APPROVED
by Order of the Director
of HardForward LLC
dated 13 November 2026 No. 9
Personal Data Processing Policy for the sites pingine.by and pinjoy.by
1. General provisions
1.1. This Policy sets out how HardForward LLC (ООО «ХардФорвард», the Operator) processes the personal data of visitors to pingine.by and pinjoy.by (each of them the Site) and of people who send requests through them. The processing of the personal data of employees, job candidates and counterparties is described in the Operator’s general Personal Data Processing Policy.
1.2. The Policy follows Law of the Republic of Belarus No. 99-Z of 7 May 2021 “On Personal Data Protection” (the Law).
1.3. Terms have the meanings given in the Law, and also:
- visitor means an individual who opens the Site;
- request means the information a person sends to the Operator through a form on the Site;
- cookies means small pieces of data the Site keeps in the visitor’s browser, including in the browser’s local storage.
1.4. The Policy is freely available on the Site. The Operator announces material changes on the Site in advance, before they take effect.
2. Operator
HardForward LLC (Общество с ограниченной ответственностью «ХардФорвард»), UNP 193939861.
Address: 6 Skryganova St., premises 7, 220073 Minsk, Republic of Belarus.
Email for requests: info@pingine.by.
The person responsible for internal control over personal data processing is the Director of HardForward LLC.
3. Purposes, data, legal grounds and periods
| Purpose | Whose data | What data | Legal ground | Storage period |
|---|---|---|---|---|
| Reply to a request, discuss a task, show the system, calculate the price and discuss a contract | Representatives of organisations; individuals and sole proprietors who contact us about a contract | Name; phone number or email; organisation or park name; number of parks; task description or question text; the page the request was sent from | Article 6, paragraph 8 of the Law for representatives of organisations; Article 6, paragraph 15 of the Law for individuals and sole proprietors entering into a contract | 3 years from the request |
| Aggregate statistics of Site visits; if the visitor sent a request, where they came from and which sections and questions they viewed before it | Visitors who gave consent in the cookie window or on the Cookie Policy page | Random visitor and visit numbers; pages and sections viewed and actions on them (clicks, scrolling, time, copying and printing, filling in the form without the text typed); whether this is a first visit; referral source and campaign tags; device type, browser, operating system, language, screen size, time zone and the country derived from it; technical page errors | The visitor’s consent (Article 5 of the Law). The consent lasts 6 months; when it ends, the visitor number is erased from the collected data | 1 year from the visit |
| Prove that consent to statistics was given or declined | Visitors who made a choice in the cookie window or on the Cookie Policy page | Date and time of the choice; the choice; version of the window text; page; with consent, the random visitor number | Article 6, paragraph 20 of the Law (the Operator’s duty to prove consent, Article 5, clause 7 of the Law) | 1 year and 6 months from the choice |
| Reply to letters sent to the Operator’s email shown on the Site | People who wrote to the Operator | What the letter contains | Article 6, paragraphs 8 and 15 of the Law for questions about a contract; Article 6, paragraph 20 of the Law for citizens’ appeals | 3 years after the correspondence ends or, if it leads to a contract, for the storage period of the contract documents; citizens’ appeals for the periods set by the law on appeals of citizens and legal entities |
When the Site is visited, the servers’ technical logs automatically record the IP address, the date and time of the request and the address of the requested page. This data is used only to keep the Site running and secure (protection against attacks, investigating failures), is not used to identify visitors or for marketing, is kept for no more than 14 days on servers located in the Republic of Belarus and is then deleted automatically. The Site does not ask for data that the purposes above do not need.
Without the visitor’s consent, the Site sends the Operator’s server anonymous visit data once, when the visitor leaves: pages and sections and actions on them (clicks, scrolling, copying and printing), the time of the visit to the hour, the site the visitor came from, the source, medium and campaign tags (utm_source, utm_medium, utm_campaign), device type, browser, operating system, time zone and the country derived from it, technical page errors. Starting to fill in the form is counted only in a daily total, with no time and no link to the visit. No visitor or visit number is created, nothing is kept in the browser, and the visit is not linked to a request. Such data cannot identify the visitor and is not personal data. The Operator uses it for aggregate visit statistics and keeps it for 1 year.
