Privacy Policy for the Processing of Personal Data

1. General provisions

1.1. The use of the medtechprima.ru website (hereinafter the "Website") by the User constitutes consent to this Policy and to the terms of processing of the User's personal data.

1.2. The Operator does not verify the accuracy of the personal data provided by the User but acts in good faith on the assumption that the User provides accurate information.

1.3. Important note: The Operator's Website is intended to inform about research and technology projects in digital medicine. The Website does not collect or process personal data of patients, including special categories of data (health status), outside of individual clinical agreements governed by independent local regulations and patient informed consents.

2. Information about the operator

Name: MedTechPrima Limited Liability Company.

Legal address: 123112, Moscow, Presnenskaya embankment, 12, premises 10/45.

INN / OGRN: 9703244631 / 1267700125043.

Contact details: phone +7 (985) 728-66-55, email mar.petrushina@yandex.ru.

Person responsible for the organization of personal data processing: Marina Petrushina.

3. Purposes of processing personal data

The Operator processes personal data exclusively for the following purposes:

• Processing of requests and inquiries: review of incoming inquiries from Users, feedback, responses to questions submitted through the contact forms on the Website.
• Conclusion and performance of contracts: preparation and conclusion of partnership agreements, NDAs and service contracts with clinics, universities, technology and pharmaceutical companies.
• Recruitment: review of applications for open positions, assessment of professional skills, communication with candidates.
• Scientific research and development (R&D): use of strictly de-identified data for training AI models, conducting research and publishing aggregated results (in accordance with clause 2, part 1, article 6 of FL-152).
• Compliance with Russian legislation: fulfilment of obligations under tax, labor and other laws of the Russian Federation.

4. Categories of personal data processed

The Operator processes the following categories of personal data:

• last name, first name, patronymic;
• contact phone number;
• email address;
• data contained in contact forms (inquiry text, organization name, position);
• education and work experience details (for job applicants);
• technical data (IP address, cookies, browser and device information).

5. Legal grounds for processing

Personal data is processed on the basis of: the Constitution of the Russian Federation; the Labor Code of the Russian Federation; the Civil Code of the Russian Federation; Federal Law No. 152-FZ "On Personal Data"; the consent of the data subject (where obtained); and other federal laws and regulations.

6. Procedure and conditions of processing

6.1. Personal data is processed with and without the use of automation tools.

6.2. The Operator collects, records, systematizes, accumulates, stores, updates, extracts, uses, transfers, blocks, deletes and destroys personal data.

6.3. Disclosure to third parties: The Operator does not disclose personal data to third parties, except where necessary to perform the contract with the User or where required by the legislation of the Russian Federation.

6.4. Cross-border transfer: The Operator does not carry out cross-border transfers of personal data. All data is stored and processed on servers located on the territory of the Russian Federation in secure cloud infrastructures certified under FL-152 and FSTEC requirements (T1 Cloud, SberCloud, Yandex Cloud).

6.5. The processing period for personal data is until the purposes of processing are achieved or until the User withdraws their consent.

7. Rights of the data subject

The User has the right to:

• receive complete information about the processing of their personal data;
• request the correction, blocking or destruction of their personal data if it is incomplete, outdated, inaccurate or unlawfully obtained;
• withdraw their consent to the processing of personal data by sending a written notice to the Operator;
• appeal the actions or inaction of the Operator to the authorized body for the protection of data subjects' rights (Roskomnadzor) or in court.

To exercise their rights, the User may send a request to the following email: mar.petrushina@yandex.ru.

8. Security measures

The Operator takes the necessary and sufficient organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying and dissemination. The Company has implemented the following protection measures:

• data encryption in line with GOST and ISO 27001 standards;
• use of architectural solutions meeting FSTEC and FL-152 requirements;
• application of Federated Learning technologies (AI training without transferring raw personal data to central nodes);
• restricted staff access to personal data based on the principle of least privilege.

9. Use of cookies

9.1. The Website uses cookies to ensure proper operation, improve the user experience and collect technical statistics.

9.2. The User may disable cookies in their browser settings. However, this may affect the functionality of certain sections of the Website.

10. Changes to the policy

The Operator reserves the right to amend this Policy. The new version of the Policy takes effect from the moment it is posted on the Website, unless otherwise provided by the new version.

11. Contact information

All questions related to the processing of personal data, as well as requests to exercise data subject rights, should be sent to: