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Personal Data Processing Policy

Rules for processing and protecting the personal data of website visitors and group clients.

Revision date: 21 October 2026.

1. General provisions

PumpTechnologies LLC, taxpayer number 291137364 (the Controller), processes personal data of visitors to pumptech.by and people submitting enquiries, price requests and tender invitations through the website.

The website represents PUMPTECH Group of Companies. All website enquiries are handled by PumpTechnologies LLC, whose registered Russian name is ООО «ПампТехнолоджис». This legal entity is the Controller under this Policy.

This Policy describes the purposes, data categories, retention periods and ways to exercise data subject rights, with reference to the Law of the Republic of Belarus No. 99-Z of 7 May 2021 on Personal Data Protection. Data is processed to the extent necessary for the relevant purpose.

2. Controller details

Legal entity
PumpTechnologies LLC (ООО «ПампТехнолоджис»)
Taxpayer number
291137364
Registered address
Office 501, 52 Pionerskaya Street, Brest, Republic of Belarus
Postal address for written requests
52 Pionerskaya Street, Brest, 224020, Republic of Belarus

3. Handling enquiries

Purposes: receive an enquiry, contact the applicant, select equipment, spare parts or services, prepare a quotation and consider a tender invitation.

Data: name, organisation details, telephone number, email address, enquiry text, equipment or procurement information, and files provided by the applicant. Depending on the form, procurement requirements and deadlines may also be requested. The request number, submission page and consent information are recorded.

Basis: consent given when submitting the form. Grounds for subsequent processing relating to a contract or a legal obligation are determined separately for the relevant activities.

Retention: enquiries that do not result in a contract, correspondence and attachments are retained for 12 months after the enquiry is closed, meaning the response or negotiations for that enquiry have ended. Data must then be deleted unless another lawful retention ground applies.

If a contract is concluded, necessary information becomes part of the relevant records. Contractual, accounting and other mandatory records are retained under applicable legal requirements; the enquiry retention period does not replace those requirements.

Please do not attach passport information, health data, bank card details or other personal information unnecessary for your enquiry. You must have a basis for providing information about other individuals.

4. Advertising emails and calls

PumpTechnologies LLC requests separate, voluntary consent for advertising emails and promotional calls. The checkbox is initially unchecked. Declining advertising does not prevent submission or consideration of an enquiry.

Purpose: communicate the Controller’s products, services and offers by email and telephone. Data: name, email address, telephone number, and consent or withdrawal records. Processing includes collection, recording, storage, use for advertising and provision of necessary information to the messaging service used.

Period: three years from separate consent, or until earlier withdrawal. Advertising use ends when consent expires or is withdrawn. Evidence of consent and withdrawal is retained separately for applicable statutory periods and is not used to continue advertising.

Withdrawal: email info@pumptech.by, asking us to stop advertising emails and calls and identifying the relevant email address or telephone number. You can also use an unsubscribe link when available in the mailing channel. Withdrawal of advertising consent does not stop handling an enquiry where a processing ground remains.

The request email and Bitrix24 lead record the choice, date and time, language, and advertising consent revision. Submitting an enquiry, or previously consenting only to an enquiry response, does not itself constitute advertising consent.

5. Services and data recipients

The Controller’s staff access information as needed to handle enquiries and perform their duties. The following services support the website and enquiry handling:

  • ООО «Суппорт чейн» / HostFly: website hosting and corporate email; according to the Controller, these are hosted in Belarus.
  • Bitrix24: enquiry records, contact details, messages and attachments; according to the Controller, CRM data is hosted in Belarus.
  • SendPulse: SMTP delivery of enquiry emails, including contact details, message text and attached files. Its public policy identifies SendPulse Inc. and allows processing in the USA and Germany. SendPulse Privacy Policy.
  • Cloudflare Turnstile: protection against automated submissions. It processes technical signals including IP address, User-Agent and TLS information. The theme does not include enquiry fields or attachments in its server-side token verification request. Turnstile Privacy Addendum.
  • Yandex Metrica: traffic, click and session analytics, including Webvisor. Yandex Metrica terms.
  • Yandex Maps: the address map on the contact page. Yandex Maps terms.

Website visits and external services may involve processing IP addresses, browser and device information, cookie identifiers, visited pages and technical logs. The exact data and retention periods used by external services depend on their terms and configuration. Enquiry consent does not replace any separate consent required for other purposes.

The session cookie pt_oem_forum_2026 controls the OEM Industrial Forum invitation. It stores the scheduled display time or a flag indicating that the invitation has already been shown, so it is not repeated across pages or tabs during the same browser session. It contains no name, email address or telephone number and is not used for advertising tracking. No persistent retention period is set; session restoration depends on browser settings.

6. Cross-border transfers

Cross-border transfer arrangements are undergoing legal review.

The Controller is clarifying overseas recipients, processing countries, applicable transfer grounds, and necessary information and consent mechanisms. This section will be updated following the review.

SendPulse, Cloudflare Turnstile and Yandex services are currently used on the website. Their use may involve processing outside Belarus. SendPulse publicly identifies the USA and Germany; the full processing and access geography of each service is being clarified under the terms applicable to the relevant accounts. Hosting the website, mailbox and CRM in Belarus does not confine the entire processing chain to Belarus.

The legal basis for each data flow is determined separately. Where consent requiring prior information about risks is the applicable basis, that information and consent must be obtained before the relevant transfer. The advertising checkbox does not replace cross-border transfer consent where such consent is required.

For questions about recipients and transfer arrangements, contact info@pumptech.by.

7. Processing and protection

Enquiry data is collected, recorded, organised, stored, updated, used, provided to necessary recipients and deleted where appropriate. Processing uses the website, email and CRM.

Data protection involves access restrictions, account and transmission security, handling data subject requests and ending processing when grounds cease. Applicable legal requirements and contractual terms must be considered when providing data to third parties.

8. Your rights and requests

Within the limits provided by law, you may obtain information about processing and disclosures, request correction of inaccurate data, request an end to processing and deletion where no further ground exists, withdraw consent and complain to the National Personal Data Protection Centre of the Republic of Belarus.

For questions and consent withdrawal, email info@pumptech.by. Written requests may be sent to 52 Pionerskaya Street, Brest, 224020, Republic of Belarus. Telephone: +375 29 777 73 73.

Requests to exercise statutory rights must use the form and details required by law. Where a signed request is required, use a written request or an electronic document signed with an electronic digital signature. The ability to withdraw consent in the form in which it was given remains available. Requests are handled within statutory deadlines.

We may need information to identify the applicant and relevant data. Do not send a passport copy without a justified need. Withdrawal does not preclude processing under another applicable legal ground; the Controller informs the applicant of that ground where it applies.

9. Policy updates

The current revision is available on this page. Updating the Policy does not itself obtain fresh consent or automatically expand previously agreed processing purposes.