1. General provisions
This Personal Data Processing Policy, hereinafter the Policy, governs processing of personal data of users of the website mnrln.com and the service Mineralnaya Music.
The Policy applies to the website, accounts, registration/contact forms, Release uploads, service payments, payouts, support and other Service features.
The Policy takes account of Belarusian personal data law, including Law No. 99-З of 7 May 2021 “On Personal Data Protection”.
2. Personal data controller
The personal data controller is “Mineralnaya Music” Limited Liability Company.
Short name
Mineralnaya Music LLC
Full name
“Mineralnaya Music” Limited Liability Company
Taxpayer ID (UNP)
193782745
State registration date
14.08.2024
Registration authority
Minsk City Executive Committee
Registered office
Republic of Belarus, Minsk, Zavodskoy District, 3 Michurina Street, premises 1
Personal data email
[email protected]
Support email
[email protected]
For processing enquiries, data subject rights, consent withdrawal, correction or cessation, contact: [email protected].
3. Key definitions
- Personal data — any information relating to an identified or identifiable individual.
- Data subject — the individual to whom personal data relate.
- Controller — a person organising and/or carrying out processing alone or jointly.
- Personal data processing — any operation(s), including collection, storage, alteration, use, disclosure, blocking and deletion.
- Authorised processor — a person processing data on the Controller’s instructions.
- User — a person using the website, account, services or contact forms.
- DSP — digital platforms, streaming services, social networks, UGC and other services publishing or monetising Content.
4. Processing principles
- lawful, fair and transparent processing;
- specific, previously declared lawful purposes;
- only data necessary and proportionate to those purposes;
- measures to keep data up to date;
- retention only as long as needed, unless law provides otherwise;
- organisational and technical measures to protect personal data.
5. Purposes, data categories, grounds and retention
Only data needed for a specific purpose are processed. The list varies with Service features used.
Registration, sign-in and account operation
Data
email, optional phone, username, password/hash, account ID, registration date, profile settings and sign-in history.
Legal basis
contract formation/performance and User registration/Service use.
Retention period
during account use and for 3 years after closure or last activity, unless longer retention is needed to protect the Controller’s rights, perform the contract or comply with law.
Digital distribution services
Data
profile, Releases, artists, authors, rights holders, Content metadata and moderation/delivery/takedown statuses.
Legal basis
contract, Public Offer, DSP delivery and Release support.
Retention period
during the contract and for 3 years after the relationship ends, unless longer retention is needed for disputes, reporting, DSP claims or legal compliance.
Service payments, payouts, reporting and accounting
Data
payment data, amount/date/method, payout details, balance history, DSP reports, accruals and deductions.
Legal basis
contract performance, accounting, bank/payment/legal requirements and fraud procedures.
Retention period
for periods required by Belarusian accounting, tax and financial law and bank/payment-system rules.
Support, complaints and communication
Data
email, name/alias, enquiry content, attachments, correspondence, support notes and account/Release information.
Legal basis
contract performance, enquiry handling and protection of Controller/User rights and lawful interests.
Retention period
up to 3 years after an enquiry closes, unless longer is needed for disputes, contract performance or Controller rights.
Security, fraud prevention and Service protection
Data
IP, user-agent, action date/time, technical logs, security events, login attempts and suspicious activity indicators.
Legal basis
account protection, abuse prevention, contract performance, Controller interests and DSP/payment-system requirements.
Retention period
up to 12 months after the event, unless longer is needed for security investigation, fraud checks, law or Controller rights.
Information and service notices
Data
email, account ID, Release status and moderation, payout, terms, security and Service notices.
Legal basis
contract performance and informing the User about Service operation.
Retention period
during Service use and as long as needed to prove notice delivery.
Marketing and promotional messages
Data
email, optional name/alias and subscription consent/refusal records.
Legal basis
User consent, where required.
Retention period
until consent withdrawal or mailing cessation, where based on consent.
Separate consent is requested when required. Withdrawal does not affect the lawfulness of prior processing.
