “Cookies” are small text files that are transferred to a user’s device browser when visiting the Website, in order to reflect the actions performed by the user. They are used to ensure the operation of the Website, to store user settings, maintain session state, and for other purposes specified in this Policy. These files allow users not to re-enter or re-select previously saved settings when revisiting the Website.

The following terms are also used in this Policy:

“IP address” – a unique address identifying a device on the Internet;

“browser” – application software used for viewing web pages;

“user” – a person who visits the Website via the Internet to perform certain actions;

“Website session” – a time period during which a user interacts with the Website, from the moment of accessing the Website until the end of the browser session;

“device” – a computer, mobile phone, or other device used by the user to access the Website.

The terms “personal data” and “data subject” are used in the meanings defined by the Law of the Republic of Belarus dated 07.05.2021 No. 99-З “On Personal Data Protection”.

1.4. The Organization processes cookies for the following purposes:

• to ensure convenience and security for Website users;

• to ensure the proper functioning of the Website;

• to collect analytical information on user interaction with the Website in order to improve the user experience.

Cookies are not used to identify a specific Website user.

2. COOKIES USED. USER INFORMATION OBTAINED THROUGH THEM. WEB ANALYTICS SERVICES AND CROSS-BORDER DATA TRANSFERS

2.1. The Organization processes the following types of cookies on the Website:

1) Technical (essential) cookies – these ensure the correct functioning and secure use of the Website. This type of cookies is not used for analyzing user behavior or for marketing purposes. The Organization does not transfer these cookies to third-party analytics systems.

2) Functional cookies – these allow the user experience on the Website to be personalized in response to user actions: they store certain user settings related to Website use, including information about the user’s consent to the use of cookies and the settings selected by the user.

3) Analytical cookies – these are used for statistical purposes: they allow counting the number and duration of Website visits, analyzing how users use the Website, including which pages are visited, which helps improve Website performance and make it more user-friendly.

2.2. Depending on the storage period, cookies are classified as follows:

– session cookies – these are deleted when the browser is closed;

– persistent cookies – these are stored for the period specified in the cookie settings or until they are deleted by the user.

2.3. The list of cookies used by the Organization, their description and storage periods are set out in Appendix 1 to this Policy.

2.4. When processing cookies, the following information about the user may be obtained:

– data on interaction with the Website (pages visited, date and time of visits, duration of the Website session, etc.);

– number of Website visits by the user within a month, aggregated statistical data on Website usage;

– information about the user’s device (device type, browser settings, operating system, referring URL, etc.), IP address.

The Organization uses this information for the purposes specified in Clause 1.4 of this Policy.

2.5. Depending on the source of installation, cookies may be either first-party cookies, which are set by the Organization, or third-party cookies, which are created by the Organization’s partner companies and are used to analyze user interaction with the Website.

For the purposes of analysing and improving the Website’s performance, the Organization may use third-party web analytics services that help collect and process statistical information about Website visits and user interaction and use their own cookies. Where the user has given consent, the Organization uses the relevant analytical cookies provided by such web analytics services. In particular, upon receipt of consent, the Organization uses the following service:

– Yandex.Metrica (Yandex LLC, address: 16 Leo Tolstoy St., Moscow 119021, Russia) – the privacy policy is available at: https://yandex.ru/legal/confidential. Yandex.Metrica is used to assess user behavior on the Website in an aggregated form and to improve its usability, without identifying a specific user.

2.6. When using the above-mentioned web analytics services, cross-border transfer of anonymized and/or aggregated personal data may take place to servers of the relevant service providers located outside the Republic of Belarus, including in countries that do not ensure an adequate level of protection of data subjects’ rights (the Organization is not able to determine the location of such servers).

In this regard, the Organization informs users that, in the case of cross-border data transfer to such countries, the following risks may arise:

– absence of personal data protection legislation;

– a limited scope of information classified as personal data relating to individuals;

– different regulation of personal data processing compared to the Republic of Belarus, including broader use of legal bases for processing other than consent, different interpretation of key concepts, etc.;

– limited scope (or absence) of data subjects’ rights;

– absence of a competent authority responsible for protecting data subjects’ rights;

– broad powers of law enforcement authorities to process personal data (including access to such data).

