1.1. The Company — Soft Programm Limited Liability Company, located at: 125212, Moscow, Kronshtadtsky Blvd., 6/Bldg. 4, Room 104, Office 3B, OGRN 1197746652135, INN/KPP 7743321173/774301001 (hereinafter also referred to as the Operator).
1.2. Personal Data Subject (PD Subject) - an individual, directly or indirectly identified or identifiable based on the Personal Data relating to him/her.
1.3. User - a legally competent individual who connects to the Site and/or Program and uses its functionality in accordance with the User Agreement for the LIKA software.
1.4. Processor - a person who processes personal data on behalf of the Operator in accordance with the requirements of the law and this Personal Data Processing Policy.
1.5. Site - a set of programs for electronic computers and other information on the Internet, accessed using the domain name https://likagpt.ru, as well as its subdomains or mirrors.
1.6. LIKA Software. (Software, Program) — a computer program owned by the Company that provides Users with access to the functionality of artificial intelligence models, including communication with artificial intelligence models, file analysis, media content creation, artificial intelligence model selection, and, in cases provided for by the selected License, data search on the Internet.
1.7. "LIKA. Standard" License — a license that provides access to communication with artificial intelligence models, file analysis, media content creation, and artificial intelligence model selection.
1.8. "LIKA. Maximum" License — a license that provides access to all the functionality of the "LIKA. Standard" License, as well as data search on the Internet.
1.9. Distribution — a set of programs and files on the Company's website for installation and initial software initialization.
1.10. Account — a collection of User data required for identification and access to their personal settings.
1.11. Personal Data (PD) — information related to a directly or indirectly identified or identifiable individual (personal data subject).
1.12. Counterparty — a legal entity or sole proprietor with whom a contract for compensation has been concluded. A Counterparty may also be a Partner.
1.13. Partner — the person to whom personal data is transferred for processing.
1.14. Operator Services — the Operator's activities in providing the User with access to the functionality of the LIKA software, as well as technical and information support in connection with its use.>
2.1. This Policy has been developed in accordance with the Constitution of the Russian Federation, the Labor Code of the Russian Federation, the Civil Code of the Russian Federation, Federal Law No. 149-FZ of July 27, 2006 "On Information, Information Technologies, and the Protection of Information," Federal Law No. 152-FZ of July 27, 2006 "On Personal Data," RF Government Resolution No. 1119 of November 1, 2012 "On Approval of Requirements for the Protection of Personal Data When Processed in Personal Data Information Systems," and other federal laws and regulations.
2.2. The Personal Data Processing Policy applies to all personal data that may be obtained by the Company in the course of its operations, including from Users.
2.3. The Personal Data Processing Policy applies to all information the Company may receive about the User during their use of the Website, services, features, any software versions, when registering and using the Account, sending requests to artificial intelligence models, uploading files, conducting dialogues, receiving Generated Content, or other Company services, and/or during the Company's execution of any agreements and contracts with the User. Advertising information may only be sent with the User's prior consent.
2.4. ContractThe Operator is responsible for ensuring that the processing of personal data complies with applicable laws and regulations and the agreement (within its area of responsibility) for the following categories of personal data:
2.4.1. Subjects of personal data transferred to the Partner for processing.
2.4.2. Individuals - representatives acting on behalf of the Counterparty.
2.4.3. Own personal data, if the Operator's Counterparty is a sole proprietor.
2.5. Security requirements for personal data transferred between the Operator and the Partner are stipulated by the agreement concluded between them in accordance with applicable law.
2.6. Processing of personal data of the Operator's Counterparty's representative is permitted if this follows from the essence of the agreement with the Counterparty.
2.7. The Operator is obliged to adhere to the following principles when processing personal data:
2.7.1. Personal data must be processed lawfully and fairly;
2.7.2. Personal data must be limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data that is incompatible with the purposes for which it was collected is prohibited;
2.7.3. Databases containing personal data processed for incompatible purposes may not be combined;
2.7.4. Only personal data that is relevant for the purposes for which it is processed may be processed;
2.7.5. The content and volume of personal data processed must correspond to the stated purposes of processing. The personal data processed must not be excessive in relation to the stated purposes of processing;
2.7.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing must be ensured. The Company shall take necessary measures or ensure that measures are taken to delete or rectify incomplete or inaccurate data;
2.7.7. Personal data shall be stored in a form that permits identification of the data subject, for no longer than required for the purposes of processing the personal data, unless the storage period for personal data is established by federal law or an agreement to which the data subject is a party, beneficiary, or guarantor. Processed personal data shall be destroyed upon achieving the processing purposes or when the need for achieving these purposes is no longer necessary, unless otherwise provided by federal law.
