Privacy Policy Regarding the Processing of Personal Data in the “POLARIS IQ Home” Mobile Application

Moscow

Version dated August 1, 2026

“Personal Data”

(abbreviated as “PD”)

any information relating directly or indirectly to an identified or identifiable individual.

“Personal Data Operator”

(abbreviated as the “Operator”)

a state authority, municipal authority, legal entity or individual that, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the categories of personal data subject to processing, and the actions (operations) performed with personal data. For the purposes of this Policy, the Personal Data Operator is AGI Electronics LLC.

“Personal Data Subject”

an individual who is directly or indirectly identified by means of personal data and whose personal data is being processed.

“Processing of Personal Data”

any action (operation) or set of actions (operations) performed with personal data, with or without the use of automation tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (dissemination, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

“Automated Processing of Personal Data”

processing of personal data using computer technology.

“Cross-Border Transfer of Personal Data”

transfer of personal data to the territory of a foreign state to a foreign state authority, foreign individual or foreign legal entity.

“Provision of Personal Data”

actions aimed at disclosing personal data to a specific person or a specific group of persons.

“Destruction of Personal Data”

actions resulting in the inability to restore the content of personal data in a personal data information system and/or resulting in the destruction of physical media containing personal data.

“Blocking of Personal Data”

temporary suspension of personal data processing (except where processing is necessary to clarify the personal data).

“Application”

a computer program in the form of a mobile application called “POLARIS IQ Home,” intended for use on the User’s mobile devices in accordance with its intended purpose.

“152-FZ”

Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data.”

“User”

a person using the Application.

“Technical Data”

information automatically collected when using the Application, including User and device identifiers, information about the software and hardware, the Application version, as well as other data necessary to ensure the proper functioning and security of the Application.

Purpose No. 1

User registration, account creation and provision of access to the Application

1.1.   Categories of Personal Data Subjects

Users.

1.2.   Legal Basis for Personal Data Processing

User Agreement between the Operator and the User (Article 6, Part 1, Clause 5 of 152-FZ).

1.3.   Categories and List of Personal Data Processed

¾     Other personal data.

¾     telephone number;

¾     email address;

¾     User’s name;

¾     User account identifier (ID);

¾     photograph (if provided, not for identification purposes);

¾     gender;

¾     date of birth;

¾     weight, height;

¾     information about the User’s habits.

1.4.   Personal Data Processing Period

During the term of the User Agreement and for 3 years after its termination on any grounds.

1.5.   Methods of Personal Data Processing

Actions performed using automated means with respect to PD: collection, creation, recording, systematization, accumulation, storage, retrieval, use, clarification (updating, modification), combination (linking), blocking, depersonalization, deletion and destruction.

Purpose No. 2

User authentication and ensuring secure access to the User’s account

2.1.    Categories of Personal Data Subjects

Users.

2.2.   Legal Basis for Personal Data Processing

User Agreement between the Operator and the User (Article 6, Part 1, Clause 5 of 152-FZ).

2.3.   Categories and List of Personal Data Processed

Other personal data.

¾     telephone number;

¾     email address;

¾     authentication data obtained through third-party services;

¾     User account identifier (ID);

¾     session information;

¾     technical data required to verify access;

2.4.   Personal Data Processing Period

During the term of the User’s account and for 90 days after its deletion by the User.

2.5.   Method of Personal Data Processing

Actions performed using automated means with respect to PD: collection, recording, verification, storage, use, clarification (updating, modification), combination (linking), blocking, depersonalization, deletion and destruction.

Purpose No. 3

Ensuring the connection, configuration and remote control of compatible smart devices, execution of User commands, display of device status, synchronization of settings, and proper functioning of the Application

3.1.    Categories of Personal Data Subjects

Users.

3.2.   Legal Basis for Personal Data Processing

User Agreement between the Operator and the User (Article 6, Part 1, Clause 5 of 152-FZ).

3.3.   Categories and List of Personal Data Processed

Other personal data.

¾     account data;

¾     User account identifier (ID);

¾     information about connected devices (device identifiers, serial numbers, device model);

¾     information about the device’s association with the User’s account;

¾     device name assigned by the User;

¾     command execution logs and information about device status;

¾     technical data required to connect and interact with the devices.

3.4.   Personal Data Processing Period

Until the User ceases to use the relevant device (unlinks the device from the account) or deletes the account, whichever occurs first.

3.5.   Method of Personal Data Processing

Actions performed using automated means with respect to PD: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (where necessary, to the device manufacturer and other persons responsible for ensuring the functioning of the device), depersonalization, blocking, deletion and destruction.

Purpose No. 4

Ensuring the connection and interaction between the Application and smartwatches, displaying information transmitted by the device, and monitoring activity and other indicators

4.1.   Categories of Personal Data Subjects

Users.

4.2.  Legal Basis for Personal Data Processing

User Agreement between the Operator and the User (Article 6, Part 1, Clause 5 of 152-FZ).

4.3.  Categories and List of Personal Data Processed

Other personal data.

¾     User account data;

¾     smartwatch identifiers;

¾     information about the device model;

¾     information about connection and synchronization;

¾     data transmitted by smartwatches (including information about physical activity, workouts, number of steps, calorie expenditure, sleep, measurements recorded by the device, as well as other data depending on the device model and permissions granted by the User);

¾     technical logs of synchronization and device operation. ID;

¾     surname, name;

¾     User account identifier (ID);

¾     gender;

¾     date of birth;

¾     weight, height;

¾     information about the User’s habits (smoking, consumption of sweets, coffee, wine, etc.).

