PRIVACY POLICY OF SMC NEUROTECH LLC

Last modified: September 16, 2024

This Privacy Policy for personal data (hereinafter referred to as the Policy) applies to all information that SMC Neurotech LLC (hereinafter referred to as the Operator), located at 119-A Dzerzhinsky, Taganrog, 347905, may receive about the user during their use of any of the Operator's websites, services, programs or products (hereinafter referred to as the Services).

1. General Provisions

1.1. Using the Operator's Services means the user's unconditional consent to this Policy and the terms of processing his/her personal data specified therein. In case of disagreement with these terms, the user must refrain from using the Services.

1.2. This Policy was developed in accordance with the Federal Law No. 152-FZ dated 07/27/2006 “On Personal Data” (hereinafter referred to as FZ-152) and other regulatory acts of the Russian Federation in the area of personal data protection.

2. Collected data

2.1. The Operator may collect the following personal data of the user:

Data provided by the user:
- Full name;
- E-mail address;
- Phone number;
- Social media profile data (when authorizing via social media);
- Other information provided by the user on their own initiative.
Data collected automatically:
- IP address;
- Information about the user's device;
- User location data (when using georeferencing services);
- Data obtained using cookies and other similar technologies.
Data received from the third parties:
- The Operator may receive data about the user from his/her partners, e. g., when using authorization services via social media.

3. Purposes of data processing

3.1. The Operator processes the user’s personal data for the following purposes:

Provision and improvement of the Services:
- User identification;
- Provision of access to Services;
- Responses to user requests;
- Analysis of user behavior to improve the Services;
- Personalization of Services;
- Provision of location-based services.
Communication with the user:
- Sending notifications related to Services use;
- Mailing out information materials;
- Conducting surveys and marketing research.
Ensuring security:
- Preventing fraud and misuse of the Services;
- Protecting the rights and interests of the Operator and users.
Compliance with legal requirements:
- Providing information upon request from public authorities.

4. Legal grounds for processing

4.1. The Operator processes the user's personal data on the following legal grounds:

User consent:
- to process data for specific purposes (e.g., to receive a newsletter).
Execution of the contract:
- to process data necessary to provide the Services.
Legitimate interests of the Operator:
- to process data to improve the Services, ensure security, and prevent fraud.
Fulfillment of legal requirements:
- to process data necessary to comply with legal requirements.

5. Data recipients

5.1. The Operator may transfer user's personal data to the following categories of recipients:

Employees of the Operator:
- who need access to the data to perform their job responsibilities.
Third-party service providers:
- whom the Operator delegates data processing (e.g. hosting providers, analytics services, mailing services).
Public authorities:
- upon request in accordance with the law.

6. Transfer of data abroad

6.1. The Operator may transfer the user's personal data outside the Russian Federation only in compliance with the requirements of FZ-152, including if the user consents to such transfer, or if there is an agreement between the Operator and a foreign recipient of the data that ensures an adequate level of protection of such personal data.

7. Data storage period

7.1. The Operator stores the user's personal data no longer than is necessary to achieve the processing purposes specified herein, or for the period established by the legislation of the Russian Federation.

8. User Rights

8.1. The users have the right:

To access their personal data:
- the user may request the Operator to provide information about his/her personal data that is being processed by the Operator.
To correct their personal data:
- the user may request the Operator to correct incomplete or inaccurate personal data.
To delete their personal data:
- the user may request the Operator to delete their personal data if they are no longer needed for the purposes of processing, or if the user has withdrawn his/her consent to the processing of the data.
To limit processing of their personal data:
- the user may request the Operator to limit the processing of his/her personal data in certain cases provided for by the FZ-152.
To transfer their personal data:
- the user may request the Operator to transfer his/her personal data to another operator in certain cases provided for by the FZ-152.
To revoke consent to the processing of their personal data:
- if data processing is based on the user’s consent, the user may revoke his/her consent at any time.

8.2. To exercise their rights, users may contact the Operator by email: support@neurotech.ru.

9. Cookies

9.1. The Operator uses cookies and other similar technologies to collect data about the user's activity on the Services.

9.2. Cookies are small text files that are stored on the user's device. They allow the Operator to recognize the user when he/she re-visits the Services.

9.3. The user can manage the use of cookies in his/her device settings.

10. Data security

10.1. The Operator takes necessary organizational and technical measures to protect the user's personal data from unauthorized access, modification, disclosure or destruction.

11. Changes to the Privacy Policy

11.1. The Operator reserves the right to make changes to this Privacy Policy.

11.2. The new version of the Policy comes into force from the moment it is posted on the Operator's website, unless otherwise provided by the new version of the Policy.

12. Contact information

12.1. For all questions related to the processing of personal data, the user can contact the Operator by e-mail: support@neurotech.ru.