1. Operator and notice to Roskomnadzor
Operator: Julow LLC. Address: 123100, Moscow, Primernaya St. 1, office 1, Russian Federation.
The Operator has filed a personal-data processing notice with Roskomnadzor pursuant to Art. 22 of 152-FZ.
Contact address for data-subject requests: privacy@julow.app.
2. Purposes of processing
The Operator processes personal data for the following purposes:
- registration and authentication of the User in the Service;
- delivery of the Service functionality (tasks, chats, documents, meetings);
- ensuring security and protection against fraud;
- notifying about material changes to the Service or its terms;
- fulfilling obligations imposed on the Operator by the law of the Russian Federation.
3. Categories of subjects and data
Subjects: individuals — Users of the Service, website visitors, representatives of corporate customers.
Categories of data processed: e-mail address, hashed password, name (where provided), IP address, session identifier, technical browser and device data, action logs within the Service.
Biometric and special categories of personal data are not processed by the Operator.
4. Legal grounds
Pursuant to Art. 6 of 152-FZ, processing is carried out on the following grounds:
- consent of the subject (ticked at registration);
- performance of an agreement to which the subject is a party (this Agreement and the provision of services);
- compliance with legal obligations imposed on the Operator;
- exercise of the Operator’s rights and legitimate interests, provided that the subject’s rights are not infringed.
5. Methods of processing
Processing is mixed: automated (on servers) and, in exceptional support cases, without the use of automation.
Operations performed: collection, recording, systematisation, accumulation, storage, clarification, extraction, use, transfer (distribution, provision, access), depersonalisation, blocking, deletion and destruction.
6. Storage and data localisation
Pursuant to Part 5 of Art. 18 of 152-FZ, personal data of citizens of the Russian Federation is recorded, systematised, accumulated, stored, updated and extracted in databases located within the territory of the Russian Federation.
Storage period: until the processing purposes are achieved or the subject withdraws consent. Thereafter, personal data is destroyed within thirty (30) days, except for information that must be retained by law.
7. Third parties and cross-border transfer
The Operator does not transfer personal data to third parties except: (a) with the subject’s consent; (b) to competent state authorities upon lawful request; (c) to entities engaged by the Operator to perform the agreement (for example, cloud-infrastructure providers located within the Russian Federation), subject to confidentiality obligations.
Cross-border transfer of personal data is not carried out without a separate prior notice to Roskomnadzor pursuant to Art. 12 of 152-FZ and without ensuring adequate protection of subjects’ rights.
8. Cookies and analytics
The Service uses strictly necessary cookies for its functioning (for example, storing the session token) and, subject to the User’s consent, analytical cookies.
The User may restrict the use of cookies through browser settings; certain features of the Service may then become unavailable.
9. Security measures
Pursuant to Art. 18.1 and Art. 19 of 152-FZ, the Operator applies:
- organisational measures: appointment of a responsible officer, internal regulations, staff training;
- technical measures: TLS encryption in transit, password hashing, role-based access control, action logging, regular security audits;
- accounting of information carriers and access control to premises where personal data is processed.
10. Incident notification
In the event of an incident involving unlawful transfer (provision, distribution, access) of personal data, the Operator notifies Roskomnadzor:
- within 24 hours — of the fact of the incident and presumed causes;
- within 72 hours — of the results of the internal investigation and of the persons whose actions caused the incident,
in the manner established by the legislation of the Russian Federation in force from 30 May 2025.
11. Rights of the data subject
Pursuant to Art. 14 and 20 of 152-FZ, the subject has the right to:
- obtain information about the processing of their personal data and demand its clarification, blocking or destruction if it is incomplete, outdated or unlawfully obtained;
- withdraw consent to processing at any time by sending a request to privacy@julow.app;
- appeal the Operator’s actions to Roskomnadzor or before a court.
The response period for subject requests is no more than 30 days from receipt of the request.
12. Processing of minors’ data
The Service is not intended for persons under 14 years of age. Processing of data of persons aged 14 to 18 is carried out with the consent of their legal representatives where required by law.
13. Changes to the Policy
The Operator may amend this Policy. The current version is always available at julow.app/privacy. Users are notified of material changes a reasonable time before they take effect.
14. Contacts
Subject requests are sent to privacy@julow.app.
Officer responsible for the organisation of personal-data processing — contact details available upon written request.