MedTech — IT solutions in the field of medicine

1. General Provisions
This Personal Data Processing Policy has been drawn up in accordance with the requirements of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data” (hereinafter referred to as the Personal Data Law) and determines the procedure of processing personal data and measures to ensure the security of personal data taken by “Intelligent Analytics” LLC (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator’s policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator can obtain about visitors to the website https://i-analytics.ru.

2. Basic terms used in the Policy
2.1. Automated processing of personal data – processing of personal data using computer technology. 
2.2. Blocking of personal data – temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases, ensuring the availability on the Internet at the network address https://i-analytics.ru.
2.4. Information system of personal data – a set of personal data contained in databases, and providing its processing of information technologies and technical means. 
2.5. Depersonalization of personal data – actions as a result of which it is impossible to determine, without the use of additional information, the belonging of personal data to a specific User or other personal data subject. 
2.6. Processing of personal data – any action (operation) or a set of actions (operations) performed using or without using automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion and destruction of personal data. 
2.7. Operator – a state body, municipal body, legal entity or individual, independently of jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of such a processing, the composition of personal data to be processed, actions (operations) performed with personal data. 
2.8. Personal data – any information relating directly or indirectly to a specific or identifiable User of the website https://i-analytics.ru.
2.9. Personal data permitted by a personal data subject for disclosure – personal data, access of an unlimited number of persons to which is provided by a personal data subject by giving consent to the processing of personal data permitted by a personal data subject for disclosure in the manner prescribed by the Law on Personal Data (hereinafter – personal data permitted for distribution)
2.10. User – any visitor to the website https://i-analytics.ru.
2.11. Provision of personal data – actions aimed at disclosing personal data to a certain person or a certain circle of persons. 
2.12. Distribution of personal data – any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or at familiarization with the personal data of an unlimited number of persons, including the disclosure of personal data in the media, posting on information and telecommunication networks or providing access in any other way.
2.13. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to the authority of a foreign state, to a foreign individual or legal entity. 
2.14. Deletion of personal data – any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoring the content of personal data in the information system and (or) material carriers of personal data are destroyed.

3. Basic rights and obligations of the Operator
3.1. The Operator has the right to: 
– receive reliable information and / or documents containing personal data from a personal data subject;
– if a personal data subject withdraws consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of a personal data subject if here are grounds specified in the Law on Personal Data;
– independently determine the composition and list of measures necessary and sufficient to ensure the implementation of the obligations provided for by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws. 
3.2. The Operator is obliged to:
– provide a personal data subject, upon his or her request, with information regarding the processing of his or her personal data;
– organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;
– respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
– inform the authorized body for the protection of the rights of personal data subjects at the request of this body the necessary information within 30 days from the date of receipt of such a request;
– publish or otherwise provide unrestricted access to this Policy in relation to the processing of personal data;
– take legal organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, alteration, blocking, copying, provision, disclosure of personal data, as well as from other illegal actions in relation to personal data;
– stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and in cases specified in the Law on Personal Data. 

4. Basic rights and obligations of personal data subjects 
4.1. Personal data subjects have right to:
– receive information regarding the processing of his or her personal data, with the exception of cases provided for by the federal laws. The information is provided to a personal data subject by the Operator in an accessible form, and it should not contain personal data relating to other personal data subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;
– require the Operator to clarify his or her personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided by law to protect their rights;
– set forth a condition of prior consent when processing personal data in order to promote goods, works and services on the market; 
– withdraw consent to the processing of personal data;
– appeal to the authorized body for the protection of the rights of personal data subjects or in court the illegal actions or inaction of the Operator when processing his or her personal data;
– exercise other rights provided for by the legislation of the Russian Federation. 
4.2. Personal data subjects are obliged to:
– provide the Operator with reliable data about themselves;
– inform the Operator about the clarification (update, change) of their personal data. 
4.3. Persons who have transferred false information about themselves to the Operator, or information about another personal data subject without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

