Personal data processing policy

1. General Provisions

This personal data processing policy has been drawn up in accordance with the requirements of the Federal Law of 27.07.2006. No. 152-FZ "On Personal Data" (hereinafter referred to as the Personal Data Law) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by Individual Entrepreneur Anna Sergeevna Prokopenko (TIN 312336840404, hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of man and citizen when processing his personal data, including the protection of the rights to privacy, personal and family secrets.
1.2. This Operator policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may receive about visitors to the website https://annelschool.com/          

2. Basic concepts used in the Policy

2.1. Automated processing of personal data – the processing of personal data using computer technology.
2.2. Blocking of personal data – a temporary cessation of the processing of personal data (except in cases where the processing is necessary to clarify personal data).
2.3. Website – a collection of graphic and information materials, as well as computer programs and databases, ensuring their availability on the Internet at the network address https://annelschool.com/
2.4. Personal data information system – a set of personal data contained in databases and the information technologies and technical means that ensure their processing.
2.5. Processing of personal data – any action (operation) or set of actions (operations) performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), blocking, deletion, destruction of personal data.
2.6. Operator – a state body, municipal body, legal entity or individual that independently or jointly with other individuals organizes and/or carries out the processing of personal data, as well as determines the purposes of processing personal data, the composition of personal data subject to processing, actions (operations) performed with personal data.
2.7. Personal data – any information relating directly or indirectly to a specific or identifiable User of the Website.
2.8. Personal data permitted for distribution by the subject of personal data – personal data, access to which by an unlimited number of individuals is granted by the subject of personal data by giving consent to the processing of personal data permitted by the subject of personal data for distribution in the manner prescribed by the Law on Personal Data (hereinafter referred to as personal data permitted for distribution).
2.9. User – any visitor to the Website.
2.10. Provision of personal data – actions aimed at disclosing personal data to a specific person or a specific group of individuals.
2.11. Dissemination of personal data — any actions aimed at disclosing personal data to an indefinite number of individuals (transfer of personal data) or familiarizing an unlimited number of individuals with personal data, including the publication of personal data in the media, posting in information and telecommunications networks or providing access to personal data in any other way.
2.12. Cross-border transfer of personal data – the transfer of personal data to the territory of a foreign state to a foreign government body, a foreign individual or a foreign legal entity.
2.13. Destruction of personal data — any actions as a result of which personal data are destroyed irrevocably with the impossibility of further restoration of the content of personal data in the personal data information system and/or the destruction of tangible media of personal data.

3. Basic rights and obligations of the Operator

3.1. The Operator has the right:
— receive from the subject of personal data reliable information and/or documents containing personal data;
— in the event of the personal data subject’s withdrawal of consent to the processing of personal data, as well as the sending of an application with a request to stop the processing of personal data, the Operator has the right to continue processing personal data without the consent of the personal data subject if there are grounds specified in the Law on Personal Data;
— independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.
3.2. The Operator is obliged to:
— provide the subject of personal data, at his request, with information concerning the processing of his personal data;
— organize the processing of personal data in accordance with the procedure established by the current legislation of the Russian Federation;
— respond to requests and inquiries from personal data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;
— notify the authorized body for the protection of the rights of personal data subjects, at the request of this body, of the necessary information within 10 days from the date of receipt of such request;
— publish or otherwise provide unrestricted access to this Policy regarding the processing of personal data;
— take legal, organizational and technical measures to protect personal data from unauthorized or accidental access to them, destruction, modification, blocking, copying, provision, distribution of personal data, as well as from other illegal actions in relation to personal data;
— stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and cases stipulated by the Law on Personal Data;
— in the event of establishing the fact of unlawful accidental transfer (provision, distribution, access) of personal data, which resulted in the violation of the rights of Users, within 24 hours from the moment of detection of such an incident, notify the authorized body of the incident that occurred, and also take other measures in connection with the identified incident within the timeframes established by law;
— fulfill other obligations stipulated by the Law on Personal Data.