3. LEGAL BASIS FOR COOKIE PROCESSING

3.1. For the purposes of ensuring the full and proper functioning of the Website, as well as its secure use, the Organization processes technical cookies regardless of whether the user has provided consent.

Such cookies cannot be disabled through the Website functionality; however, the user may configure their browser to block their use or receive notifications about them (see Clause 3.3 of this Policy for more details). At the same time, it should be considered that blocking/disabling technical cookies may result in incorrect functioning of certain Website features.

3.2. With respect to functional and analytical cookies, the Organization requests the user’s consent for their processing. In order to obtain such consent, a pop-up window (banner) appears when the user visits the Website, offering one of the following options:

– “accept”, meaning the user’s consent to the processing of functional and analytical cookies;

– “reject”, meaning the user’s refusal to allow the processing of functional and analytical cookies. In this case, the Organization will continue to use only technical cookies necessary for the operation of the Website.

The information banner will be shown to the user again after the expiration of the cookie storage period (after the expiration of the period for storing information about the previously made choice, or after such information is deleted by the user).

3.3. The user may manually clear their device and/or refuse the use of all or certain cookies through browser settings. Some browsers allow users to visit websites in “incognito” mode in order to limit the amount of information stored on the device and to automatically delete session cookies. It is also possible to delete previously stored cookies by selecting the appropriate option in the browser history settings.

In addition, certain browsers provide options for managing cookie processing (allowing, blocking, and deleting cookies). Relevant settings can be found via external links to the respective pages of major browsers:

– Google Chrome: https://support.google.com/chrome/answer/95647?hl=ru;

– Firefox: https://support.mozilla.org/ru/kb/udalenie-kukov-dlya-udaleniya-informacii-kotoruyu-;

– Microsoft Edge (Internet Explorer): https://support.microsoft.com/ru-RU/edge/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use;

– Opera: https://help.opera.com/ru/latest/web-preferences/#Управление-файлами-cookie;

– Safari: https://support.apple.com/ru-ru/guide/safari/sfri11471/mac;

– Yandex Browser: https://yandex.ru/support/browser/ru/personal-data-protection/cookies.html .

3.4. In addition, the user may restrict the operation of third-party web analytics services by installing special blocking plugins, in particular:

– Yandex.Metrica opt-out tool: https://yandex.ru/support/metrica/ru/general/opt-out.html.

4. USERS’ RIGHTS IN CONNECTION WITH COOKIE PROCESSING

4.1. Users of the Website, as data subjects, have the right to:

– withdraw their consent to the use of cookies at any time (except for technical cookies);

– receive information on how cookies are processed;

– know which third parties receive cookies;

– request the cessation of cookie processing and/or their deletion where there are no legal grounds for such processing;

– lodge a complaint with the competent authority for the protection of data subjects’ rights in accordance with the procedure established by the legislation of the Republic of Belarus.

4.2. The user may contact the Organization for assistance in exercising their rights in relation to cookie processing in one of the following ways:

– in person;

– by sending a written application by post to: 76B Nezavisimosti Avenue, Minsk 220012;

– by sending an application in the form of an electronic document containing the data subject’s signature to the email address minsk@verkhovodko.com or privacy@verkhovodko.com.

4.3. For assistance in exercising their rights, the data subject may also contact the person responsible for internal control over personal data processing within the Organization by sending a message to: privacy@verkhovodko.com.

4.4. The list of data subjects’ rights and the procedure for exercising such rights are also set out in detail in the relevant section of the Personal Data Processing Policy of Verkhovodko & Partners LLC which is available on the Website at: https://www.verkhovodko.com/privacy-policy/.

5. FINAL PROVISIONS

5.1. This Policy shall enter into force from the date of its approval. The current version of the Policy is publicly available on the Website.

5.2. The Organization has the right to unilaterally amend and supplement this Policy at any time and without prior notice to data subjects. The new version of the Policy shall enter into force from the moment it is published on the Website, unless otherwise provided by the new version of the Policy.

5.3. Any matters related to personal data processing that are not regulated by this Policy shall be governed by the legislation of the Republic of Belarus.

Appendix 1

to the Cookie Processing Policy

of Verkhovodko & Partners LLC

Information on cookies used on the Website