This Privacy and Personal Data Processing Policy (hereinafter – the Policy) has been drawn up in accordance with the requirements of Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" (hereinafter – the Personal Data Law) and defines the procedure for processing personal data and the measures taken to ensure the security of personal data undertaken by Aleksey Olegovich Balashov (hereinafter – the Operator).
1.1. The Operator regards the observance of human and civil rights and freedoms in the processing of personal data, including the protection of the rights to privacy and to personal and family confidentiality, as the most important purpose and condition of carrying out its activities.
1.2. This Policy applies to all information that the Operator may obtain about visitors and users of the website https://startupium.ru (hereinafter – the Site).
1.3. Date of the last update of the Policy: 29 May 2026.
2.1. Automated processing of personal data – the processing of personal data by means of computing equipment.
2.2. Blocking of personal data – the temporary suspension of the processing of personal data (except where processing is necessary to clarify the personal data).
2.3. Website – a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://startupium.ru.
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. Anonymization of personal data – actions as a result of which it becomes impossible, without the use of additional information, to determine that the personal data belong to a specific User or other personal data subject.
2.6. Processing of personal data – any action (operation) or set of actions (operations) performed with or without the use of automation tools with personal data, including the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), anonymization, blocking, deletion, and destruction of personal data.
2.7. Operator – a natural person who, independently or jointly with other persons, organizes and (or) carries out the processing of personal data, and also determines the purposes of processing personal data, the composition of the personal data to be processed, and the actions (operations) performed with personal data.
2.8. Personal data – any information relating directly or indirectly to a specified or identifiable User of the Site https://startupium.ru.
2.9. User – any visitor to the Site https://startupium.ru, including a registered user of the service.
2.10. Provision of personal data – actions aimed at disclosing personal data to a specific person or to a specific group of persons.
2.11. Destruction of personal data – any actions as a result of which personal data are irretrievably destroyed with the impossibility of further restoring the content of the personal data in the personal data information system and (or) as a result of which the material carriers of the personal data are destroyed.
2.12. Cookie – a small piece of data sent by the Site and stored on the User's device; it is used for the operation of the Site and the collection of anonymized statistics.
3.1. The Operator has the right to:
– obtain from the personal data subject accurate information and (or) documents containing personal data;
– in the event that the personal data subject withdraws consent to the processing of personal data, continue processing the personal data without the subject's consent where there are grounds specified in the Personal Data Law;
– independently determine the composition and list of measures necessary and sufficient to ensure the fulfilment of the obligations provided for by the Personal Data Law and the regulatory legal acts adopted in accordance with it, unless otherwise provided by law.
3.2. The Operator is obliged to:
– provide the personal data subject, at their request, with information concerning the processing of their personal data;
– organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
– respond to appeals and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Law;
– publish or otherwise ensure unrestricted access to this Policy;
– take legal, organizational, and technical measures to protect personal data from unlawful or accidental access to them, destruction, modification, blocking, copying, provision, dissemination, and from other unlawful actions;
– cease processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;
– in the event that a fact of unlawful processing or a leak of personal data is identified, notify the authorized body for the protection of the rights of personal data subjects within the time limits established by law.
4.1. Personal data subjects have the right to:
– receive information concerning the processing of their personal data, except in cases provided for by federal laws;
– require the Operator to clarify their personal data, to block or destroy them where the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the stated purpose of processing;
– withdraw consent to the processing of personal data;
– independently delete their account in the personal account area, which entails the cessation of processing and the destruction of the personal data associated with it in the manner set out in Section 10 of this Policy;
– appeal against unlawful actions or inaction of the Operator to the authorized body for the protection of the rights of personal data subjects or in court;
– exercise other rights provided for by the legislation of the Russian Federation.
4.2. Personal data subjects are obliged to:
– provide the Operator with accurate data about themselves;
– inform the Operator of the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with inaccurate information about themselves, or information about another personal data subject without the latter's consent, bear responsibility in accordance with the legislation of the Russian Federation.
5.1. The Operator processes the following personal data of the User, provided by them during registration and use of the service:
– email address (e-mail);
– first name and (or) nickname (the displayed user name), surname (where provided);
– account identifier, date and time of registration;
– profile image (avatar) uploaded by the User;
– profile information provided by the User voluntarily: desired position/role, professional skills, work experience, brief description (biography), locality (city, region, country), links to external resources and social networks;
– information voluntarily posted by the User in projects, blog posts, comments, tracker tasks, and chat messages.