5. The Operator can process the following User’s personal data:
5.1. First name, Last name, Patronymic (if any).
5.2. Email address.
5.3. Phone numbers.
5.4. Also, the Website collects and processes depersonalized data about visitors (including cookies) using Internet statistics services (Yandex Metrica and Google Analytics and others). 
5.5. The above data hereinafter in the text of the Policy are united by the general concept of Personal data.
5.6. The processing of special categories of personal data concerning race, nationality, political views, religious or philosophical beliefs, sexual life is not carried out by the Operator.
5.7. The processing of personal data permitted for distribution from among the special categories of personal data specified in Art. 10.1 of the Law on Personal Data is allowed if the prohibitions and conditions provided for in Art. 10.1 of the Law on Personal Data. 
5.8. The User’s consent to the processing of personal data permitted for distribution is drawn up separately from other consents to the processing of his or her personal data. In this case, the conditions provided for, in particular, Art. 10.1 of the Law on Personal Data. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects. 
5.8.1. The consent to the processing of personal data permitted for distribution is provided by the User directly to the Operator. 
5.8.2. The Operator is obliged, no later than three working days from the moment of receipt of the specified consent of the User, to publish information about the processing conditions, about the existence of prohibitions and conditions for processing personal data by an unlimited number of persons, allowed for disclosure. 
5.8.3. The transfer (distribution, provision, access) of personal data permitted by the personal data subject for distribution must be stopped at any time at the request of a personal data subject. This requirement should include the last name, first name, patronymic (if any), contact information (phone number, e-mail address or postal address) of a personal data subject, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this requirement can be processed only by the Operator to whom it is sent. 
5.8.4. Consent to the processing of personal data permitted for distribution is terminated from the moment the Operator receives the request specified in clause 5.8.3 of this Policy in relation to the processing of personal data. 

6. Principles of personal data processing 
6.1. The processing of personal data is carried out on a legal and fair basis. 
6.2. The processing of personal data is limited to the achievement of specific, predetermined and legitimate purposes. Processing of personal data that is impermissible with the purposes of collecting personal data is not allowed.
6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other. 
6.4. Only personal data that meet the purposes of their processing is subject to processing. 
6.5. The content and volume of the processed personal data correspond to the stated purposes of the processing. The redundancy of the processed personal data in relation to the stated purposes of their processing is not allowed.
6.6. When processing personal data, the accuracy of personal data, their sufficiency, and, if necessary, relevance in relation to the purposes of processing personal data is ensured. The operator takes the necessary measures and / or ensures their adoption to remove or clarify incomplete or inaccurate data. 
6.7. The storage of personal data is carried out in a form that makes it possible to determine a personal data subject, no longer than the purpose of processing personal data requires, if the storage period for personal data is not established by federal law, an agreement to which a personal data subject is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

7. Purposes of personal data processing
7.1. The purpose of the processing of the User's personal data:
– informing the User by sending emails. 
7.2. The Operator also has the right to send the User notifications about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending the Operator an e-mail to director@i-analytics.ru with the note “Refusal of notifications about new products and services and special offers”. 
7.3. Depersonalized data of Users collected using Internet statistics services are used to collect information about the actions of Users on the site, improve the quality of the site and its content. 

8. Legal basis for the personal data processing
8.1. The legal grounds for the processing of personal data by the Operator are:
– the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”; 
– Federal law, other regulations in the field of personal data protection; 
– the consent of the Users to the processing of their personal data, to the processing of personal data permitted for distribution. 
8.2. The Operator processes the User's personal data only if they are filled in and / or sent by the User independently through special forms located on the website https://i-analytics.ru / or sent to the Operator via email. By filling out the appropriate forms and / or sending his or her personal data to the Operator, the User agrees with this Policy. 
8.3. The Operator processes depersonalized data about the User if it is allowed in the settings of the User's browser (the storage of cookies and the use of JavaScript technology are enabled). 
8.4. A personal data subject independently decides on the provision of his or her personal data and gives consent freely, of his or her own free will and in his or her interest. 

9. Conditions for personal data processing 
9.1. The processing of personal data is carried out with the consent of a personal data subject to the processing of his personal data. 
9.2. The processing of personal data is necessary to achieve the goals provided for by the
international treaty of the Russian Federation or by law, for the implementation of the functions, powers and duties imposed by the legislation of the Russian Federation on the Operator. 
9.3. The processing of personal data is necessary for the justice, the execution of a judicial act, an act of another body or official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings. 
9.4. The processing of personal data is necessary for the execution of an agreement, to which a personal data subject is a party or beneficiary or guarantor, as well as for concluding an agreement on the initiative of a personal data subject or an agreement under which a personal data subject will be the beneficiary or guarantor. 
9.5. The processing of personal data is necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant goals, provided that this does not violate the rights and freedoms of a personal data subject. 
9.6. The processing of personal data is carried out, access to an unlimited number of persons to which is provided by a personal data subject or at his or her request (hereinafter – publicly available personal data). 
9.7. The processing of personal data is carried out, subject to publication or mandatory disclosure in accordance with federal law.

