VIDEO SURVEILLANCE POLICY

Last Updated: 10 March 2025

  1. 1. This Video Surveillance Policy (hereinafter – the Policy) has been developed in accordance with the requirements of the Law of the Republic of Belarus No. 99-Z dated May 7, 2021 “On the Protection of Personal Data” and defines the procedure for video surveillance by Fabros LLC (hereinafter – the Operator) in the premises located at: Minsk, Pobediteley Avenue 106, 3rd floor.

  1. 2. Purpose:

    • (1) The Operator carries out video surveillance in order to control visitor access to the Operator’s office premises, in particular for the purpose of protecting the Operator’s property and confidential information.

    • (2) In exceptional cases, when other methods of recording the actual working hours of employees do not enable the determination of the time when specific employees arrive at and leave work, recordings from the video surveillance cameras may be used by the Operator as a means to establish the arrival and departure times of employees.

  1. 3. Camera Placement:

    • (1) The cameras are located at the entrance (in common areas) and at the exit (inside the Operator's office premises) of the office premises located at: Minsk, Pobediteley Avenue 106, 3rd floor. The cameras are aimed at the entrance doors.

    • (2) The Operator does not conduct video surveillance in the Operator’s work zones and rest areas; however, these zones may partially fall within the view of the cameras due to the open space layout of the office.

  1. 4. Features of the Video Surveillance System:

    • (1) The video surveillance system does not allow the identification of individuals captured on the video recording (it is not used for identifying persons).

    • (2) The video surveillance system does not record audio.

    • (3) Video recording is not conducted uninterruptedly and 24 hours a day; the surveillance cameras are motion-activated and begin recording once movement is detected within their view area.

  1. 5. Data Transmission:

    • (1) The Operator does not engage third parties to process recordings from the surveillance cameras. The Operator stores the data locally (on its own servers) using software to which third parties do not have access.

    • (2) The Operator may provide recordings from the surveillance cameras exclusively upon the request of the appropriate government authorities and other persons, as well as in other cases when such disclosure is necessary for the purposes of judicial, administrative, or criminal proceedings, and to protect its own legitimate interests and rights.

  1. 6. Data Retention Period:

    • (1) The records of the video cameras are retained by the Operator for 60 calendar days, after which they are deleted from the system.

    • (2) If the Operator receives information suggesting that the cameras have recorded an event that may indicate the occurrence of a disciplinary misconduct, administrative offense, or criminal act, the retention period for such video recordings may be extended for the duration of the relevant proceedings as per the oral instructions of the Operator's management.

  1. 7. Rights of Personal Data Subjects:

    • (1) Personal data subjects (individuals captured by the Operator's video cameras) have the right to:

      • i. obtain from the Operator information concerning the processing of their personal data;

      • ii. receive from the Operator information about the disclosure of their personal data to third parties once per calendar year free of charge;

      • iii. request from the Operator the free cessation of processing of their personal data, including their deletion, if there are no grounds for processing of such personal data;

      • iv. appeal the actions (or inactions) and decisions of the Operator that violate the rights of personal data subjects to the designated authority for the protection of personal data subjects rights (National Center for the Protection of Personal Data of the Republic of Belarus, https://cpd.by), with the decision of that authority being subject to review in court;

      • v. demand compensation for material and moral damages, as well as for any incurred losses resulting from the violation of the rights established by the personal data laws.

    • (2) In order to exercise the aforementioned rights, the personal data subject must submit a written application to the Operator (either by postal mail or in person) or in the form of an electronic document (i.e., signed with the electronic digital signature). The application must contain:

      • i. surname, first name, patronymic (if applicable), the address of residence (or place of stay);

      • ii. date of birth;

      • iii. identification number, or, if absent, the number of the identity document;

      • iv. nature of the request;

      • v. personal signature or electronic digital signature.

  1. 8. Operator's Contact Information: privacy@fabros.by.