Draft — pending legal review. This English text is a working translation of the Russian original, which is based on Russian data-protection law (No. 152-FZ). For an EN/EU-facing service the applicable data-protection regime (e.g. GDPR) differs and this document must be adapted by qualified counsel before it is relied upon.
This Privacy Policy (hereinafter, the “Policy”) defines the procedure for collecting, processing, using, storing and transferring the data of Users of the Smart Longevity service (the smartlongevity.com website and all of its sections, hereinafter, the “Service”). The data processing operator is the administration of the Smart Longevity Service (hereinafter, the “Operator”).
The Policy has been developed in accordance with Russian Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”. By using the Service, completing registration and/or checking the consent box, the User freely, by their own will and in their own interest gives the Operator consent to the processing of their data on the terms of this Policy.
1. What data we collect
1.0. The Operator does not require and does not collect a real name (surname, given name, patronymic) or other identity documents. The User is identified by their email address and the pseudonym (@handle) chosen by the User. The Operator adheres to the principle of minimization and, where possible, processes data in a depersonalized and aggregated form. At the same time, certain collected data (for example, email address, IP address, identifiers, pseudonym, entered indicators) may constitute personal data and are processed on the terms of this Policy and in accordance with No. 152-FZ.
The Operator is entitled to collect and process, in particular:
1.1. Registration data: email address, name/pseudonym, gender, handle (@handle), city, password (in encrypted form).
1.2. Profile and community data: biography, interests, goals, expertise, links to social networks and other information provided by the User.
1.3. Data entered into calculators and tools (including anthropometric, laboratory and other indicators that the User enters voluntarily), as well as calculation results and saved results.
1.4. Usage data: actions within the Service, views, reactions, history of tool runs, bookmarks, support requests.
1.5. Technical data: IP address, device and browser type, identifiers, cookie data and similar technologies, approximate location.
1.6. Other data that the User provides or that is generated when using the Service.
2. Processing purposes
The Operator processes data for the following purposes (including simultaneously):
2.1. Providing, operating, supporting and developing the Service; registering and identifying the User.
2.2. Personalization of content and recommendations; analytics, statistics and improvement of the Service.
2.3. Marketing, advertising, promotion (including mailings and targeting), effectiveness measurement.
2.4. Research, scientific and commercial purposes, including the creation, use and monetization of depersonalized and aggregated data.
2.5. Ensuring security, preventing abuse, complying with legal requirements.
2.6. Other purposes not contrary to law that are covered by the User’s consent.
3. Legal grounds and consent
3.1. Processing is carried out on the basis of the User’s consent (including consent given during registration), as well as on other grounds provided for by law (performance of a contract, legitimate interests of the Operator).
3.2. Consent is given for processing by both automated and non-automated means, including the collection, recording, systematization, accumulation, storage, updating, use, transfer (including cross-border transfer), depersonalization, blocking, deletion and destruction of data.
3.3. The User consents to the transfer of their data to third parties and to cross-border transfer on the terms of Section 4.
4. Transfer of data to third parties
4.1. The Operator is entitled to transfer the User’s data to: affiliates and partners; service providers and contractors (hosting, analytics, mailings, payments, advertising); advertising and marketing partners; legal successors in the event of reorganization, sale or transfer of the business; government authorities in cases provided for by law.
4.2. The Operator is entitled to use, disclose, transfer and sell depersonalized and aggregated data (which do not allow the User to be directly identified) to any third parties without restriction and without additional consent — to the maximum extent permitted by applicable law.
4.3. The User consents to such transfer, including transfer within the territory of foreign states.
5. Cookies and similar technologies
The Service uses cookies and similar technologies for operation, analytics, personalization and advertising. By continuing to use the Service, the User agrees to their use. Disabling cookies may limit the operation of the Service.
6. Data storage and protection
6.1. The Operator stores data for as long as is necessary for the processing purposes, and depersonalized and aggregated data — for an unlimited period.
6.2. The Operator takes reasonable organizational and technical measures to protect data; however, it does not guarantee absolute security and is not liable for unauthorized access that occurs through no fault of its own, to the maximum extent permitted by applicable law.
7. Rights of the personal data subject
7.1. The User has the rights provided for by No. 152-FZ, including the right to obtain information about the processing of their data, to have it updated, blocked or deleted, and the right to withdraw consent by sending a request to info@smartlongevity.com.
7.2. Withdrawal of consent or deletion of data does not apply to processing carried out before the moment of withdrawal, to depersonalized and aggregated data, or to data whose processing is necessary by virtue of law or the legitimate interests of the Operator. After consent is withdrawn, the Operator is entitled to cease providing the Service to the User.
8. Minors
The Service is intended for persons over the age of 18. The Operator does not intentionally collect data of persons under the age of 18.
9. Amendments to the Policy
The Operator is entitled to amend this Policy unilaterally at any time. The new version takes effect from the moment it is posted on the Site. The User is obliged to monitor changes independently; continued use of the Service constitutes agreement with the new version.
10. Contacts
For questions regarding data processing: info@smartlongevity.com. This Policy is an integral part of the Terms of Service.