[Privacy Policy]
1. General Provisions
This Policy has been drafted in accordance with Federal Law No. 152-FZ dated July 27, 2006 "On Personal Data" (hereinafter — 152-FZ) and defines the procedure for processing personal data and measures to ensure their security undertaken by JSC "Concentration" (hereinafter — the Operator).
1.1. The Operator's paramount goal is to uphold the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Policy applies to all information that the Operator may obtain about visitors to the website appscience.ru. The processing of personal data of employees, candidates, clients, and counterparties of the Operator is governed by a separate Personal Data Processing Policy of JSC "Concentration."
1.3. Operator details: TIN 9709131553, OGRN 1257700589167, address: 109147, Moscow, Vorontsovskaya St. 49/28, Building 1.
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 personal data processing (except in cases where processing is necessary to clarify personal data).
2.3. Personal data information system — a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.4. Anonymization of personal data — actions that make it impossible, without the use of additional information, to determine whether personal data belongs to a specific data subject.
2.5. Processing of personal data — any action (operation) or set of actions performed with or without the use of automation tools with personal data (collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, anonymization, blocking, deletion, destruction).
2.6. Operator — a legal entity that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, and determines the purposes of processing, the composition of data, and the actions performed.
2.7. Personal data — any information relating directly or indirectly to a specific or identifiable User of the website https://conc.ru/.
2.8. User — any visitor to the website https://conc.ru/.
2.9. Cross-border transfer of personal data — transfer of personal data to the territory of a foreign state to a foreign state authority, a foreign individual, or a foreign legal entity.
2.10. Destruction of personal data — actions that result in the permanent destruction of personal data with no possibility of further restoration of their content and/or destruction of the physical media containing personal data.
3. Rights and Obligations of the Operator
3.1. The Operator has the right to:
— with the consent of the data subject, entrust the processing of their personal data to another party on the basis of a concluded agreement, unless otherwise provided by 152-FZ;
— provide personal data to third parties if this is provided for by the legislation of the Russian Federation (including to investigative authorities, inquiry bodies, and other authorized agencies);
— process personal data without the consent of the data subject in cases provided for by the legislation of the Russian Federation;
— refuse to provide personal data in cases provided for by the legislation of the Russian Federation;
— defend its interests in judicial bodies.
3.2. The Operator is obliged to:
— before commencing processing, notify Roskomnadzor of its intention to process personal data and be registered in the operator registry (Article 22 of 152-FZ);
— provide the data subject, upon request, with information regarding the processing of their personal data and the opportunity to access them within the timeframes established by Article 20 of 152-FZ;
— update, block, or destroy personal data if they are incomplete, inaccurate, outdated, unlawfully obtained, or no longer necessary for the purposes of processing (Articles 20–21 of 152-FZ);
— ensure the recording, systematization, accumulation, storage, updating, and retrieval of personal data of citizens of the Russian Federation using databases located on the territory of the Russian Federation (Part 5, Article 18 of 152-FZ);
— notify Roskomnadzor of incidents: within 24 hours — of the fact of unlawful or accidental transfer; within 72 hours — of the results of internal investigations (Article 21 of 152-FZ);
— implement legal, organizational, and technical measures to protect personal data and other measures necessary to comply with the requirements of 152-FZ.
4. Personal Data Processed by the Operator
The Operator may process the following personal data of the User:
4.1. Surname, first name, patronymic;
4.2. Email address;
4.3. Phone number;
4.4. The website also collects and processes anonymized data about visitors (including cookie files) using internet statistics services (Yandex Metrica);
4.5. The above data are collectively referred to in this Policy as "Personal Data."
5. Purposes of Personal Data Processing
5.1. Receiving and processing the User's inquiry and providing feedback.
5.2. Informing the User about products, services, special offers, and events — with the User's consent. The User may opt out of receiving such communications at any time by sending an email to info@appscience.ru with the subject line «Opt-out of informational messages».
5.3. Analyzing and improving the website's performance using internet statistics services.
6. Legal Basis for Processing. Consent
6.1. Legal grounds for processing: 152-FZ and other regulatory legal acts; contracts concluded between the Operator and the data subject; consent of the data subject to the processing of personal data.
6.2. Consent to the processing of personal data is formalized as a separate document, distinct from this Policy and other terms and conditions (Article 9 of 152-FZ). On the website, consent is provided as a separate element — a checkbox "I consent to the processing of personal data" — not combined with acceptance of the Policy. The text of the consent is provided in the Appendix.
6.3. The use of cookies and internet statistics services is based on the informed consent of the User, obtained through an information banner upon the first visit to the website, with the option to refuse non-essential cookies.
7. Procedure for Processing, Storage, and Transfer. Rights of the Data Subject
7.1. The security of personal data is ensured through the implementation of legal, organizational, and technical measures. The Operator takes measures to prevent unauthorized access to personal data.
7.2. To achieve the purposes of processing, the Operator has the right to entrust the processing of personal data to processors on the basis of a contract in compliance with Article 6 of 152-FZ. Processors include, in particular, operators of internet statistics services (Yandex Metrica). Personal data is provided to other third parties only if there are grounds provided for by the legislation of the Russian Federation.
7.3. The retention period for personal data is no longer than required by the purposes of processing, unless a different period is established by law or contract. Upon achievement of the processing purposes or upon withdrawal of consent (in the absence of another legal basis), the data is destroyed; destruction is confirmed by an act, and in the case of automated processing — by an extract from the log (Roskomnadzor Order No. 179 dated October 28, 2022). Withdrawal of consent is sent to info@appscience.ru with the subject line «Withdrawal of consent to the processing of personal data».
7.4. The User has the right to: receive information regarding the processing of their personal data and access to them; request their updating, blocking, or destruction; withdraw consent; appeal the Operator's actions to Roskomnadzor or in court (Article 14 of 152-FZ). The Operator responds to requests within the timeframes established by 152-FZ.
8. Cross-Border Transfer of Personal Data
8.1. The Operator does not carry out cross-border transfer of personal data. The collection and processing of statistics are carried out through services located on the territory of the Russian Federation. Should the need for cross-border transfer arise, the Operator will first comply with the requirements of Article 12 of 152-FZ.
9. Officer Responsible for the Organization of Personal Data Processing
9.1. The person responsible for the organization of personal data processing at JSC "Concentration" (Article 22.1 of 152-FZ) is the General Director, Igor S. Yaremenko.
9.2. Inquiries regarding the processing of personal data may be sent to the Operator's address: 109147, Moscow, Vorontsovskaya St. 49/28, Building 1.
10. Final Provisions
10.1. The User may obtain clarifications regarding the processing of their personal data by contacting the Operator at info@appscience.ru. info@appscience.ru.
10.2. Any changes to this Policy will be reflected in this document. The Policy is valid indefinitely until replaced by a new version.
10.3. The current version of the Policy is available at https://conc.ru/politika-konfidenczialnosti/