PERSONAL DATA PROCESSING POLICY

of the AEGIS mobile application

This is a courtesy English translation. In case of any discrepancy, the Russian version prevails. Русская версия

Revision of 01.10.2026.

1. General provisions

1.1. This Personal Data Processing Policy (the “Policy”) sets out the procedure for processing and protecting the personal data of users of the AEGIS mobile application (the “Application”, the “Service”).

Personal data operator: Limited Liability Company «АЕГИС» (OOO «АЕГИС»), TIN 1683034413, KPP 168301001, PSRN 1261600033562, registered address: Republic of Tatarstan, Vysokogorsky District, village Vysokaya Gora, Tsentralnaya street, building 3 (Республика Татарстан, Высокогорский район, село Высокая Гора, улица Центральная, дом 3); email for enquiries: [email protected].

1.2. The Policy has been prepared in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data”, as well as the requirements of the Apple App Store Review Guidelines and the Google Play Developer Policy regarding the processing of user data.

1.3. By using the Application, the user confirms that they have read this Policy and consents to the processing of personal data on the terms set out below.

2. Terms and definitions

“Personal data” — any information relating directly or indirectly to an identified or identifiable natural person (the data subject).

“Processing of personal data” — any action with personal data, including collection, recording, storage, use, transfer and deletion.

“Family” — a group of Application users united within the Service for the purpose of mutual safety.

“SOS signal” — an emergency alert function which, when activated, transmits the user’s geolocation, audio and video stream to the user’s family members.

“SafeWalk” — a function whereby the family escorts the user in real time, with transmission of geolocation, audio and video streams for the duration of the session.

3. Categories of personal data processed

3.1. When the Application is used, the following categories of data are processed:

Account data: name, email address, phone number, password (in hashed form)

Geolocation data — the last known location shown to family members on the family map for as long as the user is in the family (including in the background if the “Always” permission has been granted); in real time during an active SOS signal or SafeWalk session; safe-zone entry and exit events; and the aggregated history of completed SafeWalk sessions

Audio and video stream from the user’s device — during an SOS signal, a SafeWalk session or an audio request that the user has explicitly approved (and during a silent alert triggered by a duress code or voice command); it is transmitted to the user’s family members directly through a third-party communications operator (WebRTC technology) and is not stored, recorded or cached by the Operator either during the broadcast or after the session ends

Device data: model, OS version, push notification identifier

Data on the composition of the family within the Application: list of members, roles (including the marking of an account as belonging to a minor), status of invitations

Documents uploaded by the user to the “Documents” section (the family file storage)

3.2. The user’s geolocation is shown to family members on the family map for as long as the user is in the family, including in the background if the user has granted the “Always” permission. The user can turn this off at any time with the “live tracking” switch in the Family tab; for accounts marked as belonging to a minor, switching it off independently is not available. When it is turned off, the last known location is deleted. Audio and video are transmitted during an SOS signal, a SafeWalk session or an audio request that the user has explicitly approved, and an indicator of active transmission is shown on the device. The exception is a silent alert triggered by a duress code or a voice command: no indicator is shown and the family receives a notification.

4. Purposes of personal data processing

1. Ensuring the functioning of the user’s account and authentication in the Application.

2. Showing the user’s geolocation to their family members on the family map; transmitting geolocation, audio and video streams to the user’s family members during an active SOS signal or SafeWalk session initiated by the user or by another family member with mandatory notification of the user.

3. Storing the history of completed SafeWalk sessions so that family members who had access to the session in real time can view the route.

4. Sending the user service notifications related to the operation of the Application (verification codes, family activity alerts).

5. Ensuring the operation of the family document file storage.

6. Compliance with the requirements of the legislation of the Russian Federation, including requests from authorized state bodies.

5. Legal grounds for processing

5.1. Personal data is processed on the basis of the data subject’s consent, and to the extent necessary to perform the terms of the user agreement (offer agreement) between the user and the Operator.

5.2. Consent to the processing of personal data related to the transmission of geolocation, audio and video streams within the family is requested separately and consciously at the stage when the user joins a family in the Application (see the separate document “Texts of consents and system permissions”).

5.3. The personal data of minors is processed taking into account the requirements of Part 1 of Article 9 of Federal Law No. 152-FZ. Accounts marked as belonging to a minor may be added to a family only by a current family member who has the rights of a legal representative or is otherwise responsible for the minor within family relations.

5.4. The Application does not technically verify the family or guardianship relationship between the family member who adds the minor’s account and the minor themselves — responsibility for the accuracy of such a status and for the existence of lawful grounds for the corresponding processing of the minor’s data rests with the family member who added that account.

6. Cross-border data transfer

The primary collection, recording and storage of users’ personal data are carried out on servers physically located in the territory of the Russian Federation (hosting provider Timeweb), in accordance with the requirement of Part 5 of Article 18 of Federal Law No. 152-FZ. Delivery of traffic to the servers technically passes through the Cloudflare network (CDN, DDoS protection, DNS) — Cloudflare does not independently store users’ personal data and is used solely as a network intermediary node for transmitting encrypted (HTTPS/TLS) traffic to the same server in the Russian Federation.

