Privacy Policy - STARTUP CONNECT (KS1016)

1. General provisions

1.1. This Privacy Policy (hereinafter referred to as the “Policy”) governs the processing of personal and other data provided by the Applicant in the relevant application sent through the Website, as well as the use of the Materials submitted by the Applicant.

2. Terms and Definitions

2.1. Applicant - a legal entity, an individual entrepreneur or a group of individuals without a legal entity, which has sent an application.

2.2. Company - Cursor Oy, Kotka-Hamina Regional Development Company, Finland, Business ID 0727178-6, location address Kyminlinnantie 6, P.O. Box 14, FIN-48601 Kotka, Finland.

2.3. Contest - Startup Connect Contest is a competition for startups implemented as part of the Startup.Connect cross-border cooperation project funded by the European Union, the Russian Federation and the Republic of Finland in the framework of South-East Finland-Russia CBC 2014-2020 programme (https://www.sefrcbc.fi). The goal of the Program is to support startups, student entrepreneurship, small and medium-sized technological businesses in the border region in order to create a community of business leaders ready to enter the global market. The operator of the cross-border cooperation project Startup.Connect is the Cursor Oy Company and acts as the Organizer of the Contest.

2.4. Materials - any documents (copies of documents) and information materials of various formats (.docx, .pdf, .ppt, etc.) that the Applicant attaches to the application.

2.5. Website – Contest website on the Internet, located at http://startupconnect.info.

3. Submission of an application

3.1. Submission of an applicationthrough the Website is considered to be the filling in and submission by the Applicant or representative of the Applicant of personal data when filling out information fields on the Company's website, including when completing the contact application form for registration purposes to participate in the competitive selection of early stage projects from Finland and Russia interested in entering new markets and international expansion. When submitting an application, the Applicant expresses his full and unconditional consent and will to process his personal data freely, by his own will and in his own interests in accordance with clause 1, Article. 9 of the Federal Law of the Russian Federation from June 27, 2006 “On Personal Data”, and confirms that he is familiar with this Policy.

4. Personal data processing

4.1. The purpose of personal data processing: the organization and conduction of the Contest, the dissemination of information aimed at drawing attention to the ongoing Contest, collecting information about potential participants, determining the compliance of potential participants with the stated requirements, the Contest Regulations; communication with potential participants by e-mail, telephone, address of residence; determining the winners, organizing accommodation and travel, awarding the winners of the Contest, publishing lists of winners and nominees of the competitive selection, forming a database of potential participants.
The Company processes personal data submitted by the Applicant by submitting an application on the Website, during the period of achieving the goals of personal data processing within the framework of the Contest project.

4.2. The Company processes the following personal data of the Applicant and / or his representatives:
• surname, name, patronymic (if available)
• age
• city
• contact telephone number, email address and other contact information for the Applicant’s representative
• place of work and position held, information about education, address of location of work and place of residence
• information about accounts in social networks, information about interests, information about membership in clubs, associations and unions.

4.3. The basis for the processing of personal data are: Art. 24 of the Constitution of the Russian Federation; Article 6 of the Federal Law of the Russian Federation No. 152 “On Personal Data”; Contest Regulations, this Privacy Policy.

4.4. The processing of personal data is carried out by performing both with the use of automation tools and without using such tools, the following actions (operations) or a set of actions (operations): collection, recording, systematization, accumulation, storage, refinement (update, change), extraction, use, transfer (provision, access), blocking, deletion, destruction.

4.5. By submitting personal data of his representative, the Applicant confirms that, in accordance with the Federal Law of the Russian Federation “On Personal Data”, he properly received from his representative consent to the processing of such personal data, including their transfer to a partner in accordance with clause 4.8. of this Policy.

4.6. A representative of the Applicant, whose personal data is indicated in the application, may at any time withdraw his consent to the processing of his personal data by sending a written notice to the Company. If the representative of the Applicant withdraws his consent to the processing of personal data, the Company is entitled to continue processing his personal data without his consent if there are grounds specified in clauses 2–11 of part 1 of article 6, part 2 of article 10 and part 2 of article Federal Law of the Russian Federation No. 152 About personal data from 06.26.2006.

