PRIVACY POLICY FOR THE MOBILE APPLICATION “MEDIKTEST”

1. DEFINITIONS

“Law” means the Federal Law of the Russian Federation “On Personal Data” with all amendments and supplements, as well as other legislative acts of the Russian Federation.

“Controller” means the person responsible for the processing and protection of Personal Data of Users located in the EU within the meaning of the General Data Protection Regulation (GDPR) of April 27, 2016.

“Mobile Application” means the software (with all existing additions and improvements) designed to operate on smartphones, tablets, watches, and other mobile devices, developed for a specific platform (iOS, Android, Windows Phone, etc.). For the purposes of this Policy, the Mobile Application refers to the following software: MEDIKTEST.

“Personal Data” means the totality of personal data and/or non-personalized information about the User, provided by the User to the Rights Holder and/or automatically collected by the Rights Holder and/or third parties.

“Policy” means this Privacy Policy of the Mobile Application (with all existing additions and amendments).

“User” means a legal entity or individual who has downloaded the Mobile Application to a smartphone, tablet, watch, or any other mobile device and/or has activated such Mobile Application on one of the specified devices.

“User Agreement” means the agreement concluded between the Rights Holder and the User regarding the procedure, rules, and specifics of the User’s use of the Mobile Application. The User accedes to such agreement and has no right to make and/or demand any changes or additions to it.

“Rights Holder” means the following person who holds exclusive ownership rights to the Mobile Application:

Individual Entrepreneur Aleksey Vladimirovich Anisov, Russia, village of Kislovka, Marina Tsvetaeva Street 4
Email: mediktest.official@gmail.com

“Processor” means a person who, within the meaning of the GDPR, performs the storage and/or processing of Personal Data received from Users on behalf of the Controller.

“Cookies” means small files sent by any mobile application or website and placed on smartphones, tablets, watches, and other mobile devices of the User to improve the operation of such applications or websites, as well as the quality of the content posted on them.

2. SCOPE OF THE POLICY

General provisions

This Policy applies exclusively to Personal Data obtained from the User in connection with the use of the Mobile Application. The provisions of this Policy are aimed at:

  1. determining the types of Personal Data collected, the directions and purposes of use (processing) of Personal Data, as well as the sources of obtaining such Personal Data;
  2. determining the rights of the User regarding the protection of the confidentiality of their Personal Data;
  3. determining the persons responsible for the processing and storage of Personal Data, as well as third parties to whom such data is disclosed (in whole or in part).

The rules of this Policy do not apply in cases where third parties process Personal Data voluntarily provided by the User.

By installing and/or activating the Mobile Application on a smartphone, tablet, watch, or other mobile device, the User agrees to the terms of this Policy and gives consent to the Rights Holder to collect, process, retain, and store Personal Data in accordance with this Policy.

If the User does not agree with the terms of the Policy and/or certain terms of the Policy are unclear, the User must immediately stop using the Mobile Application.

User rights regarding the protection of personal data

In connection with providing Personal Data, the User automatically receives the following rights:

  1. to receive data concerning the processing of their Personal Data (grounds and purposes of such processing, applied processing methods, information about persons who have access to them or to whom they may be disclosed on the basis of a contract or the Law);
  2. to receive data on the location and identification data of persons performing the processing of Personal Data;
  3. to receive data on the retention periods of Personal Data;
  4. to receive data on the cross-border transfer of Personal Data that has been carried out or is envisaged;
  5. to receive information on the location and identification data of persons performing the storage of Personal Data;
  6. to appeal the actions or inaction of the Rights Holder to the authorized body for the protection of the rights of personal data subjects or in court;
  7. to receive compensation for damages and/or moral harm in court as a result of violations of the User’s rights to the protection of their Personal Data committed by the Rights Holder and/or third parties;
  8. to exercise other rights in the field of personal data protection provided by the Law or the provisions of this Policy.

3. LIST OF PERSONAL DATA COLLECTED

Non-personalized information about users

In connection with the use of the Mobile Application, the Rights Holder may automatically collect and process the following non-personalized information about the User:

  1. information about traffic, possible number of clicks, logs, and other data;
  2. information about the device (identification number, mobile operator network) from which access is made, operating system, platform, browser type and other browser information, IP address.

Personal data about users

The User provides the Rights Holder with the following personal data:

  1. email address;
  2. data contained in the User’s personal account (profile);
  3. data on orders/purchases made by the User and/or services received/paid through the Mobile Application;
  4. data and information obtained as a result of combining certain Personal Data of a specific User, as well as data and information obtained about the User from third parties (partners, marketers, researchers).