4. What is done with the data
4.1. The Operator collects, organises, stores, uses and deletes personal data. Processing is automated.
4.2. The Operator makes no decisions with legal consequences for you based solely on automated processing.
4.3. Requests, statistics and consent records are deleted automatically when their storage periods in section 3 end. Letters are deleted when their period in section 3 ends, and copies of requests in the mailbox on the same schedule as the requests.
4.4. The Operator stops processing personal data when:
- the purpose of processing is achieved;
- the storage period ends;
- you withdraw your consent and there is no other ground for processing;
- unlawful processing is found.
5. Who else receives the data
5.1. Site data is stored on a server in the Republic of Belarus.
5.2. Letters to the Operator’s email shown on the Site, and the copies of requests the Site sends to that email, are stored by the mail service on servers in the Republic of Belarus.
5.3. The Site loads no fonts, scripts or images from third-party services and uses no third-party counters or advertising pixels.
5.4. The Operator shares data with others only where the law requires it.
5.5. Data received through the Site is stored on a server in the Republic of Belarus and is not transferred outside it.
6. Cookies
Which cookies the Site uses, why, and how to opt out of statistics is described in the Cookie Policy.
7. Your rights and how to use them
7.1. You have the right to:
- withdraw your consent at any time. Consent to statistics can be withdrawn with the “Cookie settings” link at the bottom of the Site: the Site deletes the visitor number from the browser, and the Operator deletes the data collected under it from the server within 15 days. If consent is withdrawn by an application, the Operator stops processing and deletes the data within 15 days of receiving it;
- get information about the processing of your personal data — within 5 working days of receiving the application;
- require that your data be changed if it is incomplete, outdated or inaccurate — within 15 days;
- get information about your data being provided to third parties — free of charge once a calendar year, within 15 days;
- require that processing of your data stop and that it be deleted — within 15 days;
- appeal the Operator’s actions (inaction) and decisions to the National Personal Data Protection Center.
7.2. Information about the processing of your personal data contains:
- the Operator’s name and location;
- confirmation that the Operator processes your personal data;
- your personal data and where it was obtained;
- the legal grounds and purposes of processing;
- the period for which consent was given, where processing is based on consent;
- the name and location of the authorised person, where another organisation processes the data on the Operator’s instructions;
- other information required by law.
7.3. To use these rights, send an application in writing to the Operator’s address or as an electronic document with a digital signature. State your surname, first name, patronymic (if any), address of residence (stay), date of birth, the substance of your demands and your signature. If this information was given with your consent or the processing is done without consent, also state your identification number or, if you have none, the number of your identity document.
8. How the Operator protects the data
- The Site works only over HTTPS.
- Requests and statistics are available only to persons authorised by the Operator, through personal accounts. Employees with access to them have read this Policy.
- Data is kept no longer than the periods in section 3: requests, statistics and consent records are deleted automatically, letters when their period ends.
- The Site’s server is in the Republic of Belarus, and only persons authorised by the Operator have access to it.
- The Operator notifies the National Personal Data Protection Center of security breaches affecting personal data immediately, and no later than three working days.
9. Final provisions
9.1. This Policy takes effect on the day it is approved. The Operator may change this Policy. A new version takes effect on the date stated in it.
9.2. The current version of the Policy is published on each Site: pingine.by/privacy and pinjoy.by/privacy (Russian, binding), pinjoy.by/en/privacy (English translation).
9.3. Personal data matters not covered by this Policy are governed by the law of the Republic of Belarus.
9.4. Questions about this Policy can be sent to info@pingine.by.
Director of HardForward LLC P. V. Shukan