4.7. Personal data is processed in accordance with the Policy for processing personal data in Cursor Oy.

4.8. The Company has the right to entrust the processing of the personal data of the Applicants to its partner – Fund IT Innovations (BINR 1147800002790, address: 197046, St. Petersburg, Chapaeva St., 11/4-38). The personal data processing policy of IT Innovations Fund. The Company also has the right to involve external experts in order to evaluate received applications from Applicants. The Applicant hereby agrees with the possibility of transferring personal data to third parties.

4.9.  Confirmation of consent by the Applicant with possible cross-border transmission of personal data and advertising alerts via email and telephone is made by the entry by the Applicant of personal data when filling out information fields on the Website for submitting an application for registration to participate in the Contest and then putting the “V” icon in the active Website window opposite «I, the User, being a subject of personal data, give a consent for the collection, recording, storage and transfer of the submitted information and personal data in the databases used by the South-East Finland-Russia Cross Border Cooperation Programme authorities, management bodies and project partners of Startup Connect project and confirm that I have read the Contest Privacy Policy. Organisers commit to follow the legislation of their own countries and the Program documents and acts for protection of personal data collected.»

4.10. The Applicant is notified that in the case of a withdrawal of personal data by the subject or his representative, consent to the processing of personal data, the Company is entitled to continue processing personal data without the consent of the personal data subject if there are grounds specified in clauses 2-11 of part 1 of article 6, part 2 of article 10 and part 2 of Article 11 of the Federal Law of the Russian Federation No. 152 “On Personal Data” from 06.26.2006.

5. Processing of other data and materials

5.1. The Company processes the following other data:
• product information (IT solution, computer program, various devices): name, direction of use, brief description, etc.
• any other information provided by the Applicant.

5.2. Other data and materials are processed by the Company for the purposes of processing the application and for the purposes of interaction with the Applicant within the framework of the Contest.

5.3. By providing other data and Materials, the Applicant confirms that such data and Materials are not confidential, including are not a trade secret, do not contain signs of know-how.

5.4. Other data and materials should not:
• contain information constituting a secret protected by law, including information about the private lives of individuals;
• call for violence, racial discrimination, terrorist or other illegal activities, other extremist materials;
• contain materials that offend the religious feelings of believers, elements of pornography, as well as violence or cruelty, or illegal actions;
• contain abusive words, obscene and offensive images, comparisons and expressions, including with regard to professions, age, language, official state symbols of the Russian Federation and the Republic of Finland, objects of cultural heritage of the Russian Federation and the Republic of Finland;
• contain information on the stay of minors in a state of danger to their life and / or health, elements of use, demonstration of tobacco products and / or alcoholic beverages, narcotic substances;
• contain objects that are the intellectual property of third parties;
• contain information and (or) materials that violate other rights and interests of citizens and legal entities, the requirements of the legislation of the Russian Federation and the Republic of Finland or public morality and ethics.

6. Final provisions

6.1. The Company may at any time make changes or additions to this Policy unilaterally without prior approval from the Applicant. The new version of the Policy is placed instead of the previous version on the Website.

6.2. Confirmation of the consent by the Applicant for the processing of personal data is the input by the Applicant of personal data when filling out information fields on the Site for filing an application for registration to participate in the Contest, followed by putting the “V” icon in the active window of the Site opposite the inscription «I, the User, being a subject of personal data, give a consent for the collection, recording, storage and transfer of the submitted information and personal data in the databases used by the South-East Finland-Russia Cross Border Cooperation Programme authorities, management bodies and project partners of Startup Connect project and confirm that I have read the Contest Privacy Policy. Organisers commit to follow the legislation of their own countries and the Program documents and acts for protection of personal data collected.»

6.3. The Applicant’s consent to the processing of personal data is valid all the time until the termination of the processing of personal data in accordance with the terms of this Policy.