2.8. The Company assumes that the User consciously determines their requests and the composition of the uploaded data, controls the technical parameters of the equipment they use, and has read this Policy in full. If the User disagrees with the Policy, use of the Software shall be discontinued. Reading this Policy does not replace the User's separate consent to the processing of personal data in cases where such consent is required by law.
2.9. This Policy is published online and also posted in the Program interface.
3.1. The Operator processes the personal data of the following categories of personal data subjects:
3.1.1. The Operator's employees, dismissed employees, candidates for vacant positions, and similar categories whose processing is stipulated by labor legislation (hereinafter referred to as the Operator's Employees);
3.1.2. Users;
3.1.3. Representatives of the Operator's Contractors.
4.1. The personal data of the Operator's Employees are processed on the basis of subparagraphs 1, 2, and 7 of paragraph 1 of Article 6 of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data" for the purpose of enforcing the provisions of the Labor Code of the Russian Federation (hereinafter also referred to as the Labor Code of the Russian Federation), for the purpose of enforcing the provisions of the employment contract, as well as regulatory legal acts related to the Labor Code of the Russian Federation.
4.2. The personal data of Users regarding the use of the Site, Software, and receipt of the Operator's Services are processed in accordance with subparagraphs 1 and 5 of paragraph 1 of Article 6 of the Federal Law of 27.07.2006 N 152-FZ "On Personal Data" for the purposes of registering and authorizing the User, creating and maintaining an Account, concluding and executing an agreement, providing access to the Software and its functionality, processing requests and uploaded files, generating generating responses and Generated Content, performing settlements, providing technical support, and ensuring software security.
4.3. The personal data of the Counterparty's representatives is processed in accordance with Subparagraphs 5 and 7 of Clause 1 of Article 6 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" for the purpose of concluding and executing the agreement with the Counterparty.
4.4. The personal data of various categories of personal data subjects is processed in accordance with Subparagraphs 1, 5, and 7 of Clause 1 of Article 6 of Federal Law No. 152-FZ of July 27, 2006 "On Personal Data" for the purpose of reviewing requests and making decisions on them, informing about the decisions made, and providing information in connection with requests.
4.5. Personal data is processed in accordance with subparagraphs 1, 7, and 9 of paragraph 1 of Article 6 of Federal Law No. 152-FZ of July 27, 2006, "On Personal Data" for the purposes of conducting marketing research, studying consumer satisfaction with service quality and characteristics, and statistical purposes. The sending of advertising materials and the use of optional analytical, functional, and advertising cookies are subject to the User's separate consent.
4.6. Personal data may be used for other purposes if required by Russian law.
4.7. The processing of personal data is limited to achieving specific, predetermined, and legitimate purposes. Processing of personal data incompatible with the purposes of collecting personal data is prohibited.
4.8. The personal data of Users, the content of their requests, dialogues, uploaded files, and Generated Content are not used by the Operator to train artificial intelligence models.
5.1. The Operator processes the following categories of personal data of Employees: last name, first name, patronymic, year of birth, gender, age, profession, income, social status, employment, passport details; military ID (for those liable for military service), TIN assignment certificate, pension insurance certificate, files containing materials on advanced training and retraining, certification, official investigations, account, residential address, registration address, telephone number, date of birth, job title, information about change of name, nearest metro station, information about skills, health status, information about financial obligations.
5.2. The Operator processes the following categories of personal data of Users, if they are provided by the User or are generated during the use of the Site and Software: last name, first name, patronymic; email address; mobile phone number; Account ID; information about the selected tariff, license, or subscription; Account payment and balance information; support requests; IP address; cookie data; device, browser, and operating system information; access date and time; User actions on the Website and in the Software; selected artificial intelligence model; content of requests, dialogs, and downloaded files; generated content; other information independently provided by the User while using the Software.
5.3. The Operator processes the personal data of the Counterparty's representatives: last name, first name, patronymic (if any), job title, and other information stipulated by the agreement with the Counterparty.
5.4. When using the Website and Software, the Operator may process technical data transmitted in accordance with Internet data exchange protocols, including IP address, device identifier, cookie data, browser and operating system information, access date and time, technical logs, and information about the User's actions in the Software.
5.5. When using the Software, the Operator processes the data listed in paragraphs 5.2 and 5.4 of this Policy if such processing is required by the actual functionality of the Software and is necessary to achieve the purposes specified in Section 4 of this Policy.
