Privacy Policy

1. Data controller

Your personal data will be processed according to the purposes specified in section 3 below, “Purpose of processing personal data”, and by the following entities as autonomous data operators:

• MBE Bel LLC, the exclusive licensee in the Republic of Belarus for Mail Boxes Etc (hereinafter also referred to as “MBE”)
• The MBE franchisee – that is, the entrepreneur indicated on the delivery order form to which the specified Privacy Notice is attached.

2. Categories of processed personal data

2.1. Personal data provided by you voluntarily

Please note that the personal data that you provide directly is subject to processing.

Personal data means “any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is a person who can be identified, directly or indirectly, in particular by reference to such an identifier as a name, identification number, location data, network identifier or one or more factors specific to physical, physiological, genetic, mental, economic, cultural or social identity of this individual, including photographs.

2.2. Personal data of third parties provided by you voluntarily

You note that any indication (for example, when you fill out a delivery order form and/or electronic forms via the Internet and/or the MBE franchisee) of personal data and contact of any other entity as part of the delivery service is a case of processing personal data when you speak as a Data Controller in relation to the above entities. Thus, you, as the Controller of personal and contact data, guarantee that such data is collected and transmitted in accordance with the relevant provisions. For this purpose, you undertake to inform the indicated entities whose personal data are collected and transmitted in connection with the procedures and purposes of processing. The personal data of these entities are communicated solely for the purpose of sending and accompanying accompaniment.

3. Purpose of processing personal data

Your personal data will be processed, if necessary, with your prior explicit consent of MBE Bel LLC and/or the MBE franchisee and/or courier, depending on the goals pursued by each as an autonomous Data Controller.

3.1 Purpose of processing personal data of the MBE franchisee.

The MBE franchisee will process your personal data for:

Sending and accompanying, as indicated in the delivery order form, including payments, any complaints and communication with you; marketing purposes in the broad sense, that is, sending to you by any means of communication (fax, email, text messaging, multimedia messaging service, paper mail, phone calls) advertising materials and documents of an advertising nature or commercial offers related to services, products or discounts offered by the MBE franchisee, as well as for research and market reviews and the creation of relevant statistics.

3.2. The purpose of the processing of personal data by MBE Bel LLC

MBE Bel LLC will process your personal data for:

Marketing purposes in the broad sense, that is, sending to you by any means of communication (fax, email, text messaging, multimedia messaging service, paper mail, phone calls) advertising materials and documents of an advertising nature or commercial offers related to services, products or discounts offered by the MBE franchisee, as well as for research and market reviews and the creation of relevant statistics. profiling goals for individual clients or groups of clients, so that you can evaluate, analyze or anticipate aspects regarding personal preferences regarding the cost and type of services purchased, the method and type of delivery, reliability, destination addresses of your items, as well as services that most often required to offer you additional services, products or discounts (for example, stationery, graphic materials, printing products, websites, direct debit services, etc.).

4. Legal basis for the processing of personal data
– The legal basis for the processing of personal data for the purposes specified in section 3.1 (i) is the agreement to which you are a party to make it possible to send and accompany the goods at your request.

The provision of your personal data and/or data of the consignee for the above purposes is optional, however, failure to comply with this requirement will result in the inability to carry out and accompany the dispatch in accordance with your request.

– The legal basis for processing for the purposes specified in Section 3.1 (ii) is your express consent.

The provision of your personal data for these purposes is optional, and failure to fulfil this condition will have the sole consequence that the MBE franchisee will not be able to send you advertising and promotional messages, as well as to conduct marketing research. Instead, the execution and management of your shipment by the MBE franchisee remain unbiased.

– The legal basis for processing for the purposes specified in section 3.2 (i) and (ii) is your express consent.

The provision of your personal data for these purposes is optional, and their failure to provide will have the only consequence that MBE Bel LLC will not be able to send you advertising and promotional messages, as well as to conduct marketing research and/or ii) do the above profiling. The execution and management of your shipment by the MBE franchisee remain unbiased.

We further indicate that if you have agreed that the MBE franchisee and MBE Bel LLC pursue these goals, in accordance with section 3.1 (ii) and 3.2 (i) and (ii) above, you can withdraw your consent at any time and/or object to the processing of data for the above purposes by sending, without any formalities, a clear written message to our address, as described in section 10 below, “Contacts for exercising the rights of the data subject and for receiving additional information.”

With regard to the exercise of the right to object to the processing of data for marketing purposes, we inform you that if you use it, this will apply to all means of communication, whether electronic, automated or traditional, but you have the right to exercise your right to object to a limited extent, only some communication channels. For example, at any time, by contacting the appropriate Data Controller at the addresses specified in Section 10 below, “Contacts for exercising the rights of the data subject and for obtaining additional information”, you may object to the sending of advertising messages by automatic means (i.e. communications by e-mail, text messaging, multimedia messaging services, etc.) and, therefore, give your consent solely to receive messages in traditional ways (i.e. by mail or phone calls using the operator).

After receiving such a statement of withdrawal and/or objection, the MBE franchisee and/or, as the case may be, MBE Bel LLC will promptly proceed to delete and erase your personal data from the database and inform, if possible, any third parties, to which your data was transmitted.

5. The procedure for processing personal data

The processing of your personal data will be carried out using manual and information devices, as well as paper.

The personal data provided by you will not be subject to an automated decision-making process, except for profiling in accordance with section 3.2 (ii) above.

