Cookie Policy

POLICY
on the use of cookie files

CHAPTER 1

GENERAL PROVISIONS

1. This Cookie Policy (hereinafter — Policy) has been developed in accordance with the Law of the Republic of Belarus dated May 7, 2021 № 99-Z "On Personal Data Protection" (hereinafter — the Law). It serves as one of the measures to protect the personal data of users of the website www.belhotel.by (hereinafter — the Website), owned by the private scientific and production unitary enterprise "Automated Tourism Technologies" (Republic of Belarus, Minsk, Surazhskaya St. 10, office 21) (hereinafter — the Operator).

2. The Policy explains to Website users how and for what purposes the Operator processes cookie files and how users can control this process.

3. Terms and definitions used in this Policy:

cookie files — small strings of data sent to the user's browser when visiting the Website, allowing the Website to remember certain user and device information (such as preferences, language settings, etc.);
IP address — a unique address identifying a device on the Internet;
browser — application software used for viewing web pages;
web analytics tools — online resources that collect user behavior data on the Website: number of unique users, session duration, page depth, navigation patterns, user interactions;
Website user — an individual using the Internet who visits the Website to perform any actions;
session — the time period during which a user interacts with the Website from the moment of entry to the browser session closure;
device — a computer, mobile phone or other user device used to access the Website.

The terms and definitions used in this Policy also follow the meanings established by the Law.

4. The Operator processes cookie files for the following purposes:

to ensure user safety on the Website;
to ensure the proper functioning of the Website and improve its usability;
to create and deliver personalized advertisements;
to collect analytical data on user interactions with the Website in order to enhance its performance.

5. Cookie files are not used by the Operator to identify specific users of the Website.

CHAPTER 2

TYPES OF COOKIES USED AND USER INFORMATION OBTAINED THROUGH THEM

6. The Operator processes the following types of cookie files:

6.1. Technical (necessary) cookies.
Ensure the proper functioning and secure use of the website. These cookies do not store user data for marketing purposes and are not shared with third-party analytics systems. This type of cookie cannot be disabled.
6.2. Functional (personalized) cookies.
Used to personalize the user experience in response to user actions (e.g., storing site theme, language, location preferences).
6.3. Analytical cookies.
Allow counting the number and duration of visits to the Website, analyzing how users interact with it (including which pages they visit), thus helping to improve site performance and usability.
6.4. Advertising cookies.
Used for marketing purposes and to enhance the relevance and quality of advertisements, including delivering personalized content and targeted advertising based on user interests.

7. Depending on the storage duration in the user's browser, the Operator uses session and persistent cookies.
Session cookies are stored only during the user's visit, while persistent cookies remain for the period defined in their parameters or until deleted by the user.

8. The processing of cookie files may result in the collection of the following user-related information:

information about the pages visited;
number of visits within a month;
details about the user's operating system and browser;
IP address;
session duration on the Website.

This data is collected in accordance with the purposes stated in Section 4 of the Policy.

9. Depending on who sets (generates) the cookies, they are classified as:

first-party cookies — set (generated) by the Operator;
third-party cookies — set by third parties and used by the Operator for user interaction analytics and personalized advertising based on user preferences.

10. A list of cookies used by the Operator, along with their descriptions and storage durations, is provided in the annex, which is an integral part of this Policy.

CHAPTER 3

INFORMATION OBTAINED BY THE OPERATOR FROM COOKIE FILES. THIRD PARTIES TO WHOM THE OPERATOR TRANSFERS COOKIE FILES. CROSS-BORDER TRANSFER

11. The following information may be obtained through the processing of the used cookie files:

device information (device type, browser type and settings, operating system, source URL of the request, etc.);
content preferences (visited web pages, date and time of the Site visit, etc.);
information about advertisement display (viewability and user interaction with advertising content).

The Operator collects the specified information in accordance with the purposes stated in clause 4 of this Policy.

12. The Operator uses analytical tools and relevant cookie files from the following service providers:

Google Analytics – Google Analytics Privacy Policy;
Yandex.Metrica – Yandex Privacy Policy.

Google Analytics is applied for the purpose of providing statistical indicators of the Site's usage without identifying users.
Yandex.Metrica is applied for the purpose of improving user interaction with the Site, using cookie files to collect information about user behavior on the Site without identifying them.

13. For the purpose of dynamic map display on the Site, the Operator uses the Yandex.Maps API service provided by YANDEX LLC, as well as Google My Maps provided by Google LLC, in the “Contacts” section and on object pages.

To correctly display maps on the Site, third-party analytical cookie files are used by YANDEX LLC, which are technically necessary for the proper display of maps on the Site:

_yasc – allows counting the number of visitors and traffic sources;
yashr – used by Yandex.Metrica to collect information about user characteristics, target actions, etc.;
yandexuid – used to record user behavior data;
i, bh – allow distinguishing between Site users.

Thus, to properly display maps on the Site, the user must give consent to the use of analytical cookie files; otherwise, the maps will not be displayed.

14. For the purpose of dynamic map display on the Site, the Operator uses the Google My Maps service provided by Google LLC on object pages and on the "Contacts" page.

To correctly display maps on the Site, third-party analytical cookie files are used by YANDEX LLC, which are technically necessary for the proper display of maps on the Site:

_yasc – allows counting the number of visitors and traffic sources;
yashr – used by Yandex.Metrica to collect information about user characteristics, target actions, etc.;
yandexuid – used to record user behavior data;
i, bh – allow distinguishing between Site users.

Thus, to properly display maps on the Site, the user must give consent to the use of analytical cookie files; otherwise, the maps will not be displayed.

