Personal data processing Policy
This Personal Data Processing Policy (hereinafter referred to as the "Policy") applies to all personal data that Limited Liability Company "RITM" (LLC "RITM"; TIN 9 731 011 702; KPP 773 101 001; OGRN 1 187 746 843 811; Legal address: 121 205, Moscow, intracity territory of the municipal district Mozhayskiy, territory of the Skolkovo Innovation Center, Bolshoy Boulevard, building 42, structure 1, floor/room/workplace 4/1592/9; hereinafter referred to as "RITM") may receive from the User while the User uses the website located on the Internet at https://start.engee.com/ (hereinafter referred to as the "Website") and/or during other interaction between the User and "RITM".
This Policy is mandatory for review and compliance by all persons admitted to the processing of personal data at "RITM", as well as by persons involved in organizing the processing and ensuring the security of personal data at "RITM".
This Policy is mandatory for review and compliance by all persons admitted to the processing of personal data at "RITM", as well as by persons involved in organizing the processing and ensuring the security of personal data at "RITM".
Key terms used in this Policy
- Personal Data — any information relating directly or indirectly to an identified or identifiable individual (the personal data subject).
- Personal Data Operator (Operator) — a person who independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data (“RITM”).
- Processing of Personal Data — any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools. Processing includes, but is not limited to: collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, destruction.
- Automated Processing of Personal Data — processing of personal data using computer technology.
- Provision of Personal Data — actions aimed at disclosure of personal data to a specific person or a specific group of persons.
- Blocking of Personal Data — temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).
- Destruction of Personal Data — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and/or as a result of which material media containing personal data are destroyed.
- Anonymization of Personal Data — actions as a result of which it becomes impossible, without the use of additional information, to determine the принадлежность of personal data to a specific personal data subject.
- Personal Data Information System — a set of personal data contained in databases and information technologies and technical means ensuring their processing.
- Cross-Border Transfer of Personal Data — transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual, or foreign legal entity.
This Policy applies to all processes of collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), blocking, deletion, and destruction of personal data carried out using automation tools.
"RITM" processes personal data in compliance with the principles, norms, requirements, and rules established by Federal Law of the Russian Federation No. 152-FZ dated July 27, 2006 "On Personal Data".
"RITM" does not control and is not responsible for third-party websites to which the User may navigate via links available on the Website. Third-party websites may have their own privacy policies and may collect or request other personal data from the User.
This Policy explains how "RITM" processes and protects personal data and other user information.
By using the Website and providing "RITM" with information necessary to initiate further interaction, you consent to its use in accordance with this Policy.
For specific Services, "RITM" may publish provisions supplementing this Policy.
This Policy is subject to update in the event of changes in the legislation of the Russian Federation on personal data.
"RITM" processes personal data in compliance with the principles, norms, requirements, and rules established by Federal Law of the Russian Federation No. 152-FZ dated July 27, 2006 "On Personal Data".
"RITM" does not control and is not responsible for third-party websites to which the User may navigate via links available on the Website. Third-party websites may have their own privacy policies and may collect or request other personal data from the User.
This Policy explains how "RITM" processes and protects personal data and other user information.
By using the Website and providing "RITM" with information necessary to initiate further interaction, you consent to its use in accordance with this Policy.
For specific Services, "RITM" may publish provisions supplementing this Policy.
This Policy is subject to update in the event of changes in the legislation of the Russian Federation on personal data.
1. Personal data of users processed by "RITM"
1.1. For the purposes of this Policy, "user personal data" shall mean:
— personal data that the user provides about themselves independently when registering (creating an account) on the Website;
— for registered users of the Website — individuals who have successfully completed registration on the Website: last name, first name, patronymic, contact phone number, organization details, job title, email address, information about country, city, and region of residence;
— for individuals and/or legal entities in contractual relations with "RITM": last name, first name, patronymic, job title in the organization with indication of the organization name, email address, contact phone number.
1.2. Personal data provided to "RITM" may be considered inaccurate and may be blocked until consent to personal data processing is obtained from the user or their legal representative in any additional form specified by "RITM", other than that provided on the Website.
1.3. "RITM" does not make decisions producing legal consequences for users or otherwise affecting their rights and legitimate interests solely on the basis of automated personal data processing.