4. Basic rights and obligations of personal data subjects

4.1. Subjects of personal data have the right to:
— receive information regarding the processing of his personal data, except for cases stipulated by federal laws. Information is provided to the personal data subject by the Operator in an accessible form, and it should not contain personal data related to other personal data subjects, except for cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Law on Personal Data;
— demand that the Operator clarify his personal data, block it or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing, and also take measures provided by law to protect his rights;
— to put forward the condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
— to revoke consent to the processing of personal data, as well as to send a request to stop the processing of personal data;
— appeal to the authorized body for the protection of the rights of personal data subjects or in court against the illegal actions or inaction of the Operator when processing his personal data;
— to exercise other rights provided for by the legislation of the Russian Federation.
4.2. Subjects of personal data are obliged to:
— provide the Operator with reliable information about yourself;
— inform the Operator about clarification (update, change) of your personal data.
4.3. Individuals who have provided the Operator with false information about themselves or information about another personal data subject without the latter’s consent shall be liable in accordance with the legislation of the Russian Federation.

5. Principles of personal data processing

5.1. The processing of personal data is carried out on a lawful and fair basis.
5.2. The processing of personal data is limited to achieving specific, predetermined and legitimate purposes. Processing of personal data that is incompatible with the purposes of collecting personal data is not permitted.
5.3. It is not permitted to combine databases containing personal data, the processing of which is carried out for purposes that are incompatible with each other.
5.4. Only personal data that meets the purposes of their processing are subject to processing.
5.5. The content and volume of personal data processed correspond to the stated purposes of processing. Excessive amounts of personal data processed in relation to the stated purposes of their processing are not permitted.
5.6. When processing personal data, the accuracy of the personal data, their sufficiency, and, where necessary, relevance in relation to the purposes of processing the personal data are ensured. The Operator takes the necessary measures and/or ensures their adoption to delete or clarify incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the subject of personal data to be identified, for no longer than is required by the purposes of processing personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor. Processed personal data shall be destroyed or depersonalized upon achieving the purposes of processing or in the event of loss of need to achieve these purposes, unless otherwise provided by federal law.

6. Purposes of personal data processing

7. Terms of personal data processing

7.1. The processing of personal data is carried out with the consent of the subject of personal data to the processing of his personal data.
7.2. The processing of personal data is necessary to achieve the goals stipulated by an international treaty of the Russian Federation or by law, to exercise the functions, powers and obligations imposed on the Operator by the legislation of the Russian Federation.
7.3. The processing of personal data is necessary for the administration of justice, the execution of a judicial act, an act of another body or official subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings.
7.4. The processing of personal data is necessary for the performance of an agreement to which the personal data subject is a party, beneficiary or guarantor, as well as for the conclusion of an agreement on the initiative of the personal data subject or an agreement under which the personal data subject will be a beneficiary or guarantor.
7.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the Operator or third parties or for the achievement of socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated.
7.6. The processing of personal data is carried out, access to which by an unlimited number of individuals is provided by the subject of the personal data or at his request (hereinafter referred to as publicly available personal data).
7.7. The processing of personal data is subject to publication or mandatory disclosure in accordance with federal law.

