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Personal Data Processing Policy

Effective date: 01.08.2026

Date last updated: 01.08.2026

1. General Provisions

1.1. This Personal Data Processing Policy, hereinafter referred to as the “Policy”, establishes the procedure for the processing and protection of personal data of users of the DevCV.pro online service.

1.2. The personal data operator is:

State registration authority: Minsk City Executive Committee

Email: devcvsupport@gmail.com

Website: https://devcv.pro

Hereinafter referred to as the “Operator”.

1.3. The Policy has been developed in accordance with the Law of the Republic of Belarus No. 99-Z of 7 May 2021 “On Personal Data Protection” and other applicable legislative acts.

1.4. The Policy explains:

  • what personal data the Operator processes
  • from where the Operator obtains the data
  • for what purposes and on what grounds the data are processed
  • to whom the data may be disclosed
  • for how long the data are retained
  • what rights the personal data subject has
  • how those rights may be exercised

1.5. The Policy applies to data of users of the DevCV.pro website and service, purchasers of services, persons contacting technical support, and website visitors.

1.6. This Policy does not, in itself, constitute consent to the processing of personal data. Where consent is required by law, it is requested separately.

2. Core Principles of Data Processing

2.1. The Operator processes personal data:

  • on lawful and fair grounds
  • solely for specific, predetermined purposes
  • to the extent necessary to achieve the relevant purposes
  • for no longer than required by the purposes of processing and applicable law
  • while taking the necessary organisational, legal and technical security measures

2.2. The Operator does not sell users’ personal data.

2.3. The User must not enter into the Service excessive information that is not required to create a résumé.

2.4. The Service is not intended for the processing of special categories of personal data, including information concerning:

  • health
  • racial or ethnic origin
  • religious or philosophical beliefs
  • political views
  • trade union membership
  • intimate life
  • criminal convictions
  • biometric and genetic characteristics

The User is advised not to include such information in résumés or requests to artificial intelligence features unless this is objectively necessary.

3. Sources of Personal Data

The Operator obtains personal data:

  • directly from the User when using the Service
  • from forms and résumé sections completed by the User
  • from technical support requests
  • automatically when visiting the website and using the Service
  • from the payment provider after payment has been made
  • from banks and payment systems to the extent necessary to confirm the transaction
  • from technical services and authorised persons engaged by the Operator

4. Registration and Access to the Service

4.1. Purpose of Processing

Creating an account, identifying the User, providing access to DevCV.pro features, performing the Public Offer, and providing technical support for the Service.

4.2. Data Processed

The Operator may process:

  • email address
  • account creation date
  • information on purchased access
  • start and end dates of paid access
  • history of key actions in the Service
  • language and interface settings

4.3. Legal Basis

entering into and performing a contract with the User;

taking actions at the User’s initiative before entering into a contract;

the User’s consent, where required by law.

4.4. Retention Period

Account data are retained:

  • 30 days after the end of use of the service

Backups of deleted data may be retained for no more than 60 calendar days, unless a longer retention period is required by law or for the investigation of a security incident.

5. Creation and Storage of Résumés

5.1. Purpose of Processing

Enabling the User to create, edit, analyse and download résumés in PDF format.

5.2. Data Processed

The Operator may process information that the User independently includes in a résumé, including:

  • first and last name
  • contact details
  • city and country of residence
  • education information
  • work experience information
  • professional skills
  • project information
  • language proficiency
  • links to professional profiles, portfolios and repositories
  • a photograph, where the Service provides the option to upload one
  • other information voluntarily entered by the User

5.3. The User independently determines the content of the résumé and is responsible for the accuracy and lawfulness of the information entered.

5.4. The User must not provide personal data of other individuals without a legal basis.

5.5. Legal Basis

performance of a contract with the User;

the User’s consent, where the processing of specific data is not necessary for performance of the contract.

5.6. Retention Period

Résumé data are retained:

  • 30 days after the end of use of the service

A generated PDF file may be retained in the Service for the period necessary for its download, after which it is deleted or retained in the account in accordance with the storage model selected by the Operator.

The User must independently save the completed PDF file before the end of the paid access period.

6. Payment Processing

6.1. Purpose of Processing

Accepting payments, confirming payment, providing paid access, processing refunds, and maintaining accounting and tax records.

6.2. Data Processed

The Operator may receive:

  • the User’s email address
  • payment amount and currency
  • date and time of the transaction
  • payment identifier
  • transaction status
  • partially masked card details
  • name of the payment system
  • refund information
  • other data contained in the confirmation of the payment transaction

6.3. Full bank card details are entered on the secure page of the bePaid payment provider.

6.4. The Operator does not receive or store:

  • the full bank card number
  • CVC/CVV code
  • 3-D Secure password
  • bank transaction confirmation codes

6.5. Legal Basis

entering into and performing a contract;

fulfilment of obligations established by law;

protection of the rights and legitimate interests of the Operator and the User in the event of disputes.

6.6. Retention Period

Information on payments and refunds is retained for the periods established by the legislation of the Republic of Belarus for accounting, tax and other mandatory documents.

7. Technical Support Requests

7.1. Purpose of Processing

Reviewing requests, resolving technical issues, processing refund requests, and exercising the rights of personal data subjects.

7.2. Data Processed

name;

email address;

telephone number, if provided by the User;

text of the request;

attached files;

payment information;

technical information necessary to resolve the issue;

correspondence history.

7.3. Legal Basis

performance of a contract;

consent expressed by voluntarily submitting a request;

fulfilment of obligations provided for by law.

