This Cookie Policy (the “Policy”) describes the types of cookies and the purposes for which they are used, how the Company processes data collected when Visitors use https://orthometrica.pro/, and how Visitors can refuse cookie processing.
1. Terms and definitions
The following terms are used in this Policy:
Company — ANAMNES LLC, OGRN 1232600000665, INN 2632121300, located at Premises 38, 45 Kirova Avenue, Pyatigorsk, Stavropol Krai, Russia.
Website Visitor (Visitor) — a person who visits and uses the Website.
Website — a collection of computer software and hardware that makes information and data with a common purpose publicly available through the technical means used for communication between computers on the Internet. The Website is available at https://orthometrica.pro/.
Yandex — YANDEX Limited Liability Company, OGRN 1027700229193119021, 16 Lev Tolstoy Street, Moscow, 119021, Russia.
Cookies — small pieces of data that the Website requests from the browser on a Visitor’s computer or mobile device. Cookies reflect the Visitor’s preferences or actions on the Website, as well as information about their equipment and the date and time of a session. Cookies are stored locally on the Visitor’s computer or mobile device. Visitors can delete stored cookies in their browser settings.
IP address — a unique network address of a device on a computer network using the Internet Protocol.
2. General provisions
2.1. When a Visitor first accesses the Website using a new browser or private browsing mode, a banner informs them that cookies are collected and requests their consent to cookie processing.
2.2. By clicking “Accept” or continuing to use the Website, the Visitor consents to cookie processing and agrees to this Policy. Continued use means following any link or clicking any button on the Website, or viewing content on any page of the Website.
2.3. Visitors may refuse cookies in their browser settings; instructions are available in the browser’s Help section. In this case, the Website will use only cookies strictly necessary for its operation and services. However, refusing cookies may cause the Website to work incorrectly.
2.4. This Policy applies only to the Website. The Company does not control and is not responsible for third-party websites accessible through links on the Website.
3. Data processing on the Website
3.1. This Policy establishes the Company’s obligations to keep confidential and protect Visitor data that it may obtain during visits to the Website.
3.2. The Company protects data automatically transmitted when Visitors access Website pages containing the system’s statistics script (“pixel”), including:

• IP address;
• browser information and page address, or information about another program used to access the Website;
• access time;
• referrer (the address of the previous page);
• other cookie information, depending on the cookie type listed in Section 4.

3.3. The Website uses the Yandex Metrica web analytics service provided by Yandex on the following terms:
3.3.1. Yandex Metrica uses cookies.
3.3.2. Information about Visitors’ use of the Website collected through cookies is transferred to Yandex and stored on its servers in the Russian Federation. Yandex processes this information to evaluate Visitors’ use of the Website and prepare reports on Website activity.
3.3.3. Yandex processes the information in accordance with:

• Yandex Cookie Policy;
• Yandex Metrica Terms of Use;
• Yandex Privacy Policy.

By continuing to use the Website, Visitors agree to Yandex processing their data in the manner and for the purposes described in Section 3.3.
4. Types of cookies used by the Company
4.1. Essential cookies. These cookies are necessary to use the Website and its features. They cannot be disabled. They are set in response to your requests, such as setting privacy preferences, signing in or completing forms.
4.2. Analytics cookies. These cookies collect information to help us understand how our Website is used, assess the effectiveness of our marketing campaigns and customise the Website for you.
4.3. Advertising cookies. These cookies provide information about your online activity to help show you more relevant online advertising or limit how often advertisements are displayed.
5. Purposes of collecting Visitor data
5.1. The Company uses cookies to improve the Website.
5.2. Information about Visitors’ actions is processed to improve the Company’s products and services, identify Visitors’ preferences and provide targeted information about the Company’s products and services.
6. Additional terms
6.1. The Website owner may amend this Policy.
6.2. A new Policy takes effect on the date it is published on the Website, unless the new version states otherwise.
6.3. The current Policy is available at https://orthometrica.pro/.
6.4. For questions about the processing of Visitors’ personal data or the exercise of data subject rights, Visitors may contact the Company at aeplaksin@gmail.com. The response period is 10 (ten) working days.

1. General provisions
This Personal Data Processing Policy has been prepared in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (the “Personal Data Law”). It defines the procedures for processing personal data and the measures taken by ANAMNES LLC (the “Controller”) to protect personal data.
1.1. The Controller considers respect for human and civil rights and freedoms when processing personal data, including the right to privacy and personal and family confidentiality, to be a fundamental objective and condition of its activities.
1.2. This Policy applies to all information that the Controller may obtain about visitors to https://orthometrica.pro/.
2. Key terms used in this Policy
2.1. Automated processing of personal data — processing personal data using computer equipment.
2.2. Blocking personal data — temporarily suspending processing, except where processing is necessary to clarify personal data.
2.3. Website — the collection of graphic and informational materials, computer programs and databases that makes them accessible online at https://orthometrica.pro/.
2.4. Personal data information system — a collection of personal data held in databases and the information technologies and technical equipment used to process it.
2.5. Anonymisation of personal data — actions that make it impossible, without additional information, to attribute personal data to a particular User or other data subject.
2.6. Processing of personal data — any action or set of actions performed on personal data, with or without automated tools, including collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (dissemination, provision or access), anonymisation, blocking, deletion and destruction.
2.7. Controller — a state or municipal authority, legal entity or individual that, alone or jointly with others, organises and/or processes personal data and determines the purposes of processing, the data to be processed and the actions performed on it.
2.8. Personal data — any information directly or indirectly relating to an identified or identifiable User of https://orthometrica.pro/.
2.9. Personal data authorised by the data subject for dissemination — personal data made accessible to an unlimited number of persons by the data subject’s consent to processing such data in accordance with the Personal Data Law (“data authorised for dissemination”).
2.10. User — any visitor to https://orthometrica.pro/.
2.11. Provision of personal data — actions aimed at disclosing personal data to a specific person or group of persons.
2.12. Dissemination of personal data — any actions aimed at disclosing personal data to an unspecified group of persons or making it available to an unlimited number of persons, including publication in the media, placement on information and telecommunications networks, or providing access in any other way.
2.13. Cross-border transfer of personal data — transferring personal data to the territory of a foreign state, to a foreign state authority, foreign individual or foreign legal entity.
2.14. Destruction of personal data — actions that irreversibly destroy personal data so that its content cannot be restored in the personal data information system, and/or destroy physical media containing personal data.
3. Principal rights and obligations of the Controller
3.1. The Controller has the right to:

• obtain reliable information and/or documents containing personal data from the data subject;
• continue processing personal data without consent after consent is withdrawn or a request to stop processing is received, where grounds specified in the Personal Data Law apply;
• independently determine the measures necessary and sufficient to fulfil its obligations under the Personal Data Law and regulations adopted under it, unless that Law or other federal laws provide otherwise.

3.2. The Controller must:

• provide data subjects, on request, with information about the processing of their personal data;
• organise processing in accordance with current Russian legislation;
• respond to enquiries and requests from data subjects and their legal representatives as required by the Personal Data Law;
• provide the authorised data protection authority with requested information within 10 days of receiving its request;
• publish this Policy or otherwise make it available without restriction;
• take legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, modification, blocking, copying, provision, dissemination and other unlawful actions;
• cease transferring (disseminating, providing or granting access to) and processing personal data, and destroy it, in the manner and circumstances required by the Personal Data Law;
• fulfil other obligations established by the Personal Data Law.

4. Principal rights and obligations of data subjects
4.1. Data subjects have the right to:

• obtain information about the processing of their personal data, except as provided by federal law. The Controller must provide this information in an accessible form without including other data subjects’ personal data unless there are lawful grounds for disclosure. The Personal Data Law establishes the information to be provided and the procedure for obtaining it;
• require the Controller to clarify, block or destroy incomplete, outdated, inaccurate or unlawfully obtained personal data, or data unnecessary for the stated processing purpose, and take measures provided by law to protect their rights;
• require prior consent to processing for the marketing of goods, works and services;
• withdraw consent to processing and request that processing cease;
• challenge the Controller’s unlawful actions or omissions before the authorised data protection authority or in court;
• exercise other rights provided by Russian legislation.

4.2. Data subjects must provide accurate information about themselves and inform the Controller when their personal data needs clarification, updating or modification.
4.3. Persons who provide false information about themselves or information about another data subject without that person’s consent are liable under Russian legislation.
5. Principles of personal data processing
5.1. Personal data is processed lawfully and fairly.
5.2. Processing is limited to specific, predetermined and lawful purposes. Processing incompatible with the purposes for which the data was collected is prohibited.
5.3. Databases containing personal data processed for incompatible purposes must not be combined.
5.4. Only personal data relevant to the processing purposes may be processed.
5.5. The content and volume of processed personal data must correspond to the stated purposes. Excessive processing in relation to those purposes is prohibited.
5.6. Personal data must be accurate, sufficient and, where necessary, up to date for the processing purposes. The Controller takes or ensures necessary measures to delete or clarify incomplete or inaccurate data.
5.7. Personal data is retained in a form permitting identification of the data subject no longer than necessary for the processing purposes, unless a retention period is established by federal law or a contract to which the data subject is a party, beneficiary or guarantor. Data is destroyed or anonymised when the purposes are achieved or no longer need to be achieved, unless federal law provides otherwise.
6. Purposes of processing personal data
Purpose: providing the User with access to services, information and/or materials on the Website.
Personal data:

• surname, first name and patronymic;
• email address;
• telephone numbers;
• taxpayer identification number, tax registration date and tax registration certificate details;
• primary state registration number (OGRN) and registered address.

