1.1. The Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been developed in accordance with Federal Law No. 152-FZ of July 27, 2006 “On Personal Data” and other regulatory acts of the Russian Federation.
1.2. This Policy defines the procedure for processing personal data of users of the website https://hackatom.energy (hereinafter referred to as the “Website”), the conditions and principles of processing personal data, the rights and obligations of Users and the Operator, as well as information about the measures implemented to protect processed personal data in connection with the Global HackAtom international student competition (hereinafter referred to as the “Event”), organized by ANO Energy of the Future (hereinafter referred to as the “Operator”) jointly with third parties.
1.3. This Policy applies to all personal data that the Operator receives from users of the Website (hereinafter referred to as “Users” or “User”).
1.4. If the User does not agree with the terms of the Policy, they must immediately cease any use of the Website.
1.5. This Policy applies only to the Website. The Operator does not control and is not responsible for third-party websites to which the User may navigate via links available on the Website.
2.1. The following terms and definitions are used in this Policy: Website – the website located at https://hackatom.energy;
Personal Data (hereinafter – “PD”) – any information relating directly or indirectly to a specific or identifiable natural person (subject of PD);
Blocking of PD – temporary suspension of PD processing (except in cases where processing is required to clarify PD);
Depersonalization of PD – actions that result in it being impossible, without additional information, to determine the ownership of PD by a specific subject;
Processing of PD – any action (operation) or set of actions (operations), performed with or without the use of automation tools, involving personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of PD;
Operator – ANO Energy of the Future, address (location): 117105, Moscow, Varshavskoe shosse, Building 3, INN 7726385219, OGRN 1167700063300;
Provision of PD – actions aimed at disclosing PD to a specific person or a defined group of persons;
Distribution of PD – actions aimed at disclosing PD to an indefinite number of persons (transfer of PD) or at making personal data available to an unlimited number of persons, including publication in mass media, posting in information and telecommunication networks, or providing access to personal data by any other means;
User – a visitor to the Website, a subject of PD. If the User is a minor, this term refers both to the minor and their legal representative (parent). If the User is legally incapacitated, this term refers both to the incapacitated person and their legal representative;
ISPD – information system of personal data.
Destruction of PD – actions that result in the impossibility of restoring the content of PD in the ISPD and/or that result in the destruction of physical carriers of PD;
Cookies – data that are automatically transmitted to the Operator in the process of using the Website by means of software installed on the User’s device, including IP address, geographic location, information about the browser and type of operating system of the User’s device, technical characteristics of the hardware and software used by the User, date and time of access to the Website. By accepting the terms of the Policy, the User agrees to the use of cookies.
3.1. The legal bases for processing PD are:
Civil Code of the Russian Federation;
Federal Law No. 152-FZ of July 27, 2006 “On Personal Data”;
Federal Law No. 149-FZ of July 27, 2006 “On Information, Information Technologies, and Information Protection”;
Other regulatory legal acts of the Russian Federation;
Local regulatory acts of the Operator.
3.2. The Operator processes the User’s PD exclusively for the following purposes:
3.2.1. Registration and identification of the User on the Website, providing the User with the opportunity to fully use the Website within the organization and holding of the Event;
3.2.2. Display of the User’s profile to other Users of the Website;
3.2.3. Establishing and maintaining communication between the User and the Operator, consulting on issues of organizing and holding the Event, and conducting activities aimed at promoting the Event;
3.2.4. Sending the User promotional messages, newsletters about the Operator’s and its partners’ products and services, special offers, promotional campaigns, raffles, contests, surveys to the User’s email address, by phone, via messengers “WhatsApp”, “Viber”, “Telegram”, by mail, SMS messages, push notifications, as well as providing such information orally by phone;
3.2.5. Posting on the Website, in official social network groups, and other Operator communities on the Internet, in other advertising and/or information sources, for purposes not related to identifying the User:
− photos and/or videos taken during the organization and holding of the Event,
− reviews about the Event provided by the User.
3.2.6. Improving the quality of User service and upgrading the Website;
3.2.7. Statistical and other research based on anonymized information provided by the User;
3.2.8. Providing the User with access to third-party websites or services of the Website’s partners for the purpose of receiving their offers, updates, or services;
3.2.9. Posting information on the Website about events conducted by the Operator within the framework of organizing, holding, and promoting the Event, as well as in any materials published on external and internal boards, in printed and/or electronic publications (booklets, advertising and informational materials), on the Internet, as well as in video files of any format, both in the Russian Federation and abroad.
3.3. The specific scope of PD processed for the purposes listed above is defined in Section 5 of the Policy.
4.1. The Operator does not verify the PD provided by the User. Therefore, the Operator assumes that the User, when providing PD on the Website:
4.1.1. Is a legally capable person. In the event that the person using the Website is legally incapable, consent to the processing of PD is provided by the User’s legal representative, who has reviewed and accepted the conditions of PD processing set out in this Policy, including consent to the processing and/or dissemination of PD under the terms specified herein.
4.1.2. Is of legal age. Participation in the Event by minors aged 14 to 18 years is carried out through their legal representatives in accordance with the legislation of the Russian Federation. With respect to a minor Participant, consent to the processing of PD is provided by their legal representative (parent), who has reviewed and accepted the conditions of PD processing set out in this Policy, including consent to the processing and/or dissemination of PD under the terms specified herein.
4.1.3. Provides accurate information about themselves or about the represented legally incapable (minor) person (clauses 4.1.1 and 4.1.2) to the extent necessary to use the Website. The User independently keeps the provided PD up to date.
4.1.4. Understands that information posted on the Website by the User about themselves may become available to other Users and may also be copied and disseminated by such Users in cases provided for by the Policy and/or as a result of malicious programs (viruses).
4.2. The User accepts the terms of the Policy and gives the Operator informed and conscious consent to the processing and/or dissemination of their PD under the terms specified in the Policy and the legislation of the Russian Federation:
4.2.1. Upon registration and identification on the Website – for PD provided by the User to the Operator by filling out the registration form located at https://hackatom.energy. The User is considered to have given consent to the processing and/or dissemination of their PD at the moment of clicking the “Register” button or another button of similar meaning (or placing another mark in the registration field). Separate additional consent for the processing and/or dissemination and/or use of the User’s photo or video image is not required.
4.2.2. When entering or modifying PD in the “Personal Information” section of the registration form – when editing or supplementing information in the “Personal Information” section. The registration form requires the following information: full name; date of birth; gender; contact phone number; passport data (including scanned copies of passport data). The specified PD may be used by the Operator to fulfill obligations provided for by the terms of the Event. The User is considered to have given consent to the processing of newly entered or modified PD at the time of completing their editing. After filling in any of the fields specified in the “Personal Information” section, PD are updated automatically.
4.2.3. When filling out the feedback form, including an application for the use of other Website services – for PD that the User provides to the Operator when filling out the feedback form on the Website and electronic services. The User is considered to have given consent to the processing and/or dissemination of their PD entered in the feedback form fields at the moment of clicking the button confirming submission of the application (buttons may be labeled “Send,” “Submit Application,” “Sign Up,” “Get a Consultation,” or other similar wording).
4.2.4. When subscribing to receive informational and news materials from the Operator – by filling out the subscription form located on the Website at https://hackatom.energy. The User is considered to have given consent to the processing and/or dissemination of their PD when checking the box “I agree to the terms of PD processing.”
4.2.5. When using the Website in any way – for PD that are automatically transmitted to the Operator during the use of the Website via software installed on the User’s device. The User is considered to have given consent to the processing and/or dissemination of their PD at the moment of beginning to use the Website.
4.3. By performing the actions specified in clause 4.2 of this Policy, the User gives the Operator consent to the processing and/or dissemination of the corresponding PD, the list of which is specified in Section 5 of this Policy, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision to third parties, access), depersonalization, blocking, deletion, destruction of PD, with or without the use of automation tools, in accordance with the purposes specified in Section 3 of this Policy.
4.4. Consent provided by the User in accordance with this Policy to the processing of PD is valid from the day such consent is provided and throughout the period necessary to achieve the purposes of PD processing or until such consent is withdrawn by the User, unless otherwise provided by the legislation of the Russian Federation. Consent provided by the User in accordance with this Policy may be withdrawn by the User at any time. The User may withdraw previously provided consent to the processing of PD by one of the following methods:
By sending a corresponding written statement by mail to: 117105, Moscow, Varshavskoe shosse, Building 3;
By sending a corresponding statement in electronic document form to the email address: info@hackatom.energy.
