Version dated November 30, 2025
1. GENERAL PROVISIONS
1.1. Introduction. This Privacy and Data Processing Policy (hereinafter referred to as the "Policy") defines the procedure and conditions for data processing, including personal, biometric, and other confidential data, by "NEYRO" LLC (Tax ID (INN) 9709103450 / Primary State Registration Number (OGRN) 1237700886620, 109147, Moscow, ul. Marksistskaya, d. 20, str. 8, pom. 1/1), hereinafter referred to as the "Operator" or "We".
1.2. Scope. This Policy applies to all individuals (hereinafter referred to as "Users" or "You") who interact with the "BRICS RECORD" ecosystem (hereinafter referred to as the "Ecosystem"), including the use of websites (including https://bricsrecord.org), mobile applications, Telegram bots.
1.3. Acceptance of the Policy. By using any services of the Ecosystem, providing us with your data, or performing the actions specified in the Public Offer as acceptance, you confirm that you have read this Policy, understood your rights and our obligations, and unconditionally agree to all its terms. If you do not agree with the terms of this Policy, you must immediately cease using the Ecosystem.
1.4. Foundational Principles. We process your data based on the principles of lawfulness, fairness, transparency, data minimization, accuracy, storage limitation, integrity, and confidentiality. Your trust is our key asset.
2. WHAT INFORMATION WE COLLECT AND PROCESS
We collect various categories of data necessary to provide you with our services.
2.1. Data provided by you directly:
Identification data: Last name, first name, patronymic, date of birth, age.
Contact data: Email address, phone number, messenger and social media accounts.
Professional and financial data: Profession, position, place of work, income level, payment details (processed by our payment partners).
Data for record or achievement registration: Responses to questionnaires, chatbots, and other communication tools.
2.2. Data collected automatically:
Technical data: IP address, cookie data, browser and operating system information, device data, access time, and browsing history on our sites.
3. PURPOSES AND LEGAL GROUNDS FOR DATA PROCESSINGWe process your data for specific, explicit, and lawful purposes.
Purpose of processing. | Categories of data processed. | Legal basis (in accordance with Federal Law No. 152-FZ). |
Performance of a contract with you (providing access to the community, providing support). | 2.1, 2.2 | Performance of a contract to which the personal data subject is a party (Clause 5, Part 1, Article 6). |
Marketing communications (informing about new products, promotions, news). | 2.1 | Your consent (Clause 1, Part 1, Article 6). |
Ecosystem improvement and analytics (analyzing service usage to enhance them). | 2.2 , 2.1 | Statistical and other research purposes, subject to mandatory anonymization (Clause 9, Part 1, Article 6). |
Ensuring security and preventing fraud. | 2.2 | Exercising the rights and legitimate interests of the Operator (Clause 7, Part 1, Article 6). |
4. DATA TRANSFER TO THIRD PARTIES
We do not sell your personal data. We may transfer it to third parties only in the following cases and in compliance with strict security measures:
4.1. Service Providers. We engage trusted partners to ensure the functioning of the Ecosystem. They only have access to the information necessary for them to provide services and are bound by contractual obligations to protect it. Categories of providers include:
- Payment systems (for processing payments).
- Cloud hosting and database providers (for storing information).
- Email and messenger distribution services (for communication with you).
- Analytics services (for analyzing the use of our websites).
4.2. With Your Consent. We may transfer your data to third parties if you have given explicit consent for this (for example, when integrating with partner services).
4.3. As Required by Law. We may disclose your data upon a lawful request from a court, law enforcement, or government authorities.
4.4. Cross-Border Transfer. By using global cloud services, we may carry out cross-border transfer of your data. We guarantee that such transfers are made to countries ensuring an adequate level of data protection or using standard contractual clauses approved by the legislation of the Russian Federation.
5. DATA STORAGE AND DELETION
5.1. Storage Period. We store your personal data for the period necessary to achieve the purposes of its processing, but no longer than required to fulfill contracts with you and comply with legislation. Typically, this period is 3 (three) years after the termination of our contractual relationship (statute of limitations).
5.2. Data for Research. Information used for statistical purposes undergoes a depersonalization (anonymization) procedure and can be stored indefinitely in this form.
5.3. Data Deletion. Upon the expiration of the storage period or upon your request for deletion (in cases provided by law), we irreversibly delete or anonymize your personal data.
6. PROTECTION OF YOUR DATA
We implement comprehensive legal, organizational, and technical measures to protect your data from unauthorized access, destruction, alteration, blocking, and other unlawful actions. These measures include:
- Encryption of data during transmission (SSL/TLS) and storage.
- Pseudonymization and anonymization of data where possible.
- Strict access control based on the principle of "least privilege".
- Regular software and security system updates.
- Conducting internal audits and assessing the effectiveness of implemented measures.
7. YOUR RIGHTS AS A PERSONAL DATA SUBJECT
You have the following rights regarding your personal data:
- Right of Access: To receive information concerning the processing of your data.
- Right to Rectification: To demand the correction of inaccurate or incomplete data.
- Right to Withdraw Consent: To withdraw previously given consent to data processing at any time.
- Right to Erasure and Restriction: To demand the erasure or blocking of your data if processed unlawfully or no longer necessary for the stated purposes.
Other rights provided by the legislation of the Russian Federation.
To exercise your rights, please send a written request to the email address: info@bricsrecord.org. We will respond to your request within the time limits established by law.
8. POLICY CHANGES
We reserve the right to unilaterally amend this Policy. The new version of the Policy comes into force from the moment of its publication on our official website (https://bricsrecord.org/). We recommend that you regularly check this page for updates.
9. OPERATOR'S CONTACT INFORMATION
"NEYRO" LLC
Tax ID (INN) 9709103450 / Primary State Registration Number (OGRN) 1237700886620
Legal address: 109147, Moscow, ul. Marksistskaya, d. 20, str. 8, pom. 1/1
Email for inquiries: info@bricsrecord.org
Phone: +7 960 791 93 10