1. General Provisions
This Personal Data Processing Policy (the “Policy”) has been prepared in accordance with Federal Law No. 152-FZ of the Russian Federation dated July 27, 2006, “On Personal Data” (the “Personal Data Law”), and establishes the procedures for the processing of personal data and the measures adopted by Maria Aleksandrovna Samokhvalova (the “Operator”) to ensure the security of personal data.
1.1. Operator considers the observance of the rights and freedoms of individuals and citizens in the course of personal data processing, including the protection of the right to privacy and personal and family confidentiality, to be a fundamental principle and an essential condition of its activities.
1.2. This Policy governing Operator’s processing of personal data (the “Policy”) applies to all information that Operator may obtain about visitors to the website https://www.learnox.app/.
2. Definitions
For the purposes of this Policy, the following terms shall have the meanings set forth below:
2.1. Automated Processing of Personal Data — processing of personal data by means of computer technology.
2.2. Blocking of Personal Data — temporary suspension of the processing of personal data, except where processing is necessary for the clarification or updating of such personal data.
2.3. Website — a collection of graphic and informational materials, as well as software and databases, ensuring their availability on the Internet at https://www.learnox.app/.
2.4. Personal Data Information System — a combination of personal data contained in databases, together with information technologies and technical means used for the processing of such personal data.
2.5. Depersonalization (Anonymization) of Personal Data — actions resulting in the impossibility of determining, without the use of additional information, whether personal data relates to a specific User or another data subject.
2.6. Processing of Personal Data — any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, systematization, accumulation, storage, updating, modification, retrieval, use, transfer (distribution, provision, or granting of access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. Operator — a state authority, municipal authority, legal entity, or individual that independently or jointly with others organizes and/or carries out the processing of personal data, as well as determines the purposes of processing, the categories of personal data to be processed, and the operations performed on such personal data.
2.8. Personal Data — any information relating directly or indirectly to an identified or identifiable User of the website https://www.learnox.app/.
2.9. Personal Data Permitted for Dissemination — personal data to which the data subject has granted access to an unlimited number of persons by providing consent for the processing of personal data permitted for dissemination in accordance with the procedure established by the Personal Data Law.
2.10. User — any visitor to the website https://www.learnox.app/.
2.11. Provision of Personal Data — actions aimed at disclosing personal data to a specific person or a defined group of persons.
2.12. Dissemination of Personal Data — any actions aimed at disclosing personal data to an indefinite number of persons, including publication in mass media, placement in information and telecommunications networks, or granting access to personal data by any other means.
2.13. Cross-Border Transfer of Personal Data — the transfer of personal data to the territory of a foreign state, to a foreign public authority, foreign individual, or foreign legal entity.
2.14. Destruction of Personal Data — any actions resulting in the irreversible destruction of personal data with no possibility of restoring its content within a personal data information system and/or the destruction of physical media containing personal data.
3. Rights and Obligations of Operator
3.1. Operator shall have the right to:
- obtain accurate information and/or documents containing personal data from the data subject;
- continue processing personal data without the data subject’s consent where such consent has been withdrawn or where the data subject has requested the cessation of processing, provided that the grounds established by the Personal Data Law exist;
- independently determine the composition and scope of legal, organizational, and technical measures necessary and sufficient to ensure compliance with the obligations imposed by the Personal Data Law and other applicable legislation, unless otherwise provided by law.
3.2. Operator shall:
- provide the data subject, upon request, with information concerning the processing of their personal data;
- organize the processing of personal data in accordance with the applicable legislation of the Russian Federation;
- respond to requests and inquiries submitted by data subjects and their authorized representatives in accordance with the requirements of the Personal Data Law;
- provide the competent authority responsible for the protection of the rights of personal data subjects with the information requested by such authority within ten (10) days from receipt of the relevant request;
- publish this Policy or otherwise ensure unrestricted access to it;
- implement legal, organizational, and technical measures to protect personal data against unauthorized or accidental access, destruction, modification, blocking, copying, disclosure, dissemination, and any other unlawful processing;
- cease the transfer (including dissemination, provision, or granting access), processing, and destroy personal data in the cases provided for by the Personal Data Law;
- perform any other obligations prescribed by applicable legislation.
