Personal Data Processing Policy
1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the “Personal Data Law”) and establishes the procedures for processing personal data and measures to ensure the security of personal data implemented by GEROPRO AI LLC (hereinafter referred to as the “Operator”).
1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the right to privacy, personal and family confidentiality, as a fundamental goal and essential condition of its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors of the website https://geroproai.ru/.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computing technology.
2.2. Blocking of personal data – temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as computer software and databases, ensuring their availability online at https://geroproai.ru/.
2.4. Personal data information system – a set of personal data contained in databases, as well as information technologies and technical tools enabling their processing.
2.5. Depersonalization of personal data – actions that make it impossible to determine, without the use of additional information, whether the personal data belongs to a specific User or another personal data subject.
2.6. Personal data processing – any action (operation) or set of actions (operations), performed with or without the use of automation tools, involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state or municipal body, legal entity, or individual who organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) to be performed.
2.8. Personal data – any information related directly or indirectly to an identified or identifiable User of the website https://geroproai.ru/.
2.9. Personal data permitted by the personal data subject for dissemination – personal data that the personal data subject has made accessible to an unlimited number of persons by giving consent for processing under the procedure provided by the Personal Data Law (hereinafter referred to as “personal data permitted for dissemination”).
2.10. User – any visitor of the website https://geroproai.ru/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or allowing access to personal data to an unlimited group of persons, including publication in mass media, placement in information and telecommunication networks, or providing access in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign country to a foreign authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible elimination of personal data without the possibility of further recovery, and/or destruction of physical media containing personal data.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
— request accurate information and/or documents containing personal data from the data subject;
— continue processing personal data without the subject’s consent in cases specified by the Personal Data Law, including when consent is withdrawn or a request to stop processing is submitted;
— independently determine the composition and list of measures required and sufficient to fulfill the obligations stipulated by the Personal Data Law and related regulatory acts, unless otherwise provided by federal law.
3.2. The Operator is obligated to:
— provide the data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with applicable legislation of the Russian Federation;
— respond to requests and inquiries from data subjects and their legal representatives in compliance with the Personal Data Law;
— provide, upon request, necessary information to the authorized data protection authority within 10 days from the date of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— implement legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions;
— cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in cases and under the procedures established by the Personal Data Law;
— fulfill other obligations as provided by the Personal Data Law.
4. Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— obtain information regarding the processing of their personal data, except in cases stipulated by federal laws. Such information must be provided in an accessible form and must not include personal data of other subjects unless there are legal grounds for disclosure. The scope and procedure for obtaining information are set by the Personal Data Law;
— demand that the Operator clarify, block, or delete their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared purpose of processing, and to take legal measures to protect their rights;
— condition prior consent to the processing of personal data for the purposes of promoting goods, works, and services in the market;
— withdraw consent for personal data processing and request termination of processing;
— lodge complaints regarding unlawful actions or inaction of the Operator to the authorized data protection authority or in court;
— exercise other rights provided by Russian law.
4.2. Personal data subjects are required to:
— provide accurate information about themselves to the Operator;
— notify the Operator about updates (changes, modifications) to their personal data.
4.3. Individuals who have provided false information about themselves or about another personal data subject without that person’s consent are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. The processing shall be limited to achieving specific, pre-defined, and lawful purposes. The processing of personal data incompatible with these purposes is not permitted.
5.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of processing may be processed.
5.5. The content and scope of personal data processed must correspond to the declared purposes of processing. The processed data must not be excessive in relation to these purposes.
5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing must be ensured. The Operator shall take necessary measures, or ensure they are taken, to delete or clarify incomplete or inaccurate data.
5.7. Personal data must be stored in a format that allows identifying the subject for no longer than required for the purposes of processing, unless a longer retention period is established by federal law or contract. Once processing purposes are achieved or the necessity to achieve them is lost, personal data must be destroyed or depersonalized, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: to provide the User with access to services, information and/or materials available on the website.
Personal data: email address.
Legal basis: Federal Law “On Information, Information Technologies and Protection of Information” No. 149-FZ of 27.07.2006.
Types of processing: collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
7. Conditions for Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject.
7.2. Processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, or to perform functions, powers, and duties imposed on the operator by Russian legislation.
7.3. Processing is necessary for the administration of justice or the enforcement of a court ruling, a legal act of another authority, or an official enforceable under Russian enforcement proceedings law.
7.4. Processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, or to enter into a contract at the subject’s initiative.
7.5. Processing is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant objectives, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing is carried out for personal data made publicly available by the subject or at their request (hereinafter — publicly available personal data).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure under federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures required to fully comply with current legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2. Personal data will never, under any circumstances, be transferred to third parties, except as required by applicable law or with the consent of the data subject for the fulfillment of a civil contract.
8.3. If any inaccuracies are found in the personal data, the User may update it by sending a notification to the Operator’s email at office@geroproai.ru with the subject “Personal Data Update.”
8.4. The period of personal data processing is determined by the purpose for which the data was collected, unless otherwise established by contract or law.
