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Personal Data Processing and Protection Policy

1. GENERAL TERMS

1.1. This Policy is developed in accordance with Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” (hereinafter – FZ-152) and defines the procedure for processing and protection by Limited Liability Company “Brand Quad” (hereinafter – the Operator) of information about individuals (hereinafter – the User), which may be obtained by the Operator when the User uses services/goods provided, including through the Website intrical.ai, services, programs used by the Operator (hereinafter – the Website, Services).

1.2. The purpose of this Policy is to ensure proper protection of personal information that the User provides about themselves independently when using the Website, Services or during registration (account creation), for purchasing goods/services from unauthorized access and disclosure.

1.3. Relations related to the collection, storage, distribution and protection of information provided by the User are regulated by this Policy, other official documents of the Operator and the current legislation of the Russian Federation.

1.4. By registering on the Website and using the Website and Services, the User expresses their full consent to the terms of this Policy.

1.5. If the User disagrees with the terms of this Policy, the use of the Website and/or any Services available when using the Website must be immediately discontinued.

1.6. The following basic concepts are used in the Policy:

Personal data – any information relating to a directly or indirectly identified or identifiable individual (personal data subject).

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

Automated processing of personal data – processing of personal data using computer technology.

Blocking of personal data – temporary cessation of personal data processing (except in cases where processing is necessary to clarify personal data).

Depersonalization of personal data – actions as a result of which it becomes impossible without using additional information to determine the ownership of personal data to a specific personal data subject.

Processing of personal data – any action or set of actions with personal data performed using automation tools or without their use. Processing of personal data includes, among other things: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

Operator – Limited Liability Company “Brand Quad”, located at: Moscow, territory of the Skolkovo Innovation Center, Nobel Street, building 7, premises 48. The Operator independently organizes and carries out the processing of personal data, and also determines the purposes of personal data processing, the composition of personal data to be processed, actions performed with personal data.

Website — a set of information, texts, graphic elements, design, images, photo and video materials and other results of intellectual activity, as well as computer programs contained in an information system ensuring the availability of such information on the Internet by entering Account information at the network address https://intrical.ai/

Website Services — functional capabilities and tools of the Website that provide Users with access to the Contractor’s services.

Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of persons.

Distribution of personal data – actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or at familiarizing an unlimited number of persons with personal data, including publication of personal data in mass media, placement in information and telecommunication networks, or providing access to personal data in any other way.

Destruction of personal data – actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed.

Cookie files — User data that is automatically transmitted to the Operator in the process of using the Website using software installed on the User’s device. Cookie files include IP address, information about the browser and type of operating system of the User’s device, technical characteristics of equipment and software used by the User, date and time of access to the Website, other actions performed on the Website.

The Operator is obliged to publish or otherwise provide unlimited access to this Operator’s Policy regarding the processing of personal data in accordance with part 2 of Article 18.1 of FZ-152.

2. LEGAL GROUNDS AND PURPOSES OF PERSONAL DATA PROCESSING

2.1. Processing of the User’s personal data is carried out in accordance with the legislation of the Russian Federation.

2.2. The Operator processes the User’s personal data for the purposes of:

2.2.1. User registration on the Website.

2.2.2. User identification on the Website for the Operator.

2.2.3. Providing the User with goods/services, access to the Website, Services

2.2.4. Displaying the User’s profile to other Website Users for the purpose of maintaining communication, including when providing services remotely.

2.2.5. Establishing and maintaining communication between the User and the Operator, consulting on service provision issues.

2.2.6. Fulfillment by the Operator of obligations to the User under agreements and contracts concluded with the Operator. Fulfillment of obligations, in particular, includes informing about the date and time of courses/classes/trainings, etc. (including by calling and sending SMS messages); sending documents on completing courses/classes/trainings, etc.

2.2.7. Sending advertising messages to the User; targeting advertising materials, providing information about services provided by the Operator. Sending advertising messages and providing information can be carried out both by the Operator and by third parties who participate in providing services to the User. Advertising messages may be sent to the User’s email address and mobile phone number.

2.2.8. Posting in official groups of social networks and other communities of the Operator on the Internet, other advertising and information sources:

— photo and video materials obtained in the process of providing services,

— comments left by the User about services provided by the Operator.

2.2.9. Improving the quality of User service and modernizing the Operator’s Website by processing requests and applications from the User.

2.2.10. Verification, research and analysis of such data, allowing to maintain and improve services and sections of the Website, as well as develop new services and sections of the Website;

2.2.11. Statistical and other studies based on depersonalized information provided by the User.

3. PROCEDURE AND CONDITIONS FOR PROCESSING PERSONAL DATA

3.1. The Operator takes all necessary measures to protect the User’s personal data from unauthorized access, modification, disclosure or destruction.

3.2. The Operator provides access to the User’s personal data only to those employees and contractors who need this information to ensure the functioning of the Website, Services and provision of Services, sale of goods to the User.

3.3. The Operator has the right to use information provided by the User, including personal data, in order to ensure compliance with the requirements of current legislation of the Russian Federation (including for the purpose of preventing and/or suppressing illegal and/or unlawful actions of Users). Disclosure of information provided by the User may be made only in accordance with the current legislation of the Russian Federation at the request of the court, law enforcement agencies, as well as in other cases provided for by the legislation of the Russian Federation.

3.4. The Operator does not verify the personal data provided by the User. In this regard, the Operator proceeds from the fact that when providing personal data on the Website, the User:

3.4.1. Is a capable person.

3.4.2. Provides reliable information about themselves in volumes necessary for using the Website. The User independently maintains the provided personal data in an up-to-date state. The consequences of the User providing inaccurate or insufficient information are defined in the User Agreement.

3.4.3. Is aware that information on the Website posted by the User about themselves may become available to other Website Users, may be copied and distributed by such Users.

3.5. The User accepts the terms of the Policy and gives the Operator informed and conscious consent to process their personal data in the following order:

3.5.1. When registering on the Website — for personal data that the User provides to the Operator:

— by filling out the registration form located on the Operator’s website. The User is considered to have provided consent to process their personal data, as well as familiarized themselves with the Policy regarding the processing and protection of personal data at the moment of clicking the “Sign Up” button;

— by filling out the “Contact Us” form located on the Operator’s website. The User is considered to have provided consent to process their personal data, as well as familiarized themselves with the Policy regarding the processing and protection of personal data at the moment of clicking the “Submit Request” button;

— by authorization using personal data specified by the User in social networks or electronic services. The User is considered to have provided consent to process their personal data, as well as familiarized themselves with the Policy regarding the processing and protection of personal data at the moment of clicking the button displaying the social network or electronic service selected for authorization.

By clicking the specified button, the User consents to transfer to the Operator all personal data that was specified in the profile of the corresponding social network or electronic service. The User has the right at any time to change or delete personal data provided in this way in the “Personal Information” section (Settings tab).

3.5.2. When using the Website in any way – for Cookie files. The User is considered to have provided consent to process such data at the moment of clicking the “Understood” button in the corresponding notification.

3.5.3. When subscribing to the newsletter on the Website — for personal data that the User provides to the Operator:

— by filling out the newsletter subscription form located on the Operator’s website. The User is considered to have provided consent to process their personal data, as well as familiarized themselves with the Policy regarding the processing and protection of personal data at the moment of clicking the “Subscribe” button;

3.6. Processing of the User’s personal data includes the Operator performing the following actions: collection, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.

3.7. The User’s consent for the Operator to process their personal data is carried out (depending on which event occurs first):

— until the moment of their deletion by the User in the Personal Account on the Website;

— until the moment of their destruction by the Operator — in case of receipt from the User of withdrawal of consent to personal data processing or a request for destruction of personal data;

— until the moment of achieving the purposes of personal data processing.

3.8. Clarification of personal data can be carried out by the User independently in the “Personal Information” section or by the Operator at the User’s request.

4. TERMS OF USE OF THE WEBSITE, SERVICES

4.1. The User, when using the Website, confirms that they:

— possess all necessary rights allowing them to register (create an account and personal cabinet) and use the Website Services;

— provide reliable information about themselves in volumes necessary for using the Website Services, fields mandatory for filling in for further provision of Website Services are marked in a special way, all other information is provided by the user at their own discretion.