7.4. Retention Period

Requests and correspondence are retained for 3 years after the review of the request is completed, unless another period is required by law or by the nature of the dispute.

8. Technical Data and Security Logs

8.1. Purposes of Processing

ensuring operation of the website;

authenticating the User;

protecting accounts;

preventing fraud and abuse;

identifying and correcting errors;

ensuring information security.

8.2. Data Processed

IP address;

date and time of access to the Service;

browser type and version;

device type and operating system;

address of the requested page;

information on actions performed;

error messages;

technical application logs.

8.3. Legal Basis

performance of a contract;

ensuring the security of the Service;

compliance with legal requirements.

8.4. Retention Period

Technical logs are retained for no more than 12 months, unless a longer retention period is required to investigate an incident, resolve a dispute, or comply with legal requirements.

9. Cookies and Analytics

9.1. The website uses technical and analytics cookies.

9.2. Technical cookies are necessary for the proper operation of the Service and for retaining the User’s session and preferences.

9.3. Yandex Metrica is used to analyse traffic and improve the Service. It may set analytics cookies and collect technical information about website visits, the device, browser and user actions.

9.4. The User may delete or block cookies in browser settings. Disabling technical cookies may cause certain Service features to function improperly.

10. Storage of Personal Data

10.1. User data are stored on cloud infrastructure:

Provider: CloudVPS.by

Country or countries where servers are located: Republic of Belarus.

10.2. The Operator must ensure that the actual storage architecture conforms to the information specified in this Policy.

10.3. If data are stored simultaneously in several countries or the server location may change, this must be expressly stated in the Policy.

10.4. Once the purposes of processing have been achieved, data are deleted or anonymised unless their further retention is required by law.

10.5. Deletion of data from backups may not occur immediately but within the established backup refresh cycle.

11. Authorised Persons and Third Parties

11.1. For operation of the Service, the Operator may entrust data processing to the following categories of persons:

  • cloud and hosting providers
  • bePaid and participating banks, for payment processing
  • Google and the Gmail service, for processing requests sent to devcvsupport@gmail.com
  • technical infrastructure providers
  • providers of error-monitoring and analytics services, where connected
  • specialists providing development, technical support and security for the Service

11.2. The current list of principal authorised persons:

bePaid payment provider

CloudVPS.by cloud provider

Google service providers, processing email correspondence sent to devcvsupport@gmail.com.

Yandex Metrica analytics service

11.3. Personal data may be provided to state authorities, courts and other persons in the cases and in accordance with the procedure provided by law.

11.4. The Operator does not disclose to third parties more data than is necessary to achieve the relevant purpose.

12. Protection of Personal Data

12.1. The Operator takes legal, organisational and technical measures to protect personal data against:

  • unauthorised access
  • alteration
  • copying
  • dissemination
  • deletion
  • blocking
  • loss
  • other unlawful actions

12.2. Access to data is granted only to persons who require it for the operation of the Service and performance of their duties.

12.3. Despite the measures taken, no method of data transmission or storage can guarantee absolute security.

12.4. Upon identifying a breach of the personal data protection system, the Operator takes measures in accordance with the legislation of the Republic of Belarus.

13. Rights of the Personal Data Subject

The User has the right to:

  • withdraw previously given consent
  • obtain information about the processing of their personal data
  • request correction of incomplete, outdated or inaccurate data
  • obtain information about the disclosure of data to third parties
  • request cessation of processing and deletion of data where there is no legal basis for continuing the processing
  • appeal the actions or inaction of the Operator to the National Center for Personal Data Protection of the Republic of Belarus
  • apply to a court for protection of their rights
  • exercise other rights provided by law

Data will not be deleted, or deletion may be limited, where the Operator is required to continue retaining the data under law or to protect rights in an existing dispute.

14. Procedure for Exercising Rights

14.1. To exercise their rights, the User may submit a request to:

Email: devcvsupport@gmail.com

14.2. The request should include:

  • surname, given name and patronymic
  • contact email address
  • the substance of the request
  • information enabling identification of the User and retrieval of their data
  • a list of the data or processing operations to which the request relates

14.3. To prevent unlawful access, the Operator may request additional information necessary to confirm the applicant’s identity.

14.4. Do not send the Operator a copy of your passport, full bank card number, CVC/CVV code, passwords, or bank confirmation codes unless the Operator has expressly informed you of a lawful need to provide a specific document by a secure method.

14.5. Requests are considered in accordance with the procedure and within the time limits established by the legislation of the Republic of Belarus.

14.6. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal and does not terminate processing where another legal basis exists.

15. Minors

15.1. DevCV.pro paid services are intended for persons who have the legal capacity necessary to enter into a contract.

15.2. A minor may use the Service with the consent of a legal representative where provided by law.

15.3. If the Operator becomes aware that a minor’s data were provided without the necessary consent, the Operator may restrict the processing and delete such data.

16. Changes to the Policy

16.1. The Operator may amend the Policy in the event of changes to:

  • legislation
  • the functionality of the Service
  • the categories of data processed
  • service providers
  • data storage procedures
  • purposes or methods of processing

16.2. The current version of the Policy is published on the DevCV.pro website.

16.3. If changes require new consent from the User, the Operator requests such consent before commencing the relevant processing.

17. Contact Information

For matters concerning the processing and protection of personal data, please contact:

Email: devcvsupport@gmail.com

Requests are accepted 24 hours a day and processed on business days from 09:00 to 18:00 Minsk time.