The User is the sole person responsible for the completeness of the personal data provided and is obliged to promptly update, verify, and correct them on a regular basis.

The Rights Holder assumes that all personal data provided by the User is accurate and that the User maintains such information up to date.

Information about transactions

The User may make payments for goods or services through the Mobile Application by entering payment card information and identification data of the card owner in a designated field. The User may make payments in the Mobile Application by the following methods:

The collection and processing of User data in this case is carried out exclusively for the purposes of processing payments, preventing fraud, and complying with other requirements of the Law.

The User gives consent to the Rights Holder and the relevant payment system or banking institution through which the payment is made to access and collect such Personal Data, and also agrees to the privacy policy of the relevant payment system or banking institution.

Use of cookies

This Mobile Application uses certain Cookies to save the IP address, User preferences, or the type of device used for the following purposes:

  1. maintaining visit statistics and site traffic;
  2. personalizing the data displayed to the User;
  3. saving data necessary for User identification, including when accessing from different devices;
  4. displaying advertising in accordance with the User’s interests and preferences.

The Mobile Application may use both its own Cookies belonging to the Rights Holder and third-party Cookies.

The Mobile Application uses the following Cookies:

  1. Technical (functional) Cookies that are needed to control traffic and data transfer, to identify Users and provide the User with access to the content of the Mobile Application, and without which the use of the Mobile Application is functionally limited, as well as to prevent providing recommendations that do not match the User’s interests.
  2. Statistical Cookies that are needed to track the frequency of visits by Users, to identify how the User uses the Mobile Application, and to identify the type and kind of content that is popular or interesting to the User.
  3. Advertising (marketing) Cookies that are needed to place advertising and/or marketing notices in the Mobile Application that match the User’s preferences and interests.
  4. Third-party Cookies that are set by third parties with the User’s permission and are intended for conducting statistical research regarding the User’s behavior on the Internet and/or sending personalized advertising or marketing materials to the User and/or providing goods or services.

4. PURPOSES OF COLLECTION AND PROCESSING OF PERSONAL DATA

Definition of processing purposes

The collection and processing of Personal Data is carried out for the following purposes:

  1. to analyze User behavior and identify User preferences for certain types of content;
  2. for the proper and correct operation of the Mobile Application, improving the functionality, content, internal architecture, and features of the Mobile Application;
  3. to identify the User;
  4. to provide personalized advertising and marketing materials;
  5. to comply with the requirements of the Law;
  6. to track orders/purchases made by the User through the Mobile Application;
  7. for technical support of the Mobile Application, identifying problems in its operation and resolving them;
  8. to maintain communication with the User;
  9. to fulfill other obligations of the Rights Holder that have arisen before the User;
  10. for conducting statistical research;
  11. for any other purposes, subject to obtaining separate consent from the User.

The processing of Personal Data is carried out on the basis of the principles of: (1) legality of purposes and methods of processing; (2) good faith; (3) compliance of the purposes of processing Personal Data with the purposes predetermined and stated during the collection of such Personal Data; and (4) compliance of the volume and nature of the processed Personal Data with the stated purposes of their processing.

Conditions for processing personal data

The processing of Personal Data is carried out in cases of: (1) obtaining consent from the User; or (2) achieving by the Rights Holder the purposes provided for by an international treaty or the Law; or (3) the User providing their Personal Data to an unlimited number of persons; or (4) fulfilling other obligations of the Rights Holder to the User, including but not limited to providing certain content to the User; or (5) saving the life or health of the User when consent to the processing of their Personal Data cannot be obtained in advance.

In the case of anonymization of Personal Data, which does not allow direct or indirect identification of the User, subsequent use and disclosure of such data to third parties is permitted and the rules of this Policy no longer apply to them.

The Rights Holder takes all possible measures to protect the confidentiality of the received Personal Data, except in cases where the User has made such data publicly available.

The processing of Personal Data is carried out using automation tools and without using such automation tools.

5. THIRD-PARTY ACCESS TO PERSONAL DATA

Use of analytics platforms

The Rights Holder uses the Yandex analytics platform for: (1) tracking the frequency of visits by Users; (2) tracking how the User uses the Mobile Application and/or its content; and (3) identifying the type and kind of content that is popular among Users. The User also gives consent to the Rights Holder to use information obtained about the User from Yandex.

For the specified purposes, the Yandex analytics platform may collect data about the IP address, geolocation, User behavior, as well as their preferences and interests regarding certain content.