The User may withdraw consent at any time by emailing the Operator at office@geroproai.ru with the subject “Withdrawal of Consent for Personal Data Processing.”
8.5. All data collected by third-party services (including payment systems, communication tools, and other service providers) is stored and processed in accordance with their own User Agreements and Privacy Policies. The Operator bears no responsibility for third-party actions.
8.6. Restrictions imposed by the data subject on transfer (other than access), as well as on processing or its conditions (other than access), do not apply where personal data is processed for public, state, or other legally significant purposes as defined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that enables the identification of the subject only as long as required to fulfill the processing purposes, unless a different retention period is required by law or contract.
8.9. Grounds for termination of processing may include the achievement of the processing purpose, expiration of consent, withdrawal of consent by the data subject, or identification of unlawful processing.
9. List of Actions Performed with Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator may conduct automated processing of personal data with or without transmission via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before conducting cross-border transfers of personal data, the Operator must notify the authorized body for personal data protection of its intention to do so (this notification is separate from the notification of intent to process personal data).
10.2. Prior to such notification, the Operator must obtain from foreign authorities, individuals, or legal entities (to whom the transfer is planned) the relevant information as required by law.
11. Confidentiality of Personal Data
The Operator and other persons with access to personal data must not disclose or distribute it to third parties without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may request clarification on any matters regarding their personal data by contacting the Operator via email at office@geroproai.ru.
12.2. Any changes to this Personal Data Processing Policy will be reflected in this document. The Policy is valid indefinitely until replaced with a new version.
12.3. The current version of the Policy is publicly available at:
https://geroproai.ru/en/privacy
1. General Provisions
This Personal Data Processing Policy has been prepared in accordance with the Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter referred to as the “Personal Data Law”) and establishes the procedures for processing personal data and measures to ensure the security of personal data implemented by GEROPRO AI LLC (hereinafter referred to as the “Operator”).
1.1. The Operator considers the observance of human and civil rights and freedoms when processing personal data, including the right to privacy, personal and family confidentiality, as a fundamental goal and essential condition of its activities.
1.2. This Policy of the Operator regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors of the website https://geroproai.ru/.
2. Key Terms Used in the Policy
2.1. Automated processing of personal data – processing of personal data using computing technology.
2.2. Blocking of personal data – temporary suspension of personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Website – a set of graphic and informational materials, as well as computer software and databases, ensuring their availability online at https://geroproai.ru/.
2.4. Personal data information system – a set of personal data contained in databases, as well as information technologies and technical tools enabling their processing.
2.5. Depersonalization of personal data – actions that make it impossible to determine, without the use of additional information, whether the personal data belongs to a specific User or another personal data subject.
2.6. Personal data processing – any action (operation) or set of actions (operations), performed with or without the use of automation tools, involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, usage, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
2.7. Operator – a state or municipal body, legal entity, or individual who organizes and/or carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) to be performed.
2.8. Personal data – any information related directly or indirectly to an identified or identifiable User of the website https://geroproai.ru/.
2.9. Personal data permitted by the personal data subject for dissemination – personal data that the personal data subject has made accessible to an unlimited number of persons by giving consent for processing under the procedure provided by the Personal Data Law (hereinafter referred to as “personal data permitted for dissemination”).
2.10. User – any visitor of the website https://geroproai.ru/.
2.11. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.
2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or allowing access to personal data to an unlimited group of persons, including publication in mass media, placement in information and telecommunication networks, or providing access in any other way.
2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign country to a foreign authority, foreign individual, or foreign legal entity.
2.14. Destruction of personal data – any actions resulting in the irreversible elimination of personal data without the possibility of further recovery, and/or destruction of physical media containing personal data.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
— request accurate information and/or documents containing personal data from the data subject;
— continue processing personal data without the subject’s consent in cases specified by the Personal Data Law, including when consent is withdrawn or a request to stop processing is submitted;
— independently determine the composition and list of measures required and sufficient to fulfill the obligations stipulated by the Personal Data Law and related regulatory acts, unless otherwise provided by federal law.
3.2. The Operator is obligated to:
— provide the data subject, upon request, with information regarding the processing of their personal data;
— organize the processing of personal data in accordance with applicable legislation of the Russian Federation;
— respond to requests and inquiries from data subjects and their legal representatives in compliance with the Personal Data Law;
— provide, upon request, necessary information to the authorized data protection authority within 10 days from the date of such request;
— publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
— implement legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions;
— cease the transfer (distribution, provision, access) of personal data, cease processing and destroy personal data in cases and under the procedures established by the Personal Data Law;
— fulfill other obligations as provided by the Personal Data Law.
4. Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects have the right to:
— obtain information regarding the processing of their personal data, except in cases stipulated by federal laws. Such information must be provided in an accessible form and must not include personal data of other subjects unless there are legal grounds for disclosure. The scope and procedure for obtaining information are set by the Personal Data Law;
— demand that the Operator clarify, block, or delete their personal data if the data is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the declared purpose of processing, and to take legal measures to protect their rights;
— condition prior consent to the processing of personal data for the purposes of promoting goods, works, and services in the market;
— withdraw consent for personal data processing and request termination of processing;
— lodge complaints regarding unlawful actions or inaction of the Operator to the authorized data protection authority or in court;
— exercise other rights provided by Russian law.