5.1. Processing of Users’ PD is carried out under the following conditions:
PURPOSE OF USING PD |
SCOPE OF PROCESSED PD |
Registration of the User on the Website, providing the User with the opportunity to fully use the Website within the organization and holding of the Event (clause 3.2.1) |
full name; email address; phone number; date of birth; citizenship; country of residence; passport data*; year of participation; team name *for participants of the 2025 Event |
Establishing and maintaining communication between the User and the Operator, consulting on issues of organizing and conducting the Competition, conducting activities aimed at promoting the Competition (clause 3.2.3) |
full name; citizenship; country of residence; city; phone number; email address |
Sending promotional messages; newsletters; providing information of a promotional nature orally and in writing (clause 3.2.4) |
full name; phone number; email address |
Posting (including providing experts with photo and video materials obtained during the organization and conduct of the Competition; Users’ comments regarding the organization and conduct of the Competition) (clause 3.2.5) |
full name; gender; country of residence; citizenship; image, including video (free of charge); social media account data (if provided in the “Personal Information” section) |
Improvement of User Service quality and Website modernization (clause 3.2.6) |
cookies |
Statistical and other research based on anonymized information (clause 3.2.7) |
cookies |
Providing the User with access to third-party websites or services of the Website’s partners for the purpose of receiving their offers, updates, or services (clause 3.2.8) |
full name; email address |
Posting information on the Website about events conducted by the Operator in the framework of organizing, conducting, and promoting the Event, as well as in any materials posted on external and internal boards, in printed and/or electronic publications (booklets, advertising and informational materials), on the Internet, as well as in video files of any format, both in the Russian Federation and abroad (clause 3.2.9) |
full name; gender; country (city) of residence; citizenship; image, including video (free of charge) |
6.1. The Operator processes PD based on the following principles:
Legality and fairness;
Limiting the processing of PD to achieving specific, predetermined, and legitimate purposes;
Prohibition of processing PD that is incompatible with the purposes of data collection;
Prohibition of combining databases containing PD that are processed for incompatible purposes;
Processing only those PD that meet the purposes of their processing;
Compliance of the content and scope of the processed PD with the stated purposes of processing;
Prohibition of processing PD that are excessive in relation to the stated purposes of processing;
Ensuring the accuracy, sufficiency, and relevance of PD in relation to the purposes of processing;
Destruction or depersonalization of PD upon achieving the purposes of their processing or if the need to achieve these purposes is lost, upon receipt of a request from the User for the destruction of PD, or upon receipt of a withdrawal of consent from the User.
6.2. The Operator processes Users’ PD (recording, systematization, accumulation, storage, clarification (updating, modification), retrieval) using databases located in the territory of the Russian Federation.
6.3. The Operator processes Users’ PD both with and without the use of automated tools.
6.4. The Operator and other persons who have gained access to PD are obliged not to disclose PD to third parties and not to distribute PD without the consent of the PD subject, unless otherwise provided by the legislation of the Russian Federation.
6.5. Processing of the User’s PD includes the following actions by the Operator: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision to third parties, access), depersonalization, blocking, deletion, destruction.
6.6. Users’ PD is stored on electronic media. When processing PD for the purpose of fulfilling obligations under agreements with the User, the Operator may extract PD and store them on physical media. Such PD are stored for the period established by the legislation of the Russian Federation.
Storage of PD is carried out (depending on which event occurs first):
Until their deletion by the User in the “Personal Information” section of the registration form on the Website;
Until their destruction by the Operator – in case the User withdraws consent to PD processing or requests their destruction;
Until the expiration of the consent period (clause 4.4 of the Policy).
6.7. The Operator is entitled to transfer PD in accordance with the requirements of the legislation of the Russian Federation or with the consent of the PD subject to third parties, namely:
6.7.1. Partners, such as website and application owners, advertising networks, and other partners providing the Operator with services related to the placement and display of advertising on websites, in programs, products, or services owned or controlled by such partners;
6.7.2. Legal entities and/or individuals engaged by the Operator for the organization, conduct, and promotion of the Event;
6.8. Transfer of personal data to third parties specified in clause 6.7 of the Policy is carried out subject to the following conditions:
The third party processes PD using databases located in the territory of the Russian Federation;
The third party ensures the confidentiality of PD during their processing and use, undertakes not to disclose PD to other persons, and not to distribute Users’ PD without their consent;
The third party guarantees compliance with the following measures to ensure the security of PD during processing: use of information protection tools, detection and recording of unauthorized access to personal data and taking measures to restore PD, restriction of access to personal data, registration and accounting of actions with personal data, monitoring, and evaluation of the effectiveness of applied measures to ensure the security of PD;
The list of permitted methods of PD processing: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction, both with and without the use of automation tools;
The third party is prohibited from transferring and distributing PD further.