5.5.1. The User is prohibited from uploading personal data of third parties, special categories of personal data, biometric personal data, or information constituting a secret protected by law to the Software.
5.6. The storage period for personal data is determined by the contract or the nature of another basis for processing:
5.6.1. The processing period for Employees' personal data shall not exceed 30 (thirty) days from the date the basis for processing ceases to exist.
5.6.2. The User's personal data shall be processed for the duration of the contract and the period of use of the Software.Account. After deletion of an Account or termination of the Agreement, the data will be destroyed within 30 (thirty) days, unless further storage is required by law or other legal grounds.
5.6.3. Duration of processing of the Counterparties' personal data: until the Agreement is terminated; storage of tangible media containing the personal data of the Counterparty's representatives - until the expiration of the statute of limitations.
5.7. To ensure the storage of personal data on tangible media, premises equipped with protective equipment are designated in accordance with the enterprise order. Completed documents containing personal data are stored in an archive or in a separate room (cabinet). Tangible media containing personal data are stored separately for each category of personal data subjects.
5.8. Consent to the processing of personal data may be revoked by the Personal Data Subject. If the Personal Data Subject revokes their consent to the processing of their personal data, the Operator has the right to continue processing the personal data without the consent of the Personal Data Subject, provided there are grounds specified by applicable law.
6.1. The Operator may process personal data in personal data information systems.
6.2. If personal data is transferred for processing to a Partner where the use of the PDIS is assumed, the concluded agreement shall stipulate the obligation to protect the personal data in the PDIS in accordance with applicable law.
7.1. The Personal Data Subject has the right to:
7.1.1. request changes to or deletion of the personal data provided;
7.1.2. Request notification of all persons previously provided with incorrect or incomplete personal data;
7.1.3. Send inquiries to the Operator regarding the processing of their personal data;
7.1.4. Request a list of their personal data processed by the Company and the source thereof;
7.1.5. Receive information on the processing timeframes for their personal data, including the storage periods;
7.1.6. Request notification of all persons previously provided with incorrect or incomplete personal data of any deletions, corrections, or additions made to it;
7.1.7. To protect their rights and legitimate interests, including compensation for damages and/or moral damages in court;
7.1.8. Exercise other rights provided for by current legislation.
8.1. The Operator has the right to:
8.1.1. Process the personal data of the Personal Data Subject in accordance with the stated purpose;
8.1.2. Require the Personal Data Subject to provide reliable personal data necessary for the performance of the contract, the provision of the service, the identification of the Personal Data Subject, and in other cases stipulated by personal data legislation;
8.1.3. Restrict the Personal Data Subject's access to their personal data if the personal data is processed in accordance with legislation on combating the legalization (laundering) of proceeds from crime and the financing of terrorism, the Personal Data Subject's access to their personal data violates the rights and legitimate interests of third parties, as well as in other cases stipulated by the legislation of the Russian Federation;
8.1.4. Process publicly available personal data of individuals;
8.1.5. Process personal data subject to publication or mandatory disclosure in accordance with the legislation of the Russian Federation;
8.1.6. Entrust the processing of personal data to another person with the consent of the Personal Data Subject, if such consent is required by law, on the basis of an agreement concluded with such person and in accordance with the terms of this Policy.
8.2. The Operator is obliged to:
8.2.1. Use the received Personal Data solely for the purposes specified in this Policy;
8.2.2. Ensure that Personal Data is kept confidential, not disclosed without the prior written consent of the User, and not sell, exchange, publish, or otherwise disclose the transferred Personal Data of the User, except in cases providedpursuant to legislation, the Policy, the Agreement, and the User's consent;
8.2.3. Take legal, organizational, and technical measures necessary to protect Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, and distribution;
8.2.4. Block personal data related to the relevant User from the moment of the User's request or appeal by their legal representative or authorized body for the protection of the rights of personal data subjects during the verification period, if inaccurate personal data or illegal actions are detected.
8.3. Upon achieving the purposes of personal data processing, or if the personal data subject revokes consent to its processing, personal data shall be destroyed if:
8.3.1. The Company may not process personal data without the consent of the Personal Data Subject on the grounds stipulated by the Federal Law "On Personal Data" or other federal laws;
8.3.2. Unless otherwise provided in another agreement between the Company and the Personal Data Subject.
8.4. The Company is obligated to inform the Personal Data Subject or their representative of the processing of their personal data upon their request.