15. To create more accessible and informative content for users on the Site in the “News”, “Articles”, and “Object Page” sections, the Operator may use embedded YouTube videos. When visiting such pages of the Site, regardless of the user's cookie settings, and if the user is logged into Google services, the YouTube hosting service uses third-party cookie files that are technically necessary for the correct display of videos on our Site:

VISITOR_INFO1_LIVE – used to estimate the bandwidth of users on pages with embedded YouTube videos;
VISITOR_PRIVACY_METADATA – stores the user's consent status for cookie usage on the current website;
YSC – used to register a unique identifier to track statistics of videos viewed by the user on YouTube.

Please note that these cookie files are not used by the Operator to collect analytical data about users and are removed from the user's browser when navigating to another page of the Site.

16. Combined information about users, collected based on their behavior on the Site and the use of the Site, presented as a unified data array (hereinafter referred to as “aggregated data”), which is not associated with the identification of a specific user, may be transferred to the following interested third parties (advertisers and/or publishers) for the purpose of developing targeted advertising, studying advertising effectiveness, and improving it:

Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043; Google Analytics Privacy Policy;
Yandex Advertising LLC, Minsk, Dzerzhinsky Ave. 5, office 303.1; Yandex Privacy Policy;
ARTOX Media LLC, Minsk, Tolbukhin St. 2, floor 5. ARTOX Media Privacy Policy.

17. When using cookie files, the Operator performs cross-border transfer of aggregated data to third parties specified in clause 15 of this Policy.

Within the use of the Google Analytics web analytics service by the Operator, cross-border transfer of aggregated data to Google LLC servers located in countries that do not provide an adequate level of protection for the rights of personal data subjects is carried out.

In this regard, the Operator additionally informs personal data subjects about the existence of risks arising due to the lack of an adequate level of personal data protection in such foreign countries:

• absence of special legislation regulating the processing of personal data, including requirements for compliance with such standards;
• absence of an independent authorized public authority for the protection of personal data subjects' rights;
• limited rights of personal data subjects;
• use of inappropriate methods for obtaining personal data, unlawful processing of personal data, resulting in personal data being accessible to an unlimited number of persons.

Additional information on the procedure for processing personal data by Google LLC when working with Google Analytics can be found on the official website of the company on the Internet at the following link.

CHAPTER 4

METHODS OF OBTAINING USER CONSENT FOR COOKIE PROCESSING

18. Upon the first visit to the Site, the Operator offers the user the option to either consent to the use of cookie files or refuse them by clicking the “accept” or “decline” buttons on the pop-up information banner.
By clicking the “accept” button, the user gives consent to the use of all types of cookie files listed in clause 6 of the Policy. By clicking the “decline” button, the user refuses the use of functional and analytical cookie files.
Since the Operator can ensure the full and correct operation of the Site, including its safe usage, only through the use of technical cookie files, this type of cookie file cannot be disabled by the user and is processed regardless of the user’s consent.
Additionally, by following the “More about cookie settings” link on the pop-up information banner, the user can configure the use of specific types of cookie files (“functional”, “analytical”) as desired, with the exception of “technical (necessary) cookie files”.

19. The Site retains the user's cookie settings preference for a period of 1 (one) year. Upon expiration of this period, the Site will again request the User’s consent via a pop-up information banner.

CHAPTER 5

METHODS FOR REFUSING COOKIE PROCESSING

20. The User of the Site may change their selection and also refuse the use of cookie files, with the exception of the “technical (necessary) cookie files” type, before the expiration of the period specified in clause 10 of this Policy, by clicking the “Cookie Settings” button at the bottom of the Site page.

21. The User may also manually clear their device and/or refuse the use of cookie files by accessing the browser configuration settings and selecting one of the following options:

• blocking cookie files on the User’s device;
• prompting the browser to notify the User about the consent to install a new cookie file on the User’s device;
• accepting or rejecting cookie files depending on the sender.

Some browsers allow visiting websites in “incognito” mode, which automatically deletes session cookie files.
More information about cookie management settings is available via the external links leading to the websites of major browsers:

• Firefox;
• Google Chrome;
• Safari;
• Opera;
• Microsoft Edge;
• Internet Explorer.

Additionally, the User may use the following tools:

• Yandex.Metrica blocker;
• Google Analytics blocker.

Blockers are browser plugins that prevent the placement of cookie files on the User’s computer and limit the transfer of data to Yandex.Metrica and Google Analytics, respectively.

22. The correct operation of the Site is possible only when using technical (necessary) cookie files. If this type of cookie file is disabled, the Operator cannot guarantee the User full and efficient operation of all functional capabilities of the Site.
Disabling functional, analytical, and/or advertising cookie files will prevent improvements to the Site based on User preferences, as well as personalized advertising and other marketing content relevant to each specific User.

CHAPTER 6

ASSISTANCE IN THE EXERCISE OF RIGHTS RELATED TO COOKIE PROCESSING

23. The User has the right to contact the Operator for assistance in exercising their rights related to the processing of cookie files using one of the following methods:

• in person;
• by sending a written request by post to the address: Republic of Belarus, Minsk, Surazhskaya St. 10, office 21.

24. To obtain assistance in the exercise of rights, the personal data subject may also contact the person responsible for internal control over personal data processing at the Operator by sending a message to the email address: info@att.by.

CHAPTER 7

FINAL PROVISIONS

26. The current version of this Policy is published in open access on the Site.

27. The Operator reserves the right to make changes and additions to the Policy at any time unilaterally.

28. A draft of the updated Policy will be published on the Site for user review.

29. Matters related to the processing of personal data not regulated by this Policy shall be resolved in accordance with the legislation of the Republic of Belarus.

Appendix 1
to the Cookie Policy
Statement