7.1. The Operator takes necessary and sufficient legal, organizational, and technical measures to protect information provided by Users from unlawful or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other unlawful actions with it by third parties. Such actions include, in particular:
Appointment of a person responsible for PD processing;
Implementation of organizational and technical measures to ensure the security of PD during their processing in information systems;
Monitoring incidents of unauthorized access to PD and taking measures to prevent such incidents in the future;
Monitoring the measures taken to ensure the security of PD and the level of protection of personal data information systems.
8.1. The User decides to provide their PD and gives consent to its processing freely, by their own will, and in their own interest. The User expresses their consent to PD processing in the manner specified in clause 4.2 of the Policy.
8.2. The User has the right to receive from the Operator information concerning the processing of their PD.
8.3. The User has the right to send the Operator their requests and requirements (hereinafter referred to as “Request”), including regarding the use of their PD, as well as withdrawal of consent to PD processing. A Request may be sent by the following methods:
8.3.1. In writing to the Operator’s address (Section 11 of the Policy);
8.3.2. In the form of an electronic document (scan, photo copy of the document). The document must be sent from the User’s email address specified during registration on the Website to the email address: info@hackatom.energy.
9.1. The Operator undertakes to inform the User or their legal representative, in the manner prescribed by the legislation of the Russian Federation, about the existence of PD relating to this User, as well as to provide the opportunity to review this PD upon the request of the User or their legal representative within 10 (ten) days from the date of receipt of the request. The specified period may be extended, but not more than 5 (five) working days, after a motivated notification is sent to the User indicating the reasons for the extension.
9.2. The Operator undertakes to provide the User or their legal representative with free access to PD relating to this User.
9.3. Within no more than 7 (seven) working days from the date of submission by the User or their legal representative of information confirming that PD are incomplete, inaccurate, or outdated, the Operator undertakes to make the necessary changes.
9.4. Within no more than 7 (seven) working days from the date of submission by the User or their legal representative of information confirming that such PD were unlawfully obtained or are not necessary for the stated purpose of processing, the Operator undertakes to destroy such PD. The Operator also undertakes to inform the User or their legal representative (parent) of the changes made and measures taken and to take reasonable steps to notify third parties to whom this User’s PD was transferred.
9.5. If the fact of inaccuracy of PD is confirmed, the Operator, based on the information provided by the User or their legal representative, or by the authorized body for the protection of PD subjects’ rights, or other necessary documents, undertakes to clarify the PD or ensure their clarification (if the PD is processed by another person acting on behalf of the Operator) within 7 (seven) working days from the date of submission of such information and to lift the blocking of PD.
9.6. The Operator undertakes to stop processing PD or ensure the cessation of PD processing by a person acting on behalf of the Operator:
In the case of detection of unlawful processing of PD by the Operator or a person acting on behalf of the Operator, within no more than 3 (three) working days from the date of detection;
In the case of withdrawal by the User of consent to PD processing;
In the case of achieving the purpose of PD processing.
9.7. The Operator undertakes to destroy the User’s PD or ensure their destruction (if PD processing is carried out by another person acting on behalf of the Operator) within no more than 30 (thirty) calendar days from the date of achieving the purpose of PD processing.
9.8. If it is not possible to destroy PD within the period specified in clause 9.7 of the Policy, the Operator blocks such PD or ensures their blocking (if PD processing is carried out by another person acting on behalf of the Operator) and ensures the destruction of PD within no more than 6 (six) months, unless another period is established by the legislation of the Russian Federation.
10.1. The Operator reserves the right to make changes to the Policy. The User is obliged to review the text of the Policy each time they use the Website.
10.2. The new version of the Policy comes into force from the moment it is posted in the appropriate section of the Website. Continued use of the Website or its services after publication of the new version of the Policy constitutes acceptance of the Policy and its terms by the User. If the User does not agree with the terms of the Policy, they must immediately stop using the Website and its services.
10.3. All suggestions and/or questions regarding this Policy must be sent to the email address info@hackatom.energy.
ANO Energy of the Future, address (location): 117105, Moscow, Varshavskoe shosse, Building 3, INN 7726385219, OGRN 1167700063300
