This Policy is drafted in accordance with Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” and defines the procedures and security measures applied by Individual Entrepreneur Artyom Arsenievich Dekhtiarov (TIN 665801467598, OGRNIP 304665823900951; hereinafter, the “Operator”) for processing personal data. The Operator, when processing personal data, adheres to the rights and freedoms of individuals, including the right to privacy and the protection of personal and family secrets. This Policy applies to all information the Operator may obtain about a User during registration and use of the mobile application Stability (the “Application”).

2.1. Automated Processing of Personal Data — processing by means of computing equipment.

2.2. Blocking of Personal Data — temporary suspension of processing (except for data clarification).

2.3. Application — the mobile application Stability and all its components accessible to the User.

2.4. Personal Data Information System — a combination of databases and technical means ensuring the processing of personal data.

2.5. Anonymization of Personal Data — actions rendering impossible the determination of the data subject’s identity without additional information.

2.6. Processing of Personal Data — any operation with personal data, including collection, recording, systematization, storage, clarification, extraction, use, transfer, anonymization, blocking, deletion, or destruction.

2.7. Operator — Artyom Arsenievich Dekhtiarov, the individual deciding the purposes and means of data processing.

2.8. Personal Data — any information relating directly or indirectly to an identified or identifiable User.

2.9. User — any individual using the Application and providing personal data to the Operator.

3.1. The Operator may process:

• surname, given name and patronymic;
• date of birth;
• e-mail address;
• telephone number;
• photographic images;
• technical data on Application usage (IP address, cookies, device type, etc.).

3.2. Personal data are submitted via registration forms and other Application services. By submitting data, the User consents to processing for the purposes set out in Section 5.

3.3. All personal data are confidential and may not be used by the Operator for purposes other than those specified in this Policy or as required by Russian law.

4.1. Legality and fairness.

4.2. Purpose limitation: data are processed only for defined, lawful purposes.

4.3. Data minimization: scope and content of processed data correspond to processing purposes.

4.4. Accuracy and relevancy: the Operator takes measures to update or delete incomplete or inaccurate data.

4.5. Storage limitation: data are retained no longer than required by purposes, unless otherwise stipulated by law.

4.6. Destruction or anonymization upon achieving processing purposes or when no longer needed.

5.1. User identification for access to Application features.

5.2. Provision of personalized services.

5.3. Notification of services, updates and promotions via e-mail and push notifications.

5.4. Conclusion and performance of the license agreement with the User.

5.5. Delivery of customer and technical support.

5.6. Analysis of Application performance to improve service quality.

5.7. Other functions as required by Russian law.

6.1. The Operator shall:

• inform the User upon request of processing methods and purposes;
• block or delete data at the User’s request where provided by law;
• ensure data confidentiality and security.

6.2. The full list of the Operator’s obligations is established by Federal Law No. 152-FZ.

7.1. The User has the right to:

• obtain information about processing of their personal data;
• request clarification, blocking or deletion of their data;
• withdraw consent to processing in whole or in part;
• contact Roskomnadzor or the courts for protection of their rights.

7.2. The User shall:

• provide accurate data;
• update data upon changes.

8.1. Processing is carried out by automated and non-automated means.

8.2. Retention periods are determined by processing purposes and Russian legislation.

8.3. After achieving processing purposes or upon consent withdrawal, data are destroyed or anonymized within 30 days.

9.1. The Operator does not disclose personal data to third parties without the User’s consent, except as required by law.

9.2. To provide services, the Operator may engage affiliates or contractors under confidentiality agreements.

10.1. The Operator implements legal, organizational and technical measures to prevent loss, unauthorized access, disclosure, modification or destruction of personal data.

10.2. The Operator is responsible for organizing processing and protecting personal data.

11.1. Processing purposes and procedures are determined by federal legislation, the Operator’s governing documents and the User’s consent.

12.1. The Application uses cookies and similar technologies to store settings and statistics.

12.2. The User may disable cookies in device settings, which may limit Application functionality.

13.1. The Operator may amend this Policy unilaterally; the new version takes effect upon publication in the Application.

13.2. All inquiries regarding personal data processing should be sent to [email protected].