PERSONAL DATA PROCESSING POLICY FOR USERS OF VR CONCEPT LLC WEBSITES

Version dated 19 August 2026

This Policy sets out the procedure for processing the personal data of users of VR Concept LLC websites and applies to websites, forms, cookies, analytics, applications, enquiries, event registrations, educational projects, advertising and informational communications, and other interactions carried out through the Operator’s websites.
This Policy is a public document intended for publication on the Operator’s websites. Internal organisational and technical measures for the protection of personal data that are not intended for public disclosure are governed by the Operator’s internal documents.
This version of the Policy enters into force on the date of its publication on the Operator’s website.
1. Personal Data OperatorThe personal data operator is VR Concept LLC (the “Operator”).
- Full legal name in English: “VR Concept” Limited Liability Company.
- Primary State Registration Number (OGRN): 1117746903394.
- Taxpayer Identification Number (INN): 7710900640.
- Address: 42 Bolshoy Boulevard, Building 1, Floor 3, Premises 1131, Workplace No. 10, Skolkovo Innovation Center Territory, Moscow, 121205, Russian Federation.
- Email address for personal data enquiries: info@vrconcept.net.
- Telephone: +7 (495) 212-11-47.
2. Websites Covered by this PolicyThis Policy applies to the Operator’s websites and web pages, including their sections, forms and landing pages that contain a link to this Policy, including:
- https://vrconcept.net/
- https://academy.vrconcept.net/
- https://en.vrconcept.net/
- https://accelerator.vrconcept.net/
- https://hackathon.vrconcept.net/
- other websites, pages and landing pages of the Operator that contain a link to this Policy.
When a user follows an external link to a third-party website, including an educational platform, social network, video-hosting service or partner service, the processing of personal data by that third party is governed by its own terms and privacy documents. The Operator is not responsible for data processing independently determined by such third parties.
3. Terms and DefinitionsThe terms used in this Policy have the meanings established by Federal Law No. 152-FZ of 27 July 2006 “On Personal Data”.
- personal data means any information relating directly or indirectly to an identified or identifiable individual;
- personal data processing means any operation or set of operations performed on personal data, including collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (including dissemination, provision and access), depersonalisation, blocking, deletion and destruction;
- user means a website visitor, a person completing a form, submitting an application, subscribing to advertising and informational communications or otherwise interacting with the Operator through a website;
- cookie means a small piece of data stored on a user’s device and used for website operation, analytics, interface settings and other purposes specified in this Policy and the Cookie Policy.
4. Categories of Users and Personal DataThe Operator may process personal data relating to website visitors; persons submitting requests to download, purchase or demonstrate a product, receive a consultation or order a project; representatives of organisations and educational institutions; partners, customers and prospective customers; participants in educational projects, courses, hackathons, accelerators and other events; persons consenting to receive advertising and informational communications; and persons submitting project or lesson ideas, comments, questions or other enquiries.
The Operator may process a surname, first name, patronymic (if applicable) or username; organisation name; position or role within an organisation; email address; telephone number; Telegram username or identifier; educational institution; information about a product of interest, product version, project, course, event, discount, early access or consultation; the text of a comment, question, project idea or lesson idea; and technical data, including IP address, cookies, information about the browser, device, operating system, language and region, referral source, actions on the website and other technical parameters.
The Operator may also process other information that the user voluntarily enters into website forms or otherwise provides to the Operator. The Operator does not request through its websites special categories of personal data, data concerning health, biometric personal data, information concerning political opinions, religious or philosophical beliefs, intimate life, nationality or race. Users should not provide such information in free-text fields of website forms.
The Operator processes information entered by the user in free-text form fields only to the extent necessary to review the relevant enquiry, application, comment, question, proposal or other communication from the user.
Where a user acts as a representative of an organisation, the Operator may process information about that organisation, the user’s position or role and business contact details for business communications, preparing proposals, entering into and performing contracts, and supporting applications, projects, educational initiatives and partnership initiatives.
Where a user submits data in connection with an educational project, course, hackathon, accelerator or other event, the Operator may process information necessary to organise participation, communicate with the participant, confirm registration, provide materials and support the relevant project. Where data relating to a minor are provided, the person providing such data must have a lawful basis for doing so.
5. Website Forms and Data CollectedForms on the Operator’s websites collect data necessary to process the relevant application or enquiry and contact the user. The website https://vrconcept.net/ uses the forms “Download VR Concept”, “Contact Us”, “Buy VR Concept”, “Order a VR Project”, as well as the “Learn More About the Offer” forms on https://vrconcept.net/page-vuz and https://vrconcept.net/specprice. Depending on the form, the Operator may process the user’s full name, organisation name, email address, telephone number, product version, product or project of interest, educational institution and comment.
