Privacy policy

This Personal Data Processing Policy (hereinafter — the Policy) has been developed in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter — Law No. 152-FZ) and defines the procedure for processing personal data, as well as the measures taken to protect it, applied with respect to users of the RegMedGrupp website (hereinafter — the Site).

1. General Provisions

1.1. The Policy applies to all information that the Site Administration may obtain about a user during the user's use of the Site and its services.

1.2. Use of the Site constitutes the user's unconditional consent to this Policy and to the conditions for processing the user's personal data set out herein.

1.3. Should the user disagree with the terms of the Policy, the user is obliged to cease using the Site.

1.4. This Policy applies only to the Site. The Administration does not control and is not responsible for the data processing carried out by third-party sites that the user may access via links posted on the Site.

2. Terms and Definitions

Personal data — any information relating, directly or indirectly, to a determined or determinable natural person (the personal data subject).

Processing of personal data — any action (operation) or set of actions performed on personal data, with or without the use of automation tools: collection, recording, systematization, accumulation, storage, clarification, retrieval, use, transfer, deletion, and destruction.

Confidentiality of personal data — a mandatory requirement not to allow the dissemination of personal data without the consent of the subject or another lawful ground.

User — a natural person who visits the Site, completes feedback forms, or otherwise interacts with the Site.

Site — a set of software, software-and-hardware, and technical resources accessible at network addresses, on which materials and information about the company's activities are posted.

Site Administration — the persons authorized by the Site owner to manage the Site and to organize the processing of personal data.

Cookie — a fragment of data sent by a web server and stored on the user's device, which the user's web client or browser sends back to the web server each time it attempts to open a page of the Site.

3. Principles of Personal Data Processing

3.1. Personal data is processed on a lawful and fair basis.

3.2. Processing is limited to the achievement of specific, predetermined, and lawful purposes. Processing that is incompatible with the purposes of collecting the personal data is not permitted.

3.3. It is not permitted to merge databases containing personal data that is processed for incompatible purposes.

3.4. Only personal data that corresponds to the purposes of its processing is processed.

3.5. During processing, the accuracy, sufficiency, and relevance of the data in relation to the purposes of processing are ensured.

3.6. Personal data is stored in a form that allows the subject to be identified for no longer than the purposes of processing require.

4. Composition of Personal Data and Purposes of Processing

4.1. Purposes of Personal Data Processing

• processing of requests and inquiries from users submitted via the Site's forms;
• provision of consulting services in the field of medical device registration;
• informing the user about the progress of service delivery, new services, and special offers;
• conducting statistical and analytical research, including on the basis of anonymized data, to improve the quality of the Site and its services;
• ensuring the security of the Site and detecting and preventing fraudulent activity and spam;
• compliance with the requirements of the legislation of the Russian Federation.

4.2. Categories of Processed Personal Data

Within the scope of the stated purposes, the following categories of data, provided voluntarily by the user, are processed:

• surname, first name, and patronymic (where voluntarily provided);
• contact telephone number;
• email address;
• name of the organization (where voluntarily provided);
• the content of the message left via the feedback form.

In addition, the following data is collected automatically:

• IP address;
• information from cookie files;
• information about the browser, operating system, and screen resolution;
• the address of the Site page on which the user submitted a request, and the address of the page from which the user navigated to the Site (HTTP Referer);
• UTM tags and other advertising campaign parameters;
• the date, time, and duration of the visit to the Site.

4.3. Special Categories of Personal Data

The Site Administration does not process special categories of personal data concerning racial or ethnic origin, political views, religious or philosophical beliefs, state of health, or intimate life, nor does it process biometric personal data.

5. Legal Grounds for Personal Data Processing

5.1. The legal grounds for processing personal data are:

• the subject's consent to the processing of their personal data, expressed when completing a form on the Site;
• the necessity of performing a contract concluded with the user at the user's initiative or on the basis of a public offer;
• the requirements of the legislation of the Russian Federation.

6. Procedure and Conditions for Personal Data Processing

6.1. Personal data is collected directly from the subject when completing forms on the Site, as well as automatically by technical means.

6.2. Personal data is processed using mixed (automated and non-automated) processing.

6.3. Personal data is transferred to third parties only in the following cases:

• with the explicit consent of the user;
• in the performance of a contract to which the user is a party;
• upon the lawful request of authorized state bodies;
• using web analytics services (Yandex.Metrica and similar), as well as anti-bot and CAPTCHA services — exclusively in anonymized form.

6.4. Cross-border transfer of personal data is not carried out. Databases containing the personal data of citizens of the Russian Federation are located on servers physically situated within the territory of the Russian Federation.

7. Storage Periods and Conditions for Termination of Processing

7.1. Personal data is stored for the period necessary to achieve the purposes of its processing, but for no more than 5 years from the date of the user's last interaction with the Site, unless otherwise provided by the legislation of the Russian Federation or by a contract.

7.2. The processing of personal data is terminated in the following cases:

• the purposes of processing have been achieved or the need to achieve them has been lost;
• the subject withdraws consent to processing;
• unlawful processing of data is identified;
• liquidation of the Site.

7.3. Upon expiry of the storage periods, personal data is destroyed or anonymized.

8. Rights of the Personal Data Subject

8.1. The personal data subject has the right to:

• obtain information about the fact, purposes, methods, and periods of the processing of their personal data;
• require the clarification, blocking, or destruction of their personal data where it is incomplete, inaccurate, or unlawfully processed;
• withdraw consent to the processing of personal data at any time by sending a corresponding request to the Administration's email;
• appeal the actions or inaction of the Administration to the authorized body for the protection of the rights of personal data subjects (Roskomnadzor) or through the courts.

9. Measures to Ensure the Security of Personal Data

9.1. The Site Administration takes the necessary organizational and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination, and other unlawful actions.

9.2. The measures applied include:

• encryption of the data transmission channel (HTTPS, TLS);
• differentiation of employee access to information systems;
• logging of the actions of users and administrators;
• regular backups;
• control of and protection against automated attacks (rate-limit, anti-bot, CAPTCHA);
• regular security audits.

10. Use of Cookie Files

10.1. The Site uses cookie files and similar technologies to ensure the operation of certain functions, to analyze visitor behavior, and to improve the usability of the Site.

10.2. A detailed description of the cookie files used is contained in the Cookie Policy posted on a separate page of the Site.

11. Procedure for Handling Requests and Inquiries

11.1. Requests, inquiries, and demands of personal data subjects concerning the processing of their data are sent to the Administration's email specified in the "Contact Information" section.

11.2. The period for processing a request is no more than 30 calendar days from the date of receipt, unless a different period is established by the legislation of the Russian Federation.

12. Amendments to the Policy

12.1. The Administration has the right to unilaterally amend this Policy. The new version of the Policy comes into force from the moment it is posted on the Site, unless otherwise provided by the new version of the Policy.

12.2. The current version of the Policy is always available at the address of this page.

13. Contact Information

13.1. All questions related to the processing of personal data, the withdrawal of consent, and the exercise of the subject's rights are to be sent to the following email address: info@regmedgrupp.ru.

13.2. It is recommended to indicate "Personal Data" in the subject line of the inquiry to expedite its review.