7. Transfer of data to third parties

7.1. The Operator engages the following third parties (service providers) to ensure the operation of the Application:

Timeweb — hosting of the Application’s server side and database (territory of the Russian Federation)

Cloudflare — content delivery network, DDoS protection, DNS, and also relaying of the audio and video stream during active SOS/SafeWalk sessions/sound-on-request sessions using WebRTC technology (without storing the transmitted data)

Resend — sending of transactional emails (verification codes, alerts)

Cloudflare R2 — storage of document files and avatars uploaded by users

SMS.RU — sending SMS messages with verification codes to a phone number

Apple (Apple Push Notification service) — delivery of push notifications to iOS devices

Google (Firebase Cloud Messaging) — delivery of push notifications to Android devices

When signing in through an external provider (at the time of publication, Apple ID, Google and Yandex ID are connected; VK ID is not connected), the relevant provider transmits to the Operator the data necessary to identify the user (account identifier, email) — the processing of this data by the external provider itself is governed by its own privacy policy.

7.2. The said persons process personal data solely to the extent necessary to provide the relevant technical services and do not use it for their own purposes.

7.3. The Operator does not transfer users’ personal data to third parties for advertising or marketing purposes and does not sell it.

8. Periods of processing and storage

8.1. Account personal data is processed for the entire period during which the user’s account in the Application remains active.

8.2. The audio and video stream transmitted during an active SOS signal or SafeWalk session is not stored on the Operator’s servers on a permanent basis after the session ends.

The audio and video stream is transmitted using WebRTC technology directly between the devices of the participants of an active session through a relay network node (clause 7.1), which does not record or cache the transmitted data at any stage — there is no technical possibility of storing media data on the Operator’s servers.

8.3. Geolocation points of completed SafeWalk sessions are stored so that family members who had access to the session can view the route history.

8.4. When an account is deleted, personal data (name, email address, phone number, geolocation data, profile photo and other identifying data) is anonymized immediately, at the time the deletion request is processed, except where longer storage of certain data is required by the legislation of the Russian Federation. When a user leaves a family (without deleting the account), the personal data of the account itself continues to be processed in accordance with this Policy, while the access of other family members to data previously transmitted within that family ceases.

9. Rights of the personal data subject

The user has the right to:

Obtain information concerning the processing of their personal data

Demand clarification, blocking or destruction of personal data if it is incomplete, outdated, inaccurate or unlawfully obtained

Withdraw consent to the processing of personal data by leaving the family in the Application or by deleting the account

File a complaint with the authorized body for the protection of the rights of personal data subjects (Roskomnadzor)

10. Measures to ensure the security of personal data

Data transmission over a secure communication channel (HTTPS/TLS)

Storage of passwords exclusively in hashed form

Differentiation of access rights to data within the family depending on the member’s role (including limited rights for minors’ accounts)

The audio and video stream is transmitted only to family members entitled to receive it; the Operator takes organizational and technical measures to prevent third-party access to the stream

11. Specifics of data processing when using SOS and SafeWalk

11.1. The SOS and SafeWalk functions involve transmitting the user’s geolocation, audio and video stream to other members of their family within the Application. This transmission takes place exclusively between members of one family who have voluntarily joined together within the Service, and is not carried out in respect of outsiders.

11.2. The user who is being monitored (including an account marked as belonging to a minor) sees on the device screen, throughout the entire time audio or video is being transmitted, an indicator showing that data is being actively transmitted, with the ability to stop it at any time. The exception is an SOS signal raised by the User themselves with a duress code or a voice command: it is sent without visible signs on the screen of the person raising it, so as not to put them at risk, and all family members are alerted.

11.3. The function of remotely starting SafeWalk by another family member is accompanied by mandatory notification of the user for whom the session is started, at the moment it begins.

11.4. An SOS signal may be sent by voice command through the device’s system voice assistant (Siri) without opening the Application’s interface, including when the device screen is locked. This function uses solely the device’s system facilities and is not associated with the Application continuously listening to the microphone in the background — the Application receives control only at the moment the command set by the user is spoken. Upon activation, the Application reads the device’s last known geolocation and sends it together with the signal to family members; the voice assistant does not play an audible or visual confirmation that the signal has been sent, which is done deliberately for the safety of a user who may be in a potentially dangerous situation. Audio and video broadcasting to family members begins only after the user opens the Application themselves. If there is no network connection at the moment the voice signal is sent, the signal is temporarily stored on the user’s device and is sent automatically as soon as the user opens the Application with a connection available, but no later than 30 minutes after the signal was sent — after this period an unsent signal is deleted from the device.

11.5. The “Safety timer” function allows the User to set a countdown timer for themselves, or allows the family owner to set one for another family member. If the User for whom the timer is set does not confirm through the Application’s interface that they are safe before the set time expires, the Application automatically and without any additional confirmation from the User or any other family member initiates an SOS signal on behalf of the User whose timer has expired: determination and transmission of their geolocation, and broadcasting of an audio and video stream from their device to family members, are switched on — on the same terms and with the same guarantees (including the permanent on-screen indicator of active transmission specified in clause 11.2) as when an SOS signal is sent manually. Thus, the expiry of the safety timer is equated to sending an SOS signal and entails the start of processing of the specified categories of data without a separate expression of will by the User at the moment of expiry — the corresponding consent is given in advance, at the moment the timer is switched on. A timer set by the family owner for another member may be cancelled at any time before it expires, both by that member and by the family owner who set it.

12. Amendment of the Policy

The Operator may amend this Policy. The current version of the Policy is published in the Application and on the Operator’s website. Continued use of the Application after amendments are made means the user’s agreement with the updated version of the Policy.

13. Contact information

For questions about the processing of personal data, the user may contact the Operator: OOO «АЕГИС», email: [email protected], postal address: Republic of Tatarstan, Vysokogorsky District, village Vysokaya Gora, Tsentralnaya street, building 3 (Республика Татарстан, Высокогорский район, село Высокая Гора, улица Центральная, дом 3).