5.2. When authorizing via third-party services (for example, Yandex ID), the Operator receives from the relevant service basic account data: name, email address, profile image, and user identifier — to the extent permitted by the settings of that service.
5.3. The Site also collects and processes anonymized data about visitors (including cookies) using the Yandex Metrica internet statistics service (see Section 12).
5.4. The data listed above are hereinafter in the text of the Policy collectively referred to by the general concept of "personal data".
5.5. The Operator does not process special categories of personal data (concerning racial or ethnic origin, political views, religious or philosophical beliefs, state of health, or sexual life) or biometric personal data.
5.6. The Operator does not process personal data authorized by the subject for dissemination to an unlimited circle of persons within the meaning of Article 10.1 of the Personal Data Law. Profile information published by the User on the Site is posted by them independently and voluntarily.
5.7. The Operator does not collect data of minors. The service is intended for persons who have reached the age at which, under the legislation of the Russian Federation, independent provision of consent to the processing of personal data is permitted.
6.1. The processing of personal data is carried out on a lawful and fair basis.
6.2. 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 collecting the personal data is not permitted.
6.3. It is not permitted to merge databases containing personal data the processing of which is carried out for purposes incompatible with one another.
6.4. Only personal data that meet the purposes of their processing are subject to processing.
6.5. The content and volume of the personal data processed correspond to the stated purposes of processing. Redundancy of the personal data processed in relation to the stated purposes of their processing is not permitted.
6.6. When processing personal data, the accuracy of the personal data, their sufficiency, and, where necessary, their relevance to the purposes of processing are ensured.
6.7. Personal data are stored in a form that allows the personal data subject to be identified for no longer than the purposes of processing require, unless the storage period is established by federal law or by a contract. The personal data processed are destroyed or anonymized upon achievement of the purposes of processing or in the event that the need to achieve those purposes is lost.
7.1. The Operator processes the User's personal data for the following purposes:
– registration and authentication of the User, creation and maintenance of an account;
– providing access to the functions of the startup platform: creating and managing projects, searching for and forming teams, collaborative work on projects;
– maintaining a profile, publishing blog posts, exchanging comments, communicating in chat, working with the task tracker;
– sending service and notification messages related to the use of the service, including by email;
– providing feedback to the User and considering their appeals;
– ensuring the security of the service, preventing fraudulent and other unlawful actions;
– improving the quality of the operation of the Site and its content on the basis of anonymized statistics.
7.2. The User may at any time opt out of receiving informational messages by changing the notification settings in the personal account area or by sending the Operator a letter to the address contact@startupium.ru.
7.3. The anonymized data collected using the internet statistics service serve to gather information about Users' actions on the Site and to improve the quality of the service.
8.1. The legal grounds for the processing of personal data by the Operator are:
– Federal Law No. 152-FZ of 27 July 2006 "On Personal Data";
– Federal Law No. 149-FZ of 27 July 2006 "On Information, Information Technologies, and the Protection of Information";
– the consent of the personal data subject to the processing of their personal data (clause 1 of part 1 of Article 6 of the Personal Data Law);
– a contract (user agreement/offer) to which the personal data subject is a party or which is concluded at their initiative (clause 5 of part 1 of Article 6 of the Personal Data Law);
– the exercise of the rights and legitimate interests of the Operator (clause 7 of part 1 of Article 6 of the Personal Data Law), provided that the rights and freedoms of the personal data subject are not violated.
8.2. Consent to the processing of personal data is provided by the User separately from other documents, by placing a mark (not pre-filled) in a special field during registration, which complies with the requirements of Article 9 of the Personal Data Law (in the version in force from 01 September 2025). Registration without the provision of such consent is not possible.
8.3. The Operator processes anonymized data about the User where this is permitted in the User's browser settings (the saving of cookies is enabled) and confirmed by them in the cookie usage information banner.
8.4. The personal data subject independently decides on the provision of their personal data and gives consent freely, of their own will, and in their own interest.
9.1. The processing of personal data is carried out with the consent of the personal data subject to the processing of their personal data.
9.2. The processing of personal data is necessary for the performance of a contract to which the personal data subject is a party or a beneficiary, as well as for the conclusion of a contract at the initiative of the personal data subject.
9.3. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator, provided that the rights and freedoms of the personal data subject are not violated thereby.