Legal basis: Federal Law No. 149-FZ of 27 July 2006 “On Information, Information Technologies and Information Protection”.
Processing activities: collection, recording, systematisation, accumulation, storage, destruction and anonymisation of personal data; sending informational emails.
7. Conditions for processing personal data
7.1. Personal data is processed with the data subject’s consent.
7.2. Processing is necessary to achieve purposes provided for by an international treaty of the Russian Federation or by law, or to carry out functions, powers and obligations imposed on the Controller by Russian legislation.
7.3. Processing is necessary for the administration of justice or the enforcement of a judicial act or an act of another authority or official enforceable under Russian enforcement legislation.
7.4. Processing is necessary to perform a contract to which the data subject is a party, beneficiary or guarantor, or to conclude a contract at the data subject’s initiative or under which the data subject will be a beneficiary or guarantor.
7.5. Processing is necessary to exercise the rights and legitimate interests of the Controller or third parties, or to achieve socially significant objectives, provided that the data subject’s rights and freedoms are not violated.
7.6. Processing concerns personal data made available to an unlimited number of persons by the data subject or at their request (“publicly available personal data”).
7.7. Processing concerns personal data subject to publication or mandatory disclosure under federal law.
8. Collection, storage, transfer and other processing procedures
The security of personal data processed by the Controller is ensured through the legal, organisational and technical measures needed to fulfil all requirements of current personal data protection legislation.
8.1. The Controller safeguards personal data and takes all possible measures to prevent access by unauthorised persons.
8.2. The User’s personal data will never be transferred to third parties, except where required to comply with current legislation or where the data subject has consented to transfer to a third party to fulfil obligations under a civil-law contract.
8.3. If personal data is inaccurate, the User may update it by notifying the Controller at aeplaksin@gmail.com with the subject “Personal data update”.
8.4. The processing period is determined by achievement of the purposes for which the data was collected, unless a different period is required by contract or current legislation. The User may withdraw consent at any time by emailing aeplaksin@gmail.com with the subject “Withdrawal of consent to personal data processing”.
8.5. All information collected by third-party services, including payment systems, communications providers and other service providers, is stored and processed by those parties (controllers) in accordance with their Terms of Use and Privacy Policies. The Controller is not responsible for the actions of third parties, including the providers listed in this clause.
8.6. Restrictions imposed by the data subject on the transfer (other than granting access) or processing, or conditions of processing (other than obtaining access), of data authorised for dissemination do not apply where processing serves state, social or other public interests defined by Russian legislation.
8.7. The Controller ensures the confidentiality of personal data during processing.
8.8. The Controller retains personal data in an identifiable form no longer than necessary for the processing purposes, unless a retention period is established by federal law or a contract to which the data subject is a party, beneficiary or guarantor.
8.9. Processing may cease when its purposes are achieved, consent expires or is withdrawn, the data subject requests cessation, or unlawful processing is identified.
9. Actions performed by the Controller on personal data
9.1. The Controller collects, records, systematises, accumulates, stores, clarifies (updates or modifies), retrieves, uses, transfers (disseminates, provides or grants access to), anonymises, blocks, deletes and destroys personal data.
9.2. The Controller performs automated processing with or without receiving and/or transmitting information through information and telecommunications networks.
10. Cross-border transfers
10.1. Before commencing cross-border transfers, the Controller must notify the authorised data protection authority of its intention to carry out such transfers. This notification is separate from the notification of its intention to process personal data.
10.2. Before submitting that notification, the Controller must obtain the relevant information from the foreign authorities, individuals or legal entities to which it plans to transfer personal data.
11. Confidentiality of personal data
The Controller and other persons who obtain access to personal data must not disclose it to third parties or disseminate it without the data subject’s consent, unless federal law provides otherwise.
12. Final provisions
12.1. Users may obtain clarification on any questions about the processing of their personal data by contacting the Controller at aeplaksin@gmail.com.
12.2. Any changes to the Controller’s personal data processing policy will be reflected in this document. This Policy remains in effect indefinitely until replaced by a new version.
12.3. The current Policy is freely available at https://orthometrica.pro/.

These Terms of Use (the “Agreement”) govern the relationship between ANAMNES LLC (“Orthometrica” or the “Administration”) and the Website user.
The Orthometrica Website is not a mass media outlet.
By using the Website, you agree to this Agreement. If you do not agree, do not use the Orthometrica Website.
Rights and obligations of the parties
The User may:

• search for information on the Website;
• obtain information from the Website;
• use Website information for personal, non-commercial purposes.

The Administration may:

• create, change or cancel rules at its discretion and as necessary;
• restrict access to any information on the Website;
• create, change or delete information;
• delete accounts;
• refuse registration without giving reasons.

