Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy has been prepared in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006, “On Personal Data” (hereinafter referred to as the “Personal Data Law”) and establishes the procedure for processing personal data and the measures taken by AlfaLab LLC (hereinafter referred to as the “Operator”) to ensure the security of personal data.

1.1. The Operator considers the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and personal and family confidentiality, to be one of its most important objectives and an essential condition of its activities.

1.2. This Personal Data Processing Policy of the Operator (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain about visitors to the website at https://www.alphalabs.ru/.

2. Key Terms Used in the Policy

2.1. Automated processing of personal data means the processing of personal data using computing equipment.

2.2. Blocking of personal data means the temporary suspension of personal data processing, except where processing is necessary to clarify or correct personal data.

2.3. Website means a collection of graphic and informational materials, computer programs, and databases that makes such materials available on the internet at https://www.alphalabs.science/.

2.4. Personal data information system means a collection of personal data contained in databases, together with the information technologies and technical means used to process such data.

2.5. Anonymization of personal data means actions as a result of which it becomes impossible, without the use of additional information, to determine whether personal data belongs to a particular User or another personal data subject.

2.6. Processing of personal data means any action or operation, or a set of actions or operations, performed on personal data with or without the use of automated means, including the collection, recording, organization, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (distribution, provision, or access), anonymization, blocking, deletion, and destruction of personal data.

2.7. Operator means a state authority, municipal authority, legal entity, or individual that, independently or jointly with others, organizes and/or carries out the processing of personal data and determines the purposes of such processing, the personal data to be processed, and the actions or operations to be performed on personal data.

2.8. Personal data means any information relating directly or indirectly to an identified or identifiable User of the website at https://www.alphalabs.science/.

2.9. Personal data authorized by the personal data subject for distribution means personal data to which the personal data subject has granted access to an unlimited number of persons by consenting to the processing of personal data authorized by the personal data subject for distribution in accordance with the procedure established by the Personal Data Law (hereinafter referred to as “personal data authorized for distribution”).

2.10. User means any visitor to the website at https://www.alphalabs.science/.

2.11. Provision of personal data means actions aimed at disclosing personal data to a particular person or a particular group of persons.

2.12. Distribution of personal data means any actions aimed at disclosing personal data to an indefinite number of persons (transfer of personal data) or making personal data available to an unlimited number of persons, including publication in the mass media, placement on information and telecommunications networks, or providing access to personal data by any other means.

2.13. Cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state, to an authority of a foreign state, or to a foreign individual or legal entity.

2.14. Destruction of personal data means any actions as a result of which personal data is permanently destroyed so that its contents cannot subsequently be restored in the personal data information system and/or the physical media containing the personal data is destroyed.

3. Principal Rights and Obligations of the Operator

3.1. The Operator has the right to:

• obtain accurate information and/or documents containing personal data from the personal data subject;
• continue processing personal data without the consent of the personal data subject, where grounds specified in the Personal Data Law exist, if the personal data subject withdraws their consent to processing or submits a request to cease processing;
• independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations established by the Personal Data Law and regulations adopted pursuant to it, unless otherwise provided by the Personal Data Law or other federal laws.

3.2. The Operator must:

• provide the personal data subject, upon request, with information concerning the processing of their personal data;
• organize the processing of personal data in accordance with the applicable laws of the Russian Federation;
• respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
• provide the competent authority responsible for protecting the rights of personal data subjects, upon its request, with the necessary information within 10 days of receiving such request;
• publish or otherwise provide unrestricted access to this Personal Data Processing Policy;
• take legal, organizational, and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, or distribution, as well as against other unlawful actions involving personal data;
• cease the transfer (distribution, provision, or granting of access) and processing of personal data and destroy personal data in the manner and circumstances prescribed by the Personal Data Law;
• perform other duties prescribed by the Personal Data Law.

4. Principal Rights and Obligations of Personal Data Subjects

4.1. Personal data subjects have the right to:

• obtain information concerning the processing of their personal data, except in cases provided for by federal law. The Operator must provide this information to the personal data subject in an accessible form. It must not contain personal data relating to other personal data subjects unless there are lawful grounds for disclosing such data. The list of information to be provided and the procedure for obtaining it are established by the Personal Data Law;
• require the Operator to clarify, block, or destroy their personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to take measures provided by law to protect their rights;
• require prior consent as a condition for processing personal data for the purpose of promoting goods, works, or services in the market;
• withdraw consent to the processing of personal data and submit a request to cease the processing of personal data;
• appeal unlawful actions or omissions of the Operator in processing their personal data to the competent authority responsible for protecting the rights of personal data subjects or before a court;
• exercise other rights provided for by the laws of the Russian Federation.

4.2. Personal data subjects must:

• provide the Operator with accurate information about themselves;
• inform the Operator of any clarification, update, or change to their personal data.

4.3. Persons who provide the Operator with inaccurate information about themselves or information about another personal data subject without that person’s consent shall be liable in accordance with the laws of the Russian Federation.

5. Principles Governing the Processing of Personal Data

5.1. Personal data shall be processed lawfully and fairly.

5.2. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Personal data may not be processed in a manner incompatible with the purposes for which it was collected.

