CONSENT TO PERSONAL DATA PROCESSING

Version dated September 11, 2026

This Consent to Personal Data Processing (the “Consent”) applies when using the websites, applications, and services of Verilyze, including:

  • https://verilyze.ru;
  • https://demo.verilyze.ru;
  • https://app.verilyze.ru;
  • other subdomains of verilyze.ru;
  • related forms, web applications, APIs, and other Verilyze components

(collectively, the “Service”).

1. Personal Data Operator

The personal data operator is:

Individual Entrepreneur Denis Anatolyevich Denisov
Taxpayer Identification Number (INN): 525813258650
Primary State Registration Number of Individual Entrepreneur (OGRNIP): 325527500044492
Region of state registration: Russian Federation, Nizhny Novgorod Region
Email for personal data matters: [email protected]

hereinafter referred to as the “Operator”.

2.1. The data subject provides this Consent freely, voluntarily, and in their own interest.

2.2. Consent is provided separately from other documents and user confirmations by means of a separate affirmative action, for example:

  • selecting a separate consent checkbox;
  • clicking a separate confirmation button;
  • or taking another action that reliably confirms that Consent has been provided.

2.3. Consent is deemed to have been provided when the user performs the relevant action and submits the form, creates an account, or performs another operation directly associated with this Consent.

2.4. The Operator may record information sufficient to demonstrate that Consent was provided, including:

  • date and time;
  • IP address;
  • session identifier;
  • user identifier, if available;
  • the page and form through which Consent was provided;
  • the version of this Consent;
  • the technical confirmation event;
  • other necessary technical information.

2.5. This Consent does not constitute consent to the dissemination of personal data within the meaning of Article 10.1 of Federal Law No. 152-FZ “On Personal Data.”

2.6. This Consent also does not constitute consent to receive advertising or marketing communications. Such consent, where required, is provided separately.

3. Age of the Data Subject

3.1. By providing this Consent when registering, ordering services, or making full use of Verilyze functionality, the data subject confirms that they are 18 years of age or older and possess the necessary legal capacity.

3.2. If the data subject acts on behalf of a legal entity or individual entrepreneur, they also confirm that they have the necessary authority to perform the relevant actions.

4.1. The scope of personal data depends on the specific Verilyze form or function used by the data subject.

4.2. The Operator processes only those categories of data listed below that the user provides directly or that are necessary to perform the relevant action.

4.2.1. Identification Data

  • surname;
  • first name;
  • patronymic;
  • display name;
  • username;
  • internal account identifier.

4.2.2. Contact Data

  • email address;
  • telephone number, if requested by the relevant function;
  • other contact details voluntarily provided by the user.

4.2.3. Professional and Organizational Information

  • organization name;
  • job title;
  • department;
  • information about affiliation with an organization;
  • information concerning professional activity voluntarily provided by the user.

4.2.4. Account Data

  • login;
  • email;
  • password hash;
  • roles and access permissions;
  • organization affiliation;
  • interface language;
  • time zone;
  • account settings;
  • notification settings;
  • information about account registration and use.

The user’s password is not stored by the Operator in plain text.

4.2.5. Application and Inquiry Data

  • text of the inquiry;
  • contents of the application;
  • information concerning the intended use of Verilyze;
  • information concerning the organization’s needs;
  • comments;
  • correspondence with the Operator;
  • information voluntarily provided during communication with the Operator.

4.2.6. Order Data

  • information about the selected service;
  • order parameters;
  • information about ordered reports;
  • monitoring parameters;
  • analytical task parameters;
  • order execution history;
  • order identifiers;
  • other information necessary to provide the selected service.

4.2.7. User Materials

Depending on the function used, the data subject may provide:

  • texts;
  • files;
  • documents;
  • images;
  • spreadsheets;
  • archives;
  • links;
  • website addresses;
  • queries;
  • instructions;
  • analysis parameters;
  • parsing parameters;
  • other materials.

This Consent applies to the personal data of the data subject contained in such materials.

The transfer and processing of third-party personal data are governed by applicable law, the Personal Data Processing Policy, the Verilyze Terms of Use, and, where necessary, a contract or personal data processing instruction.

4.2.8. Technical Information

In connection with form submission, registration, and use of the relevant function, the following information may be processed:

  • IP address;
  • date and time of the action;
  • browser information;
  • User-Agent;
  • operating system;
  • device type;
  • session identifier;
  • authentication information;
  • technical event logs;
  • information necessary to protect against abuse and confirm that Consent was provided.

5. Purposes of Processing Depending on the User’s Action

This Consent is unified for the Verilyze ecosystem; however, personal data is processed only for purposes related to the specific action performed by the user.

5.1. Application for an Invitation

If the user submits an application for access to Verilyze, the data is processed for:

  • receiving and reviewing the application;
  • identifying the applicant;
  • contacting the applicant;
  • assessing whether access can be provided;
  • issuing an invitation;
  • arranging a product demonstration;
  • maintaining correspondence relating to the application.

5.2. Request for Assistance or Feedback

If the user submits an inquiry, the data is processed for:

  • receiving the inquiry;
  • providing a response;
  • providing technical and informational support;
  • reviewing a proposal or complaint;
  • resolving the issue described by the user;
  • maintaining correspondence relating to the inquiry.

