LLC EVA Bioengineering

Russian Federation, Moscow, per. Khitrovsky, 3

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Privacy policy

1. General Provisions

This Personal Data Privacy Policy (hereinafter referred to as the Policy) determines the procedure for processing personal data and measures to ensure the security of personal data taken by EVA Bioengineering Limited Liability Company TIN 9709081126, OGRN 1227700294711.

This Policy has been drawn up in accordance with the requirements of the current legislation of the Russian Federation, Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” (hereinafter referred to as the Personal Data Law), Federal Law No. 323-FZ of November 21, 2011 “On the Basics of Protection health of citizens in the Russian Federation”, Decree of the Government of the Russian Federation of November 1, 2012 No. 1119 “On approval of requirements for the protection of personal data during their processing in personal data information systems”, Roskomnadzor Order of September 5, 2013 No. 996 “On approval of requirements and methods for depersonalization personal data”, Order of the FSTEC of Russia dated February 18, 2013 No. 21 “On approval of the Composition and content of organizational and technical measures to ensure the security of personal data during their processing in personal data information systems”.

1.1. The operator carries out its activities on a legal and fair basis.

1.2. The operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man and citizen in the processing of his personal data.

1.3. This Policy applies to all information posted on the site on the Internet at: https://signum-v.ru/ (hereinafter referred to as the Site), which the Operator (other entities) can receive about the Site Users while using the Site, its services, programs and products.

1.4. Using the services of the Site means the User’s unconditional consent to this Policy and the conditions for processing his personal information specified in it, in case of disagreement with these conditions, the User must refrain from using the services.

1.5. The user is given the opportunity to review information on specific products before using the relevant services.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data — processing of personal data using computer technology.

2.2. Blocking of personal data is a temporary suspension of the processing of personal data (unless the processing is necessary to clarify personal data).

2.3. Personal data information system — a set of personal data contained in databases, and information technologies and technical means that ensure their processing.

2.4. Use of the Site — any action performed by the User on the Site, including the first transition to the Site.

2.5. Click — the User’s access to the contained link.

2.6. Content — all or any information contained on the Site in text, graphic and other forms.

2.7. Confidentiality of personal data is a mandatory requirement for the Operator or other person who has gained access to personal data to prevent their distribution without the consent of the subject of personal data or other legal grounds.

2.8. Depersonalization of personal data — actions as a result of which it is impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data.

2.9. Processing of personal data — any action (operation) or a set of actions (operations) performed with or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.

2.10. Operator — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) carrying out the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data to be processed, the actions (operations) performed with personal data.

2.11. Personal data — any information relating directly or indirectly to a specific or identifiable individual (subject of personal data) — the User of the Site https://signum-v.ru.

2.12. Personal data permitted by the subject of personal data for distribution — personal data, access to an unlimited number of persons to which is provided by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter — personal data allowed for distribution), when registering (creating an account) or in the process of using the Services. The information required for the provision of the Services is marked in a special way. Other information is provided by the User at his discretion.

2.13. Personal information — data that is automatically transmitted to the services of the Site in the process of using them using the software installed on the User’s device, including IP address, cookie data, information about the User’s browser (or other program that accesses the services ), technical characteristics of the equipment and software used by the User, date and time of access to the services, addresses of the requested pages and other similar information.

2.14. User — a person who has a certain role in the System and access to the Site https://signum-v.ru via the Internet and uses the information, materials and products of the Site, .

2.15. Providing personal data — actions aimed at disclosing personal data to a certain person or a certain circle of persons.

2.16. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite circle of persons (transfer of personal data) or familiarizing with personal data of an unlimited number of persons, including the disclosure of personal data in the media, placement in information and telecommunication networks or providing access to personal data in any other way.

2.17. Roles in the system — persons (medical workers of relevant medical institutions, performing in accordance with Federal Law No. 152-FZ of July 27, 2006 «On Personal Data», Federal Law No. 323-FZ of November 21, 2011 «On the Basics of Protecting the Health of Citizens in of the Russian Federation, responsible for maintaining, processing dynamic data containing a certain nature and type of information, depending on the functional affiliation of the person; patients; relatives — users of the site https://signum-v.ru of its services, programs and products and other individuals faces.

The system provides for the following roles:

2.18. Site — a set of graphic and information materials, as well as computer programs and databases that ensure their availability on the Internet at a unique address (URL) https://signum-v.ru, as well as its subdomains.

2.19. The Signum — V system is a set of systems (programs) on the Site created for diagnosing cardiovascular diseases, monitoring the health of patients, determining its location and managing the patient until the arrival of an ambulance and further hospitalization of the patient.