The User must:

• not disrupt the operation of the Website;
• not create multiple accounts that effectively belong to the same person;
• not allow third parties to use their account or their account login and password;
• not register an account on behalf of or instead of another person, except as permitted by Russian legislation;
• not use scripts or programs to collect information or interact with the Website and its services automatically.

The Administration must:

• maintain the Website’s operation, except where this is impossible for reasons beyond its control;
• provide comprehensive protection for the User’s account;
• provide all available information about the User to authorised state authorities where required by law.

Liability of the parties

• The User is personally and fully responsible for information they distribute.
• The Administration is not responsible for differences between services expected by the User and those actually received.
• The Administration is not responsible for services provided by third parties.
• In force majeure circumstances, including hostilities, a state of emergency or natural disasters, the Administration does not guarantee the preservation of information posted by the User or uninterrupted operation of the information resource.

Term of the Agreement
This Agreement takes effect whenever the Website is used. It ceases to apply when a new version is issued.
The Administration reserves the right to amend this Agreement unilaterally at its discretion and does not notify Users of amendments.

I consent to ANAMNES LLC, INN 2632121300, OGRN 1232600000665 (the “Controller”), processing my personal data: name, telephone number, email address, details of medical organisations, patients’ full names and treating physicians’ full names.
My consent is specific, purpose-defined, informed, conscious and unambiguous.
The Controller processes personal data solely to fulfil obligations, including obligations under transactions without consideration, provide information about services, conclude and perform a service agreement, and provide access. I consent to the Controller providing my personal data to third parties to achieve the stated processing purposes.
The Controller processes personal data through collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, anonymisation, transfer (access or provision), blocking, deletion and destruction.
The Controller processes personal data both with and without automated tools.
This consent is effective from the time it is given until it is withdrawn.
I have been informed and understand that:

• I may require the Controller to stop processing my personal data by sending an electronic request to aeplaksin@gmail.com;
• if I request that processing cease, the Controller may continue processing without my consent, for example where I have an active contract with the Controller;
• if I refuse to provide personal data, I will be unable to use the Controller’s services.

The Controller considers requests to withdraw consent within 30 (thirty) calendar days of receipt.
Controller details
ANAMNES LLC
INN: 2632121300
OGRN: 1232600000665
Registered address: Premises 38, 45 Kirova Avenue, Pyatigorsk, Stavropol Krai, Russia.

In accordance with Part 1 of Article 18 of Federal Law No. 38-FZ of 13 March 2006 “On Advertising” (“38-FZ”) and Article 9 of Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” (“152-FZ”), by selecting “I consent to receive information and promotional messages” and clicking “Send” in the contact form, I, the data subject, freely, voluntarily and in my own interests consent to ANAMNES LLC, OGRN 1232600000665, INN 2632121300, registered at Premises 38, 45 Kirova Avenue, Pyatigorsk, Stavropol Krai, Russia (the “Controller”), sending me informational and marketing messages and processing my personal data for that purpose on the following terms.
1. The Controller may send informational and marketing messages:

• by SMS using the mobile telephone number provided in the contact form at https://orthometrica.pro/ (the “Website”);
• by email using the address provided in the Website’s contact form;
• through telecommunications networks, including telephone, fax and mobile radiotelephone communications;
• through messaging services, including WhatsApp, Telegram and Viber.

2. For these messages, the Controller processes the following personal data: surname, first name and patronymic; email address; and mobile telephone number.
3. The Controller processes personal data both automatically and without automated tools.
4. The Controller may collect, record, systematise, accumulate, store, clarify (update or modify), retrieve, use, block, transfer (provide or grant access to), delete and destroy my personal data.
5. To send informational and marketing messages, the Controller may transfer my personal data to telecommunications operators, messaging services and email service providers.
6. This consent is valid for 10 years from the date it is given.
7. I have been informed of my right to obtain information about the processing of my personal data under 152-FZ and that I may withdraw this consent at any time by written request. Written requests should be sent to: Premises 38, 45 Kirova Avenue, Pyatigorsk, Stavropol Krai, Russia.
8. I warrant that the mobile telephone number and email address I provide in the Website’s contact form belong to me. If I stop using that telephone number and/or email address, I undertake to inform the Controller. If I provide a telephone number and/or email address belonging to a third party, I warrant that I have obtained that person’s consent to receive marketing messages from the Controller in accordance with this consent.
10. You may opt out of informational and marketing messages by following the “Unsubscribe” link in emails or sending a request to aeplaksin@gmail.com.
Company details
ANAMNES LLC
INN: 2632121300
OGRN: 1232600000665
Registered address: Premises 38, 45 Kirova Avenue, Pyatigorsk, Stavropol Krai, Russia.