4.4.  Personal Data Processing Period

Throughout the period during which the User uses the smartwatch together with the Application, or until the relevant function is discontinued (the device is unlinked) or the account is deleted, whichever occurs first.

4.5.  Method of Personal Data Processing

Actions performed using automated means with respect to PD: collection, recording, systematization, accumulation, storage, clarification (updating, modification), retrieval, use, transfer (if necessary to ensure interaction with smartwatches and the functioning of the Application), depersonalization, blocking, deletion and destruction.

Purpose No. 5

Ensuring the functioning of the Voice Assistant, processing the User’s voice and text requests using artificial intelligence technologies, generating responses, executing commands to control compatible devices, and providing informational and reference materials

5.1.     Category of Personal Data Subjects

Users.

5.2.    Legal Basis for Personal Data Processing

User Agreement between the Operator and the User (Article 6, Part 1, Clause 5 of 152-FZ).

5.3.    Category and List of Personal Data Processed

Other personal data.

¾     User account data (ID);

¾     text queries;

¾     voice messages (when using voice input);

¾     automatically generated text transcriptions of voice messages;

¾     content of queries and commands;

¾     information about the results of processing queries;

¾     technical information about the interaction session (date and time of the request, session identifier, information about the device and Application version);

¾     other data voluntarily provided by the User while interacting with the Voice Assistant.

5.4.    Personal Data Processing Period

For as long as the User uses the Voice Assistant functionality or until the User deletes the relevant interaction history (if such functionality is available) or deletes the account, whichever occurs first.

5.5.     Method of Personal Data Processing

Actions performed using automated means in relation to Personal Data: collection, recording, systematization, accumulation, storage, updating (including modification), retrieval, use, transfer, depersonalization, blocking, deletion, destruction.

Purpose No. 6

Ensuring the functioning of the Application, identification of the User’s session, retention of User settings, and proper functioning of the Application as a whole

2.    

3.    

4.    

6.1.   Category of Personal Data Subjects

Users.

6.2.  Legal Basis for Personal Data Processing

User Agreement between the Operator and the User (Article 6, Part 1, Clause 5 of 152-FZ).

6.3.  Category and List of Personal Data Processed

Other personal data.

¾     User account identifier (ID);

¾     Application installation identifier;

¾     session identifiers;

¾     authorization and refresh tokens (access token, refresh token);

¾     device information (model, manufacturer, operating system version, system language, Application version);

¾     IP address; network connection information; technical logs of the Application’s operation;

¾     information about failures, errors and User actions related to the functioning of the Application.

6.4.  Personal Data Processing Period

For as long as the User’s account remains active and, for certain technical data, no longer than objectively necessary to ensure the security, authorization and functioning of the Application.

6.5.  Method of Personal Data Processing

Actions performed using automated means in relation to Personal Data: collection, recording, systematization, accumulation, storage, updating (including modification), retrieval, use, depersonalization, blocking, deletion, destruction.

Purpose No. 7

Promoting the Application through marketing communications, including advertising messages, notifications about new features, special offers and promotions

7.     

7.1.    Category of Personal Data Subjects

Users.

7.2.   Legal Basis for Personal Data Processing

User consent to the processing of personal data (such consent is given by clicking the relevant checkbox to opt in to advertising communications).

7.3.   Category and List of Personal Data Processed

Other personal data.

¾     name;

¾     email address;

¾     telephone number;

¾     account information;

¾     information about the current subscription and use of the Application (where necessary to personalize messages);

¾     User preferences regarding how messages are received.

7.4.   Personal Data Processing Period

Until the User withdraws consent to receive advertising communications or the Operator ceases to process Personal Data for the relevant purposes.

7.5.   Method of Personal Data Processing

Actions performed using automated means in relation to PD: collection, recording, accumulation, storage, retrieval, use, clarification (updating, modification), combination (linking), blocking, depersonalization, deletion, and destruction.

Purpose No. 8

Provision of paid Application functionality and payment processing

8.    

8.1.   Categories of Personal Data Subjects

Users.

8.2.  Legal Basis for Personal Data Processing

User Agreement between the Operator and the User (Article 6, Part 1, Clause 5 of 152-FZ).

8.3.  Categories and List of Personal Data Processed

Other personal data.

¾     subscription plan information;

¾     subscription status;

¾     payment information;

¾     information about transactions;

¾     information about the linked bank card;

¾     other payment data.

8.4.  Personal Data Processing Period

During the term of the User Agreement + 3 years after its termination or until the User withdraws information about the payment method.

8.5.   Method of Personal Data Processing

Actions performed using automation tools in relation to PD: collection, recording, storage, use, transfer, clarification, blocking, depersonalization, deletion, destruction.

Purpose No. 9

Receiving, reviewing and processing User requests and providing User support

9.    

9.1.   Categories of Personal Data Subjects

Users

9.2.   Legal Basis for Personal Data Processing

User Agreement between the Operator and the User (Article 6, Part 1, Clause 5 of 152-FZ).

9.3.   Categories and List of Personal Data Processed

Other personal data.

¾     name;

¾     telephone number;

¾     email address;

¾     content of the User’s request/feedback;

¾     technical information related to the request (e.g., information about the device, Application version, error description);

¾     screenshots and other materials voluntarily provided by the User.

9.4.   Personal Data Processing Period

For the period necessary to review the request, provide a response and complete the interaction with the User, but no longer than 3 years from the date of the last interaction with the User.

9.5.   Methods of Personal Data Processing

Actions performed using automation tools in relation to PD: collection, recording, use, deletion, destruction.

1.1.1.                          

Yandex.Cloud LLC

INN 7704458262

1 Poiskovaya St., Bldg. 2, Energetik microdistrict, Vladimir, Vladimir Region, 600902