6. Recipients of personal data
Your personal data, which will not be distributed by either the MBE franchisee or MBE Bel LLC, may be transferred:

From the franchisee MBE: MBE franchisee employees, agents or colleagues located in the Republic of Belarus and the European Union; employees, agents or colleagues of MBE Bel LLC located in the Republic of Belarus; entities involved in assistance and consultation on behalf of the MBE franchisee in the following areas: accounting, administrative, legal, tax and financial matters that are located in the Republic of Belarus and the European Union; entities, bodies or institutions to which your personal data is required by virtue of provisions of the law or orders issued by authorities.

On the part of MVE Bel LLC: MBE franchisee employees, agents or colleagues located in the Republic of Belarus and the European Union; entities located on the territory of the Republic of Belarus and the European Union, which MBE Bel LLC uses for profiling and marketing activities; branches and subsidiaries that currently include MBE Worldwide S.p.A., Jonathan & Assist S.r.l, PonyZero S.r.l., Eurocubia S.r.l., DireFareStampare S.r.l. and Buy-me S.r.l .; to third parties located on the territory of the Republic of Belarus and the European Union, with which from time to time commercial partnership agreements and/or joint initiatives, campaigns and projects will be developed; persons, companies or professional offices located in the European Union that provide assistance and advice on accounting, administrative, legal, tax and financial matters; entities, bodies or institutions to which your personal data is required by virtue of provisions of the law or orders issued by authorities.

Subjects or categories of entities to which your personal data will be transferred MBE Franchisee and/or MBE Bel LLC. They can process your personal data as data processors, standalone data controllers or collaborative data controllers.

Complete list of data processors:

The MBE franchisee is available at the legal address; for more information, you can contact us in writing at the addresses indicated in section 10 below, “Contacts for exercising the rights of the data subject and for receiving additional information”. MBE Bel LLC is available at a legal address; for more information, you can contact us in writing at the addresses indicated in section 10 below “Contacts for protecting the rights of the data subject and for more information”.

7. Transfer of personal data outside the UP
Your personal data and recipient data will not be transferred outside the Republic of Belarus and the European Union to either MBE Bel LLC or MBE franchisee.

8. Retention of personal data

In accordance with the principle of proportionality, we inform you that:

(i) The MBE franchisee, for the purposes specified in section 3.1 (i) above (sending and managing forwarding), will retain your personal data for the time necessary to complete and maintain the package, without prejudice to any specific legal obligations with respect to storage of accounting documents;

(ii) The beneficiary of the MBE franchise, for the purposes specified in section 3.1 (ii) above (marketing), will store your personal data for a period not exceeding twenty-four months from the date of its recording, unless the anonymity does not allow it, even Indirectly or in conjunction with other data, identify the data subject; (iii) MBE Bel LLC, for the purposes specified in Section 3.2 (i) (marketing) and 3.2 (ii) (profiling) above, will store your personal data for a period of not more than twenty-four and twelve months, respectively, from the moment of their recording, with the exception of cases when anonymity does not allow, even indirectly or in conjunction with other data, to identify the data subject;

MBE Bel LLC and MBE franchisees have implemented appropriate mechanisms for the automatic deletion of personal data, including from any third parties to whom such data could be transferred.

9. Exercise of rights by the data subject
We inform you that:

a) You have the right to contact the data controller for access to personal data, its correction or deletion or restriction of processing in relation to you, as well as to object to such processing or withdraw consent, in addition to the right to data portability.

b) You have the right to file a complaint.

c) Any correction, deletion or restriction on processing made at your request, unless it is impossible or requires disproportionate efforts, will be communicated by the Data Controller(s) to each of the recipients to whom or to whom your personal data was transferred. The Data Controller(s) may inform you of such recipients if you make a special request.

Your application for the exercise of such rights must be sent in writing to the Data Controller(s) at the addresses indicated in section 10 below, “Contacts for exercising the rights of the data subject and for obtaining additional information”.

The exercise of rights is not subject to any formal restrictions and is free.

For convenience, we provide below the text of article 7 of the Italian Privacy Code:

The right to access personal data and other rights The data subject has the right to receive confirmation of the existence or absence of personal data concerning him, even if they have not yet been registered, as well as the right to transmit it in an understandable form.

The data subject has the right to receive information:

a) The source of personal data

b) The goals and methods of processing

c) The logic applied to processing, if carried out by electronic means

d) The identity of the data operator, data processing operators and the designated representative in accordance with Article 5.2

e) About entities or categories of entities to which personal data may be transferred, or who may learn about them as an authorized representative in the territory of the State, a data processor(s) or a person(s) responsible for data processing.

3. The data subject has the following rights: a) receive updates, corrections or, if he/she is interested in it, replenishment of data; b) the deletion, alteration or blocking of data that was processed unlawfully, including data whose storage is not required for the purposes for which it was collected or subsequently processed; c) obtain confirmation that the operations in accordance with paragraphs a) and b) have been communicated, including with regard to their contents, to those to whom the data have been communicated or disseminated, unless this requirement is impossible or explicitly required disproportionate effort in relation to the right to be retained.4. The data subject has the right to object, in whole or in part: a) legally, to the processing of personal data concerning him/her, even if they are related to the purpose of the collection; b) to process personal data concerning him/her when it is carried out for the purpose of sending out advertising materials or direct selling, or for conducting market research or commercial communication survey.