Personal Data Processing Policy

This Personal Data Processing Policy (the “Policy”) applies to all information that the NEO DIGITAL website (https://neo-digital.ceo) (the “Website”) may receive about a visitor while they use the Website, including the request form and the AI chat.

The Policy has been drawn up in accordance with Federal Law No. 152-FZ “On Personal Data” of 27 July 2006 (“152-FZ”).

The personal data operator is ИП Коневец Артём Владимирович (the “Operator”), INN (taxpayer ID) 221004258530, OGRN/OGRNIP (state registration number) 323220200109529.

The Policy applies to the personal data of the following categories of data subjects:

• Website visitors who use the AI chat;
• people who have submitted a request through the form on the Website (prospective and current clients).

The Operator may process the following data:

• name;
• phone number;
• email address;
• Telegram username, if the data subject has provided it as a contact method;
• the content of messages sent through the request form and the Website’s AI chat;
• technical data: IP address, browser and device data (user agent), and data that the Website stores in the visitor’s browser storage (sessionStorage and localStorage) for the interface to work (for example, the AI chat message history within the current session and a record of the consent given to personal data processing).

As of this edition of the Policy, the Website does not use analytics or advertising cookies and does not track visitors for marketing purposes. If this changes, the Policy will be updated and a corresponding notice will appear on the Website.

• handling requests and inquiries received through the form on the Website and through the AI chat;
• consulting on the Operator’s services;
• preparing, concluding and performing contracts with the data subject;
• ensuring the operation, functionality and security of the Website.

Personal data is processed on the basis of the data subject’s consent to the processing of their personal data (Article 6 of 152-FZ), as well as where processing is necessary to conclude or perform a contract to which the data subject is a party or beneficiary, or to take steps at the data subject’s request before concluding a contract.

The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (provides, grants access to), anonymizes, blocks, deletes and destroys personal data, both with and without the use of automation tools.

Personal data received through the Website is recorded, systematised, accumulated, stored, updated and retrieved using databases located in the Russian Federation (Part 5 of Article 18 of Federal Law No. 152-FZ): requests are stored on the Website’s server in the Russian Federation. The Operator learns about a new request from a notification in the Telegram messenger that contains no personal data (only the request number, its type, the selected service and the time).

For the purposes listed in section 4, the Operator may transfer data to the following parties:

• the hosting provider whose servers in the Russian Federation host the Website — for the technical operation of the Website;
• Anthropic PBC (USA) — if the Website uses an AI chat based on Anthropic technology: to process AI chat messages and generate responses by artificial intelligence. Using such an AI chat involves cross-border transfer of personal data outside the Russian Federation; messages are transferred only after the visitor has given consent with the button in the chat window. We recommend not including sensitive data in AI chat messages (passport details, bank details, health data and other special categories of personal data) — the AI model must not request such data.

Personal data is not transferred to other third parties not listed in this section without the data subject’s consent, except in cases expressly provided for by the laws of the Russian Federation.

• data received in requests is processed until the purposes of processing are achieved, but no longer than 3 (three) years from the data subject’s last interaction with the Operator, unless a longer retention period is required by applicable law;
• messages sent to the AI chat are not stored by the Operator for longer than necessary to handle the corresponding request and generate a response;
• records of consents to personal data processing and of their withdrawal (consent number, date and time, document edition, page address, IP address and browser data, a mark that a request was sent from the AI chat) are kept for 3 (three) years from the moment consent is given or withdrawn, so that the Operator can prove that consent was obtained and withdrawn. Records are deleted monthly, no later than 37 months after they are made. These records do not contain message content or contact details.

Once the processing period expires, personal data is destroyed or anonymized unless otherwise provided by law.

The Operator takes the necessary legal, organizational and technical measures to protect personal data from unlawful or accidental access, destruction, alteration, blocking, copying, provision or dissemination, as well as from other unlawful actions of third parties with respect to personal data, to the extent necessary to comply with 152-FZ and the regulations adopted under it.

Under Article 14 of 152-FZ, the data subject has the right to receive information about the processing of their personal data by the Operator; to demand that their personal data be clarified, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or not necessary for the stated purpose of processing; to withdraw consent to the processing of personal data; and to appeal the Operator’s actions or inaction to the authorized body for the protection of data subjects’ rights or in court.

To exercise these rights, or to withdraw consent to personal data processing, send a request to konevets12@bk.ru. The Operator reviews the request and replies within 10 (ten) business days of receiving it; this period may be extended by no more than 5 (five) business days, with notice of the extension to the data subject.

Consent given in the AI chat window can also be withdrawn with the “Withdraw consent” link in that window — see section 8 of the Consent to Personal Data Processing.

The Website is not intended for persons under 18. The Operator does not knowingly collect personal data of minors. If you become aware that a minor has provided their personal data to the Operator, please let us know at konevets12@bk.ru — the data will be deleted.

The Operator may amend this Policy. A new edition of the Policy takes effect once it is published on the Website, unless the new edition provides otherwise. The current edition is always available at https://neo-digital.ceo/en/privacy (translation) and https://neo-digital.ceo/privacy (Russian, legally binding).

For any questions related to personal data processing, please email konevets12@bk.ru.