— personal data that the user provides about themselves independently when registering (creating an account) on the Website;
— for registered users of the Website — individuals who have successfully completed registration on the Website: last name, first name, patronymic, contact phone number, organization details, job title, email address, information about country, city, and region of residence;
— for individuals and/or legal entities in contractual relations with "RITM": last name, first name, patronymic, job title in the organization with indication of the organization name, email address, contact phone number.
1.2. Personal data provided to "RITM" may be considered inaccurate and may be blocked until consent to personal data processing is obtained from the user or their legal representative in any additional form specified by "RITM", other than that provided on the Website.
1.3. "RITM" does not make decisions producing legal consequences for users or otherwise affecting their rights and legitimate interests solely on the basis of automated personal data processing.
2. Purposes of personal data processing
The right holder grants the User who accepts the terms of this Agreement the right to use the computer program "Engee Modeling and Technical Computing Environment" under a simple (non-exclusive) license with the following scope of rights: launching and evaluating the functionality of Engee.
2.1. "RITM" processes only those personal data that are necessary for interaction with the User and for the provision and improvement of the quality of services.
2.2. "RITM" may use the user’s personal data for the purpose of fulfilling obligations under orders, requests, notifications, contracts, and other obligations accepted by "RITM" as binding towards the user. Within this purpose, "RITM" carries out actions aimed at:
2.2.1. identification of the party within the use of the Website;
2.2.2. provision of personalized services to the user, if provided by the user account;
2.2.3. improvement of service quality and development of new services;
2.2.4. conducting statistical and other research based on anonymized data;
2.2.5. registration of software usage rights in the name of the user or organization represented by the user, subject to a relevant agreement;
2.2.6. providing Website users with secure and convenient functionality and effective display of information;
2.2.7. proper fulfillment of contracts and other obligations undertaken by "RITM";
2.2.8. processing user inquiries;
2.2.9. registration of users for events;
2.2.10. performance of functions, powers, and duties imposed on "RITM" by Russian legislation;
2.2.11. collection of data for marketing purposes (contact via email or phone, newsletters, event registration).
2.2. "RITM" may use the user’s personal data for the purpose of fulfilling obligations under orders, requests, notifications, contracts, and other obligations accepted by "RITM" as binding towards the user. Within this purpose, "RITM" carries out actions aimed at:
2.2.1. identification of the party within the use of the Website;
2.2.2. provision of personalized services to the user, if provided by the user account;
2.2.3. improvement of service quality and development of new services;
2.2.4. conducting statistical and other research based on anonymized data;
2.2.5. registration of software usage rights in the name of the user or organization represented by the user, subject to a relevant agreement;
2.2.6. providing Website users with secure and convenient functionality and effective display of information;
2.2.7. proper fulfillment of contracts and other obligations undertaken by "RITM";
2.2.8. processing user inquiries;
2.2.9. registration of users for events;
2.2.10. performance of functions, powers, and duties imposed on "RITM" by Russian legislation;
2.2.11. collection of data for marketing purposes (contact via email or phone, newsletters, event registration).
3. Legal grounds for personal data processing
— Articles 23 and 24 of the Constitution of the Russian Federation;
— Article 90 of the Labor Code of the Russian Federation;
— Federal Law No. 152-FZ "On Personal Data";
— Charter and constituent documents of "RITM";
— User consent to personal data processing;
— Internal regulatory and administrative documents of "RITM".
— Article 90 of the Labor Code of the Russian Federation;
— Federal Law No. 152-FZ "On Personal Data";
— Charter and constituent documents of "RITM";
— User consent to personal data processing;
— Internal regulatory and administrative documents of "RITM".
4. Transfer of personal data to third parties
4.1. User personal data remain confidential, except where unrestricted access is granted by the user or at their request.
4.2. "RITM" may transfer personal data to third parties if:
4.2.1. the user has given consent;
4.2.2. such transfer is required by law.
4.3. For fulfillment of contractual obligations, "RITM" may carry out cross-border transfer of personal data.
4.4. Data recipients include service providers acting on behalf of "RITM" (technical, marketing, software support), independent third parties (auditors, lawyers, authorities), or recipients determined by user actions.
4.2. "RITM" may transfer personal data to third parties if:
4.2.1. the user has given consent;
4.2.2. such transfer is required by law.