4.2. Personal data subjects are required to:
— provide accurate information about themselves to the Operator;
— notify the Operator about updates (changes, modifications) to their personal data.
4.3. Individuals who have provided false information about themselves or about another personal data subject without that person’s consent are liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. Personal data shall be processed lawfully and fairly.
5.2. The processing shall be limited to achieving specific, pre-defined, and lawful purposes. The processing of personal data incompatible with these purposes is not permitted.
5.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.
5.4. Only personal data that meets the purposes of processing may be processed.
5.5. The content and scope of personal data processed must correspond to the declared purposes of processing. The processed data must not be excessive in relation to these purposes.
5.6. The accuracy, sufficiency, and, where necessary, relevance of personal data to the purposes of processing must be ensured. The Operator shall take necessary measures, or ensure they are taken, to delete or clarify incomplete or inaccurate data.
5.7. Personal data must be stored in a format that allows identifying the subject for no longer than required for the purposes of processing, unless a longer retention period is established by federal law or contract. Once processing purposes are achieved or the necessity to achieve them is lost, personal data must be destroyed or depersonalized, unless otherwise provided by federal law.
6. Purposes of Personal Data Processing
Purpose of processing: to provide the User with access to services, information and/or materials available on the website.
Personal data: email address.
Legal basis: Federal Law “On Information, Information Technologies and Protection of Information” No. 149-FZ of 27.07.2006.
Types of processing: collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data.
7. Conditions for Personal Data Processing
7.1. Personal data is processed with the consent of the personal data subject.
7.2. Processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, or to perform functions, powers, and duties imposed on the operator by Russian legislation.
7.3. Processing is necessary for the administration of justice or the enforcement of a court ruling, a legal act of another authority, or an official enforceable under Russian enforcement proceedings law.
7.4. Processing is necessary for the performance of a contract to which the personal data subject is a party, beneficiary, or guarantor, or to enter into a contract at the subject’s initiative.
7.5. Processing is necessary to exercise the rights and legitimate interests of the operator or third parties or to achieve socially significant objectives, provided that the rights and freedoms of the data subject are not violated.
7.6. Processing is carried out for personal data made publicly available by the subject or at their request (hereinafter — publicly available personal data).
7.7. Processing is carried out for personal data subject to publication or mandatory disclosure under federal law.
8. Procedure for Collection, Storage, Transfer, and Other Types of Processing
The security of personal data processed by the Operator is ensured through legal, organizational, and technical measures required to fully comply with current legislation on personal data protection.
8.1. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized access.
8.2. Personal data will never, under any circumstances, be transferred to third parties, except as required by applicable law or with the consent of the data subject for the fulfillment of a civil contract.
8.3. If any inaccuracies are found in the personal data, the User may update it by sending a notification to the Operator’s email at office@geroproai.ru with the subject “Personal Data Update.”
8.4. The period of personal data processing is determined by the purpose for which the data was collected, unless otherwise established by contract or law.
The User may withdraw consent at any time by emailing the Operator at office@geroproai.ru with the subject “Withdrawal of Consent for Personal Data Processing.”
8.5. All data collected by third-party services (including payment systems, communication tools, and other service providers) is stored and processed in accordance with their own User Agreements and Privacy Policies. The Operator bears no responsibility for third-party actions.
8.6. Restrictions imposed by the data subject on transfer (other than access), as well as on processing or its conditions (other than access), do not apply where personal data is processed for public, state, or other legally significant purposes as defined by Russian law.
8.7. The Operator ensures the confidentiality of personal data during processing.
8.8. The Operator stores personal data in a form that enables the identification of the subject only as long as required to fulfill the processing purposes, unless a different retention period is required by law or contract.
8.9. Grounds for termination of processing may include the achievement of the processing purpose, expiration of consent, withdrawal of consent by the data subject, or identification of unlawful processing.
9. List of Actions Performed with Personal Data
9.1. The Operator carries out collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator may conduct automated processing of personal data with or without transmission via information and telecommunications networks.
10. Cross-Border Transfer of Personal Data
10.1. Before conducting cross-border transfers of personal data, the Operator must notify the authorized body for personal data protection of its intention to do so (this notification is separate from the notification of intent to process personal data).
10.2. Prior to such notification, the Operator must obtain from foreign authorities, individuals, or legal entities (to whom the transfer is planned) the relevant information as required by law.
11. Confidentiality of Personal Data
The Operator and other persons with access to personal data must not disclose or distribute it to third parties without the consent of the data subject, unless otherwise provided by federal law.
12. Final Provisions
12.1. The User may request clarification on any matters regarding their personal data by contacting the Operator via email at office@geroproai.ru.
12.2. Any changes to this Personal Data Processing Policy will be reflected in this document. The Policy is valid indefinitely until replaced with a new version.
12.3. The current version of the Policy is publicly available at:
https://geroproai.ru/en/privacy
GeroPro AI LLC