UNUM Disclaimer

APPROVED
Director of Limited Liability Company "LV Tekhnolodzhi
A.P. Dulsky
«05» January 2026

Initial version dated 05.01.2026
Current version dated 05.01.2026

PERSONAL DATA PROCESSING POLICY

Limited Liability Company "LV Tekhnolodzhi," the owner of the internet portal https://theunum.io (hereinafter – the SITE) (hereinafter – the UNUM portal), informs USERS about the policy applied on the SITE regarding the personal data of USERS.

This Personal Data Processing Policy (hereinafter – the "POLICY") is based on the norms of the legislation of the Republic of Belarus and international legislation in the field of personal data protection, as well as the requirements of the Hi-Tech Park Supervisory Council (hereinafter – "Legislation"). These principles and norms apply to the processing of USERS' personal data when using the SITE to protect the USER's privacy.

This POLICY is designed to ensure and guarantee that all USERS are informed about what personal data of users and visitors is collected by the UNUM portal, how this happens, and for what purposes.

This POLICY is an integral part of the USER AGREEMENT.

This POLICY applies to all information that USERS provide to the UNUM portal.

USERS – all individuals registered as users on the SITE of the UNUM portal.

By marking the corresponding consent to the USER AGREEMENT and this POLICY on the SITE and further providing personal data via the functionality of the UNUM portal, the USER gives unconditional consent to this POLICY. In case of disagreement with these terms, the USER must refrain from using the UNUM portal.

By registering on the SITE and providing personal data, the USER confirms consent to receive SMS messages and emails to the mobile phone number and email address specified during registration and use of the SITE from the UNUM portal. These communications are related to the progress of operations on the UNUM portal and may contain information about new products, promotions, special offers, etc.

This POLICY uses terms in accordance with the USER AGREEMENT and current Legislation.

1. USER'S PERSONAL DATA

1.1. The UNUM portal processes USERS' personal data with their direct consent within the framework of concluding and executing the USER AGREEMENT for the provision of services in accordance with current Legislation, including for improving and enhancing the SITE's services.
1.2. Personal data means any information relating to the USER.
1.3. Processing of personal data – any action or set of actions performed with personal data, including collection, systematization, storage, modification, use, depersonalization, blocking, distribution, provision, and deletion of personal data.
1.4. By agreeing to this POLICY, the USER provides consent to the processing of the following USER's personal data:
1.4.1. Any data allowing direct identification of the USER's identity (e.g., username, email address, phone number, etc.);
1.4.2. Any data that can be used to identify the USER's identity separately or in combination with other available information;
1.4.3. Other information obtained during the USER's identification and verification;
1.4.4. Data on operations conducted by the USER on the UNUM portal;
1.4.5. Data on the USER's payment instruments, including bank card details;
1.4.6. Technical information about the equipment used (IP address, software versions, etc.);
1.4.7. Data on USER behavior and the manner of using the UNUM portal's functionality;
1.4.8. Any other additional data voluntarily provided by the USER within the framework of concluding and executing the USER AGREEMENT, as well as obtained by the UNUM portal from other sources in accordance with the norms of this POLICY and Legislation.
1.5. By agreeing to this POLICY, the USER provides consent for the UNUM portal to perform the following actions with the USER's personal data:
1.5.1. Collection of personal data during USER identification and verification – carried out in accordance with the requirements of current Legislation;
1.5.2. Systematization, storage, depersonalization of personal data for the purpose of executing the USER AGREEMENT – carried out in accordance with the business processes of the UNUM portal;
1.5.3. Use of personal data for the purpose of fulfilling obligations in accordance with the USER AGREEMENT, as well as Legislation. The use of personal data is limited to the purposes established by this POLICY;
1.5.4. Modification, blocking, deletion of personal data – within the framework of current Legislation, including at the request of the USER or other authorized persons;
1.5.5. Provision, distribution of personal data – for the purposes of providing services in accordance with the terms of the USER AGREEMENT. Provision of the USER's personal data is possible only within the framework of the purposes stated in this POLICY. Distribution of the USER's personal data is possible only at the request of an authorized person in accordance with Legislation.

