This Policy in the field of processing and protection of personal data (hereinafter referred to as the Policy) is applied by Intellogic LLC, location address 121205, Moscow, territory of the Skolkovo Innovation Center, 42 Bolshoy Boulevard, building 1, 1st floor, part premises No. 334, a workplace No. 63 (hereinafter referred to as the Company or us), to the Internet sites, services, accounts on social networks and other products (services) of the Company through which we collect personal data and which refer to the Policy. The Policy does not apply to the websites of the Company that do not have a link to the Policy or that have a link to a document other than the Policy regarding the processing of personal data.
In the Policy, we openly talk about all methods of processing personal data when using the website of the Company. We have an expert status in protecting a wide variety of devices, infrastructures and data. Therefore, we understand the importance of a proper approach to confidentiality and data security and adhere to the principle of comprehensive and complete protection of the personal data of our users. As an international company, we take into account the conditions of other regulatory legal acts in the field of personal data, including the General Data Protection Regulation (GDPR).
The policy is developed and used in conjunction with the Consent to the user personal data processing.
1. General information
1.1. Personal data is considered to be any type of information relating directly or indirectly to a specific or non-specific individual. For example, personal data can be represented as last name, first name, middle name, position, company name, email address, phone number, and another type of information.
Personal information also includes technical information, if it can be related to an individual. For example, it can be an IP address, a type of operating system, a type of device (personal computer, mobile phone, tablet), browser, geographical location, the fact of filling out a web form, an internet provider.
If we cannot correlate information and an individual in any way, we will not consider this information to be personal data.
1.2. You understand that the Company is the operator of only that personal data that we have received from you as an individual through our websites, products, accounts on social networks, services (hereinafter referred to as the Services).
1.3. This document defines the Company's policy in the field of processing and protection of personal data and is available at https://botkin.ai/. The Company also provides unlimited access to the Policy to any person who contacts the Company personally.
1.4. The Company's main goal is to ensure the protection of the rights and freedoms of people and citizens during the processing of their personal data, including the protection of the privacy rights, personal and family secrets, strict and precise observance of requirements, primarily Russian legislation in the field of personal data.
1.5. The Policy applies to all personal data of individuals processed by the Company, as well as processes related to the personal data processing. The Company can process personal data with or without automation tools. The processes include (but are not limited to) collection, recording, systematization, accumulation, storage, clarification (updating, changing), copying, extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data.
1.6. The Company processes and stores personal data using servers located on the territory of the Russian Federation.
1.7 The Company has the right to make changes to the Policy if necessary. A mandatory review of the Policy is carried out in case of significant changes in international or national legislation in the field of personal data. If we process personal data, we will notify you of such changes via email.
1.8. The Company does not verify the accuracy of the personal data provided and the legal capacity of the person who provided them. You guarantee that all data is reliable, up-to-date and does not violate the laws of the Russian Federation.
2. Personal data processing goals
The company is guided by the principle of sufficiency, rationality and expediency of personal data processing. We carry out processes related to the personal data processing in cases specified in this section, and for relevant purposes.
2.1. When accessing the Services — in order to properly fulfill the Company's obligations to you, to provide services properly, to accept and process orders for the provision of such services, to sign in the Services, to identify the user of the Service, to recover the password for the Service, as well as in any other cases associated with such actions. Your use of the Services means unconditional agreement with this Policy and the conditions for processing personal data specified in it. In case of disagreement with this Policy, the use of the Services should be stopped immediately.
2.2. When participating in events held by the Company — for the purpose of registration for participation in such events. Participation in events held by the Company means unconditional agreement with this Policy and the conditions for processing personal data specified in it. In case of disagreement of the Personal Data Subject with this Policy, participation in events should be stopped immediately.
2.3. When communicating with you — in order to receive any feedback from you, as well as to provide you with any necessary reliable and complete information related to the activities of the Company. This includes (but is not limited to) providing information about the Services, sending out information about Services, events and promotions organized by the Company and / or authorized third parties. The Company has the right to use the phone number and / or email address you specified for communication purposes.
2.4. When receiving your feedback with the aim of:
obtaining information about loyalty and satisfaction with the Services and services, its further research and processing;
analysis to improve the quality of services and facilities;
conducting research of any categories.
2.5.When ensuring the personal data is protected and confidential — to ensure the operability and safety of the Services, to confirm the actions you take, for prevention of frauds, cyber attacks and other abuses, as well as investigation of such cases.
2.6. When considering candidates for filling vacant positions — in order to consider a candidate for filling a certain vacant position, making a decision on hiring or refusing to hire, as well as for staff formation.