8.5. The Company also has other rights and bears other obligations established by the Federal Law "On Personal Data."
8.6. The Operator does not use Users' Personal Data, the content of requests, dialogues, uploaded files, or Generated Content for training artificial intelligence models.
9.1. When processing personal data, the Operator takes the necessary legal, organizational, and technical measures and ensures their implementation to protect personal data from unauthorized or accidental access, destruction, modification, blocking, copying, provision, or distribution of personal data, as well as from other illegal actions in relation to personal data, which include, but are not limited to:
9.2. Appointing a person responsible for processing personal data.
9.3. Limiting the number of employees with access to personal data.
9.4. Software identification of Users and the Operator's employees and recording their actions.
9.5. Implementing anti-virus monitoring and other measures against malicious software and mathematical influences.
9.6. Using backup and recovery tools.
9.7. Updating software when security patches from manufacturers are available.
9.8. Implementation of encryption when transmitting personal data over the Internet.
9.9. Taking measures to ensure that only authorized persons are admitted to locations where technical equipment is installed.
9.10. Use of technical means to protect the premises where technical equipment for personal data information systems is located and the locations where tangible personal data storage media are stored.
9.11. The Operator ensures the security of personal data, in particular:
9.11.1. taking into account the potential harm to the personal data subject, the volume and content of the personal data being processed, the type of activity in the implementation of which the personal data is processed, and the relevance of threats to the security of personal data;
9.11.2. Application of technical measures in accordance with the threats to the security of personal data when processing it in personal data information systems;
9.11.3. Application of organizational and technical measures to ensure the security of personal data when processing them in personal data information systems, necessary to meet the requirements for the protection of personal data, the implementation of which ensures the levels of protection of personal data established by the Government of the Russian Federation;
9.11.4. Application of information security tools that have undergone the established procedure for assessing the conformity of information;
9.11.5. Assessment of the effectiveness of measures taken to ensure the security of personal data before commencing work in the personal data information system, carried out by the Company;
9.11.6. Taking into account machine-readable media of personal data, if used;
9.11.7. Procedures related to the detection of facts of unauthorized access to personal data and the adoption of mer;
9.11.8. Restoring personal data modified or destroyed due to unauthorized access;
9.11.9. Establishing rules for access to personal data processed in the personal data information system, as well as ensuring the registration and accounting of all actions performed with personal data in the personal data information system;
9.11.10. Monitoring the measures taken to ensure the security of personal data and the level of protection of personal data information systems;
10.1. Only licensed anti-virus tools purchased from suppliers of such tools are permitted for use.
10.2. Installation and configuration of anti-virus control tools on workstations and servers is carried out by the information security administrator or by persons under an agreement containing the relevant terms.
10.3. Antivirus software must be updated automatically. Antivirus software may only be running with updates no older than 72 hours.
10.4. An antivirus monitor must be running in resident mode on each workstation and server.
10.5. Any information received via telecommunications channels and on removable media must be subject to mandatory antivirus monitoring.
10.6. Installed software must be pre-scanned for viruses.
11.1. The following measures are taken to ensure the security of personal data during manual processing:
11.2. All personal data processing activities are performed only by the Operator's employees authorized by order of the sole executive body to handle personal data, and only to the extent necessary for these individuals to perform their job functions;
11.3. A contract is concluded with the Partner performing manual processing of personal data, including terms for the adoption of appropriate personal data protection measures.
11.4. Personal data processing is carried out in accordance with the procedure stipulated by Government Resolution No. 687 of September 15, 2008, "On Approval of the Regulation on the Specifics of Personal Data Processing Carried Out Without the Use of Automation."
12.1. The Operator and other persons who have gained access to personal data are obligated not to disclose or distribute personal data to third parties without the consent of the Personal Data Subject, unless otherwise provided by Russian Federation law.
12.2. Company employees authorized to Process Personal Data are obligated to:
12.2.1. Know and strictly comply with the provisions of Russian Federation law on Personal Data, this Policy, and the Company's internal regulations on the Processing and Security of Personal Data;
12.2.2. Process Personal Data only as part of their job responsibilities;
12.2.3. Not disclose Personal Data processed by the Company;
12.2.4. Report any actions of other persons that may lead to a violation of this Policy;
12.2.5. Report any known violations of this Policy to the person responsible for organizing the processing of Personal Data within the Company.
12.3. The User's Personal Data is kept confidential, except in cases where the User voluntarily makes their personal information publicly available to an unlimited number of persons.