5.3. Registration and Account

When registering and using an account, data is processed for:

  • creating an account;
  • identifying and authenticating the user;
  • managing access;
  • restoring access;
  • providing Service functionality;
  • saving user settings;
  • managing the organization, roles, and access permissions;
  • protecting the account;
  • communicating with the user regarding operation of the Service.

5.4. Ordering a Demonstration Case

When ordering a demonstration analysis, data is processed for:

  • receiving the task;
  • determining analysis requirements;
  • communicating with the customer;
  • preparing the demonstration case;
  • delivering the results;
  • supporting execution of the task.

5.5. Ordering a Report, Research, or Analytical Service

Data is processed for:

  • receiving and clarifying the order;
  • forming an analytical task;
  • performing the analysis;
  • preparing the report;
  • delivering the results;
  • interacting with the customer;
  • performing contractual obligations.

5.6. Ordering Monitoring

Data is processed for:

  • configuring the monitoring object and parameters;
  • performing the user’s task;
  • generating notifications and analytical materials;
  • providing monitoring results;
  • supporting the service.

Data is processed for:

  • receiving materials provided by the user;
  • performing the selected analytical operation;
  • extracting and structuring information;
  • analyzing materials;
  • executing models and algorithms;
  • generating a result;
  • providing the result to the user.

5.8. Parsing Websites and Other Sources

User data is processed for:

  • receiving task parameters;
  • configuring parsing;
  • performing the request;
  • storing the necessary task parameters;
  • informing the user about the result;
  • providing analysis results.

5.9. Security

Regardless of the specific function, minimally necessary data may be processed for:

  • preventing unauthorized access;
  • protecting accounts;
  • preventing automated abuse;
  • detecting fraudulent or suspicious activity;
  • rate limiting;
  • investigating incidents;
  • confirming actions performed by the user;
  • protecting Verilyze infrastructure.

6. Operations Performed on Personal Data

6.1. The data subject consents to the Operator performing the following operations on personal data to the extent necessary for the relevant purpose:

  • collection;
  • recording;
  • systematization;
  • accumulation;
  • storage;
  • clarification and updating;
  • alteration;
  • retrieval;
  • use;
  • comparison;
  • structuring;
  • analysis;
  • anonymization;
  • blocking;
  • deletion;
  • destruction;
  • transfer to persons engaged by the Operator in personal data processing where such transfer is necessary for the stated purpose;
  • other operations provided by law and necessary to fulfill the relevant user request.

6.2. Personal data may be processed both by automated means and without the use of automated means.

6.3. Processing may be carried out using a mixed method.

7. Automated Processing and Artificial Intelligence

7.1. To perform user tasks, Verilyze may use:

  • machine learning algorithms;
  • artificial intelligence technologies;
  • natural language processing models;
  • classification algorithms;
  • entity extraction systems;
  • sentiment analysis algorithms;
  • algorithms for detecting relationships, events, and risks;
  • other automated information analysis tools.

7.2. Such processing may generate analytical indicators, assessments, conclusions, forecasts, and other results.

7.3. Such results may be probabilistic.

7.4. The Operator does not use automated processing by Verilyze to independently make decisions solely on the basis of which legal effects arise for the data subject or the data subject’s rights are otherwise significantly affected.

8. User Materials and Model Training

8.1. The Operator does not use files, documents, texts, links, or personal data contained in them that are provided by users to train its own artificial intelligence or machine learning models.

8.2. User materials are also not transferred for fine-tuning third-party models for purposes unrelated to performing the relevant user task.

8.3. User materials may be processed to the extent necessary for:

  • performing the user’s task;
  • providing Verilyze functionality;
  • maintaining security;
  • diagnosing technical issues;
  • preventing abuse;
  • complying with legal requirements.

8.4. Anonymized and aggregated information that does not permit identification of a specific individual may be used for quality analysis and Service development.

9. Special Categories of Personal Data

9.1. Verilyze is not intended for the deliberate provision by a data subject of special categories of personal data concerning, in particular:

  • racial or ethnic origin;
  • political opinions;
  • religious or philosophical beliefs;
  • health;
  • intimate life.

9.2. The data subject should not include such information in ordinary Verilyze forms unless its processing is necessary and a specific lawful basis exists.

9.3. This Consent itself must not be interpreted as universal consent to process any special categories of personal data for all possible purposes.

10. Persons Engaged in Data Processing

10.1. To operate the Service, the Operator may engage third parties and transfer to them the minimum amount of data necessary where a lawful basis exists.

10.2. Such categories of persons may include:

  • server and cloud infrastructure providers;
  • hosting providers;
  • content delivery and network protection services;
  • anti-abuse and anti-bot services;
  • email service providers;
  • payment organizations;
  • technical contractors;
  • other providers necessary for the operation of the relevant Verilyze function.

10.3. In particular, Verilyze infrastructure may use:

  • Cloudflare;
  • Cloudflare Turnstile;
  • Resend;
  • YooKassa;
  • Russian and other VPS and server infrastructure providers;
  • other providers as the Service develops.