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

2.21. Destruction of personal data — any actions as a result of which personal data is irretrievably destroyed with the impossibility of further restoration of the content of personal data in the information system of personal data and (or) material carriers of personal data are destroyed.

2.22. Cookies are a small piece of data sent by a web server and stored on the user’s computer, which the web client or web browser sends to the web server in an HTTP request every time they try to open a page of the corresponding site.

2.23. IP address — a unique network address of a node in a computer network through which the User gains access to the Site.

All terms and definitions in the text of this document are interpreted in accordance with the generally accepted interpretation in the information and telecommunications network of the Internet, unless a different definition is given in the text of this document or in the legislation of the Russian Federation.

The policy applies both to all content, and to its part or parts individually or in aggregate, services provided by the Site online, by e-mail or any mobile device.

2.24. The device is a system complex for monitoring and warning Signum-V.

3. Basic rights and obligations of the Operator

3.1. The operator has the right:

3.1.1. receive from the subject of personal data reliable information and / or documents containing personal data;

3.1.2. independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws;

3.1.3. without the consent of the subject of personal data to process his personal data in the following cases:

3.1.4. independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Law on Personal Data and the 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:

3.2.1. use the information received solely for the purposes specified in this Policy;

3.2.2. to ensure the storage of confidential information in secret, not to disclose without the prior written permission of the User, and not to sell, exchange, publish or disclose in other possible ways the transferred personal data of the User, except as provided for in this Privacy Policy;

3.2.3. provide the subject of personal data, at his request, with information regarding the processing of his personal data;

3.2.4. organize the processing of personal data in the manner prescribed by the current legislation of the Russian Federation;

3.2.5. respond to requests and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;

3.2.6. report to the authorized body for the protection of the rights of subjects of personal data, at the request of this body, the necessary information within 30 days from the date of receipt of such a request;

3.2.7. take precautions to protect the confidentiality of the User’s personal data in accordance with the procedure usually used to protect this kind of information in existing business transactions;

3.2.8. take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;

3.2.9. stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases provided for by the Personal Data Law;

3.2.10. to block personal data relating to the relevant User from the moment of the request or request of the User or his legal representative or authorized body for the protection of the rights of subjects of personal data for the period of verification in case of revealing false personal data or illegal actions;

3.2.11. perform other duties stipulated by the Law on Personal Data.

3.3. If the Operator, on the basis of an agreement, entrusts the processing of personal data to another person, an essential condition of the agreement is the obligation of the said person to ensure the confidentiality of personal data and the security of personal data during their processing.

4. Basic rights and obligations of personal data subjects

4.1. Subjects of personal data have the right to:

4.1.1. receive information regarding the processing of his personal data, except as otherwise provided by federal laws. The information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data related to other subjects of personal data, 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;

4.1.2. require the Operator to clarify his personal data, their blocking or destruction upon the provision by the subject of personal data or his legal representative of information confirming that the personal data that relate to the relevant subject and processed by the Operator are incomplete, outdated, inaccurate, illegally obtained or are not necessary for the stated purpose of processing, as well as to take legal measures to protect their rights. The Operator is obliged to notify the subject of personal data or his legal representative and third parties to whom the personal data of this subject were transferred about the changes made and the measures taken;

4.1.3. put forward the condition of prior consent when processing personal data in order to promote goods, works and services on the market;

4.1.4. to withdraw consent (user agreement) to the processing of personal data;

4.1.5. appeal to the authorized body for the protection of the rights of subjects of personal data or in court against illegal actions or inaction of the Operator when processing his personal data;

4.1.6. to exercise other rights provided for by the legislation of the Russian Federation and the Law on Personal Data.

4.2. Subjects of personal data are obliged to:

4.2.1. provide the Operator with reliable data about yourself;

4.2.2. notify the Operator about the clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with false information about themselves or information about another subject of personal data without the consent of the latter, are liable in accordance with the legislation of the Russian Federation.

4.4. bear other obligations provided for by the Law on Personal Data.

5. The Operator may process the following personal data of the User

5.1. Last name, first name, patronymic (last if available).

5.2. Floor.

5.3. Year/month/date of birth.

5.4. Data of the identity document.

5.5. Photos/videos;

5.6. Phone numbers;

5.7. Email address (e-mail);

5.8. ECG data, measurements of the properties of the pulse, vascular resistance, blood pressure (processes the device);

5.9. Diagnosis and research;

5.10. Information about the medications you have taken and are currently taking;

5.11.Anonymous data (including cookies) is also collected and processed on the site.

