RTsim Privacy Policy

This Privacy Policy (the “Policy”) explains how we, RTsim LLC (“RTsim”, “we”, “us” etc.), collect and use your Personal Data (the “Data”). Before using our services, please read this Privacy Policy carefully to learn how we collect, use, disclose, and protect your Personal Data. Please note that by using our services you agree with the following.
By clicking "Agree" on the account registration screen, you agree and consent to RTsim collecting, using, disclosing, and/or sharing your personal data, and disclosing your personal data to our authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy.
If you do not agree with the terms of this Privacy Policy, you must not access or use any Services.
This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your personal data, and any consents you may have provided in connection with this Privacy Policy are in addition to our lawful bases for processing under applicable law to handle or process your personal data.
This Privacy Policy describes how we collect and process the Data of our customers outside the Russian Federation. For the information about processing the Data of our Russian customers please visit https://rtsim.ru/privacy-policy

I. What is Personal Data and other expressions
Personal Data is the information about you we need to process to provide you our services. The information varies depending on what services you use and is strictly limited to the purposes of processing.
Processing your Personal Data includes collecting, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure and destruction of your Data.
Depending on how you use our Services, we collect and process data that you ask us to process or which you voluntarily provide, or data that we otherwise collect.
The Services include our websites, RTsim.Career Software, RTsim Software, RTsim.Adviser Software.

II. What we collect
We collect your Personal Data in a number of different ways:
Data that you provide to us – you may provide us with your Personal Data when you for example create an account profile for our customer portal or register for one of our events or newsletters.
Data that we obtain through your use of our Services or your visit to our websites – we collect Data related to how and where you use or purchase Services and how you use our websites.
Information gathered through external sources – in order to ensure we have the most up to date information about you to provide you with better products and increasingly tailored services, we will combine Data that we hold about you, with additional information which is publicly available or obtained through authorized third parties.
Information gathered through Social Media Pages – When you communicate with us through a RTsim Social Media Page (for example, when you comment on, share or react to a post, upload media, send a personal message or subscribe to a RTsim Social Media Page), we may receive Data about you.
The categories of Data we process are:
Contact Information Data – which consists of data such as your full name, job position, company or employer, mobile phone number, email address.
Education and Professional Experience Data – which consists of data regarding your education and work history.
Customer Support Data – which consists of data which is required to provide you with customer support, including correspondence with RTsim staff and information submitted as part of a troubleshooting technical assistance or support request, or as part of a survey, chat, feedback or comment.
Technical Data – which consists of device and network connection information when you interact with RTsim websites and applications, including but not limited to advertisements and services accessed during your visit, and the date and time of each visitor request, and user identifier information, including IP address, information on your operating system, and internet and other electronic network activity information.
Customer Profile Data - data derived from your interactions with our Services, such as preferences, usage patterns, and feedback.
User Content – which consists of data of your chats with internal AI in our services.
Cookies – which are small text files stored in your computing or other electronic devices when you visit our Services.

III. Purposes and legal basis
RTsim may process your Data for the purposes contained in the table below.

Purpose of processing

Categories of Personal Data

To establish and manage business and customer relationships, including to create, administer and provide you with access to your account

·  Contact Information Data

·  Education and Professional Experience Data

·  Customer Support Data

·  Technical Data

·  Cookies

To answer your inquiries and to put you in contact with our representatives to respond to your request for a quote (including sending catalogues, specifications and technical materials), and to provide troubleshooting, support and technical assistance on our Services

·  Contact Information Data

·  Customer Support Data

·  Cookies 

To analyze and better understand your business needs and to improve our Services, including our customer services

·  Contact Information Data

·  Education and Professional Experience Data

·  Customer Support Data

·  Technical Data

·  Customer Profile Data

·  Cookies

To provide you with information about our offers on Services (including invitations to events including webinars, exhibitions, campaigns, seminars and the possibility of hosting such events) through websites and applications, or by email

·  Contact Information Data

·  Technical Data

·  Customer Profile Data

·  Cookies

To detect and prevent illegal activity, including fraud, and to keep our Services and information technology systems secure, and to protect establish, exercise, or defend our and third parties’ rights, to defend against lawsuits