10.4. Web analytics systems and optional cookie technologies are separately governed by the Cookie Policy and the applicable consent management mechanism.

11. Personal Data Localization

11.1. The primary database containing Verilyze users’ personal data is located in the Russian Federation.

11.2. When collecting personal data of citizens of the Russian Federation, the Operator performs the initial recording, systematization, accumulation, storage, updating, and retrieval of such personal data using databases located in the Russian Federation where required by law.

12. Cross-Border Transfers

12.1. Where certain technical providers are used, specific categories of personal data may be transferred across borders in cases permitted by law.

12.2. Such transfers are made only in compliance with applicable legal requirements.

12.3. Before commencing the relevant cross-border transfer, the Operator takes the measures required by law, including notifying the competent authority where such notification is mandatory.

12.4. The Operator seeks to limit the data transferred to the amount necessary for operation of the relevant technical service.

13.1. Consent remains valid from the moment it is provided until the relevant processing purpose is achieved or until it is withdrawn by the data subject, unless another lawful basis permits continued processing.

13.2. Depending on the nature of the interaction, the following indicative retention periods apply.

Invitation Applications and Inquiries

Up to 3 years from the last substantive interaction with the data subject.

Account Data

For the entire period during which the account exists.

After deletion, certain information may be retained for up to 3 years where necessary to protect the Operator’s rights, resolve disputes, maintain security, or comply with legal requirements.

Technical Logs

Generally for 6 to 12 months, unless longer retention is required to investigate a specific incident.

User Files and Materials

For the period necessary to perform the relevant task or until deletion by the user.

After deletion or completion of processing, certain copies may remain in technical backups for a limited period until scheduled backup rotation.

Orders, Payments, and Financial Operations

For the periods necessary to perform the contract and comply with accounting, tax, and other applicable legal requirements.

13.3. After the required retention period expires, personal data is deleted, destroyed, or anonymized unless another lawful basis exists for continued retention.

14.1. The data subject may withdraw this Consent in full or in the applicable part.

14.2. To withdraw Consent, a request must be sent to:

[email protected]

14.3. It is recommended that the request include:

  • the full name or name used in the Service;
  • the email address associated with the relevant data;
  • a request to withdraw Consent;
  • where necessary, information sufficient to identify the relevant account, application, or order.

14.4. The Operator may request reasonably necessary additional information to verify the applicant’s identity and prevent unauthorized deletion or disclosure of another person’s data.

14.5. Upon receipt of the withdrawal request, the Operator ceases processing personal data based solely on this Consent within the periods required by law.

14.6. Withdrawal of Consent does not affect the lawfulness of processing performed before withdrawal.

14.7. After withdrawal of Consent, the Operator may continue processing certain information without consent where such processing is permitted or required by law, including where necessary for:

  • performing an existing contract;
  • complying with a legal obligation;
  • retaining financial and accounting records;
  • protecting the Operator’s rights and legitimate interests;
  • handling claims and disputes;
  • maintaining security;
  • other purposes permitted by law.

15. Consequences of Refusing to Provide Data

15.1. Providing personal data is voluntary.

15.2. However, failure to provide data objectively necessary for a specific function may make it impossible to:

  • review an invitation application;
  • respond to an inquiry;
  • register an account;
  • provide access;
  • restore an account;
  • fulfill an order;
  • prepare an analytical report;
  • configure monitoring;
  • perform a user task;
  • provide other requested Verilyze functions.

15.3. Consent to receive advertising communications is not a mandatory condition for using the main Service functionality.

16. Relationship with Other Documents

16.1. Detailed information about the procedure for processing and protecting personal data is contained in the Verilyze Personal Data Processing Policy.

16.2. The use of cookies and web analytics systems is governed by the separate Cookie Policy.

16.3. Receipt of advertising and marketing communications is governed by the separate Consent to Receive Advertising and Informational Materials.

16.4. This Consent must be provided separately from the documents and consents listed above where required by law.

17. Confirmations of the Data Subject

By providing this Consent, the data subject confirms that they:

  1. reviewed this Consent before providing it;
  2. understand the purposes and conditions of personal data processing;
  3. provide the data voluntarily;
  4. confirm that the information provided is accurate to the extent within their control;
  5. are 18 years of age or older when using functions subject to the relevant age restriction;
  6. understand that Consent may be withdrawn;
  7. understand that withdrawal of Consent does not terminate processing where an independent lawful basis exists after withdrawal;
  8. understand that this Consent does not automatically extend to advertising communications;
  9. understand that this Consent does not constitute consent to disseminate their personal data to an indefinite number of persons.

18. Operator Contact Details

For questions relating to personal data processing and this Consent:

Individual Entrepreneur Denis Anatolyevich Denisov
Taxpayer Identification Number (INN): 525813258650
Primary State Registration Number of Individual Entrepreneur (OGRNIP): 325527500044492
Russian Federation, Nizhny Novgorod Region
[email protected]

Document: Consent to Personal Data Processing
Version: 1.0
Revision date: September 11, 2026
Operator: Individual Entrepreneur Denis Anatolyevich Denisov

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