4.3. For fulfillment of contractual obligations, "RITM" may carry out cross-border transfer of personal data.
4.4. Data recipients include service providers acting on behalf of "RITM" (technical, marketing, software support), independent third parties (auditors, lawyers, authorities), or recipients determined by user actions.
5. Personal data protection measures
5.1. "RITM" implements legal, organizational, and technical measures, including:
5.1.1. appointment of a responsible person;
5.1.2. adoption of local regulations;
5.1.3. access control rules;
5.1.4. logging of data processing actions;
5.1.5. backup and recovery procedures
5.1.1. appointment of a responsible person;
5.1.2. adoption of local regulations;
5.1.3. access control rules;
5.1.4. logging of data processing actions;
5.1.5. backup and recovery procedures
6. User rights and obligations
6.1. Users are responsible for accuracy of provided data.
6.2. Users may update their personal data.
6.3. Users may withdraw consent by written notice, which entails deletion of the account and data.
6.4. Users may request deletion of inaccurate or unnecessary data.
6.5. Users may request information about personal data processing.
6.6. Users may unsubscribe from marketing communications.
6.7. "RITM" may request identity verification.
6.8. Personal data shall be destroyed upon achievement of processing purposes.
6.2. Users may update their personal data.
6.3. Users may withdraw consent by written notice, which entails deletion of the account and data.
6.4. Users may request deletion of inaccurate or unnecessary data.
6.5. Users may request information about personal data processing.
6.6. Users may unsubscribe from marketing communications.
6.7. "RITM" may request identity verification.
6.8. Personal data shall be destroyed upon achievement of processing purposes.
7. Contact information
Questions and proposals shall be sent to info@engee.com or by mail to the legal address of "RITM".
8. Personal data retention period
"RITM" stores data collected for the fulfillment of obligations on the part of "RITM" in providing services to Users for the entire period required to fulfill such obligations, but not longer than two (2) years from the date of the last interaction with the data, except in cases where there is a valid contract, court proceedings, or a legislative requirement allowing further processing of the User’s personal data, of which the User shall be notified.
"RITM" stores data collected for marketing purposes (for contacts using email or phone to offer services, distribute newsletters, or register for events) for the entire period required to provide information to the User in accordance with their subscription, but not longer than two (2) years from the date of the last interaction with the data, except in cases where there is a valid contract, court proceedings, or a legislative requirement allowing further processing of the User’s personal data, of which the User shall be notified.
"RITM" stores User data collected via web forms for the purpose of registration for events for the entire period required to fulfill the processing purpose, but not longer than two (2) years from the date of the last registration.
"RITM" stores User data obtained through direct contact via email, phone, or mail (provision of personalized services) for the entire period required to fulfill the processing purpose, but not longer than two (2) years from the date of the last interaction with the data, except in cases where there is a valid contract, court proceedings, or a legislative requirement allowing further processing of the User’s personal data, of which the User shall be notified.
"RITM" may continue to store the User’s personal data where there is an obligation arising from a legislative requirement, to protect the vital interests of the User, or to protect the vital interests of another natural person.
Collection of data using cookies and similar technologies is carried out in accordance with the Cookie Policy.
A longer personal data retention period shall be established by applicable legislation.
Effective date of this Policy: January 16, 2023.
"RITM" stores data collected for marketing purposes (for contacts using email or phone to offer services, distribute newsletters, or register for events) for the entire period required to provide information to the User in accordance with their subscription, but not longer than two (2) years from the date of the last interaction with the data, except in cases where there is a valid contract, court proceedings, or a legislative requirement allowing further processing of the User’s personal data, of which the User shall be notified.
"RITM" stores User data collected via web forms for the purpose of registration for events for the entire period required to fulfill the processing purpose, but not longer than two (2) years from the date of the last registration.
"RITM" stores User data obtained through direct contact via email, phone, or mail (provision of personalized services) for the entire period required to fulfill the processing purpose, but not longer than two (2) years from the date of the last interaction with the data, except in cases where there is a valid contract, court proceedings, or a legislative requirement allowing further processing of the User’s personal data, of which the User shall be notified.
"RITM" may continue to store the User’s personal data where there is an obligation arising from a legislative requirement, to protect the vital interests of the User, or to protect the vital interests of another natural person.
Collection of data using cookies and similar technologies is carried out in accordance with the Cookie Policy.
A longer personal data retention period shall be established by applicable legislation.
Effective date of this Policy: January 16, 2023.