10. The procedure for collecting, storing, transferring and other types of processing of personal data
The security of personal data processed by the Operator is ensured through 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 ensures the safety of personal data and takes all possible measures to exclude access to personal data of unauthorized persons. 
10.2. The User's personal data, under any circumstances, will never be transferred to third parties, except in cases related to the implementation of current legislation or if a personal data subject has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil contract. 
10.3. In the case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator to the Operator's e-mail address strostiansky@yandex.ru marked “Updating personal data”. 
10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the contract or current legislation.
The User can at any time withdraw his or her consent to the processing of personal data by sending a notification to the Operator via e-mail to the Operator's email address strostiansky@yandex.ru with the note “Withdraw the consent to the processing of personal data”. 
10.5. All information that is collected by third-party services, including payment systems,
communication facilities and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. A personal data subject and / or the User is obliged to independently familiarize themselves with these documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
10.6. The prohibitions established by a personal data subject on the transfer (except for providing access), as well as on the processing or processing conditions (except for gaining access) of personal data permitted for dissemination do not apply in cases of processing personal data in the state, public and other public interests determined by law of the Russian Federation.
10.7. When processing personal data, the Operator ensures the confidentiality of personal data. 
10.8. The Operator stores personal data in a form that makes it possible to determine a personal data subject no longer than the purpose of processing personal data requires, unless the storage period for personal data is established by federal law, an agreement to which a personal data subject is a party, beneficiary or guarantor.
10.9. A condition for terminating the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of a personal data subject or withdrawal of consent by a personal data subject, as well as the identification of illegal processing of personal data. 

11. List of actions performed by the Operator with the received personal data
11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes and destroys personal data.
11.2. The Operator carries out automated processing of personal data with the receipt and / or transmission of the information received via information and telecommunication networks or without it. 

12. Cross-border transfer of personal data
12.1. The Operator, before starting the cross-border transfer of personal data, must make sure that the foreign state, to whose territory it is supposed to transfer personal data, provides reliable protection of the rights of subjects of personal data.
12.2. 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 a written consent of a personal data subject for the cross-border transfer of his or her personal data and / or execution of an agreement to which a 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 a personal data subject, unless otherwise provided by federal law. 

14. Final provisions
14.1. The User can receive any clarifications on issues of interest regarding the processing of his or her personal data by contacting the Operator via email director@i-analytics.ru.
14.2. This document will reflect any changes in the personal data processing policy by the Operator. The Policy is valid indefinitely until it is replaced by a new version. 
14.3. The current version of the Policy is freely available on the Internet at https://i-analytics.ru/#popup:privacy. 

Я (далее – Пользователь Интернет-сайта) свободно, своей волей и в своем интересе даю согласие ООО "Форсайт Консалтинг Групп" (ИНН 7723381939, ОГРН 1157746212799), находящемуся по адресу: 109548, город Москва, ул. Кухмистерова, д. 3 к. 2, кв. 3 (далее – Организация, Оператор) на обработку, в том числе сбор, запись, систематизацию, накопление, хранение, уточнение (обновление, изменение), извлечение, использование, передачу (предоставление, доступ), обезличивание, блокирование, удаление, уничтожение, моих персональных данных в соответствии с Федеральным законом от 27 июля 2006 г. № 152-ФЗ «О персональных данных».
Персональные данные предоставляются в целях установления обратной связи с Пользователем Интернет-сайта, направляющим свои данные через форму обратной связи на Интернет-сайте для получения консультации по предоставляемым услугам Организации.
Для указанных целей Оператор собирает следующие персональные данные Пользователя Интернет-сайта: имя, контактный телефон, адрес электронной почты (e-mail).
Настоящее согласие действует в течение 3 (трех) лет с момента последнего взаимодействия Пользователя и Оператора. Согласие может быть отозвано в любой момент путем направления письма Пользователем Интернет-сайта, содержащего фамилию, имя, отчество (при наличии), контактную информацию (номер телефона, адрес электронной почты или почтовый адрес) субъекта персональных данных, а также перечень персональных данных, обработка которых подлежит прекращению, на адрес электронной почты: director@i-analytics.ru
В случае отзыва субъектом персональных данных или его представителем согласия на обработку персональных данных ООО "Форсайт Консалтинг Групп" вправе продолжить обработку персональных данных без согласия субъекта персональных данных при наличии оснований, указанных в пунктах 2 – 11 части 1 статьи 6, части 2 статьи 10 и части 2 статьи 11 Федерального закона №152-ФЗ «О персональных данных» от 27.07.2006 г.