4. Rights and Obligations of Personal Data Subjects
4.1. Personal data subjects shall have the right to:
- obtain information concerning the processing of their personal data, except where such access is restricted by federal law. Such information shall be provided in an accessible form and shall not contain personal data relating to other individuals, unless otherwise permitted by law;
- require Operator to rectify, block, or erase personal data where such data are incomplete, outdated, inaccurate, unlawfully obtained, or unnecessary for the stated purpose of processing, and to exercise other rights provided by applicable law;
- require prior consent for the processing of personal data for the purposes of promoting goods, works, or services;
- withdraw previously granted consent to the processing of personal data and request the termination of such processing;
- lodge complaints with the competent supervisory authority responsible for the protection of personal data rights or seek judicial protection against unlawful actions or omissions of Operator relating to the processing of personal data;
- exercise any other rights granted under the legislation of the Russian Federation.
4.2. Personal data subjects shall:
- provide Operator with accurate personal data;
- promptly notify Operator of any updates or changes to their personal data.
4.3. Individuals who provide Operator with inaccurate personal data or disclose personal data relating to another individual without the latter’s consent shall bear liability in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
Operator shall process personal data in accordance with the following principles:
- personal data shall be processed lawfully and fairly; processing shall be limited to the achievement of specific, predetermined, and lawful purposes;
- personal data shall not be processed in a manner incompatible with the purposes for which such data were collected;
- databases containing personal data processed for incompatible purposes shall not be merged;
- only personal data relevant and necessary for the stated purposes of processing shall be processed;
- the scope and content of processed personal data shall correspond to the stated purposes of processing, and excessive data collection shall not be permitted;
- Operator shall ensure the accuracy, sufficiency, and, where necessary, relevance of personal data in relation to the purposes of processing and shall take all reasonable measures to rectify or erase inaccurate or incomplete personal data;
- personal data shall be stored in a form that permits identification of the data subject for no longer than is necessary to achieve the purposes of processing, unless a longer retention period is required by applicable law or by an agreement to which the data subject is a party, beneficiary, or guarantor;
- upon achievement of the processing purposes or where such purposes are no longer necessary, personal data shall be destroyed or anonymized unless otherwise required by applicable law.
6. Purposes of Personal Data Processing
Purpose of Processing
To provide the User with access to the services, information, and/or materials available on the Website.
Categories of Personal Data Processed:
- Email address
- Name
Legal Basis for Processing:
Federal Law of the Russian Federation No. 149-FZ dated July 27, 2006, “On Information, Information Technologies and Information Protection.”
Processing Activities:
Sending informational emails to the User’s email address.
Purpose of Processing
To inform the User by sending electronic communications.
Categories of Personal Data Processed:
- Email address
- Name
Legal Basis for Processing:
Federal Law of the Russian Federation No. 149-FZ dated July 27, 2006, “On Information, Information Technologies and Information Protection.”
Processing Activities:
Sending informational emails to the User’s email address.
7. Conditions for Personal Data Processing
Personal data shall be processed under one or more of the following conditions:
7.1. The data subject has provided consent to the processing of their personal data.
7.2. Processing is necessary to achieve the purposes established by an international treaty of the Russian Federation or by law, or to perform functions, powers, and obligations imposed on Operator by the legislation of the Russian Federation.
7.3. Processing is necessary for the administration of justice or for the execution of a judicial act or an act of another authority or official subject to enforcement under the legislation of the Russian Federation.
7.4. Processing is necessary for the performance of a contract to which the data subject is a party, beneficiary, or guarantor, or for entering into a contract at the initiative of the data subject.