3. Types of processed personal data
3.1. Depending on the web form you are filling out we may process the following personal data:
3.1.1. General personal data: last name, first name, middle name, position, company name, email address, phone number.
3.1.2. Other personal data: gender, date and place of birth, personal photo, citizenship, information about the place of residence and registration, identity documents, information about the position held, working conditions, basic and additional education, professional experience and skills, information on seniority, medical insurance, military registration, marital status and family, information about medical restrictions for work, conformity of the position (work performed), violations and penalties, awards and rewards, the employment expiration.
3.2. Other information processed by the Company:
3.2.1. Technical specifications and devices data: IP address, type of operating system, type of device (personal computer, mobile phone, tablet), browser type, geographical location, fact of filling out a web form, and the internet provider.
3.2.3. Information obtained as a result of your actions, including the following information: comments, requests, reviews and questions.
4. Principles of personal data processing
4. Principles of personal data processing Sufficiency is the main principle that we fully rely on when processing personal data. Your personal data will not be processed unless it is required. We also process personal data in accordance with the following principles:
4.1. The legality and fairness of the personal data processing.
4.2. Processing personal data in accordance with specific, predetermined and legal purposes.
4.3. Prevention of combining databases containing personal data, the processing of which is carried out for purposes incompatible with each other.
4.4. Processing only those types of personal data that meet the purposes of their processing.
4.5. Compliance of the content and volume of personal data with the stated processing goals.
4.6. The accuracy, sufficiency, relevance and reliability of personal data.
4.7. The legality of technical measures aimed at processing personal data.
4.8. The reasonableness and appropriateness of processing personal data.
4.9. Storage of personal data in a form that allows to determine an individual is possible no longer than the purpose of their processing requires, or during the term of consent of the individual.
4.10. The processed personal data is subject to destruction or depersonalization immediately in the cases specified in the Policy.
5. Processing personal data
5.1. Collection of personal data.
The collection of personal data is carried out in the following ways:
you provide your personal data when filling out forms, including web forms on the Services;
information is automatically collected with the usage of various technologies and services: web protocols, cookies, web tags that are launched only when you enter your data;
you provide your personal data written by hand, including by means of communication.
5.2. Storage and use of personal data.
Personal data is stored exclusively on properly protected media, including electronic ones, and is processed with or without automatic tools;
The company, with automated processing of personal data, ensures the use of databases located in the Russian Federation.
5.3. Transfer of personal data.
The company transfers personal data to third parties, such as consultants, partners, contractors and agents (hereinafter - Consultants) with your consent. Exceptions are cases when the transfer is carried out to ensure compliance with the terms of the contract, legal requirements, prevention or suppression of your illegal actions and protection of the legitimate interests of the Company and third parties; The transfer of personal data to the Consultants is carried out to achieve such goals and is based on a contract concluded with the relevant Consultant. At the same time, the Consultants undertake to use personal data exclusively in accordance with this Policy, to achieve these goals and to provide services under the concluded contract.
5.4. Erasing personal data.
The company erases personal data for the following reasons:
the presence of a threat to the security of the Services;
the achievement of personal data processing goals or in case of loss of the need to achieve such goals;
your violation of the terms of the Policy;
expiration of personal data;
expiration or suspension of the contract;
by your request or in case of withdrawal of the consent of an individual to the processing of personal data.
6. Your rights
6.1. You have the right to receive information about the processing of your personal data, including information containing:
confirmation of the processing of your personal data;
Legal basis for the processing of your personal data;
purposes and methods used by the Company to process your personal data;
which personal data we process in particular, including the ways it is received;
the processing time of your personal data, including the storage period;
the procedure for exercising the rights stipulated by the legislation of the Russian Federation;
information on completed or prospective cross-border data transfer;
information about persons to whom personal data may be disclosed on the basis of an agreement with the Company or in accordance with the legislation of the Russian Federation; p> li>
title or surname, name, patronym and address of the person who processes personal data on behalf of the Company, if processing is or will be entrusted to such a person; p> li>
other information provided by the legislation of the Russian Federation.
You have the right to receive such information an unlimited number of times. To do this, it is necessary to send to the Company a corresponding request by means described in the section 11 of the Policy.
7. Company Responsibilities
7.1. In accordance with the requirements of the Law, the Company is obligated:
7.1.1. To provide (upon your request) information on the processing of your personal data specified in clause 6.1. of the Policy, or by reasonable refusal;
7.1.2. take measures necessary and sufficient to ensure the fulfillment of the obligations stipulated by the Law;
7.1.3. at your request, specify the processed personal data, block or delete it if it is incomplete, outdated, inaccurate, illegally obtained or unnecessary for the stated purpose of processing;
7.1.4. ensure the legitimacy of the personal data processing. In the event that it is impossible to ensure the legitimacy of the processing of personal data, the Company is obligated to destroy them or ensure their destruction within a period not exceeding 10 business days from the date of detection of illegal processing of personal data;
7.1.5. in the event of termination of the contract concluded with you or your withdrawal of consent to the processing of personal data, we stop processing it and destroy it within a period not exceeding 30 work days from the date of receipt of your recall. Exceptions are cases when processing can be continued in accordance with the legislation of the Russian Federation.
