Consent to the Processing of Personal Data

This English text is a courtesy translation. The Russian-language version of
this document is the governing version and prevails in the event of any
discrepancy.

This Consent to the Processing of Personal Data (the "Consent") is given freely, by the personal-data subject's own will and in the subject's own interest, in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data", including Article 9 thereof.

The Consent is given by placing a mark (acceptance) in the Service interface during registration or use of the account. In accordance with Article 9(1) of Federal Law No. 152-FZ, this Consent is given in a form permitting confirmation of the fact of its receipt; that confirmation is the Operator's recording of the acceptance made by the subject.

1. Operator

The operator that obtains this Consent and carries out the processing of personal data is:

Hereinafter, the "Operator".

2. Personal-data subject

The personal-data subject is the natural person who has created an account and/or uses the Nash Lab service (the "Service") and has expressed this Consent. The subject is identified by their account data (the email address and name provided at registration).

3. Purposes of processing

The Operator processes personal data solely for the following purposes:

  1. providing access to the Service and delivering marketing-mix analytics

services (creating organisation workspaces, uploading and processing marketing and results datasets, building and displaying modelling results);

  1. managing the subject's account (registration, authentication, access

control, maintaining settings);

  1. providing technical support and communicating with the subject on matters

relating to use of the Service;

  1. operating and improving the website, determining user preferences and

providing targeted information about the Operator's services (web analytics).

4. Categories of personal data

Consent is given to the processing of the following personal data:

within the account);

data on the user's actions on the page — including a session recording made by the session-replay feature (Webvisor) of the metric programs, covering page views, pointer movement, scrolling and clicks — data on the user's device, and the date and time of the session.

The Operator does not request or process special categories of personal data or biometric personal data.

5. Actions with personal data and methods of processing

Consent is given to the following actions with personal data: collection, recording, systematisation, accumulation, storage, adjustment (updating, alteration), retrieval, use, blocking, deletion and destruction.

Personal data is processed both without the use of automation and with the use of automation (mixed processing). Data collected on the public marketing landing page is processed, among other means, using the metric programs Yandex Metrica and the Operator's own analytics. Personal data is not transferred (provided, made accessible) to third parties, except in cases provided for by the legislation of the Russian Federation, where processing is entrusted to a person acting on the Operator's instructions, and by transfer (provision, access) to the partners providing the service under the said metric programs — in each case provided that the requirements of Federal Law No. 152-FZ are complied with.

In accordance with Article 6(3) of Federal Law No. 152-FZ, this Consent is also given to the entrustment of the processing of personal data to a person acting on the Operator's instructions, on the basis of a contract concluded with that person. Such a person is obliged to observe the principles and rules for the processing of personal data laid down by Federal Law No. 152-FZ and may not process the personal data for its own purposes; the Operator is responsible to the personal-data subject for that person's acts. Transfers of personal data in the cases provided for by the legislation of the Russian Federation are made independently of this Consent.

Data that the subject uploads into their account (marketing and results datasets) and the modelling results built from it are processed solely for the purposes set out in items 1–3 of Section 3, that is, in order to provide the Service. Such data is not transmitted to the metric programs named above or to the partners providing the service under those programs: the metric programs operate only on the public marketing landing page and are not embedded in the account interface. Such data is not transferred to third parties for those third parties' own purposes and is not used for advertising. The foregoing does not affect the entrustment of processing to a person acting on the Operator's instructions, or transfers provided for by the legislation of the Russian Federation.

6. Term of the Consent and processing period

The Consent is valid from the day it is given until the day it is withdrawn by the personal-data subject.

Personal data is processed for the duration of the subject's use of the Service and shall be deleted (destroyed) no later than 3 (three) years after the purposes of processing have been achieved, the Consent has been withdrawn, or use of the Service has ceased (whichever occurs first), unless a longer storage period is required by the legislation of the Russian Federation.

7. Procedure for withdrawing the Consent

The personal-data subject may withdraw this Consent at any time by sending a written notice to the Operator at the email address info@probabilistic.ru, or to the Operator's registered office address specified in Section 1, or by using the corresponding function in the Service interface, where such a function is provided.

Upon withdrawal of the Consent, the Operator shall cease processing the personal data and destroy it within a period not exceeding 30 (thirty) days from the date the withdrawal is received, except where the processing and/or storage of the personal data must continue by virtue of the requirements of the legislation of the Russian Federation. Withdrawal of the Consent may make further provision of the Service impossible.

8. Rights of the personal-data subject

The personal-data subject has the rights provided for by Federal Law No. 152-FZ, including the right to obtain information about the processing of their personal data, the right to demand the adjustment, blocking or destruction of personal data, and the right to appeal the Operator's acts or omissions to the authorised body for the protection of the rights of personal-data subjects or through the courts.

9. Confirmation

By placing the acceptance mark, the personal-data subject confirms that they have read this Consent, that its content is clear to them, and that they express their consent to the processing of their personal data on the terms set out above.

10. Language of the document

This document is executed in Russian and English. In the event of any discrepancy between the Russian and English versions, the Russian version shall prevail and have governing legal force.