Personal Data Processing Policy

Version No. 1 dated December 03, 2020

1. General Provisions

This Personal Data Processing Policy (hereinafter, the Policy) is established in accordance with Federal Law No. 152-FZ On Personal Data of July 27, 2006, and determines the procedure for processing personal data and measures to ensure the security of personal data on the website https://dsight.ru/ owned (and/or administered) by Dsight Limited Liability Company (INN 9731043077, KPP 773101001, OGRN 1197746350450) located at: 7, Nobelya St., Floor 1, Office 147, Room 2, territory of Skolkovo Innovation Center, Moscow 121205, Russian Federation (hereinafter, the Operator).

1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to personal and family privacy.

1.2. This Operator's Policy regarding the personal data processing applies to all information that the Operator can obtain about visitors to the Operator's website https://dsight.ru/ and/or other Internet resources of the Operator.

2. Basic concepts used in the Policy

2.1. Automated processing of personal data means processing of personal data using computer technology;

2.2. Blocking of personal data means temporary termination of personal data processing (except where processing is necessary to adjust personal data);

2.3. Website means a set of graphic and information materials, as well as computer programs and databases ensuring their availability on the Internet at the network address https://dsight.ru/, including the Operator's Venture Market Database;

2.3.1. Operator's Internet resources mean a set of Internet resources owned and/or administered by the Operator (on its behalf), including the website https://dsight.ru/, the Venture Market Database, pages/accounts in social networks, as well as a mobile application (if any) and any electronic mailboxes of the Company, the addresses of which are stated on the Internet resources owned and/or administered by the Operator (on its behalf);

2.4. Personal data information system means a set of personal data contained in databases and information technologies and technical means providing their processing;

2.5. Depersonalization of personal data means actions that render personal data affiliation to the specific User or another personal data subject impossible without using additional information;

2.6. Personal data processing means any action (operation) or a set of actions (operations) regarding personal data performed with or without automation tools, including collection, recording, systematization, accumulation, storage, adjusting, extraction, use, transfer, depersonalization, blocking, deletion, destruction of personal data and other actions necessary for the fulfillment of the Agreement.

2.7. Operator means a state body, a municipal body, a legal entity or an individual, independently or jointly with other parties organizing and/or carrying out the personal data processing, as well as determining the purposes of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data; in the context of this Policy, the Operator is Dsight LLC;

2.8. Personal data means any information relating directly or indirectly to a specific or identifiable subject of personal data – a User of the Website and/or other Internet resources of the Operator, in particular, listed in par. 3 of the Policy below;

2.9. User means any visitor to the Website and/or other Internet resources of the Operator, the subject of personal data, including, without limitation, (representatives) of the Operator's customers interested in receiving the services of the latter;

2.10. Personal data provision means actions aimed at disclosing personal data to a certain party or a certain scope of parties;

2.11. Dissemination of personal data means any actions aimed at disclosing personal data to public at large (transfer of personal data) or at review of personal data by public at large, including the disclosure of personal data in the media, posting on information and telecommunication networks or granting access to personal data in any other manner;

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

2.13. Destruction of personal data means any actions, whereby personal data is destroyed irrevocably with the impossibility of further restoring the content of personal data in the personal data information system and/or whereby material carriers of personal data are destroyed.

3. The Operator can process the following Personal Data of Users:

• Surname, name, patronymic;
• Contact details (phone numbers, e-mail, etc.);
• Employer, business unit, position;
• Account information when using the Operator's Internet resources (passwords, logins);
• Short CV, dates of birth and death;
• INN (Taxpayer Identification Number);
• Profile photo;
• Education details (university, college, start and graduation dates);
• Academic degree and area of academic degree;
• Information other than special categories and biometric personal data, which is collected, including without limitation, by uploading/sending, collection by the User of such information independently through the Internet resources of the Operator, is collected from public domain and/or may be required for the purposes stated in par. 4 below.

3.1. The User understands and agrees that the Operator processes only the data that it has taken from public domain and/or received directly from the User.

