Consent to processing data for the level and community membership

The consent is drawn up as a separate document (Article 9(1) of Federal Law No. 152-FZ of 27 July 2006 “On personal data”) and is requested when you join the community. Without it the HemoTrack app works in full: only the level, member number and privileges are unavailable (Article 16 of the Consumer Protection Law).

1. Data subject

Full name and account email address: filled in from the profile. If the consent to processing health data has not yet been signed, the full name is entered at signing.

2. Operator

Intellectual Medical Technologies LLC (OOO «IMT»), OGRN 1269600002770, INN 6679188579, address: 620024, Sverdlovsk Region, Yekaterinburg, Bisertskaya St., 16, bldg 1, email privacy@healthrating.net.

3. Purpose of processing

One purpose: calculating my level and care points, keeping my participation history and enabling my membership of the HealthRating community, including the family level, member privileges and seasonal events.

4. Personal data

• facts of completed calendar tasks: date, task source (state check-up programme, follow-up schedule for a condition I marked, community rules, repeat test, week of self-monitoring), category;
• age and sex for the check-up calendar; conditions I marked for the follow-up calendar;
• details of the report confirming a task: laboratory name, order number, file hash (to prevent double counting);
• regularity of home readings without their values;
• the composition of my family on the Platform;
• level, care points, best result, member number, participation history;
• full name, email address.

Test values and diagnoses are not used for this purpose and do not affect the level.

5. Actions and methods of processing

Collection, recording, systematisation, accumulation, storage, updating, retrieval, use, anonymisation, blocking, deletion, destruction. Processing is automated, in the Operator’s information systems in the Russian Federation.

6. Persons processing data on the Operator’s instructions

Selectel JSC (INN 7810962785, 196006, St Petersburg, Tsvetochnaya St., 21, lit. A): computing infrastructure and data storage. Other persons are named in the Personal data processing policy.

7. What the Operator guarantees

• The level has no legal consequences: it does not affect the price or availability of services, is not passed to third parties and is not used for decisions about me (Article 16 of the Personal Data Law).
• Only I see my level; my family sees the overall family level, not my personal one. There are no public member lists.
• I may at any time obtain an explanation of the level calculation and object to it in the account; an employee of the Operator reviews the objection within 30 days.
• Anonymised community statistics are published only for groups of at least 50 people.

8. Term and withdrawal

The consent is valid from signing for as long as I am a community member. Withdrawal is equivalent to leaving the community and is done in the account settings or by a request to privacy@healthrating.net. On leaving, the level, points and participation history are destroyed within 30 days; lab reports and readings remain in my account and the app keeps working. Withdrawal does not affect the lawfulness of processing carried out before it.

9. Signing

The consent is signed with a simple electronic signature: by pressing “Join” after reading the Manifesto and the Community rules, in an account whose access was confirmed by a one-time code sent to my email address. The rules for using the simple electronic signature are set in Section 5 of the Public Offer (Article 6(2) and Article 9 of Federal Law No. 63-FZ of 6 April 2011 “On electronic signatures”).

The Operator stores the date and time of signing, the edition of the consent text and the account identifier. By signing, I confirm that I act freely, of my own will and in my own interest and that I have read the Personal data processing policy.