5.12. The above data further in the text of the Policy are united by the general concept of Personal data.

5.13. Other information that the User provides independently at his own discretion by filling out the appropriate forms on the Site.

5.14. Processing of special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Operator.

5.15. Processing of personal data permitted for distribution from among the special categories of personal data specified in Part 1 of Art. 10 of the Law on Personal Data is allowed if the prohibitions and conditions provided for in Art. 10.1 of the Personal Data Law.

5.16. Consent to the processing of personal data permitted for distribution, the User provides the Operator by concluding a user agreement when registering on the site https://signum-v.ru . At the same time, the conditions provided for, in particular, Art. 10.1 of the Personal Data Law.

5.17. The transfer (distribution, provision, access) of personal data authorized by the subject of personal data for distribution must be terminated at any time at the request of the subject of personal data. This requirement should include the last name, first name, patronymic (if any), contact information (telephone number, e-mail address or postal address) of the subject of personal data, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this request can be processed only by the Operator to whom it is sent.

5.18. Consent to the processing of personal data permitted for distribution ceases to be valid from the moment the Operator receives the request specified in clause 5.17. of this Policy regarding 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 carried out by the Operator solely to achieve the legitimate goals defined by this Policy and the user agreement. It is not allowed to process personal data that is incompatible with the purposes of collecting personal data.

6.3. It is not allowed to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.

6.4. Only personal data that meet the purposes of their processing are subject to processing.

6.5. The content and scope of the processed personal data correspond to the stated purposes of 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 allows determining the subject of personal data, no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. The processed personal data is destroyed or depersonalized upon reaching the goals of processing or in case of loss of the need to achieve these goals, unless otherwise provided by federal law.

6.8. Collection, generalization, storage of information about the patient is carried out by a medical organization and is allowed with the consent of the subject of personal data or if there are other grounds provided for by Part 1 of Article 6 of the Federal Law of July 27, 2006 No. 152-FZ «On Personal Data».

7. Purposes of personal data processing

7.1. The purpose of processing the User’s personal data:

7.2. The Operator also has the right to send notifications to the User about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending an email to the Operator at partner@signum-v.ru with the note «Refusal of notifications about new products and services and special offers».

7.3. Anonymous data collected through services serve to improve and improve the quality of life of the population, increase the efficiency of business entities in the course of introducing artificial intelligence technologies, form an integrated system for regulating public relations arising in connection with the development and use of artificial intelligence technologies, which meets the requirements specified in subparagraph 2.1 of paragraph 2 of Article 10 of the Federal Law of July 27, 2006 No. 152-FZ “On Personal Data”.

8. Legal grounds for the processing of personal data

8.1. The legal grounds for the processing of personal data by the Operator are:

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 site https://signum-v.ru. By filling out the appropriate forms and sending their personal data to the Operator, the User expresses his full consent to this Policy.

8.3. The operator processes anonymized data by «pseudo-minimization», as a result of which they cannot be attributed to a specific data subject. With regard to information, the Operator has taken technical and organizational measures to prevent its attribution to an identified or identifiable natural person.

8.4. The Operator processes anonymized data about the User if it is allowed in the User’s browser settings (saving cookies and using JavaScript technology is enabled).

8.5. The subject of personal data independently decides on the provision of his personal data and gives consent freely, of his own free will and in his own interest.

9. Conditions for the processing of personal data

9.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data, by concluding a user agreement on the Site https://signum-v.ru.

9.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or the law, to carry out the functions, powers and duties assigned by the legislation of the Russian Federation to the Operator.

9.3. The processing of personal data is necessary for the administration of 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 performance of an agreement to which the subject of personal data is a party or beneficiary or guarantor, as well as to conclude an agreement on the initiative of the subject of personal data or an agreement under which the subject of personal data 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 the rights and freedoms of the subject of personal data are not violated.

9.6. The processing of personal data is carried out, the access of an unlimited number of persons to which is provided by the subject of personal data or at his request (hereinafter referred to as publicly available personal data).

9.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.

9.8. The processing of personal data by the Operator consists in obtaining, systematizing, accumulating, storing, clarifying (updating, changing), using, distributing, depersonalizing, blocking, destroying and protecting against unauthorized access.

9.9. The processing of personal data is carried out by the method of mixed (including automated) processing using Big Data technology.

9.10. The processing of the User’s personal data can only be accessed by employees of the Company, whose duties are directly related to access and work with the User’s personal data.

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 will never, under any circumstances, be transferred to third parties, except in cases related to the implementation of applicable law or if the subject of personal data has given consent to the Operator to transfer data to a third party to fulfill obligations under a civil law contract.