2. PRINCIPLES OF PROCESSING USERS' PERSONAL DATA

2.1. The UNUM portal strives to protect the privacy of USERS and the right to confidentiality in the processing of personal data, regardless of the methods or means of collecting such data, taking into account the following principles of their processing:
2.1.1. Consent.
Personal data is processed after obtaining the USER's consent based on the norms of Legislation. If the USER does not consent to the processing of personal data, it is necessary to refrain from using the UNUM portal.
2.1.2. Lawfulness, Fairness, and Transparency.
Personal data is processed in accordance with Legislation, fairly and transparently for the USER.
2.1.3. Purpose Limitation.
Personal data is collected and processed for the achievement of specific, pre-defined lawful purposes.
2.1.4. Data Minimization.
The processing of USER's personal data (including the volume and content of collected data) must be adequate (proportionate) and relevant to the stated purposes and ensure at all stages of such processing a fair balance of interests of all stakeholders. The UNUM portal strives to collect the minimum amount of information necessary to accomplish the stated task.
2.1.5. Storage Limitation.
Storage of USERS' personal data is carried out for the period necessary to achieve the stated purposes. If the use of stored data ceases to be necessary, the UNUM portal will take measures to destroy or terminate the processing of USERS' personal data within a reasonable time, taking into account functional and legislative requirements regarding the storage and confidentiality of personal data.
2.1.6. Accuracy.
Personal data must be accurate, reliable, complete, and up-to-date for achieving the purposes of their processing. The UNUM portal takes measures to ensure the reliability of the processed personal data. At the USER's request, personal data that is inaccurate must be deleted or corrected. If necessary, the UNUM portal will take measures to change or delete incorrect or incomplete data.
2.1.7. Transparency.
The UNUM portal openly communicates the fact of collecting USERS' personal data, the purposes of collection, and processing of personal data.
2.1.8. Integrity and Confidentiality.
Personal data must be processed in a manner that ensures their security, including protection against unauthorized or unlawful processing, as well as against accidental loss, destruction, or damage.
2.2. The UNUM portal undertakes to inform USERS about cases of violation of legislation and rules for handling USERS' personal data if there is a high risk that such violations entail infringements of the rights and legitimate interests of those USERS.

3. TYPES OF USERS' PERSONAL DATA

3.1. Data independently entered by USERS:

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Full name;  
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Phone number;  
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Email address;  
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Citizenship;  
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Other data determined by the UNUM portal in accordance with the requirements of Legislation.

3.2. Data automatically collected when using services:

Technical data about the device and internet connection.

Using server logs and other tools, the UNUM portal records data about the technical device used by the USER, how this device connects to the UNUM portal services, including data on the operating system, browser version, IP addresses, and unique identification files. Typically, this data is used to obtain anonymous (depersonalized) and aggregate statistics, but it may also be linked to the USER's account (profile). This information enables analysis of how services are used and customizes them for the USER's device to facilitate and ease the use of the UNUM portal.

Data on service usage.

When the USER uses the functionality of the UNUM portal, information about this is automatically recorded in server logs. The UNUM portal uses this information to prevent abuse of services, offenses, and crimes, improve services, and ensure the display of personalized and relevant content.

Cookies and other locally stored content.

When the USER uses the UNUM portal, various tools are used to recognize the USER and simplify the use of the UNUM portal. A cookie is a small data file (a piece of text) that is transferred to the USER's browser from the SITE. Such files contain information that the SITE can later read and simplify the use of the UNUM portal for USERS.

4. PURPOSES OF USING PERSONAL DATA

4.1. The UNUM portal processes USERS' personal data for identifying USERS, as well as other aspects of service provision, improving and developing services, and for providing personalized recommendations and offers, personalized content, preventing violations, and for commercial (advertising, marketing) purposes. Personal data is used for analytical purposes: understanding market trends.
4.2. The UNUM portal stores information provided by USERS when contacting the support service or other services of the UNUM portal to be able to contact USERS and provide a response to the inquiry. The UNUM portal stores all comments and suggestions sent by USERS to it, as they help improve the services provided.
4.3. The UNUM portal will recommend content and services to USERS based on user behavior and interests. Also, the UNUM portal uses personal data to customize banner advertising and other commercial content on the SITE according to USER preferences. Based on such information, advertising campaigns will be conducted. Advertisers placing banner advertising on the SITE may gain access to USER personal data and user preferences to display relevant banner advertising for the USER, but they are strictly prohibited from using this data for other purposes different from placing banner advertising on the SITE.
4.4. Periodically, the UNUM portal sends marketing emails (newsletters) to USERS by email or via other channels (e.g., social networks), if the USER has not opted out of receiving such newsletters. This newsletter may contain information about special offers from third parties.
4.5. The UNUM portal uses USERS' personal data to provide personalized services that meet the needs and interests of the User, as well as to improve the SITE interface. Information collected for these purposes is aggregated and anonymized. However, the UNUM portal may also use this information in a non-anonymized form if necessary to resolve technical problems encountered by individual users.
4.6. The UNUM portal uses technical information and information about USER activity to limit various types of service abuse and criminal activity on the SITE. Abuse of services includes fraud, spam distribution, phishing, offers of an intimate nature, attempts to log in using others' accounts (profiles), as well as other actions prohibited by the USER AGREEMENT and Legislation.
4.7. The purpose of processing USERS' personal data is also to obtain statistics on trends in the segment of the UNUM portal's activity, used for its improvement, as well as expanding the range of products and services. Statistics may be collected through analysis conducted both by the UNUM portal and by engaged companies. Such companies analyze information based on confidentiality and delete it after completing the assigned task.
4.8. Collected personal data may be stored and processed in a centralized database to understand user activity regarding all services of the UNUM portal.
4.9. The UNUM portal collects and processes USER personal data to comply with the requirements of Legislation. In cases stipulated by Legislation, the UNUM portal has the right to provide USER personal data to authorized persons.