The Yandex analytics platform receives access to Personal Data in order to provide the Rights Holder with an understanding of how effectively the Mobile Application is working, what content is popular, how effectively advertising is placed in it, and for the purposes of developing and/or improving the existing marketing strategy of the Rights Holder.

By installing the Mobile Application, the User agrees to the Privacy Policy of Yandex, as well as to the automatic installation of the corresponding Cookies on the User’s device.

Disclosure of personal data to third parties

The Rights Holder has the right to disclose Personal Data to: (1) its affiliated persons, branches, and representative offices, both in the Russian Federation and in other countries; (2) successors of the Rights Holder that have arisen as a result of liquidation, reorganization, or bankruptcy and that have received exclusive ownership rights to the Mobile Application; (3) payment service providers or banking (financial) institutions for conducting User transactions through the Mobile Application; (4) third parties exclusively for the purposes of providing the User with certain content or access to it; (5) third parties when the User has given consent to the disclosure, transfer, or processing of their Personal Data, as well as in other cases directly provided by the Law or this Policy.

The Rights Holder discloses Personal Data only if it is (1) confident that third parties will comply with the terms of this Policy and take the same measures to protect the confidentiality of Personal Data as the Rights Holder itself, and (2) consent for such disclosure has been previously expressed by the User and/or is permitted under the Law.

Third-party advertising

The content of the Mobile Application may contain advertising banners and/or links to third-party websites. The User’s use of such websites (by clicking on a link or by any other means) may result in the collection, processing, and use of Personal Data, as well as the possible automatic transfer of Cookies to the User’s device from which the transition to third-party websites is made.

The Rights Holder bears no responsibility for the methods, means, and procedures for processing Personal Data by third-party websites. Consequently, the Rights Holder is also not a responsible person in the event of disclosure of Personal Data to an unlimited number of persons in connection with the User’s use of such websites.

The Rights Holder strongly recommends that each User familiarize themselves in detail with the personal data protection policies of the websites they use.

The User has the right at any time to disable such advertising banners and/or links by performing the following actions: in the mobile application, go to the profile tab, open the store, and purchase the “MedikTest+” subscription or “Ad Removal”.

6. ADVERTISING

Advertising in the mobile application

The Rights Holder, together with the content, places various advertising and marketing materials in the Mobile Application, taking into account the identified preferences of the User for one or another content. Placement of advertising in the Mobile Application involves the installation of certain Cookies on the User’s device.

The User has the right at any time to opt out of such advertising by performing the following actions: in the mobile application, go to the profile tab, open the store, and purchase the “MedikTest+” subscription or “Ad Removal”.

7. COMPLAINTS AND REQUESTS TO THE RIGHTS HOLDER

Request to stop processing personal data

Each User has the right to express their objection to the Rights Holder against the processing and/or storage of their Personal Data. Such objection may be expressed as follows: send an email with the request to mediktest.official@gmail.com.

Request for information about personal data

If the User has questions related to the procedure for applying or using this Policy, the procedure and/or method of processing Personal Data, the User may ask such a question as follows: send an email with the request to mediktest.official@gmail.com.

Modification (update, supplement, correction) or deletion of personal data

The User has the right at any time to independently change or delete their Personal Data, except in cases where such change or deletion may lead to: (1) violation of the rules of this Policy; or (2) violation of the Law; (3) the nature of such Personal Data constitutes evidence in any legal proceedings arising between the Rights Holder and the User. To do this, the User needs to delete their personal account (profile) in the Mobile Application.

The Rights Holder has the right at any time to delete the User’s personal account/profile, as well as all Personal Data about the User, if they have violated the terms of this Policy and/or the User Agreement.

8. DATA RETENTION AND STORAGE

Storage is carried out by third parties on behalf of the Rights Holder. The User gives consent to the storage of their Personal Data by third parties on behalf of the Rights Holder, provided that such third parties maintain the confidentiality of the received Personal Data. Information storage functions are entrusted to: YANDEX.CLOUD LLC (hereinafter the “Custodian”). Personal Data is stored on the territory of the Russian Federation.

Storage is carried out for the entire period of the User’s use of this Mobile Application.

The Rights Holder undertakes to immediately destroy or anonymize the User’s Personal Data after the User ceases to use the Mobile Application.

9. ACCESS BY MINORS TO THE MOBILE APPLICATION

Users in the Russian Federation

The use of the Mobile Application is intended for persons over 18 years of age, who gain access to it only upon providing prior consent to the processing of their Personal Data.

If the User is a minor, they must immediately stop using this Mobile Application.

Users in the European Union

The use of the Mobile Application is intended for persons aged 16 and older, who gain access to it only upon providing prior consent to the processing of their Personal Data.