·  Contact Information Data

·  Customer Support Data

·  Technical Data

·  User Content

To comply with our legal obligations

·  Contact Information Data

·  Education and Professional Experience Data

·  Customer Support Data

·  Technical Data

If you fail to provide certain information as requested, we may not be able to provide you with certain Services and/or we may not be able to perform a contract we have entered into with you.
Our Services are not directed to, or intended for, the individual under 18 (“Minors”). We do not knowingly collect Data from Minors. If you have reason to believe that a Minor has provided Data to us through the Services, please contact us via the contact details set out below. We will investigate any notification and, if appropriate, delete the Data from our systems.
You should ensure that all personal data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with any products and/or services you have requested.
By voluntarily providing your personal data for a specific purpose or where the collection, use and/or disclosure of your personal data is reasonably necessary for the conclusion and/or performance of a contract, between you and us or any other organisation entered into at your request, you explicitly consent to our processing of such data for that purpose in accordance with this Policy.
Further, in relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use and/or disclose your Data. If so, we will collect, use and/or disclose your Data for these purposes as well.

IV. Cookies
Our websites, applications and online services may use cookies or similar technologies, including unique identifiers used to identify an application or device you are using. Cookies and similar technologies may store or access certain information about your application or device, which helps us to provide or improve our Services. If used by us without your consent, these cookies and similar technologies are strictly necessary to provide you with certain functionalities or features of our websites or to provide you with a Service. Other cookies and similar technologies (e.g., cookies for marketing purposes) will only be used based on your consent.
We use the following categories of cookies:
- essential (technical) – necessary for the Services to operate and to remember visitor settings and sessions; the Services cannot function without them;
- analytical – help us understand how visitors use the Services and improve its performance; we use the “Yandex.Metrica” ​​service.
The “Yandex.Metrica” (“Metrica”) ​​service is provided by Yandex LLC (“Yandex”, TIN 7736207543) and is used to analyze visit statistics, user behavior, and the effectiveness of the Site's content.
During operation, Metrica automatically collects the following information about Site users:
·      browser type, version, and language;
·      operating system;
·      data on actions taken on the Site (pages visited, time spent on the Site);
·      referral source (search engine, advertising, social networks);
·      technical device parameters (screen, resolution, etc.).
We use data obtained via Metrica ​​exclusively to analyze traffic statistics, improve the quality of the Site, and ensure the Site's technical stability and security.
Processing is carried out with the User's consent. Consent is provided via a notification banner on the site where the files are collected.
All information collected via Metrica ​​is anonymized. We are unable to identify a specific User. Metrica ​​services employ IP address anonymization technologies, and data processing is performed in an aggregated form.
Technical data is collected by the Yandex.Metrica service directly from your device for analytical purposes in accordance with Yandex's User Agreement and Privacy Policy, available at https://yandex.ru/legal/confidential/. This data processing is technical in nature and is carried out solely for aggregated statistical purposes.
Processing and storage period: until a request to cease processing or a withdrawal of consent is received from the User, but no longer than three years from the date of the last visit to the Site.
The User may independently manage the use of Metrica by:
·         installing a tracker blocker or the Yandex "Protect" extension;
·         disabling cookies in their browser settings;
·         using the "Do Not Track" feature;
·         visiting the page https://yandex.ru/support/metrika/general/opt-out.html to disable data collection by Metrica.
The User has the right to:
·         receive information regarding the processing of data collected via Metrica;
·         request the correction, blocking, or deletion of such data;
·         withdraw consent for processing.
Disabling essential (technical) cookies may result in certain Service functions becoming unavailable.

V. How long we store Data
We will retain your Personal Data for the duration of your interaction with our Services, unless a shorter retention period is required by applicable laws or the data is no longer necessary for the purposes for which the data was obtained. Once you no longer interact with our Services, as permitted by applicable laws, we will retain your Personal Data for the period of time that enables us to:
·         fulfil our legal obligations, including legal retention periods;
·         initiate, investigate or defend against legal claims;
·         address your questions, requests or complaints; and
·         keep our records for analysis and audit purposes.
Where RTsim is processing your Personal Data on the basis of your consent, RTsim will use your Personal Data (i) only for as long as it is required to fulfil the purposes set out above or (ii) until you withdraw your consent.
To the extend required under applicable laws, we will delete or otherwise destroy your Personal Data after the retention period has elapsed, as described above.