3.2. The Operator can also process depersonalized data about Users (including cookies) using Internet statistics services (Yandex Metrica, Google Analytics, etc.) to collect information about the actions of Users on the Website and/or other Internet resources of the Operator, improving their quality and content.

3.3. The User understands and agrees that the Operator can use cookies and other similar technologies to help the User navigate the Website and/or other Internet resources of the Operator, as well as provide the User with the best user practices, analyze the use of the Operator's products and services, improve the quality of the Operator's advertising and marketing activities.

4. Users' Personal Data can be processed by the Operator for the following purposes:

• Provision of the Operator's services to Users and the use of the Operator's Internet resources by Users, (technical) support for Users, training, adjustment of the operation details and characteristics of the Operator's products, etc.;
• Continuous maintenance, provisioning, and other improvement of the quality of the Operator's Venture Market Database;
• Attaining the Operator's business goals, maintaining the Operator's reputation, promoting the Operator, collecting statistics for marketing purposes, advertising (news) mailing (informing about new partners of the Operator, about partner programs, services);
• Ensuring the safety of Users of the Operator's Internet resources;
• Other goals determined proceeding from statutory provisions of applicable laws and other regulatory legal acts of the Russian Federation, local acts of the Operator.

4.1. The User understands and agrees that the Operator has the right to send the User notices about new products and services, special offers and various events. The User can always refuse to receive informational messages by sending the Operator a written application to the mailing address of the Operator at 7, Nobelya St., Floor 1, Office 147, Room 2, territory of Skolkovo Innovation Center, Moscow 121205, or a scanned copy of the corresponding written application to e-mail hi@dsight.ru marked "Waiver of notices about new products and services and special offers", stating in such an application the surname, name, patronymic, signing it with own hand and making certain of the receipt by the Operator of the application (in particular, using the options "delivery receipt" / "read receipt"). If the Operator needs any additional information and/or a differently executed application, it will inform the User thereof within 7 days upon receipt of the said application.

4.2. Depersonalized data of Users collected using Internet statistics services are used to collect information about the actions of Users on the Website and/or other Internet resources of the Operator, to improve the quality of the Website and/or other Internet resources of the Operator.

5. Legal basis for Personal Data processing

5.1. The Operator processes the User's Personal Data only if it is filled in, uploaded, generated and/or otherwise sent by the User independently (including through special forms) located on the Website and/or other Internet resources of the Operator.

5.2. The Operator processes depersonalized data about the User, where enabled in the settings of the User's browser (the storage of cookies and the use of JavaScript technology are enabled).

5.3. The User understands and agrees that the use of the Website and/or other Internet resources of the Operator, including the provision of Personal Data through the Website and/or other Internet resources of the Operator, is allowed only by a fully capable person, or by a legal representative of an incapacitated person. In the event that the Operator becomes aware of a violation of this provision, the Operator may restrict the User's access to the Website and/or other Internet resources of the Operator until the violation is rectified.

5.4. The User's Personal Data can be processed by the Operator using the Website and/or other Internet resources of the Operator in strict accordance with the applicable laws of the Russian Federation on personal data, as well as this Policy.

6. Procedure for collecting, storing, transferring and other types of processing of Personal Data

6.1. The Operator processes Personal Data by taking actions and methods in accordance with par. 2.6 of the Policy above.

6.2. Confidentiality and security of Personal Data processed by the Operator is ensured through the implementation of legal, management and technical measures essential to fully comply with the current legislation of the Russian Federation in the field of personal data protection.

6.3. The Operator ensures the security of Personal Data and takes all possible measures to prevent unauthorized persons from accessing Personal Data.

6.4. The User's Personal Data will in no event be transferred to third parties (including cross-border transfer and/or as part of an order for Personal Data processing), except for cases related to the implementation of the current laws of the Russian Federation and/or the provisions of this Policy (in particular, par. 7 below).