10.3. In case of inaccuracies in personal data, the User can update them independently, in his personal account or by sending a scanned copy of a written application to the Operator to withdraw consent to the processing of personal data by e-mail at the following address: partner@signum-v.ru.

10.4. The term for the processing of personal data is determined by the achievement of the purposes for which the personal data were collected, unless a different period is provided for by the user agreement or the current legislation of the Russian Federation. The User may at any time revoke his consent to the processing of personal data by sending the Operator a notification by e-mail to the Operator’s email address: partner@signum-v.ru.

10.5. All information that is collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data and / or the User is obliged to independently familiarize themselves with the specified 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 the subject of personal data on the transfer (except for granting access), as well as on the processing or processing conditions (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in state, public and other public interests determined by law RF.

10.7. The operator, when processing personal data, ensures the confidentiality of personal data.

10.8. Categories of personal data (clause 5.8. — 5.10) processes the device in order to prevent the development of sudden cardiac pathology and scientific research;

10.9. The operator stores personal data in a form that allows to determine the subject of personal data, no longer than required by the purposes of processing personal data, if the period for storing personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.

10.10. The operator stores personal data specified in clause 5.8. – 5.10. in a form that does not allow to identify the subject of personal data, using methods of depersonalization of personal information.

10.11. The 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 the subject of personal data or the withdrawal of consent by the subject of personal data, as well as the identification of unlawful processing of personal data.

10.12. In accordance with Preamble 26 of the General Data Protection Regulation (hereinafter referred to as the GDPR), data protection principles must apply to any information relating to an identified or identifiable natural person. The Operator carries out its activities on the Yandex.Cloud platform, which has a certificate of compliance with ISPD, meets the information and data security requirements of the GDPR.

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 (using Big Data technology) with the receipt and / or transmission of the received information via information and telecommunication networks or without it.

12. Cross-border transfer of personal data

12.1. Before the start of the cross-border transfer of personal data, the operator is obliged to make sure that the foreign state to whose territory the transfer of personal data is supposed to be carried out 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 the subject of personal data to the cross-border transfer of his personal data and / or execution of an agreement to which the subject of personal data is a party.

13. Privacy of personal data

13.1. The information listed in Section 5 of this Policy is confidential. The Operator ensures the confidentiality of personal data and is obliged to prevent their distribution without the consent of the Users, or other legal grounds.

13.2. All confidentiality measures during the collection, processing and storage of personal data of customers apply to both paper and electronic (automated) media.

13.3. 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 the subject of personal data, unless otherwise provided by federal law.

13.4. The confidentiality regime of personal data is removed in cases of depersonalization or publication in public sources.

14. Liability of the parties

14.1. Persons guilty of violating the requirements of the Law on Personal Data shall bear liability provided for by the legislation of the Russian Federation.

14.2. In case of loss or disclosure of Confidential Information, the Operator shall not be liable if this confidential information:

14.2.1. Became public property before its loss or disclosure.

14.2.2. It was received from a third party until it was received by the Resource Administration.

14.2.3. Was disclosed with the consent of the User.

14.2. The user is fully responsible for compliance with the requirements of the current legislation, including laws on advertising, on the protection of copyright and related rights, on the protection of trademarks and service marks, but not limited to the above, including full responsibility for the content and form of materials.

14.3. The user acknowledges that the responsibility for any information (including, but not limited to: data files, texts, etc.), to which he can have access as part of the site https://signum-v.ru is the person who provided such information.

14.4. The responsibility of the persons specified in clause 2.17 of this Policy depends on their role in the relevant System and is distributed as follows:

14.5. Before using the implantable chip, the User (if it is a potential Patient) must read all the general information posted on the site https://signum-v.ru, information that must be taken into account before implantation, indications, contraindications, warnings, possible complications, storage, operation and handling of the device.

Starting to use the Site and / or its individual functions in any form (including navigating the site and studying the materials posted on it), device, or by completing the registration procedure by the User (Patient / Relative) on the Site (by filling out questionnaires and other forms posted on the Site , including when you press the buttons: “Registration”, “Application”) and providing information about yourself means the full consent of the User with the conditions for processing his personal data established by this Policy, familiarization with the conditions and rules for operating the device, and violation of the rules of which the Operator is liable does not carry possible complications.

15. Final provisions

15.1. The user can get any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail partner@signum-v.ru.

15.2. This document will reflect any changes to the Personal Data Processing Policy by the Operator. The policy is valid indefinitely until it is replaced by a new version. 15.3. The current version of the Policy in the public domain is located on the Internet at https://signum-v.ru.