5.3. Databases containing personal data processed for mutually incompatible purposes may not be combined.

5.4. Only personal data that meets the purposes of its processing shall be processed.

5.5. The content and volume of the personal data processed shall correspond to the stated purposes of processing. The processing of personal data that is excessive in relation to the stated purposes is prohibited.

5.6. When processing personal data, the Operator shall ensure its accuracy, sufficiency, and, where necessary, relevance to the purposes for which it is processed. The Operator shall take or arrange for the taking of necessary measures to delete or correct incomplete or inaccurate data.

5.7. Personal data shall be stored in a form that permits the identification of the personal data subject for no longer than required by the purposes of processing, unless a retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor. Personal data being processed shall be destroyed or anonymized once the purposes of processing have been achieved or when the need to achieve those purposes no longer exists, unless otherwise provided by federal law.

6. Purposes of Personal Data Processing

7. Conditions for Processing Personal Data

7.1. Personal data shall be processed with the consent of the personal data subject.

7.2. Personal data may be processed where necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, or to perform the functions, powers, and duties assigned to the Operator by the laws of the Russian Federation.

7.3. Personal data may be processed where necessary for the administration of justice or the enforcement of a judicial act or an act of another authority or official that is enforceable under the laws of the Russian Federation governing enforcement proceedings.

7.4. Personal data may be processed where necessary to perform an agreement to which the personal data subject is a party, beneficiary, or guarantor, as well as to enter into an agreement at the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.

7.5. Personal data may be processed where necessary to exercise the rights and legitimate interests of the Operator or third parties or to achieve socially significant purposes, provided that the rights and freedoms of the personal data subject are not thereby infringed.

7.6. Personal data to which the personal data subject has granted access to an unlimited number of persons, either directly or upon their request, may be processed (hereinafter referred to as “publicly available personal data”).

7.7. Personal data that is subject to publication or mandatory disclosure under federal law may be processed.

8. Procedure for the Collection, Storage, Transfer, and Other Processing of Personal Data

The security of personal data processed by the Operator shall be ensured through the implementation of the legal, organizational, and technical measures necessary for full compliance with the applicable personal data protection laws.

8.1. The Operator shall ensure the secure preservation of personal data and take all possible measures to prevent unauthorized persons from accessing it.

8.2. The User’s personal data shall never be transferred to third parties under any circumstances, except where required for compliance with applicable law or where the personal data subject has consented to the Operator transferring the data to a third party for the performance of obligations under a civil-law agreement.

8.3. If inaccuracies are identified in their personal data, the User may update it by emailing the Operator at info@alphalabs.ru with the subject line “Personal Data Update.”

8.4. The personal data processing period shall be determined by the achievement of the purposes for which the personal data was collected, unless a different period is established by an agreement or applicable law.

The User may withdraw their consent to the processing of personal data at any time by emailing the Operator at info@alphalabs.ru with the subject line “Withdrawal of Consent to Personal Data Processing.”

8.5. All information collected by third-party services, including payment systems, communications providers, and other service providers, shall be stored and processed by those parties (operators) in accordance with their respective User Agreements and Privacy Policies.

[Translator’s note: The source text contains an incomplete sentence at this point: “The personal data subject and/or with the specified documents.”]

The Operator shall not be liable for the actions of third parties, including the service providers referred to in this clause.

8.6. Restrictions imposed by the personal data subject on the transfer (other than the provision of access), as well as on the processing or conditions of processing (other than obtaining access) of personal data authorized for distribution, shall not apply where such personal data is processed in the state, public, or other public interests defined by the laws of the Russian Federation.

8.7. The Operator shall ensure the confidentiality of personal data when processing it.

8.8. The Operator shall store personal data in a form that permits the identification of the personal data subject for no longer than required by the purposes of processing, unless a retention period is established by federal law or by an agreement to which the personal data subject is a party, beneficiary, or guarantor.

8.9. The processing of personal data may be terminated upon achievement of the purposes of processing, expiry of the personal data subject’s consent, withdrawal of consent by the personal data subject, receipt of a request to cease processing, or identification of unlawful personal data processing.

9. Actions Performed by the Operator in Relation to Personal Data Obtained

9.1. The Operator collects, records, organizes, accumulates, stores, clarifies (updates or modifies), retrieves, uses, transfers (distributes, provides, or grants access to), anonymizes, blocks, deletes, and destroys personal data.

9.2. The Operator performs automated processing of personal data, with or without the receipt and/or transfer of the information obtained through information and telecommunications networks.

10. Cross-Border Transfer of Personal Data

10.1. Before commencing any cross-border transfer of personal data, the Operator must notify the competent authority responsible for protecting the rights of personal data subjects of its intention to conduct such transfers. This notice shall be submitted separately from the notice of intention to process personal data.

10.2. Before submitting the aforementioned notice, the Operator must obtain the relevant information from the authorities of foreign states and from the foreign individuals or legal entities to which the cross-border transfer of personal data is planned.

11. Confidentiality of Personal Data

The Operator and other persons granted access to personal data must not disclose personal data to third parties or distribute it without the consent of the personal data subject, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User may obtain clarification regarding any matters concerning the processing of their personal data by contacting the Operator at info@alphalabs.ru.

12.2. Any changes to the Operator’s Personal Data Processing Policy shall be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version.

12.3. The current version of the Policy is publicly available online at https://www.alphalabs.science/privacy.