9.4. The processing of personal data may be carried out to achieve the purposes provided for by law, for the exercise of the functions, powers, and obligations placed on the Operator by the legislation of the Russian Federation.
The security of the personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to comply in full with the requirements of the current legislation in the field of personal data protection.
10.1. The Operator ensures the safety of personal data and takes all possible measures to exclude access to personal data by unauthorized persons. Users' passwords are stored exclusively in the form of irreversible hash values; the transfer of data between the User and the Site is carried out over a secure protocol (TLS).
10.2. Databases containing the personal data of citizens of the Russian Federation are located and processed on servers situated within the territory of the Russian Federation (part 5 of Article 18 of the Personal Data Law).
10.3. The User's personal data are not transferred to third parties, except in cases expressly provided for by law, as well as in cases where the processing of data on behalf of the Operator is carried out by persons engaged by it (for example, a hosting services provider) on the terms of observing confidentiality and the requirements of part 3 of Article 6 of the Personal Data Law.
10.4. In the event that inaccuracies in personal data are identified, the User may update them independently in the personal account area or by sending the Operator a notice to the address contact@startupium.ru marked "Updating of personal data".
10.5. The User may at any time withdraw their consent to the processing of personal data by sending the Operator a notice to the address contact@startupium.ru marked "Withdrawal of consent to the processing of personal data", as well as by deleting their account in the personal account area.
10.6. The period of processing of personal data is determined by the achievement of the purposes for which they were collected, unless a different period is provided for by a contract or the current legislation. The User's personal data are processed until the account is deleted or consent is withdrawn.
10.7. When the User deletes their account or withdraws consent, the Operator ceases processing and destroys the relevant personal data within a period not exceeding 30 (thirty) days, with the exception of data that the Operator is obliged to store by virtue of law. Anonymized statistical data and security event logs may be stored for the established periods (as a rule, up to 1 year) and do not allow the subject to be identified.
10.8. Information collected by third-party services (including the web analytics service) is stored and processed by the said persons in accordance with their own policies. The Operator bears no responsibility for the actions of such third parties.
10.9. When processing personal data, the Operator ensures the confidentiality of the personal data.
11.1. The Operator carries out the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (provision, access), anonymization, blocking, deletion, and destruction of personal data. The dissemination of personal data to an unlimited circle of persons is not carried out by the Operator.
11.2. The Operator carries out mixed (automated and non-automated) processing of personal data, with or without the transfer of the information obtained over information and telecommunications networks.
12.1. The Site uses cookies. Technical (necessary) cookies ensure the operation of the Site, authorization, and session retention, and are used without the User's separate consent.
12.2. To collect anonymized visit statistics, the Yandex Metrica web analytics service is used (operator – Yandex LLC, Russian Federation). The service collects anonymized data about Users' actions on the Site using cookies. The use of analytics cookies is carried out subject to the User's consent, expressed in the cookie usage information banner.
12.3. Foreign web analytics services (in particular, Google Analytics) are not used on the Site; no cross-border data transfer for the said purposes is carried out.
12.4. The User may at any time opt out of the use of cookies by changing their browser settings. Disabling technical cookies may result in some functions of the Site becoming unavailable.
13.1. The Operator does not carry out cross-border transfer of personal data. The initial collection, recording, systematization, accumulation, and storage of the personal data of citizens of the Russian Federation are carried out using databases located within the territory of the Russian Federation.
13.2. In the event that a need for cross-border transfer of personal data subsequently arises, the Operator will notify the authorized body and ensure compliance with the requirements of Article 12 of the Personal Data Law, and the relevant processing will be carried out only where the grounds provided for by law exist.
The Operator and other persons who have gained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the personal data subject, unless otherwise provided by federal law.
15.1. The User has the right to send the Operator requests for access to their personal data, for their correction or deletion, as well as for the withdrawal of consent, to the email address contact@startupium.ru.
15.2. The Operator considers the appeal and provides a response within a period not exceeding 30 (thirty) days from the date of receipt of the request, in the manner established by Articles 14, 20, and 21 of the Personal Data Law.
15.3. Some rights (changing profile data, changing the password, deleting the account) the User may exercise independently in the personal account area.
16.1. The User may obtain any clarifications on matters concerning the processing of their personal data by contacting the Operator by email at contact@startupium.ru.
16.2. This document reflects any changes to the Operator's personal data processing policy. The Policy is valid indefinitely until replaced by a new version.
16.3. The current version of the Policy is freely available on the Internet at https://startupium.ru/policy.