Felislabs Personal Data Processing Policy

1. General provisions

This personal data processing policy (hereinafter referred to as the Policy) is in accordance with the provisions of the Federal Act of 27.07.2006. 152-FZ «About Personal Data» (hereinafter referred to as the Personal Data Act) defines the procedure for processing personal data and the security measures for personal data that Felislabs takes (PE Morozova E.N., hereinafter - the Operator)..

1.1. This Policy applies to the collection, storage, systematization, use, stockpiling, clarification, retrieval, transfer (distribution, provision, access), anonymization, blocking, removal of personal data. The listed ways of processing personal data are carried out using automation means and without the use of such means.

1.2. One of the main objectives and necessary condition of the Operator’s commercial and industrial activity is observance of the rights and freedoms of the client and the citizen in the processing of personal data, including protection of the rights to privacy, personal and family secrets.

1.3. This Policy applies to all data that the Operator may collect about users of the website where this Policy is posted.

1.4. The current version of the Policy is freely available on the Internet at https://felislabs.ai/privacy (further - Site).

1.5. The Operator reserves the right to change the Policy at any time. If you want to keep track of changes in the Policy, we recommend that you visit the Site regularly.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data - processing of personal data with the help of a personal computer, laptop, cell phone and other computer tools.

2.2. Blocking of personal data - temporary termination of processing of personal data (except when it is necessary to clarify personal data).

2.3. Website - a set of graphic and informational materials, as well as programs for personal computers and databases that make them available in the Internet at the network address felislabs.ai.

2.4. The operator processes and protects the personal data (including the name, first name, patronymic, contact telephone, e-mail address and other information) of the users of the Site filling out the Application Form (hereinafter - Form), as well as personal data, incoming to the corporate mail addresses of the Operator info@felislabs.ai and sales@felislabs.ai (hereinafter - Corporate Mail), entities that have expressed Consent to the processing of personal data (hereinafter - Consent) by sending information via the Form on the pages of the Site or by sending an e-mail. The user is deemed to agree with the Policy when he marks the corresponding field in the Form and clicks the Form Send button.

2.5. Anonymization of personal data - actions in which it is impossible to determine without requesting additional information the belonging of personal data to a particular User or other subject of personal data.

2.6. Processing of personal data - any act (transaction) or set of actions (operations) performed using or without means of automation with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7. Operator — legal or natural person, independently or jointly with other persons organizing and (or) performing processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data for processing, actions (operations)committed with personal data.

2.8. Personal data — any information relating directly or indirectly to a certain User of the Site.

2.9. Personal data permitted by the subject of personal data for dissemination — personal data, access to an unlimited number of persons to whom the subject of personal data provides when giving consent to the processing of personal data, authorized by the subject of personal data for dissemination in the manner prescribed by the Personal Data Act (hereinafter referred to as Personal Data permitted for dissemination).

2.10. User — any visitor of the Site.

2.11. Provision of personal data — actions that disclose personal data to a certain person or a certain circle of persons.

2.12. Personal Data Dissemination - any actions that disclose personal data to an undetermined circle of persons (hereinafter referred to as Personal Data Transfer) or demonstrate personal data to an unlimited number of persons, including publishing personal data in the media and/or in information and telecommunications networks. This also includes providing access to personal data in some other way.

2.13. Transfer of personal data across borders - transfer of personal data to the territory of a foreign state, to the authority of a foreign state, to a foreign natural or foreign legal person.

2.14. Deletion of personal data - any action in which the Operator permanently destroys personal data with the inability to restore deleted personal data in the information system of the Operator, and/or destroys the material carriers of personal data.

3. Basic rights and obligations of the Operator

3.1. The operator has the right:

– receive from the subject of personal data reliable data and/or documents containing personal data;

– process personal data without the consent of the subject of personal data, taking into account the grounds specified in the Personal Data Act, if the subject of personal data withdraws consent to the processing of personal data;

– Independently determine the list and content of measures necessary and sufficient to fulfil the obligations stipulated by the Personal Data Act and the relevant normative legal acts adopted; unless otherwise provided by the Personal Data Act or other federal laws;

3.2. The operator shall:

– provide the subject of personal data with details of processing of his personal data in case of request of the subject of personal data;

– organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;

– respond and respond officially to communications and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Act;

– to inform the authorized body for the protection of the rights of subjects of personal data requested information within 30 days from the date of receipt of the request from the subject of personal data;

– place on the Site or otherwise provide unrestricted access to this Privacy Policy;

– protect personal data from improper or accidental access to it, destruction, modification, blocking, copying, provision, dissemination of personal data, to use legal, organizational and technical measures, as well as to block other unlawful actions regarding personal data;

– cease processing and transmission (distribution, provision, access) of personal data, then destroy personal data in the manner and cases specified in the Personal Data Act;

– to perform other duties stipulated by the Personal Data Act.