5. PROVISION OF PERSONAL DATA TO THIRD PARTIES

5.1. USER's personal data may be provided to third parties – contractors of the UNUM portal for the provision of services, as well as to other companies for use for the purposes for which this information was collected, and only for the purposes specified in this POLICY (in particular – communication and other information service providers, financial institutions, payment companies, marketing partners). Where possible, information will be provided in an anonymous (depersonalized) form, but in some cases such information may allow identification.
5.2. Personal data may be transferred to third parties, for example, when sending service messages or when storing information on third-party servers. However, the terms of the UNUM portal's agreements with partners and contractors protect the USER's right to confidentiality and prohibit them from using the data for other purposes.
5.3. If there is reason to believe that an offense or crime has been committed through the UNUM portal, upon an official request from competent investigative authorities and in accordance with Legislation, USER data and information on the use of the UNUM portal may be transferred to such authorities.
5.4. Personal data may be transferred to relevant authorities at the initiative of the UNUM portal to prevent planned offenses and crimes if there are substantial grounds to believe that unlawful actions may be committed against third parties or the services of the UNUM portal.
5.5. The UNUM portal has the right to provide USERS' personal data to other state bodies in accordance with the requirements of Legislation, as well as, if necessary, to structural subdivisions of the Hi-Tech Park.
5.6. The UNUM portal will not use, sell, transfer, or disclose USERS' personal data in any other way and for other purposes not specified in this POLICY, unless provided for by a court decision or in case of obtaining prior explicit consent to do so.
5.7. If personal data is transferred to third parties in connection with the provision of services by the UNUM portal under an agreement, such third parties will be obliged to process the data confidentially and not to use this information for any other purposes.

6. USER RIGHTS

6.1. The USER has the right:
6.1.1. To withdraw consent to the processing of personal data at any time without giving reasons.
The UNUM portal, within fifteen days after receiving the application, terminates the processing of personal data, carries out their deletion, and notifies the USER thereof, unless there are other grounds for such actions with personal data provided for by Legislation. In the absence of technical ability to delete personal data, the UNUM portal takes measures to prevent further processing of personal data, including their blocking, and notifies the data subject thereof within the same period.
6.1.2. To obtain information concerning the processing of their personal data, containing:

name (surname, first name, patronymic (if any));
confirmation of the fact of personal data processing by the operator (authorized person);
their personal data and the source of their receipt;
legal grounds and purposes of personal data processing;
the term for which their consent was given;
the name and location of the authorized person, which is a state body, legal entity of the Republic of Belarus, or other organization, if the processing of personal data is entrusted to such a person;
other information provided for by legislation.

The UNUM portal, within five business days after receiving the application, unless another period is established by legislative acts, provides the requested information in an accessible form or notifies them of the reasons for refusing to provide it.
6.1.3. To demand amendments to their personal data if the personal data is incomplete, outdated, or inaccurate. For this, the USER submits an application with the relevant information confirming the need to amend the personal data.
The UNUM portal, within fifteen days after receiving the application, makes the corresponding amendments to their personal data and notifies the USER thereof or notifies the USER of the reasons for refusing to make such amendments, unless another procedure for making amendments is established by Legislation.
The USER also has the right to demand notification of third parties to whom personal data was transferred about the facts of correction of errors (inaccuracies) therein and the fact of their deletion (destruction).
6.1.4. To receive information about the provision of their personal data to third parties once a calendar year free of charge, unless otherwise provided by Legislation.
The UNUM portal, within fifteen days after receiving the application, provides the USER with information about which personal data and to whom were provided during the year preceding the date of application submission, or notifies the data subject of the reasons for refusing to provide it. Information may not be provided in cases provided for by Legislation.
6.1.5. To demand free termination of the processing of their personal data, including their deletion, provided there are no grounds for mandatory processing of personal data provided for by Legislation.
The UNUM portal, within fifteen days after receiving the application, terminates the processing of personal data and also carries out their deletion (ensures termination of personal data processing and their deletion by the authorized person) and notifies the USER thereof.
In the absence of technical ability to delete personal data, the UNUM portal takes measures to prevent further processing of personal data, including their blocking, and notifies the USER thereof within the same period. The UNUM portal has the right to refuse the USER's demands to terminate the processing of their personal data and (or) their deletion if there are grounds for processing personal data provided for by Legislation, including if they are necessary for the stated purposes of their processing, notifying the USER thereof within fifteen days.
6.1.6. Not to be subject to a decision made solely on the basis of automated processing of personal data.
6.1.7. To receive transparent information about the procedure for exercising the above-mentioned rights.
6.1.8. To appeal the actions of the UNUM portal in accordance with Legislation.
6.2. To exercise the rights provided for by this POLICY and Legislation, the USER submits an application to the UNUM portal in written form (a scanned copy of the application).
6.3. The USER's application must contain:

surname, first name, patronymic (if any);
address of their place of residence (stay);
date of birth of the data subject; statement of the essence of the requirements;
personal signature or digital signature.

6.4. However, if the provision of services by the UNUM portal in accordance with the USER AGREEMENT is impossible without the personal data whose destruction the USER requests, the UNUM portal has the right to terminate the provision of such services unilaterally.

7. STORAGE OF PERSONAL DATA

7.1. The UNUM portal stores collected USER personal data for the entire period of validity of the USER AGREEMENT, of which the USER is a party, and for 5 (five) years after the expiration of the USER AGREEMENT, since this period is the data retention period required in accordance with Legislation.
7.2. USER's personal data will not be stored in the UNUM portal's system longer than necessary to achieve the purposes for which they were collected. When the purposes for which personal data were collected are achieved, or if storage of personal data is no longer required in accordance with Legislation, the UNUM portal will take measures to destroy, aggregate, or depersonalize personal data.

8. SECURITY OF PERSONAL DATA

8.1. The UNUM portal stores and processes USERS' personal data in a reliable and secure manner. The UNUM portal follows procedures, principles, and measures that guarantee the confidentiality of USERS, taking into account the requirements of Legislation.
8.2. Access to USERS' personal data is carried out in accordance with the UNUM portal's local regulations regarding risk management and information protection.
8.3. The UNUM portal constantly improves the methods of collecting, storing, and processing USERS' personal data.
8.4. The UNUM portal restricts access to USERS' personal data for employees, contractors, and partners and imposes strict contractual obligations on them, with liability provided for violation.

9. POLICY CHANGES

9.1. The UNUM portal undertakes to regularly update the POLICY to inform USERS about all changes in the approach to processing USERS' personal data. In case of significant changes, USERS will be informed about them separately. All other changes to the POLICY are reflected on the SITE.
9.2. In case of questions regarding the POLICY, the USER can contact the UNUM portal user support service or at the email address specified in clause 10.3 of the POLICY.

10. AUTHORIZED PERSONS. CONTACTS

10.1. The authorized person responsible for internal control regarding the protection of personal data is the legal counsel.
10.2. The authorized person responsible for ensuring information security, including regarding the protection of personal data, is the official responsible for information security. Their functions include:
10.2.1. Development, updating, and implementation of this Policy;
10.2.2. Ensuring compliance of the personal data processing process with the requirements established by current legislation.
10.2.3. Determining and implementing security measures to protect personal data from unauthorized access, use, disclosure, modification, or destruction.
10.2.4. Ensuring employee training on the Policy and personal data protection procedures, as well as compliance with the adopted security measures.
10.2.5. Cooperation with personal data protection authorities and other regulatory bodies in case of incidents or requests related to personal data.
10.2.6. Receiving applications from the USER on issues related to this Policy.
10.2.7. Maintaining records of cases of violation of legislation and rules for handling USERS' personal data, as well as maintaining records of actions constituting the handling of client personal data in a form and manner ensuring the possibility of processing such data and prompt response.
10.3. The UNUM portal undertakes to bring to the attention of USERS up-to-date information about the contact details of the official (subdivision) responsible for ensuring information security regarding the protection of personal data by posting this POLICY on the SITE, as well as promptly informing USERS of changes to such data.
10.4. The email address of the official (subdivision) responsible for ensuring information security regarding the protection of personal data is
Info@theunum.io.

Limited Liability Company "LV Tekhnolodzhi"
220012, Minsk, Chernychevskogo Ave., 8, office 23
UIN 193758286

Personal data processing policy