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Confidentiality Policy MTS StartUp Hub

MTS StartUp Hub Privacy Policy


1. General Provisions

1.1. This privacy policy (hereinafter referred to as “Policy”) regulates processing of personal data filed by the Applicant via the Website for participation in the Project or Open Window including application and Supplementary Documents.

1.2. The Application shall be sent via the Website by way of completing the application questionnaire fields and pressing the key “file an application”. By filing an application and presenting the Supplementary Documents, the Applicant expresses its specific, informed and responsible consent to processing of its personal data according to Policy and confirms that it has read and understood the Policy.

2. Terms and Definitions

2.1. Applicant – a legal entity, an individual entrepreneurthat has submitted an application for participation in the Project or Open Window.

2.2. Participant – an Applicant qualified by the Company for stage III of the Project in accordance with the Participation Rules or selected for the Open Window.

2.3. Participation Rules – a document governing the Project and Open Window procedure posted on the Website by the Company. 

2.4. Company – Mobile TeleSystems Public Joint-Stock Company, location: 4 Marksistskaya Str., 109147 Moscow, Russian Federation 

2.5. Materials – any materials (scanned copies of documents), files and information materials of various formats (.docx, .pdf, .ppt, etc.) submitted by the Applicant together with the Application.

2.6. Website – an Internet site located at: https://startup.mts.ru.


2.7. Partner – Partnership program participant or an organization that assists, on the basis of an agreement concluded with the Company, in the implementation of the Project and/or Open Window, including but not limited to by providing expert support for the Project and/or Open Window, exchanging information about the Products of the Participants and/or Open Window, providing information support and promotion Project or Open Window, providing an infrastructure for testing of the Product upon the request of the Company.



2.8. Partnership program – a set of measures for cooperation and interaction in the field of information exchange about Applicants' Products, implemented on the basis of agreements concluded between the Company and the third parties which are indicated on the Website: https://startup.mts.ru/thirdpersonspolicy, and aimed at the search of events or infrastructure for testing of the Applicant’s Product as well as at sending proposals for testing of the Product to the Applicant, participation in programs and events of Partnership programs participants





2.9. Project – program of intense development and evaluation of benefits from interaction between the Applicant and the Company, implemented by the Company through mentorship, education and expert support.

2.10. Product – software for computing devices submitted in the form of data and instructions for PC and other computing devices, including smartphones, tablets and other mobile devices for the purpose of achievement of a particular result of device operation, including audiovisual images generated by this software, and/or services, and/or equipment including the prototype. 

2.11. Representative (Representatives) – an individual (individuals) whose personal data are transferred to the Company via the Website including data, which are contained in the application, submitted via the Website for participation in the Project or Open Window, or in any other Supplementary Documents, for the purposes of processing by the Company under this Policy.

2.12. Supplementary Documents – any information and materials (including legal documents) to be provided by the Participant or by the Applicant upon the Company’s request in the course of inspection of the Product, of the Participant or of the Applicant.



2.13. Open Window – the process by which the Company conducts a competitive comparison of Applicants' Products with other products on the market in order to identify the highest quality Product and then conduct the testing the Applicants’ Products using the resources of the Company or the Partner in order to test a business suggestion formulated to assess the prospects and format of the cooperation in accordance with the selection criteria at the discretion of the Organizer.

3. Processing of Personal Data

3.1. The Company shall process personal data of the Applicant and/or its Representatives for the following purposes:

• processing of data submitted via the Website including processing of information which is contained in the application and Supplementary Documents;

• sending to the Applicant and/or Applicant’s representatives newsletters, e-mails, written notices in order to carry out communications between the Applicant and the Company within the framework of the Project or Open Window, informing the Applicant about the progress of the Project or Open Window;

• due performance of the Company obligations within the Project, Open Window and Partnership program;

• testing the Product and the Participant during a competitive selection under the Project or Open Window:


• transfer of Applicant’s or Applicant’s representatives’ personal data to Partners for the search of events or infrastructure for testing of the Applicant’s Product as well as for the purposes of sending proposals for testing of the Product to the Applicant, participation in programs and events of Partners.

3.2. The Company shall store the personal data of the Applicant and/or its Representatives as long as it is necessary for achieving the goals such data were collected for.

3.3. By submitting the personal data of its Representative, the Applicant confirms that, in a proper manner, in accordance with the Federal Law “On Personal Data”, it has received from its representative the proper consent to the processing of such personal data. The Applicant shall provide the original of such consent within two (2) working days upon the Company’s request.

3.4. The Company shall process the following personal data of the Applicant and/or its Representatives: surname, name, patronymic, citizenship, registration address, passport series and number, issue date, name of the issuing authority and subdivision code, TIN, city of employment, a contact phone, email.

3.5. Personal data shall be processed by taking, with or without the use of the automation means, the following actions (operations) or a combination of actions (operations) with the personal data of the Applicant and/or its Representatives: collection, recording, systematization, accumulation, storage, specification (updating, change), extraction, use, transfer (provision, access), blocking, deletion, destruction. 





3.6. The Applicant expresses its consent to the transfer (distribution, provision, access) and processing of the personal data by the third parties (Partners) on behalf of the Company to the extent compatible with the purposes of processing specified in this Policy. The list of third parties who process the Applicant's and/or its Representatives personal data on behalf of the Company, as well as the addresses of such processors are indicated on the Website: https://startup.mts.ru/thirdpersonspolicy.


3.7. The Applicant and/or its Representative shall be entitled to withdraw consent to the processing of its personal data at any time by sending a relevant written notification to the Company. If a person withdraws his/her consent to the personal data processing, the Company is entitled to continue processing his/her personal data without their consent, if there are the grounds specified in cl. 2–11, Part 1 Art. 6, Part 2 Art. 10 and Part 2 Art. 11 of the Federal Law “On Personal Data”.

3.8. To the extent not regulated by this Policy, the provisions of the MTS PJSC Policy on Personal Data Processing posted on the website at: https://moskva.mts.ru/about/investoram-i-akcioneram/korporativnoe-upravlenie/dokumenti-pao-mts/politika-obrabotka-personalnih-dannih-v-pao-mts.


4. Final Provisions

4.1. The Policy has been drawn up in Russian and English. In case of discrepancy of texts of Policy in Russian and English, text in Russian shall prevail. 

4.2. The Company may amend this Policy at any time on a unilateral basis without any preliminary agreement with the Applicant or the Participant.

4.3. In case this Policy is amended, the Company shall post the updated version hereof on its Website and shall keep all prior versions in the archive.