3.3. The operator shall not transmit the personal data of the Visitors to the Site to a third party, except the following persons:

– authorized state bodies within the limits of their powers;

– persons to whom the Operator undertakes to transfer personal data in order to comply with the legislation of the Russian Federation;

– persons whom the Operator hires to process personal data;

– other persons, with the consent of the subject of personal data..

4. Basic Rights and Duties of Subjects of Personal Data

4.1. Subjects of personal data have the right:

– receive information on the processing of their personal data, except as provided for by federal laws. The operator provides the subject of personal data with information in an accessible form. The information provided shall not contain the personal data of other subjects of personal data, unless there are legitimate grounds for the disclosure of such personal data. The list of information and the procedure for obtaining it are determined by the Personal Data Act;

– to require the Operator to clarify his personal data, to block and/or destroy if personal data are incomplete, outdated, inaccurate, illegally obtained or do not meet the stated purpose of processing, and to take measures to protect their rights in accordance with federal laws;

– require prior consent in the processing of personal data in order to promote goods, works and services;

– to withdraw consent to the processing of personal data;

– to appeal to the authorized body for the protection of the rights of subjects of personal data or to the court against the unlawful actions or omissions of the Operator in the processing of his personal data;

– to exercise other rights stipulated by the legislation of the Russian Federation.

4.2. Subjects of personal data must:

– to provide the Operator with reliable data about themselves;

– to inform the Operator when it is necessary to clarify (update, change) your personal data.

4.3. Persons who give the Operator inaccurate 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. What personal data Operator can process

5.1. Surname, first name, patronymic of the subject of personal data.

5.2. Electronic address of the subject of personal data.

5.3. Telephone numbers of subjects of personal data.

5.4. The operator also collects on the Site and processes anonymised data about Users (incl. files Ookie) using Internet statistics services (Yandex Metric, Google Analytics and others).

5.5. The above data is hereinafter referred to in the Policy as Personal Data.

5.6. The operator does not process special categories of personal data, including race, nationality, political views, religious or philosophical beliefs, intimate life.

5.7. Processing of personal data authorized for dissemination from among the special categories of personal data specified in Art. 1. 10 The Law on Personal Data is allowed if the prohibitions and conditions stipulated by Art. 10.1 of the Law on Personal Data are complied with.

5.8. The User shall, separately from other consents, consent to the processing of personal data authorized for dissemination. In doing so, the conditions laid down, inter alia, by art. 10.1 of the Personal Data Act are fulfilled. The authorized body for the protection of the rights of subjects of personal data establishes the requirements for the content of such consent.

5.8.1. The User shall give consent to the processing of personal data authorized for dissemination directly to the Operator.

5.8.2. The operator is obliged to publish the information on the conditions, prohibitions and conditions for processing of personal data authorized for distribution by unlimited number of persons no later than three working days after the receipt of said User’s consent.

5.8.3. Upon request of the subject of personal data, the transfer (dissemination, provision, access) of personal data authorized by the subject of personal data for dissemination is terminated. This requirement must include the name, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data whose processing is subject to termination. Only the Operator to whom the request is addressed may process the Personal data specified in this requirement.

5.8.4. Consent to the processing of personal data authorized for dissemination shall cease as soon as the Operator receives the requirement specified in paragraph 5.8.3. of this Policy concerning the processing of personal data.

6. Principles of Personal Data Processing

6.1. The processing of personal data is legal and fair.

6.2. The processing of personal data shall be determined by a predefined, specific and lawful purpose. Processing of personal data that does not meet the purpose of collecting personal data is not permitted.

6.3. It is not permitted to combine into a single database information containing personal data processed for purposes that are incompatible with each other.

6.4. Only personal data that meet the purposes of data processing are processed.

6.5. The content and amount of personal data processed correspond to the stated purposes of processing. Redundancy of personal data processed in relation to the stated purposes of processing is not allowed.

6.6. The personal data to be processed must be accurate, sufficient and relevant to the purposes of processing personal data. The operator shall take the necessary measures to remove or clarify incomplete or inaccurate data.

6.7. Personal data shall be kept in a form that allows the identification of the subject of personal data no longer than is required by the purpose of the processing of personal data, if the retention period of personal data is not established by federal law, by agreement to which, the beneficiary or guarantor for which is the subject of personal data. The personal data processed shall be destroyed or anonymized when the purposes of processing have been achieved or if there is no need to achieve these purposes, unless otherwise provided by federal law.

