Personal Data Processing Policy

Full version: BIOCAD JSC Personal Data Processing Policy.

1. About BIOCAD JSC

1.1 Joint Stock Company BIOCAD (TIN (INN) 5024048000, PSRN (OGRN) 1025002867196; address: 198515, St. Petersburg, intra-city municipal territory Strelna settlement, ul. Svyazi, 38, bldg. 1, premises 89), hereinafter also “BIOCAD JSC”/the “Operator”/the “Company”.

1.2 BIOCAD JSC is a personal data operator entered in the Roskomnadzor register of operators.

1.3 The Company adheres to the principles of lawfulness, fairness and confidentiality when processing personal data and ensures the security of its processing operations.

2. General Provisions

2.1 This Policy on the processing and protection of personal data (hereinafter, the “Policy”) has been developed to comply with the legislation of the Russian Federation on the processing and security of personal data.

2.2 The Policy has been drafted taking into account the legislation of the Russian Federation and the internal documents of BIOCAD JSC.

2.3 The Policy is a publicly available document and is published on the official website of BIOCAD JSC at: https://biocad.ru/user-agreement/politika_kompanii

2.4 If other websites (other than this one) refer to this Policy or its Full version, this means that they also comply with the BIOCAD JSC Personal Data Processing Policy.

1.5 This document is subject to unilateral revision and amendment. The date of the current version is indicated at the top of the page below the title.

3. Purposes of Processing, Categories of Personal Data and Categories of Personal Data Subjects

3.1 Personal data are processed with or without the use of automation tools.

3.2 The Operator processes special categories of personal data concerning the health of the personal data subject for the purposes of preventing and hindering the spread of infectious diseases and complying with the occupational safety and labor legislation of the Russian Federation.

3.3 The Operator does not process biometric personal data (information characterizing a person’s physiological and biological features on the basis of which their identity can be established).

3.4 The main purposes of processing and the categories of subjects whose data may be processed when using the website https://ct.biocad.ru/ are set out in the table below. The complete list is available both in the Full version of the Policy and in the Roskomnadzor register.

Purposes of personal data processing

Categories of personal data subjects

registering and responding to requests/inquiries sent to the Operator by personal data subjects

legal representatives; individuals sending inquiries to the Operator.

publishing scientific articles and other information mailings

employees, event participants, event speakers.

cross-border transfer of personal data

personal data subjects who have consented to the cross-border transfer of personal data.

recruiting personnel (job applicants) for the Operator’s vacancies

students of educational institutions; candidates (applicants) for vacant positions; candidates (applicants) for vacant positions in affiliated companies of BIOCAD JSC.

promoting goods, works and services on the market

patients, physicians, staff of educational institutions, event participants.

organizing the subject’s voluntary participation in internal and public events unrelated to employment, as well as in charity events

employees, event participants.

organizing and conducting scientific research, including clinical trials involving personal data subjects

legal representatives, physicians, students of educational institutions, staff of educational institutions.

4. Processing of Personal Data

4.1 BIOCAD JSC uses only the data whose processing you have consented to.

4.2 BIOCAD JSC uses your data solely for the purposes specified in the consent.

4.3 Personal data may be processed without Consent only:

4.3.1 for the performance of a contract under which you are a beneficiary or guarantor;

4.3.2 to protect your life, health or other vital interests where obtaining consent is impossible;

4.3.3 for statistical or other research purposes, subject to mandatory anonymization;

4.3.4 where the data are subject to publication or mandatory disclosure under applicable federal law;

4.3.5 in other cases provided for by Article 6 of Federal Law No. 152-FZ “On Personal Data”.

5. Personal Data Security Measures

5.1 The security of personal data processed by the Operator is ensured through the implementation of legal, organizational and technical measures.

5.2 All employees of the Company comply with the Policy.

5.3 Personal data are processed on a lawful and fair basis.

5.4 The Company has appointed a Responsible Person who supervises the organization of personal data processing.

5.5 Internal control over personal data processing is carried out in accordance with the legislation of the Russian Federation, and the Operator’s internal documents have been adopted in accordance therewith.

5.6 The necessary legal, organizational and technical measures are taken to protect data against unlawful or accidental access, destruction, modification, blocking, copying, provision and dissemination, as well as against other unlawful actions in respect of personal data.

6.7 The processing of personal data is limited to the achievement of specific, predetermined and lawful purposes. Processing of personal data incompatible with the purposes of its collection is not permitted.

5.8 Combining databases containing personal data processed for mutually incompatible purposes is not permitted.

6. Your Rights

6.1 The Company complies with the legislation on the processing and protection of personal data and fully respects your rights, which are described in detail in Federal Law No. 152-FZ “On Personal Data”.

6.1 Your personal data cease to be processed once the purposes of processing have been achieved, the consent has expired, or the consent to the processing of personal data has been withdrawn.

6.2 Upon your request, the Company is obliged to provide information concerning the processing of your personal data.

6.3 You may at any time access your personal data, have it rectified, request its deletion, object to its processing and demand that the processing of your data be restricted.

6.4 Your personal data are not disclosed to third parties or disseminated without a proper legal basis, unless otherwise provided by law.

6.5 You may exercise the protection of your rights either personally or through a representative.

6.7 You may at any time withdraw your Consent or contact us on matters relating to the processing of your personal data by sending an email to [email protected] or by registered mail with a list of enclosures to the registered address of BIOCAD JSC: 198515, St. Petersburg, intra-city municipal territory Strelna settlement, ul. Svyazi, 38, bldg. 1, premises 89 (in Russian: 198515, г. Санкт-Петербург, вн. тер. г. поселок Стрельна, ул. Связи, д. 38, стр. 1, помещ. 89).