Personal Data Processing Policy

1. General Provisions

This personal data processing policy is compiled in accordance with the requirements of the Federal Law of 27.07.2006 No. 152-FZ "On Personal Data" (hereinafter - Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data undertaken by BrainPatch Ltd. (hereinafter - Operator).

1.1. The Operator's primary goal and condition for carrying out its activities is compliance with the rights and freedoms of individuals and citizens in the processing of their personal data, including the protection of rights to privacy, personal and family secrets.

1.2. This Operator's policy regarding personal data processing (hereinafter - Policy) applies to all information that the Operator can obtain about visitors to the website https://brainpatch.ai.

2. Main Definitions Used in the Policy

2.1. Automated processing of personal data - processing of personal data using computer technology.

2.2. Blocking of personal data - a temporary cessation of personal data processing (except for cases when processing is necessary to clarify personal data).

2.3. Website - a collection of graphical and information materials, as well as computer programs and databases, ensuring their availability on the internet at the network address https://brainpatch.ai.

2.4. Personal data information system - a set of personal data contained in databases and information technologies and technical means ensuring their processing.

2.5. Anonymization of personal data - actions resulting in it being impossible to determine the ownership of personal data to a specific User or another subject of personal data without using additional information.

2.6. Processing of personal data - any action (operation) or set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7. Operator - a government body, municipal body, legal entity or individual, independently or jointly with other persons organizing and/or carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, actions (operations) performed with personal data.

2.8. Personal data - any information directly or indirectly related to a specific or identifiable User of the website https://brainpatch.ai.

2.9. Personal data permitted by the subject of personal data for distribution - personal data access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Personal Data Law (hereinafter - personal data permitted for distribution).

2.10. User - any visitor to the website https://brainpatch.ai.

2.11. Provision of personal data - actions aimed at disclosing personal data to a certain person or a certain circle of persons.

2.12. Dissemination of personal data - any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarization with personal data of an unlimited circle of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, foreign individual, or foreign legal entity.

2.14. Destruction of personal data - any actions as a result of which personal data is irrevocably destroyed with the impossibility of further restoring the content of personal data in the personal data information system and/or material carriers of personal data are destroyed.

3. The Main Rights and Obligations of the Operator

3.1. The Operator has the right to:
receive reliable information and/or documents containing personal data from the subject of personal data;
if the subject of personal data withdraws consent to the processing of personal data, as well as if a request is made to stop processing personal data, the Operator may continue processing personal data without the consent of the subject of personal data if there are grounds specified in the Personal Data Law;
independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations provided by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator is obliged to:
provide the subject of personal data, at his request, with information regarding the processing of his personal data;
organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;
respond to inquiries and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Personal Data Law;
inform the authorized body for the protection of the rights of subjects of personal data at the request of this body the necessary information within 10 days from the date of receipt of such a request;
publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
take legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, change, blocking, copying, provision, dissemination of personal data, as well as from other unlawful actions in respect of personal data;
stop transferring (distributing, providing, accessing) personal data, stop processing and destroy personal data in the manner and cases provided by the Personal Data Law;
perform other duties provided by the Personal Data Law.

4. The Main Rights and Obligations of Personal Data Subjects

4.1. Subjects of personal data have the right to:
receive information regarding the processing of his personal data, except for cases provided by federal laws. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, except for cases when there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Personal Data Law;
demand the Operator to clarify his personal data, their blocking or destruction if personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights;
put forward a condition of prior consent when processing personal data for the purpose of promoting goods, works, and services on the market;
withdraw consent to the processing of personal data, as well as to make a demand for the cessation of the processing of personal data; appeal against the illegal actions or inaction of the Operator in processing his personal data to the authorized body for the protection of the rights of subjects of personal data or in court;
to exercise other rights provided by the legislation of the Russian Federation.

4.2. Subjects of personal data are obliged to:
provide the Operator with accurate data about themselves;
inform the Operator about the clarification (updating, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves, or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. Principles of Personal Data Processing

5.1. The processing of personal data is carried out on a lawful and fair basis.

5.2. The processing of personal data is limited to achieving specific, predefined, and lawful purposes. Processing of personal data incompatible with the purposes of collecting personal data is not allowed.