7.5. Processing is necessary for the legitimate interests of Operator or third parties, or for the achievement of socially significant objectives, provided that such processing does not infringe upon the rights and freedoms of the data subject.
7.6. Processing is carried out with respect to personal data that has been made publicly available by the data subject or at the data subject’s request.
7.7. Processing is carried out with respect to personal data that is subject to publication or mandatory disclosure under applicable law.
8. Procedure for Collection, Storage, Transfer, and Other Processing of Personal Data
The security of personal data processed by Operator shall be ensured through the implementation of legal, organizational, and technical measures necessary to comply fully with the applicable legislation governing personal data protection.
8.1. Operator shall ensure the confidentiality and security of personal data and shall take all reasonable measures to prevent unauthorized access to such data.
8.2. Under no circumstances shall the User’s personal data be disclosed or transferred to third parties, except where required by applicable law or where the data subject has expressly consented to such transfer for the performance of obligations under a civil law agreement.
8.3. Where inaccuracies in personal data are identified, the User may update such data by sending a notification to Operator via email at boykova.maria.ads@gmail.com with the subject line “Personal Data Update.”
8.4. Personal data shall be processed for as long as necessary to achieve the purposes for which it was collected, unless a different retention period is required by law or by contract.
The User may withdraw consent to the processing of personal data at any time by sending a notification to Operator via email at boykova.maria.ads@gmail.com with the subject line “Withdrawal of Consent to Personal Data Processing.”
8.5. Any information collected by third-party service providers, including payment systems, communication providers, and other service providers, shall be stored and processed by such providers in accordance with their respective Terms of Service and Privacy Policies.
Operator shall not be liable for the actions or omissions of such third parties.
8.6. Any restrictions imposed by the data subject on the transfer or processing of personal data made publicly available shall not apply where such processing is carried out in the public interest as provided for by applicable legislation.
8.7. Operator shall maintain the confidentiality of personal data throughout the processing activities.
8.8. Personal data shall be retained in a form permitting identification of the data subject for no longer than is necessary to achieve the purposes of processing unless a longer retention period is required by law or by contract.
8.9. Processing of personal data shall cease upon:
- achievement of the purposes of processing;
- expiration of the applicable consent period;
- withdrawal of consent by the data subject;
- receipt of a request from the data subject to cease processing; or
- identification of unlawful processing of personal data.
9. Processing Activities Performed by Operator
9.1. Operator carries out the following processing activities with respect to personal data: collection; recording; systematization; accumulation; storage; updating (modification); retrieval; use; transfer (including disclosure, provision, or granting of access); anonymization; blocking; deletion; and destruction of personal data.
9.2. Operator processes personal data using automated means, with or without the transmission of information via information and telecommunication networks.
10. Cross-Border Transfer of Personal Data
10.1. Prior to commencing any cross-border transfer of personal data, Operator shall notify the competent authority responsible for the protection of the rights of personal data subjects of its intention to carry out such transfer. Such notification shall be submitted separately from any notification regarding the processing of personal data.
10.2. Before submitting the above notification, Operator shall obtain the necessary information from the competent authorities of the foreign state, as well as from the foreign individuals and/or legal entities to whom the personal data is intended to be transferred, in accordance with the requirements of applicable legislation.
11. Confidentiality of Personal Data
Operator and any other persons who have obtained access to personal data shall maintain the confidentiality of such data and shall not disclose or disseminate personal data to any third party without the prior consent of the data subject, unless otherwise required by applicable law.
12. Final Provisions
12.1. Users may obtain clarification regarding any matters relating to the processing of their personal data by contacting Operator via email at boykova.maria.ads@gmail.com.
12.2. Any amendments to this Policy shall be reflected in this document. This Policy shall remain in effect indefinitely until replaced by a new version.
12.3. urrent version of this Policy is publicly available at: https://www.learnox.app/en/privacy-policy