12.4. The Operator has the right to transfer the User's Personal Data to third parties in the following cases:
12.4.1. The personal data subject has expressly consented to such actions;
12.4.2. The transfer is necessary for the User to use certain functions of the Website or Software or to fulfill an agreement concluded with the User and is carried out to the extent necessary to achieve the relevant purpose;
12.4.3. The transfer of Personal Data is provided for by Russian or other applicable legislation;
12.4.4. The transfer occurs as part of a sale or other transfer of a business (in whole or in part), and all obligations to comply with the terms of this Policy with respect to the personal information received by it are transferred to the acquirer;
12.4.5. As a result of processing the User's personal information by anonymizing it, anonymized statistical data may be obtained, which is transferred to a third party for research, performance of work, or provision of services on behalf of the Operator.
12.5. If an unauthorized or accidental transfer, provision, distribution, or access to personal data is detected, the Operator takes measures to eliminate the consequences of the incident and notifies the authorized body in the manner and within the timeframe established by the legislation of the Russian Federation. The User is informed of such an incident if this is necessary to protect their rights and legitimate interests.
12.6. The Company's Websites use cookies, which are used in accordance with the Cookie Policy at: https://likagpt.ru/privacy-cookies.
12.7. The Operator does not use data received from the User or data generated during the User's interaction with the Software to train artificial intelligence models.
12.8. User requests are pre-processed and anonymized on an intermediate server before being sent to the selected artificial intelligence model. The request is sent to the model provider without Account identifiers or other information that could identify the User.
13.1. The destruction of the Subject's personal data occurs in the following cases:
13.1.1. Upon achievement of the processing objectives or if there is no longer a need to achieve them, within a period not exceeding thirty days from the date the personal data processing objective is achieved, unless otherwise provided by an agreement to which the personal data subject is a party, or another agreement between the Operator and the personal data subject (their representative, or employer).
13.1.2. In the event of detection of unlawful processing of personal data, or if the Data Subject revokes consent to its processing – within the timeframes established by Russian legislation, unless the Operator has other legal grounds for continuing processing;
13.1.3. In the event of expiration of the personal data storage period determined in accordance with Russian legislation and the Operator's organizational and administrative documents;
13.1.4. In the event of an order from the authorized body for the protection of the rights of personal data subjects, the Russian prosecutor's office, or a court decision.
14.1. The Operator does not perform cross-border processing of personal data. When storing personal data using contractors' ISPDN, the Operator uses databases located in the Russian Federation.
14.2. The Operator may transfer personal data to other parties, hosting providers, analytics services, and other parties for the purpose of fulfilling the agreement concluded with the User.
14.3. The Operator guarantees that the execution of an order for the processing of personal data complies with the requirements of Russian Federation legislation if Partners are engaged in accordance with the Operator's contractual powers.
14.4. The Operator has the right to transfer personal data to inquiry and investigative bodies and other authorized bodies on the grounds stipulated by the current legislation of the Russian Federation.
15.1. The User is prohibited from including in Requests and uploaded files the information specified in Section 5.5.1 of this Policy. This restriction does not apply to the Operator's processing of Employees' personal data in cases and according to the procedure stipulated by the legislation of the Russian Federation.
15.2. The Operator does not make decisions based solely on automated processing of personal data that generate legal consequences for the User or otherwise affect their rights and legitimate interests. Generating a response using an artificial intelligence model does not constitute such a decision.
15.3. The Operator does not provide unlimited access to personal data to third parties.
15.4. The Operator contacts the User for informational and advertising purposes only with their separate prior consent. The User has the right to unsubscribe from receiving such communications at any time.
16.1. The processing period for personal data processed by the Operator may be determined (redefined) by the Operator's organizational and administrative documents in accordance with the provisions of the Federal Law "On"Personal data."
16.2. This Policy is subject to amendment and supplementation in the event of new legislative acts and special regulations on the processing and protection of personal data, as well as by decision of the Operator. The Operator makes changes to this Policy without the User's consent and prior notice to the User. The updated version of the Policy comes into effect from the moment it is posted on the Website, unless otherwise provided in the new version of the Policy. When changes are made, the date of the last update is indicated in the current version.
16.3. Compliance with the requirements of this Policy is monitored by the person responsible for organizing the processing of personal data.
16.4. Issues not regulated by this Policy are governed by the current legislation of the Russian Federation.
16.5. The User may send any suggestions or questions regarding this Policy to the Operator's address: 125212, Moscow, Kronshtadtsky Boulevard, 6/Bldg. 4, Pom. 104, Room 3B, or by email to partners@ithelper.ru.