— are aware that information on the Website posted by the User about themselves may become available to third parties not specified in this Policy and may be copied and distributed by them;

— are familiar with this Policy, express their consent to it and assume the rights and obligations specified in it. Clicking the button (“Sign Up”, “Subscribe”, “Submit Request” or social network authorization button) under the link to this Policy is the User’s written consent to the collection, storage, processing and transfer to third parties of personal data provided by the User.

4.2. The Operator does not verify the authenticity of received (collected) information about Users, except in cases where such verification is necessary for the purpose of fulfilling obligations to the User.

4.3. The User undertakes not to communicate to third parties the login and password used by them for identification in the personal cabinet on the Website.

4.4. The User undertakes to exercise due care in storing and using the login and password (including, but not limited to: using licensed antivirus programs, using complex alphanumeric combinations when creating a password, not providing to third parties a computer or other equipment with the User’s login and password entered on it, etc.)

4.5. If the Operator has suspicions regarding the use of the User’s account by a third party or malicious software, the Operator has the right to unilaterally change the User’s password.

5. PERSONAL DATA PROCESSED BY THE OPERATOR

5.1. Data provided by the User independently when using the Website, Services, including but not limited to:

  • first name, middle name, last name;
  • mobile phone number;
  • work phone number;
  • email address;
  • other information provided by the User, such as image/photograph (uploaded by the User), name of your company/employer and position, division/department of your company/employer, line manager and other information provided by the User when using the Services;
  • account identifiers such as username, account number or password, etc.

5.2. Data that is automatically transmitted to the Services in the process of their use using software installed on the User’s device, including IP address, information from cookies, information about the user’s browser (or other program through which access to the Services is carried out), access time, address of the requested page.

5.3. Additionally, on the Website there is collection and processing of depersonalized data about visitors (including “cookie” files) using internet statistics services:

5.4. The User may store or upload data of commercial content and commercial nature to the Services. Such data should not include Personal data of the User’s clients or customers without written agreement with the Operator.

5.5. The Operator does not own, control or direct the use of any data or information stored or processed by the User using the Services. Only Users have the right to access, retrieve and directed use of such information.

5.6. The Operator is not responsible for the content of data and information stored on its servers (or subcontractor servers), at the User’s discretion, and also the Operator is not responsible for how the user collects, discloses, distributes or otherwise processes such information.

5.7. In the event that any Personal data of the User’s clients will be uploaded by the User using or through the Services, the Operator has no direct relationship with persons whose Personal data it places within the data uploaded by the User. Each User is responsible for notifying their clients and third parties about the purposes for which the User collects their Personal data and how these Personal data are processed in or through the Services as part of user-uploaded data.

6. MODIFICATION AND DELETION OF PERSONAL DATA

6.1. The User may at any time change (update, supplement) the personal information they provided or part of it, as well as its confidentiality parameters, using the personal data editing function in the Personal Account of the Website. The User is obliged to take care of the timeliness of making changes to previously provided information, its updating, otherwise the Operator is not responsible for non-receipt of notifications, goods/services, etc.

6.2. The User can also delete personal information they provided within a specific account. In this case, account deletion may result in the inability to use some Services.

6.3. The User may at any time contact the Operator with requests, including for clarification of personal data; for blocking or destruction of personal data, if such data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing.

7. POLICY CHANGES. APPLICABLE LAW

7.1. The Operator has the right to make changes to this Policy. When making changes, the date of the last update is indicated in the current version. The new version of the Policy comes into force from the moment of its placement in the corresponding section of the Operator’s website. Continued use of the Website or its services after publication of the new version of the Policy means acceptance of the Policy and its terms by the User. In case of disagreement with the terms of the Policy, the User must immediately stop using the Website and its services.

7.2. The law of the Russian Federation is applicable to this Policy and the relationship between the User and the Operator arising in connection with the application of this Policy.

8. INFORMATION ABOUT THE OPERATOR

8.1. Limited Liability Company “Brand Quad”

Address: Russia, 121205, Moscow, territory of the Skolkovo Innovation Center, Nobel Street, building 7, premises 48

Mailing address: 101000, Moscow, Myasnitskaya St. 13 building 18, FRII

Phone: 8 (499) 288-17-59

Authorized email address: support@brandquad.ru