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Privacy Policy (Personal Data Processing Policy)

ICOM Consalt LLC (the “Avelsa” / “Avelsa Systems” service, avelsa.ru · axon.ikc.su)

Edition of September 5, 2026

This English text is a convenience translation. The legally binding version is the Russian one at avelsa.ru/privacy; in case of any discrepancy, the Russian version prevails.

1. General

1.1. This Policy is adopted pursuant to Federal Law of the Russian Federation No. 152-FZ of 27 July 2006 “On Personal Data” and defines how personal data (“PD”) is processed and protected.

1.2. Operator (data controller): ICOM Consalt LLC (ООО «АйКом консалт»), OGRN 1110327002543, INN 0309990882; 21a/3 Sibirskaya St., Irkutsk, 664022, Russian Federation; e-mail: office@ikc.su.

1.3. The Policy applies to personal data processed on the website avelsa.ru (and axon.ikc.su), in the Avelsa mobile application (including builds published in RuStore, the App Store and Google Play), via the voice assistant (the “Avelsa” skill for Yandex Alice) and in the cloud service.

2. Data subjects and categories of data

2.1. Users (customer representatives, equipment owners/operators): name; e-mail address; phone number (provided voluntarily in the user profile — for account recovery and for contacting support); login; password (stored only as an irreversible hash; never stored or transmitted in plain text). The Operator collects no other identity data.

2.2. Equipment data: the controller’s MAC address and other technical device identifiers, readings and telemetry. A MAC address identifies equipment, not a person.

2.3. Technical session data: IP address, activity logs, push notification identifiers (when the application is used).

2.4. As of this edition, self-service registration is not available: accounts are created by the Operator and handed over to the user. When self-registration is introduced, consent will be collected in the registration form.

2.5. The Operator does not process special or biometric categories of personal data; processing of minors’ data is not intended.

2.6. The mobile application does not request access to geolocation, contacts, camera, microphone or user files; it contains no advertising or analytics SDKs and performs no tracking. The authorization token is kept in the device’s secure storage (Keychain/Keystore). Equipment data is transmitted only to the Operator’s servers (avelsa.ru / axon.ikc.su) over an encrypted channel (TLS).

2.7. Voice assistant. The Operator provides the “Avelsa” skill for the Alice voice assistant (a service of Yandex LLC). Users’ voice commands are recognized and processed by the Yandex platform; the Operator receives from it the command text (intent) and the linked account identifier and does not receive or store voice audio recordings. Account linking (via OAuth) connects the user’s Alice account with their Avelsa account and is used solely to control equipment and report its status. Use of the Alice assistant itself is governed by Yandex documents. The skill contains no advertising or analytics SDKs, no commercial offers, and performs no tracking.

3. Purposes of processing

4. Legal bases

5. Processing procedure and conditions

5.1. Operations: collection, recording, systematization, accumulation, storage, updating, use, transfer (provision, access), blocking, deletion, destruction.

5.2. Methods: automated and non-automated processing.

5.3. Transfers to third parties are limited: data is hosted on the Operator’s own infrastructure (servers located in Russia); push notifications are delivered via the service of the respective app store (RuStore / Apple / Google). No data is shared with advertising or analytics third parties. The Operator keeps the data confidential.

5.4. Future processors. If an SMS delivery provider is engaged (for account recovery), it will act as a processor on the Operator’s instructions (Art. 6(3) of Law 152-FZ) under a data processing agreement; the provider’s name and the data shared with it (phone number) will be added to this Policy before such processing starts.

6. Data localization (Art. 18(5) of Law 152-FZ)

6.1. Recording, systematization, accumulation, storage, updating and retrieval of personal data of citizens of the Russian Federation are performed using databases located in the Russian Federation (the Operator’s servers, Irkutsk).

7. Cross-border transfer

7.1. As of this edition, no cross-border transfer of personal data takes place. If it is introduced, the Operator will comply with Art. 12 of Law 152-FZ (including prior notification of Roskomnadzor).

8. Data security

The Operator applies legal, organizational and technical measures (Art. 18.1, 19): a person responsible for organizing data processing has been appointed; internal regulations have been adopted; access control, channel encryption (TLS), backups and logging are in place.

9. Data subject rights

The data subject may: obtain information about the processing; request rectification, blocking or destruction of their data; withdraw consent; complain about the Operator’s actions to Roskomnadzor or to a court. Requests: e-mail office@ikc.su; responses are given within the time limits set by Law 152-FZ.

The user can delete their account and the associated personal data directly in the mobile application (Settings → Account → “Delete Account”) or by request to office@ikc.su; deletion is completed within up to 30 days.

10. Cookies

The website uses cookies for service operation and analytics; by continuing to use the website, the user agrees to their use (a banner notice is shown on the website).

11. Final provisions

The current Russian version is available at avelsa.ru/privacy (and axon.ikc.su/privacy); this English version is available at avelsa.ru/en/privacy. The Operator may amend this Policy; a new edition takes effect upon publication.