6.5. In the event of any identified inaccuracies in Personal Data, the User can update them independently by updating his/her profile in the Operator's Venture Market Database or sending the Operator a corresponding written notice to the Operator's mailing address at 7, Nobelya St., Floor 1, Office 147, Room 2, territory of Skolkovo Innovation Center, Moscow 121205, or a scanned copy of the corresponding written notice to e-mail hi@dsight.ru marked “Updating of personal data", stating in such a notice the surname, name, patronymic, signing it with own hand and making certain of the receipt by the Operator of the notice (in particular, using the options "delivery receipt" / "read receipt"). If the Operator needs any additional information and/or a differently executed notice, it will inform the User thereof within 7 days upon receipt of the said notice.

6.6. The period of Personal Data processing depends on the purpose of processing / terms of the agreement with the User or the provisions of the applicable laws of the Russian Federation.

6.7. The User can at any time withdraw his/her consent to Personal Data processing by sending the Operator a written notice to the Operator's mailing address at 7, Nobelya St., Floor 1, Office 147, Room 2, territory of Skolkovo Innovation Center, Moscow 121205, or a scanned copy of the corresponding written notice to e-mail hi@dsight.ru marked "Waiver of consent to personal data processing", stating in such a notice the surname, name, patronymic, signing it with own hand and making certain of the receipt by the Operator of the notice (in particular, using the options "delivery receipt" / "read receipt"). If the Operator needs any additional information and/or a differently executed notice, it will inform the User thereof within 7 days upon receipt of the said notice. If the User withdraws his/her consent to Personal Data processing, the Operator shall discontinue processing the data or ensure the termination of such processing (if the processing is carried out by another party acting on behalf of the Operator) and, if the retention of Personal Data is no longer required for Personal Data processing, destroy the Personal Data or ensure its destruction within a period not exceeding 30 days from the date of receipt of the said withdrawal, unless otherwise provided for by the applicable laws of the Russian Federation. The User understands and agrees that the consequence of his/her withdrawal of consent to Personal Data processing may, among other things, be the termination of his/her access to the Website and/or other Internet resources of the Operator.

7. Cross-border transfer of Personal Data

7.1. The Operator, prior to the cross-border transfer of Personal Data, shall make sure that the foreign state where to the Personal Data is supposed to be transferred provides reliable protection of the rights of personal data subjects (Users of the Website and/or other Internet resources of the Operator).

7.2. The User understands and agrees that solely for the purposes of normal use by the User of the Website and/or other Internet resources of the Operator and the purposes in accordance with par. 4 above, the Operator may carry out, among other things, cross-border transfer of Personal Data to the countries where its employees, affiliates, clients and contractors, other partners, and contractors are located. These countries may or may not provide adequate protection of the rights of personal data subjects (Users) – solely on the basis, in the manner and pursuant to the applicable laws of the Russian Federation, this Policy and/or an agreement with the User.

7.3. Among other things, the User understands and agrees that for the purpose of continuous maintenance, provisioning, and other improvements in the quality of the Operator's Venture Market Database, this Database may be available to Users of different countries worldwide, including countries that do not provide adequate protection of the rights of personal data subjects.

8. Final provisions

8.1. The User can receive any explanations on issues of interest regarding the processing of his/her Personal Data by contacting the Operator by e-mail at hi@dsight.ru, stating in such a request his/her surname, name, patronymic and contact details (phone number, e-mail), and making certain of the receipt by the Operator of the request (in particular, using the options "delivery receipt" / "read receipt"). If the Operator needs any additional information and/or a differently executed request, it will inform the User thereof within 7 days upon receipt of the said request.

8.2. By using (continuing to use) the Website and/or other Internet resources of the Operator, filling out the appropriate forms, uploading, generating and/or otherwise sending Personal Data to the Operator through the Website and/or other Internet resources of the Operator, the User agrees with this Policy, including all updates and changes thereto.

8.3. The current version of the Policy is freely available on the Internet at https://dsight.ru/privacy/. The User undertakes to regularly check changes to the Policy that apply to him/her from the date of their publication at the aforesaid address.