7. Purposes of personal data processing

7.1. Purpose of processing the User’s personal data:

– informing the User by e-mail;

– conclusion, execution and termination of civil contracts;

– providing the User with access to services, information and/or materials contained on the Site.

7.2. The Operator also has the right to notify the User of new products and services, special offers and various events concerning the Operator. The User may cancel the mailing list at any time by sending a message to the Operator via the feedback form on the Site or a letter to the e-mail address indicated on the Site with the mark «Refusal of notifications about new products and services and special offers».

7.3. Anonymised data of Users, which on the Site collect services of the Internet statistics, serve to collect information on actions of Users on the Site, improve the quality of the Site and its content.

8. Legal grounds for processing personal data

8.1. The legal basis for the processing of personal data by the Operator includes:

– Federal Law "On Information, Information Technologies and Information Protection" dated 27.07.2006 N 149-FZ;

– Federal laws, other regulatory acts in the sphere of personal data protection;

– the consent of the Users to the processing of personal data, to the processing of personal data permitted for dissemination.

8.2. The Operator shall process the User’s personal data only if they are filled in and/or sent by the User himself through special application forms located on the Site or sent to the Operator by e-mail. By filling in the relevant forms and/or sending your personal data to the Operator, the User expresses his consent to this Policy.

8.3. The operator will only process anonymised data about the User if this is allowed in the Account browser settings (Cookies are saved and JavaScript technology is used).

8.4. The subject of personal data independently decides on the provision of his personal data and gives consent freely, by his will and in his interest.

9. Conditions for processing personal data

9.1. The operator shall process personal data under one of the following conditions:

– the subject of personal data has given Consent to the processing of personal data;

– the processing of personal data is carried out for statistical or other research purposes, subject to mandatory anonymization of personal data;

– other conditions stipulated by the current legislation of the Russian Federation on personal data.

10. Procedures for the collection, storage, transmission and other processing of personal data

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

10.1. The operator shall ensure the preservation of personal data and shall take all possible measures to prevent access to personal data of unauthorized persons.

10.2. Personal data of the User shall never, under any circumstances, be transferred to third parties, except in cases related to the implementation of the current legislation or in the case of if the subject of personal data has given consent to the Operator to transfer the data to a third person to fulfill obligations under a civil contract.

10.3. In case of detection of inaccuracies in personal data, the User can update them by sending to the Operator a letter marked «Updating of personal data».

10.4. The period of processing of personal data is determined by the achievement of the purposes for which personal data are collected, unless another period is stipulated by the contract or the legislation in force.

10.5. All information that is collected by third-party services, including payment systems, communications and other service providers, is stored and processed by specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and/or the User is obliged to familiarize himself with these documents in a timely manner. The operator shall not be liable for the actions of third parties, including the service providers specified in this paragraph.

10.6. The operator guarantees the confidentiality of personal data when processing personal data.

10.7. The Operator shall keep the personal data of the Users in a form that allows the identification of the subject of personal data no longer than is required by the purpose of processing personal data, if the period of retention of personal data is not established by federal law, a contract to which the beneficiary or guarantor of which is the subject of personal data.

10.8. Processing of personal data may be terminated or suspended if the purposes of processing personal data have been achieved, the consent of the subject of personal data has expired or the subject of personal data withdraws consent to processing, and inappropriate processing of personal data.

11. List of actions that the Operator carries out with the personal data received

11.1. The operator collects, stores, systematizes, uses, accumulates, refines, extracts, transfers (distribution, provision, access), anonymizes, blocks, removes personal data.

11.2. The operator performs automated processing of personal data with or without the receipt and/or transmission of information on information and telecommunication networks.

12. Cross-border transfer of personal data

12.1. The operator must ensure that the rights of the subjects of personal data are guaranteed by the foreign state to which the personal data are to be transferred, before the data are transmitted across borders.

12.2. Cross-border transfer of personal data in the territory of foreign countries that do not meet the above requirements, may be carried out only if the personal data subject agrees in writing to the cross-border transfer of his personal data and/or the performance of the contract to which the personal data subject is a party.

13. 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.

14. Final provisions

14.1. The User may obtain any clarifications concerning the processing of his personal data by contacting the Operator through an application form on the Site or by letter to one of the Operator’s official e-mail addresses.

14.2. This document reflects any changes in the Operator’s personal data processing policy. The policy is valid indefinitely until the Operator updates the Policy version on the Site.