6. Sources of personal data
The Controller receives personal data:
- directly from the User during registration, profile completion, uploads, support and Service use;
- automatically: IP, cookies, technical logs and device/browser data;
- from DSPs, banks, payment systems and technology partners as needed for reporting, payouts, payments, moderation, fraud checks and Release support;
- from User-supplied documents/materials for rights evidence, payment identification or claims.
7. Disclosure to third parties and processors
Data may be shared only as needed for declared purposes, services, contract and legal obligations.
- DSPs and delivery partners — for publication, metadata processing, reporting and monetisation.
- Banks and payment services — payments, refunds, payouts, fraud checks and accounting.
- Hosting, cloud and technical providers — website/accounts, storage, backups and security.
- Communication services — emails, notifications, service messages and enquiries.
- Lawyers, auditors and advisers — as needed for rights protection, disputes, documents and obligations.
- Authorities, courts and other authorised parties — as provided by law.
When appointing a processor, the Controller takes measures to ensure processing follows instructions, declared purposes, law and contractual duties.
8. Cross-border personal data transfers
Digital distribution means DSPs, payment, communication, analytics, hosting and technology partners may be outside Belarus.
Cross-border transfers may occur only as needed for contract performance, Content publication/support, payments, payouts, Service operation, support, security and law.
Where a transfer requires separate consent or risk information, the Controller obtains consent or informs the subject as Belarusian law requires.
9. Cookies, analytics and technical data
Cookies and similar technologies may support sign-in, security, preferences, accounts, analytics and Service improvements.
- Essential cookies — website/account operation, authentication and security.
- Functional cookies — remember preferences and improve usability.
- Analytics cookies — understand website use and improve the interface.
- Marketing cookies — only with an appropriate basis, including consent where required.
Cookie data retention: for the cookie’s lifetime, no longer than needed for its stated purpose. Browser settings can restrict/delete cookies, which may affect website/account features.
10. Data subject rights
Users may exercise data subject rights under Belarusian law.
- obtain information on processing of their data;
- obtain third-party disclosure information as provided by law;
- request correction of incomplete, outdated or inaccurate data;
- request cessation without processing grounds;
- request deletion without retention grounds;
- withdraw consent where processing relies on it;
- challenge Controller acts/omissions before the authority or courts.
Send personal data requests to: [email protected]. Requests follow Belarusian statutory periods, generally 15 calendar days unless law specifies otherwise.
To prevent disclosure to others, the Controller may request information identifying the applicant and their link to the account/enquiry.
11. Personal data security measures
Necessary organisational/technical safeguards protect against unlawful/accidental access, alteration, blocking, copying, disclosure, distribution, deletion, destruction and other unlawful actions.
- access only for those who need it;
- technical protection including HTTPS, access controls, backups and security monitoring;
- activity logging as needed for security/incident investigation;
- vetting contractors/processors entrusted with data;
- responding to security incidents.
Users must still secure their own accounts: strong passwords, no credential sharing and timely reports of suspected unauthorised access.
12. Contacts, changes and current Policy
The Controller may update the Policy following changes in law, Service features, data, purposes, infrastructure or internal processes.
Current version
https://mnrln.com/politics
Last updated
22.04.2026
Document version
1.2
Personal data contact
[email protected]
Support
[email protected]
Continued use after publication means awareness of the current version for further use. Where separate consent is legally required, it is requested separately.
FAQ
Email: [email protected]. State the right you wish to exercise: information, correction, cessation, deletion or consent withdrawal.
Yes, without lawful grounds for further processing. Data needed for contracts, accounting, reports, claims or rights protection may continue to be processed as needed within applicable periods.
Yes, DSPs, payment, infrastructure and communication providers may be abroad. Transfers are limited to what processing purposes require.
Public Offer: https://mnrln.com/oferta
Terms of use: https://mnrln.com/uslovija
Support: https://mnrln.com/support
Terms of use: https://mnrln.com/uslovija
Support: https://mnrln.com/support