If the Rights Holder becomes aware that the User’s age does not meet the required age for using the Mobile Application, the Rights Holder undertakes to immediately block access for such User to the Mobile Application.

10. PERSONAL DATA PROTECTION

Protecting the confidentiality of Personal Data is a primary and important task for the Rights Holder. The Rights Holder adheres to all required international standards, rules, and recommendations for the protection of Personal Data.

The Rights Holder has implemented a number of technical and organizational methods aimed at protecting Personal Data from disclosure or unauthorized access by third parties.

11. USERS LOCATED IN THE EUROPEAN UNION

General provisions

Since the Mobile Application is available to users from the European Union, the Rights Holder undertakes to additionally comply with the provisions of the GDPR.

The Controller within the meaning of this Policy is the Rights Holder.

The Processor within the meaning of this Policy is the Custodian pursuant to Section 8 of the Policy.

The Rights Holder stores Personal Data for a reasonable period necessary to achieve the purposes of processing, but not less than the period established by the local legislation of the EU member state in which the Mobile Application is available, for the storage of a particular type of Personal Data. Upon expiration of the storage period, the Rights Holder undertakes to immediately destroy or anonymize such data.

User rights in the field of personal data protection

In accordance with Chapter 3 of the GDPR, Users located in the European Union have the following rights in the field of Personal Data protection:

  1. the right to be informed;
  2. the right of access;
  3. the right to rectification;
  4. the right to erasure;
  5. the right to restrict processing;
  6. the right to data portability;
  7. the right to object.

12. HEALTH DATA

12.1. Nature of the application and its connection to the medical field

The mobile application “MedikTest” falls under the category of “Education and Medical Literature” and is intended exclusively for preparing medical professionals for the accreditation procedure in the Russian Federation.

The Application contains:

The content of the Application includes medical terminology, descriptions of diseases, diagnostic and treatment methods, pharmaceutical drugs, and other medical information. This content is educational reference material based on open sources (the question bank of the Federal Methodological and Accreditation Center — FMZA) and is used exclusively for educational purposes.

12.2. User health data: non-collection statement

The “MedikTest” Application does not collect, store, process, transmit, or access any personal health data of Users (Health Data).

Specifically, the Application does not collect the following categories of health data:

The Application does not request access to device health APIs and services, including but not limited to: Apple HealthKit, Google Fit, Health Connect, Samsung Health, and similar platforms.

12.3. Connection between application functionality and medical content

The medical content presented in the Application is standardized educational material designed to test the professional knowledge of medical specialists. This content:

12.4. Educational activity data

During the use of the Application, educational activity data of the User may be collected, such as:

This information constitutes educational activity data, not health data (Health Data). This data:

12.5. Medical disclaimer

The “MedikTest” Application:

All content of the Application is of an exclusively educational nature and is intended for preparation for the professional accreditation procedure for medical specialists in accordance with the requirements of the legislation of the Russian Federation.

12.6. Data security in the context of Health Policy

Although the Application does not collect health data, the Rights Holder applies appropriate security measures to protect all user data, including educational activity data:

13. FINAL PROVISIONS

Availability of the policy text

Users may review the terms of this Policy at the following link: https://mediktest.ru/privacy_policy.html.

This Policy may be translated into a foreign language for Users who access the Mobile Application from outside the Russian Federation. In the event of a discrepancy between the original text (Russian) and its translation, the original language shall prevail.

This edition of the Policy is effective as of March 25, 2026.

Amendment and supplement of the policy

This Policy may be changed from time to time. The Rights Holder bears no responsibility to the User for changes to the terms of this Policy without the permission and/or consent of the User.

The User is obliged to regularly check the provisions of this Policy for possible changes or additions.

Applicable law

This Policy has been developed in accordance with the current legislation on the protection of personal data of the Russian Federation, in particular, with the norms of the Federal Law of July 27, 2006, No. 152-FZ “On Personal Data” (with all additions and amendments), the Federal Law of July 21, 2014, No. 242-FZ “On Amendments to Certain Legislative Acts of the Russian Federation Regarding the Clarification of the Procedure for Processing Personal Data in Information and Telecommunication Networks” (with all additions and amendments), as well as the provisions of the General Data Protection Regulation (GDPR) of April 27, 2016.

Risk of disclosure

Regardless of the measures taken by the Rights Holder to protect the confidentiality of the received Personal Data, the User is hereby deemed to be duly informed that any transfer of Personal Data over the Internet cannot be guaranteed to be secure, and therefore the User makes such transfer at their own risk.