5.3. Database merging containing personal data, processing of which is carried out for purposes incompatible with each other, is not allowed.

5.4. Only personal data that meets the purposes of their processing is subject to processing.

5.5. The content and volume of processed personal data correspond to the stated processing purposes. Excessive processing of personal data relative to the declared purposes of their processing is not allowed.

5.6. In processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance to the purposes of processing personal data are ensured. The operator takes necessary measures and/or ensures their adoption to remove or clarify incomplete or inaccurate data.

5.7. Storage of personal data is carried out in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, contract, a party of which, beneficiary, or guarantor is the subject of personal data. Processed personal data is destroyed or anonymized upon achieving the purposes of processing or in case of loss of the need to achieve these purposes unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

The purpose of processingproviding the User with access to the services, information, and/or materials contained on the website
Personal dataemail, gender, age
Legal basischarter (constituent) documents of the Operator
Types of personal data processingCollection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
Sending informational letters to the email address

7. Conditions for Personal Data Processing

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.

7.2. The processing of personal data is necessary to achieve the goals provided by an international treaty of the Russian Federation or the law, for the exercise of the functions, powers, and duties imposed by the legislation of the Russian Federation on the operator.

7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official to be executed in accordance with the legislation of the Russian Federation on enforcement proceedings.

7.4. The processing of personal data is necessary for the execution of the contract, a party of which, beneficiary or guarantor is the subject of personal data, as well as for concluding a contract on the initiative of the subject of personal data or a contract under which the subject of personal data will be the beneficiary or guarantor.

7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties or for achieving socially significant objectives provided that the rights and freedoms of the subject of personal data are not violated.

7.6. Processing of personal data, access to an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter - publicly available personal data), is carried out.

7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

8. The Procedure for the Collection, Storage, Transfer, and Other Types of Personal Data Processing

The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary to fully comply with the requirements of the current legislation in the field of personal data protection.

8.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons.

8.2. The User's personal data will never, under any circumstances, be transferred to third parties, except for cases related to the fulfillment of current legislation or if the subject of personal data has consented to the Operator to transfer the data to a third party to fulfill obligations under a civil law contract.

8.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator's email address info@brainpatch.ai with the note "Updating personal data".

8.4. The term for processing personal data is determined by achieving the goals for which the personal data were collected, if another term is not provided by the contract or current legislation.

The User can at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via email to the Operator's email address info@brainpatch.ai with the note "Withdrawal of consent to the processing of personal data".

8.5. All information collected by third-party services, including payment systems, communication means, and other service providers, is stored and processed by said persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or is familiar with these documents. The Operator is not responsible for the actions of third parties, including the service providers mentioned in this paragraph.

8.6. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public, and other public interests defined by the legislation of the Russian Federation.

8.7. The Operator ensures the confidentiality of personal data when processing them.

8.8. The Operator stores personal data in a form that allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the storage period of personal data is not established by federal law, contract, a party of which, beneficiary, or guarantor is the subject of personal data.

8.9. The condition for ceasing the processing of personal data may be achieving the purposes of processing personal data, expiration of the consent of the subject of personal data, withdrawal of consent by the subject of personal data, or a request to stop processing personal data, as well as the identification of unlawful processing of personal data.

9. List of Actions Performed by the Operator with the Obtained Personal Data

9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.

9.2. The Operator carries out automated processing of personal data with the receipt and/or transmission of the information obtained through information and telecommunication networks or without such.

10. Cross-Border Transfer of Personal Data

10.1. Before starting the activity related to the cross-border transfer of personal data, the Operator is obliged to make sure that the foreign state to which it is planned to transfer personal data provides reliable protection of the rights of subjects of personal data.

10.2. Cross-border transfer of personal data on the territory of foreign states that do not meet the above requirements can be carried out only if there is written consent of the subject of personal data to the cross-border transfer of his personal data and/or the execution of a contract to which the subject of personal data is a party.

11. Confidentiality of Personal Data

The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the subject of personal data unless otherwise provided by federal law.

12. Final Provisions

12.1. The User can get any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via email info@brainpatch.ai.

12.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced with a new version.

12.3. The current version of the Policy in the public domain is located on the Internet at https://brainpatch.ai/privacy-policy.