8. Information about the protection of personal data
8.1. All personal data you provide is confidential by default. The protection of personal data processed by the Company is ensured by the implementation of legal, organizational and technical measures necessary and sufficient to meet the requirements of the legislation of the Russian Federation in the field of personal data protection. However, we always try to protect your data as much as possible and apply a greater number of measures to protect personal data than is prescribed by law. Here are some of the measures taken by the Company to protect your personal data:
8.2. Legal measures include:
8.2.1. development of local regulatory acts of the Company that implement the requirements of Russian legislation, including this Policy regarding the processing and protection of personal data, and its posting at https: // botkin. ai / .
8.2.2. refusal of any methods of processing personal data that do not meet the goals predetermined by the Company.
8.3. Organizational measures include:
8.3.1. appointment of a person responsible for organizing the processing of personal data. You can contact such a person using the following email address: email@example.com ;
8.3.2. restriction of the composition of the Company's employees with access to personal data, and the organization of an authorization system for access to them;
8.3.3. periodic risk assessment regarding the processing of personal data;
8.3.4. conducting internal investigations to detect facts related to unauthorized access to personal data;
8.3.5. the use of encryption methods in the processing of personal data;
8.3.6. monitoring and analysis of security of the Company's network infrastructure;
8.3.7. familiarization of the Company's employees with the provisions of the legislation of the Russian Federation on personal data, including the requirements for the protection of personal data, with local acts of the Company on the processing of personal data, training of these employees.
8.3.8. the organization of a security regime for the premises in which personal data carriers are located that impedes the possibility of uncontrolled entry or stay in these premises of persons who do not have access to these premises;
8.3.9. organization of trainings for Company employees regarding various issues of personal data processing.
8.4. The company undertakes and obliges third parties, in case of transfer to them the right to process personal data, to observe the confidentiality regime in relation to personal data and not to use personal data without legal grounds for their processing.
9. Cross-border transfer of personal data
9.1. We are an international company. Therefore, in order to achieve the goals specified in the Policy, we may transfer your personal data to countries other than the country from which they were originally obtained. This is called cross-border transfer of personal data. Prior to the cross-border transfer of personal data, the Company must make sure that the foreign state to whose territory personal data is transferred adequately protects your rights as the subject of personal data. When cross-border transfer of personal data is occurred, we protect your data in accordance with the Policy.
9.2. Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of your rights may be carried out in the following cases:
We have your written consent for the cross-border transfer of your personal data;
it is provided for by international treaties of the Russian Federation;
it is provided for by federal laws if necessary in order to protect the foundations of the constitutional system of the Russian Federation, ensure the country's defense and state security, as well as ensure the security of the stable and safe functioning of the transport complex, protect the interests of individuals, society and the state in the field of the transport complex from acts unlawful interference;
the performance of a contract to which you are a party;
protect your life, health, and other vital interests of yours or the interests of others when it is impossible to obtain your written consent.
10. Policy Limitation
10.1. You are also obligated to take a reasonable and responsible approach to posting your own personal data in the public domain, including the Services if you leave any feedback and comments.
10.2. The company is not responsible for the actions of third parties who gained access to your personal data because your actions.
11. Appeals of the Personal Data Subject
11.1. You have the right to send your requests to the Company, including requests regarding the use of your personal data:
11.1.1. to the address: 121205, Moscow, the territory of the Skolkovo Innovation Center, Bolshoy Boulevard, 42, building 1, 1 floor, part of room No. 334, workplace No. 63.
11.1.2. to the email address: firstname.lastname@example.org.
11.2. The request should contain the following information:
11.2.1. ID number;
11.2.2. information on the date of issue of the specified document and the issuing authority;
11.2.3. Information confirming your participation in relations with the Company;
11.2.4. your signature.
11.3. The company undertakes to review and send a response to the request at the address indicated in the request within 30 calendar days from the date of receipt of the request.
11.4. All correspondence received by the Company (written or electronic communications) refers to restricted information and is not disclosed without your written consent.
12. Contact information and details of the Company:
|Full company name||Intellogic Limited Liability Company|
|Location Address / Postal Address||121205, Moscow, the territory of the Skolkovo Innovation Center, Bolshoy Boulevard, 42, building 1, 1 floor, part of room No. 334, workplace No. 63|
|CEO||Sorokin Sergey Yuryevich|
|Contact Phone||(495) 649-13-09|