The website https://academy.vrconcept.net/ uses the forms “Contact Us”, “Submit an Application”, “Request a Consultation”, “Suggest an Idea”, “Ask Us a Question”, “Enrol in Stepik Courses” and “Get Early Access and a Discount”. Depending on the form, the Operator may process the user’s full name, organisation name, email address, telephone number, Telegram details, educational institution, information about a course, early access or discount, comment, question, project idea or lesson idea.
The website https://en.vrconcept.net/ uses the “Get VR Concept” and “Contact Us” forms. Depending on the form, the Operator may process the user’s full name, organisation name, email address, telephone number and comment.
For https://hackathon.vrconcept.net/ and https://accelerator.vrconcept.net/, personal data are processed through forms or other data-entry functionality only where such functionality is actually made available to users and contains a link to this Policy. The scope of personal data depends on the fields presented to the user in the relevant form.
Where a new form is added to an Operator website, this Policy applies to personal data submitted through that form if the form contains a link to this Policy. The scope of data collected depends on the purpose of the form and the fields presented to the user.
6. Purposes of Personal Data ProcessingThe Operator processes personal data for the purposes of receiving, processing and fulfilling user applications; providing access to software distributions, demo versions, educational materials, products, courses and other Operator materials; providing feedback and consultations; responding to questions; and providing technical and informational support.
Personal data are also processed to prepare commercial proposals; organise sales; support contractual and pre-contractual relations; organise educational projects, courses, hackathons, accelerators, events and other activities; and review project ideas, lesson ideas, proposals and feedback.
In addition, the Operator may process personal data for CRM administration, recording enquiries, routing applications, monitoring communications, sending advertising and informational communications where the user has provided separate consent, analysing website performance, improving usability, evaluating the effectiveness of pages, forms and marketing materials, ensuring website security, preventing abuse and technical failures, and complying with the requirements of the legislation of the Russian Federation.
7. Legal Grounds for ProcessingThe Operator processes personal data on the basis of the user’s consent; where processing is necessary to enter into a contract at the user’s initiative or to perform a contract to which the user is a party, beneficiary or guarantor; to comply with the Operator’s obligations under the legislation of the Russian Federation; to exercise the Operator’s rights and legitimate interests, provided that the user’s rights and freedoms are not thereby violated; and on other grounds provided for by the legislation of the Russian Federation.
8. Procedure for Processing and Transfer of Personal DataPersonal data may be processed by automated means or without the use of automated means. The Operator may perform operations necessary to achieve the purposes of processing, including collection, recording, systematisation, accumulation, storage, clarification (updating or modification), retrieval, use, transfer (including dissemination, provision and access), depersonalisation, blocking, deletion and destruction.
The Operator may engage third parties to process personal data on its behalf and may transfer personal data to persons and service providers supporting the operation of websites, forms, CRM systems, communications, analytics, hosting and technical infrastructure. Such processing and transfers are limited to the extent necessary to achieve the relevant purposes and are carried out subject to applicable legal requirements.
For website operation and application processing, the Operator may use Tilda as a website builder, form system, Tilda CRM and technical application-routing tool. Bitrix24 may be used to record and process enquiries, applications and communications. Unisender may be used for advertising and informational communications and contact database management.
Applications and messages may be sent to corporate email addresses, including academy@vrconcept.net and other Operator addresses, as well as to the Telegram bot @vrconceptbot, where such routing is configured. Yandex Metrica, Yandex Webmaster, Tilda technical tools and other analytics tools actually deployed on the relevant website may be used to analyse website traffic and assess the performance of pages and forms.
Stepik and other educational platforms may be used as external resources. When a user follows a link to such a platform, the user interacts with that platform independently, and data processing by that platform is governed by the platform’s own terms and privacy documents.
Other external technical, analytics, advertising or marketing tools are used only where they are actually deployed and their use complies with applicable legal requirements. Where required, the Operator updates this Policy and related notices to reflect such use.
The Operator does not sell users’ personal data to third parties. Personal data may be transferred only where there is a lawful basis for the transfer, to the extent necessary for the stated purpose, or in other cases provided for by the legislation of the Russian Federation.
9. Recording of ConsentsWhen website forms are completed, the Operator may record the fact that the user has consented to the processing of personal data and, where applicable, has separately consented to receive advertising and informational communications.