VI. Data Protection
We use appropriate technical and organizational measures to protect the personal data that we collect, use, disclose, and process. These measures are designed to provide a level of security appropriate to the risk of processing. Specific measures we use include encrypting your personal data in transit and at rest; developing and implementing an Information Security Programme in accordance with a standard industry framework; employing advance malware protections; implementation of other reasonable security defences (including vulnerability management, access management and recovery/resilience measures).
Nevertheless, no data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we take reasonable measures protect your personal data, we cannot completely guarantee the security of any personal data you transmit to us and you do so at your own risk. We cannot and do not guarantee security of your account, devices, or personal data in connection with your use of the Services. Where you have created an account with us and set a password to access our Services, it is your responsibility to keep this password secure and confidential.

VII. Disclosure of Data
Where relevant and necessary, RTsim may provide access to your Data or transfer your Data to:
·         RTsim Business Partners, including service providers (e.g., cloud service, IT maintenance and support services, marketing services, data digitization services and system development services), who support us in connection with the purposes set out in this Policy or in our business relationship with you.
·         Public authorities, justice and law enforcement, fiscal authorities and other authorities assigned with investigative powers or public authority, to the extent we are legally required or have legitimate interests to do so;
·         With professional advisors, investigators, or credit reference agencies to the extent we are legally required or have legitimate interests to establish, exercise or defend our legal rights, or prevent or detect crime and fraud.

VIII. Storage and Processing Location
Your personal data will be processed outside of the jurisdiction in which you are located. The main jurisdiction in which we collect, store and process Data is the Russian Federation.

IX. Your rights
We respect the rights granted to you under applicable laws. These include the right to access your Data that we hold about you, to rectify or erase certain Data, to restrict processing of your Data and to get an electronic copy of your Data for purposes of transmitting it to another company.
In addition, where we rely on our legitimate interest to process your Data, you have the right to object to such processing, wholly or partly, on grounds related to your particular situation and in accordance with the laws applicable to you. Where we rely on your consent to process your Data, you may have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. Under applicable laws you may also have the right to lodge a complaint with your supervisory authority.
You may withdraw your consent as provided for under the applicable law. However, if you withdraw your consent to any or all collection, use, and/or disclosure of your personal data for one or more purposes, depending on the nature of your request, we may not be in a position to continue to provide our products or services to you, administer any contractual relationship already in place, or perform or conclude an existing or prospective agreement. This may also result in the termination of any agreements you have with us and/or you being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved.
To exercise your rights, please submit a written request to info@rtsimtwins.com with the subject line “Data Subject Request”. We will respond to your request within 30 days, subject to any legal extensions.
Please note that if your personal data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf.

X. Other terms
Our Services may be provided to you at the request of the organization by which you are employed or which you otherwise represent. If this is the case, our processing of your Data may be subject to a data processing agreement between your organization and us. In such instance, you should first direct any questions about how your Data is processed to your organization.
We are not responsible for the privacy practices of third parties. If you access or use any third party products or services, you should check the applicable third party privacy policy to determine how they will handle any personal data you provide to them or which they collect from you. We are not responsible for any third party’s improper use or disclosure of any personal data.
In the event of a conflict between this Policy and the Data processing terms of an agreement between you (or your organization) and RTsim for our Services, the terms of such agreement will prevail unless otherwise set forth in the agreement between you (or your organization) and RTsim.
Nothing in this Policy shall be construed to deprive you of the mandatory protections afforded to you under the data protection laws of your country of residence.
We may update this Privacy Policy from time to time in response to changing legal, regulatory, technical or business developments. Any changes to this Privacy Policy will be communicated by us updating the Privacy Policy accessible via the Services. The updated Privacy Policy will become immediately effective once updated or at such date as we may specify. We may also in our discretion provide notice to you changes to the Privacy Policy via such means as we deem appropriate, such as by email (sent to the e-mail address specified in your account) or by means of a notice via the Services prior to the change becoming effective. To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of the Privacy Policy as modified from time to time. Please check back regularly for updated information on the handling of your personal data.

XI. Our contacts
If you have any questions or wish to contact us for any reason, please be free to contact us via following addresses:
RTsim LLC
Russian Federation, Moscow, intracity territory of the city, Mozhaiskii municipal district, territory of Skolkovo Innovative Centre, 42 Bolshoi Avenue, building 1, floor 1, room 150, workplace 11
E-mail: info@rtsimtwins.com
Web-site: https://rtsimskills.online/