8. Procedure for collecting, storing, transferring and other types of processing personal data

8.1. The security of personal data processed by the Operator is ensured by implementing legal, organizational and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.
Description of the measures provided for in Articles 18.1 and 19 of the Federal Law "On Personal Data": the following measures are taken to ensure the security of personal data: legal, organizational and technical measures to ensure the security of personal data. Study of the provisions of the Russian Federation legislation on personal data, including the requirements for the protection of personal data. Third-party access to personal data is limited. The storage locations of personal data and the means of their protection are determined. Means of ensuring the security of personal data: storage in safes, passwords, information protection software (antiviruses).
8.2. The Operator ensures the safety of personal data and takes all possible measures to prevent unauthorized individuals from accessing personal data.
8.3. The User’s personal data is not transferred to third parties, except in cases related to compliance with current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party.
If the User has given their consent to the collection of cookies using the Yandex Metrica web analytics service, this means that the User also gives their consent to the transfer of the specified data to Yandex (LLC Yandex; Primary State Registration Number (OGRN) 1027700229193, 119021, Russia, Moscow, Leo Tolstoy St., 16) for the processing of data about the User in the manner and for the purposes specified below.
Cookies are small text files placed on the User's computer for the purpose of analyzing user activity.
The information collected using cookies cannot identify the User, but it can help the Operator improve the operation of the Website. Information about the User's use of the Website, collected using cookies, will be transferred to the providers of the metric service. The metric service will process this information to evaluate the User's use of the Website, compile reports on the website's activity for the Operator and provide other services.
The User may refuse the use of cookies by selecting the appropriate settings in their browser. However, this may affect the operation of some functions of the Site. In relation to cookies collected by Yandex LLC, the User may use the tool — https://yandex.ru/support/metrika/general/opt-out.html.
The User is informed and agrees that the Website is created on the Tilda platform, the owner of which is JSC Tilda Publishing (Primary State Registration Number (OGRN) 1247700830354, 107031, Moscow, internal territory of the city, Tverskoy municipal district, Petrovskie Linii St., 2, office 4/1). Taking into account the technical features of the platform, the User gives the Operator consent to the instruction to process the User's personal data (last name, first name, patronymic, email address, account in the Telegram messenger, information about the User's actions on the Website (cookies) of JSC Tilda Publishing on the terms and for the purposes specified in the Instruction for the Processing of Personal Data https://tilda.ru/ru/dpa/. The User is notified that without providing the relevant Order, the Operator cannot use the Website, and in the event of his/her disagreement with the order for data processing, he/she undertakes to refrain from using the Website and/or purchasing the Operator’s services.
8.4. In the event of detection of inaccuracies in personal data, the User may update them independently by sending the Operator a notification to the Operator’s e-mail address ryzanel@gmail.com with the subject line “Updating personal data”.
8.5. The period of processing personal data is determined by the achievement of the purposes for which the personal data were collected, unless another period is provided for by the agreement or applicable law. The User may at any time revoke their consent to the processing of personal data by sending a notification to the Operator by e-mail to the Operator's e-mail address ryzanel@gmail.com with the subject line "Revocation of consent to the processing of personal data".
8.6. All information collected by third-party services, including payment systems, communication tools and other service providers, is stored and processed by the said individuals (Operators) in accordance with their User Agreement and Privacy Policy. Subject of personal data and/or with the said documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.7. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing of personal data in state, public and other public interests determined by the legislation of the Russian Federation.
8.8. When processing personal data, the Operator ensures the confidentiality of personal data.
8.9. The operator shall store personal data in a form that allows the identification of the subject of personal data for no longer than is required by the purposes of processing the personal data, unless the storage period for personal data is established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor.
8.10. The condition for termination of the processing of personal data may be the achievement of the purposes of processing personal data, the expiration of the consent of the subject of personal data, the withdrawal of consent by the subject of personal data or the requirement to terminate the processing of personal data, as well as the detection of unlawful processing of personal data.
8.11. By transferring personal data of third parties (including names, contacts) to the Operator, the User confirms that he/she has received the prior consent of such third parties to transfer their personal data to the Operator in relation to the purpose for which the data is actually transferred. In the absence of such consent, the User is obliged to refrain from transferring the data.

9. List of actions performed by the Operator with the received personal data

9.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (provides, accesses), distributes, blocks, deletes and destroys personal data.
9.2. The Operator carries out automated processing of personal data with or without the receipt and/or transmission of the received information via information and telecommunications networks.

10. Cross-border transfer of personal data

The Operator does not carry out cross-border transfer of personal data.

11. Confidentiality of personal data

The Operator and other individuals who have gained access to personal data are obliged not to disclose to third parties or distribute personal data without the consent of the subject of the personal data, unless otherwise provided by federal law.

12. Final Provisions

12.1. The User can receive any clarifications on issues of interest regarding the processing of his personal data by contacting the Operator via e-mail ryzanel@gmail.com
12.2. This document will reflect any changes to the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at https://annelschool.com/policy     

Operator details:
Individual Entrepreneur Prokopenko Anna Sergeevna
TIN 312336840404
ryzanel@gmail.com
+7 (908) 786-88-55