Privacy Policy

1. General provisions

1.1. Personal data controller: CortexNeo Limited Liability Company (LLC "CORTEXNEO").

1.2. Primary State Registration Number (OGRN): 1262100002053
Taxpayer Identification Number (INN): 2100032137

1.3. Registered address: Building 5, Tserkovnaya Street, Starye Urmary Village, Chuvash Republic — Chuvashia, 429409, Russian Federation.

1.4. The controller is registered in the register of personal data operators maintained by Roskomnadzor (Federal Service for Supervision of Communications, Information Technology and Mass Media): registration number 52-26-259848, notification registration date — 5 July 2026, processing start date — 5 July 2026.

1.5. This Policy is developed in accordance with Federal Law No. 152-FZ of 27 July 2006 "On Personal Data" and other applicable regulations of the Russian Federation governing personal data protection.

1.6. By using the Site, the user confirms that they have read and understood the terms of this Policy.

2. What data we collect

2.1. Data voluntarily provided through the Site contact form:

• name;
• job title and/or organization (if provided);
• phone number.

2.2. Technical and web analytics data collected automatically when you visit the Site:

• IP address;
• browser type and version, operating system, device type;
• cookies;
• Site interaction data (pages visited, time on site, referral source).

Technical data is collected using Yandex.Metrica. Processing by the analytics service is also governed by that service's privacy policy.

2.3. The Site is not intended for persons under 18 years of age. We do not knowingly collect personal data from minors.

3. Cookies

3.1. Cookies are used to enable web analytics and improve Site performance.

3.2. On your first visit, the Site displays a notice about cookie use. By continuing to use the Site after reviewing the notice, you consent to their use.

3.3. You may disable cookies in your browser settings; however, this may affect the correct operation of certain Site features.

4. Purposes of personal data processing

4.1. Personal data is processed for the following purposes:

• contacting the user in response to a request submitted via the contact form;
• arranging product demonstrations and consultations;
• communication and handling of inquiries;
• analyzing and improving Site quality based on anonymized web analytics data.

4.2. Personal data is not used for purposes not specified in this Policy without obtaining additional user consent.

5. Legal grounds for processing

5.1. Personal data is processed based on the data subject's consent, expressed by checking the consent box when submitting the contact form, as well as in other cases provided for by the legislation of the Russian Federation.

5.2. The Site contact form includes a separate consent element that is not enabled by default, with the text: "By submitting, you agree to personal data processing and the privacy policy" and a direct link to this Policy.

6. Processing and data transfer conditions

6.1. Personal data is processed using automated means and without them.

6.2. Access to personal data is granted exclusively to employees and contractors of the controller who require such access to achieve the processing purposes set out in Section 4, provided they comply with confidentiality requirements.

6.3. The controller does not sell personal data to third parties.

6.4. Personal data may be transferred to third parties only:

• where lawful grounds are provided by the legislation of the Russian Federation;
• to ensure technical infrastructure (hosting provider, web analytics service), provided such parties ensure an adequate level of data protection;
• with the data subject's separate consent.

6.5. Users' personal data is processed and stored on servers located in the Russian Federation. The controller does not carry out cross-border transfer of personal data.

7. Retention periods

7.1. Personal data is retained no longer than necessary to achieve the processing purposes set out in Section 4, or for periods established by the legislation of the Russian Federation.

7.2. Upon expiry of the retention period, personal data shall be destroyed or anonymized.

8. Rights of the data subject

The data subject has the right to:

8.1. Receive information relating to the processing of their personal data, including details on purposes, methods, and retention periods.

8.2. Request rectification, blocking, or erasure of personal data if it is incomplete, outdated, inaccurate, unlawfully obtained, or no longer necessary for the stated processing purpose.

8.3. Withdraw consent to personal data processing by sending a corresponding notice to the controller.

8.4. Lodge a complaint regarding the controller's actions or inaction with the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) or in court.

9. Personal data security measures

9.1. The controller implements necessary legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, distribution, and other unlawful actions by third parties. In particular, the following are applied:

• data encryption;
• access restrictions;
• regular security audits.

10. Withdrawal of consent and data deletion

10.1. To withdraw consent to personal data processing or request data deletion, the user may contact the controller using the details in Section 12 or via the Site contact form.

10.2. The controller reviews the request and takes necessary action within 30 days of receipt, in accordance with the requirements of the legislation of the Russian Federation.

11. Changes to the Policy

11.1. The controller may amend this Policy. The current version is always published on this page of the Site.

11.2. In the event of material changes affecting the scope or purposes of personal data processing, the controller notifies users by posting relevant information on the Site.

12. Contact information

12.1. For any questions regarding this Policy and personal data processing, please contact us at legal@cortexneo.digital

Last updated: 11 July 2026.