To demonstrate that consent has been given, the Operator may record the date and time of consent, the URL of the page or form, the version of the relevant consent wording, confirmation that the relevant checkbox was selected, the IP address, technical information about the browser and device, and other information necessary to demonstrate the lawfulness of processing.
10. Advertising and Informational CommunicationsAdvertising and informational communications are sent to the user only where separate prior consent has been obtained, if such consent is required by law. Consent to personal data processing for a website form does not, by itself, constitute consent to receive advertising communications.
The user may withdraw consent or opt out by using the unsubscribe or other opt-out mechanism available in a message, or by sending a request to the Operator. Upon receipt of an opt-out request, the Operator shall immediately cease sending advertising communications through the relevant communication channel. Service communications relating to the fulfilment of an application, provision of a download link, response to an enquiry, organisation of participation in an event or performance of a contract may continue to be sent, provided that they do not constitute advertising and are necessary to fulfil the relevant request or contract.
11. Cookies and AnalyticsThe Operator’s websites use cookies and similar technologies. Cookies may be strictly necessary, functional, analytics, advertising or marketing cookies. Where the relevant functionality is available, the user can manage cookies through the website settings, cookie banner or browser settings.
Strictly necessary cookies support website operation, forms, navigation, security and correct page loading. Such cookies may be used to operate application forms, maintain technical website settings and prevent failures.
Functional cookies enable the website to remember user settings and improve usability, for example language, region or interface settings, where such functionality is enabled.
Analytics cookies are used to analyse website traffic, referral sources, user actions on pages and the performance of forms. Such tools may include Yandex Metrica, Tilda technical tools and other analytics tools actually deployed on the relevant website.
Advertising and marketing cookies, pixels and similar tools may be used to assess advertising effectiveness, configure advertising campaigns and support marketing communications only where the relevant tools are actually deployed and the applicable legal requirements are met.
Where prior consent is required by applicable law, advertising, marketing and other non-essential cookies or similar technologies are not activated before the user makes the relevant selection.
The Operator may use Yandex Metrica, Yandex Webmaster, Tilda technical tools and other analytics tools actually deployed on the relevant website. Such tools may process technical user data, including IP address, cookies, information about the browser and device, referral source, actions on the website and other visit parameters.
Further information about cookie categories, tools used and available cookie settings is provided in the Cookie Policy published on the Operator’s websites.
12. Data Localisation and Cross-Border Transfers of Personal DataWhen collecting personal data of citizens of the Russian Federation through websites, the Operator ensures the recording, systematisation, accumulation, storage, clarification and retrieval of such personal data using databases located within the territory of the Russian Federation, in the cases required by the legislation of the Russian Federation.
The Operator carries out cross-border transfers of personal data only where there is a lawful basis for such transfer and in compliance with the legislation of the Russian Federation. Before initiating a cross-border transfer, the Operator takes the actions required by law, including assessing the conditions of the transfer and submitting any required notification to the competent supervisory authority.
13. Retention PeriodsPersonal data are retained for no longer than is necessary for the purposes of processing, subject to the legislation of the Russian Federation, contracts, user consents, limitation periods and applicable accounting, tax, archival and other legal requirements.
Once the purposes of processing have been achieved, consent has been withdrawn, the applicable retention period has expired or unlawful processing has been identified, processing must be discontinued and the data deleted, destroyed, blocked or depersonalised in accordance with applicable law and the Operator’s internal documents, unless there is another lawful ground for continuing the processing.
14. User RightsThe user has the right to obtain information about the processing of their personal data, request clarification, blocking or destruction of personal data where provided for by law, withdraw consent to personal data processing, opt out of advertising communications and exercise other rights provided for by the legislation of the Russian Federation.
To exercise these rights, the user may send a request to info@vrconcept.net. The Operator may request information necessary to verify the user’s identity and properly consider the request.
15. Personal Data Protection MeasuresThe Operator takes the necessary legal, organisational and technical measures to protect personal data against unlawful or accidental access, destruction, alteration, blocking, copying, provision, dissemination and other unlawful actions.
Such measures include appointing responsible persons, restricting access to personal data, using corporate information systems, maintaining access records and controls, implementing organisational confidentiality measures, making backups, using antivirus protection, passwords and other security safeguards, training and informing employees, monitoring processing carried out on the Operator’s behalf, and taking other measures appropriate to the nature of the processing.
16. Amendments to this PolicyThe Operator may amend this Policy. A new version enters into force upon publication on the relevant website unless a different effective date is specified in the new version. Users are advised to check the current version of the Policy periodically.
The current version of this Policy is published on the Operator’s websites. Questions regarding personal data processing may be sent to info@vrconcept.net.